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  '^T?3^--''2'*^;i'"^*^-w'4*""-V<-^"^                                    '
                                       ?. "^.f'.-fr.'r^'.-?* Łm«rg(»ncy
DIRECTIVE NUMBER:
                                                      9523.o-5
                           EFFECTIVE DATE:
                           ORIGINATING OFFICE;
-  » fr.,?1Ktj?(.\fJ.3Sjlt*!»Ji,!S!V-=W* 16..W-".••*">
                                                 ^

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   v EPA
               Wasnmgton, OC 2C460
OSWER Directive Initiation Request
                                                                         9523.00-5
 Name of Contact Person
   Art  Day
         Man Cooe  -
                                           Branch
 .eao O'fice
    i_J OEBR
    D OSW
                i_i OUST
                LJ OWPE
                D AA-OSWEfi
         Signature of C'f>ca
  Permit Applicant's Guidance -Manual  for Hazardous Waste  Lana
  Treatment,  Storage,  ana  Disposal Facilities
 Summary of Directive
    SUMMARY                                  .                           n
       To  provide guidance  for  preparation of  Part  A and  Part  B
    permit applications for hazardous waste land treatment,
    llorage In6  disposal  facilities  regulated  under RCRA  1976
    Some of the  standards  in effect  when  the Manual was published
    have been  replaced, i.e.,  some guidelines  are obsolete while
    others remain current.
         it,  Treatment,  Storage, Disposal, Landfill, Groundwater  Monitoring
 Typt of Directive (Minutl. Policy Qtrtctnt. Announcement, etcj
                                                            Status
                                                               D Draft
                                                               O F.nat
                                                                              G New
                                                                              LJ Revision
 Do«»tnis Dir»ctiv« Sup*ri«M Prtvtom Otfectiva(s;>   [ | Yes  j_'j No   Does it Supplement Previous Directives!'   |J Yes
  'Yes • to Either Question, VVnat Directive (number nt/ei
  view Plan
   D AA-OSWER  D OUST
   D OERB      D OWPE
   Q OSW      O Regions
D OECM
D OGC
D OPPE
                                             D
                          Other ,'Specifyl
I   "—i U9vv      i—_i nvgions       •  ' U
jTh.s Request Meets OSWER Directives System Format
ISigrature of Lead Office Directives Officer
_..--.. ••«^M««» >*>w»« N^^w^ri ^11 WlvltVW* JT
ISigr-ature of Lead Office Directives Officer
                                                                       ' Date
 Signature of OSWER Directives Officer
                                                                        Date

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&EPA
           United States
           Environmental Protection
           Agency
            Office of Solid Waste
            and Emergency nesoonse
            .Vasnmgton DC 20450
October 1983
Draft
           Permit Writers5
           Guidance Manua! for
           Hazardous Waste
           Land Treatment, Storage, anc
           Disposal Facilities
          Volume 2
          For Internal Use Only

-------
                                      OSWtR -.

                                   95*3 •
PERMIT WRITER'S GUIDANCE MANUAL FOR
  HAZARDOUS WASTE LAND TREATMENT,-
 STORAGE, AND DISPOSAL FACILITIES

             Volume 2
 This Document has not been Peer and Administratively
 Reviewed within EPA and is for Internal Agency Use/
 Distribution Only. •
          Project Officer

           Jon R. Perry
       Land Disposal Branch
       Office of Solid Waste
      Washington, D.C.  20460
     OFFICE OF SOLID WASTE  AND
        EMERGENCY RESPONSE
U. S. ENVIRONMENTAL PROTECTION  AGENCY
       WASHINGTON, D.C.   20460

-------
                                   DISCLAIMER
     This Drait Final Raport was furnished to the Environmental Protection
Agency by the GCA Corporation, CCA/Technology Division, 3edfora, ;iassacnusects
01730, in fulfillment of Contract No. 68-02-3168, Assignment No. 37-(3).  The
opinions, findings, and conclusions expressed are those of the authors and not
necessarily Chose of the Environmental Protection Agency or the cooperating
agencies.  Mention of company or product names is not to be considered as an
endorsement by the Environmental Protection Agency.

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                                ACKNOWLEDGMENTS
     The authors express their appreciation to the staff of  the Office of
Solid Waste, Land Disposal Branch, including Mr. Jon Perry,  the EPA Project
Officer, and Messrs. Art Day and Mike Flynn, for their assistance and helpful
guidance throughout this program.  We also acknowledge tne collective group
of authors whose work is cited throughout this document including researchers
associated with the EPA Municipal Environmental Research Laboratory in
Cincinnati, and organizations such as K. W. Brown and Associates, Inc..
GeoTrans, Inc., and Matrecon, Inc.

     This manual was prepared by the GCA/Technology Division of GCA Corpor-
ation, Bedford, MA.  The principal authors were Charles W. Young, Peter H.
Anderson, Stephen V. Capone, John P. Patinskas, Ronald K. Bell, Lisa A. Baci,
Nancy H. Krusell, and Pablo Huidobro.  We thank other GCA staff members who
contributed to this document, including Messrs. Thomas J. Nunno, Daniel J.
Goode, and Michael R. Jasinski.  We also axtend our appreciation to the staff
of the GCA Technical Publications Department, managed by Ms. Sharon Pleskowicz,
for their dedicated assistance in preparing this document.
                                     1 1 l

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                                    CONTENTS
Acknowledgments 	  ..,..,.    iii
Figures	    viii
Tables	    xxiv

     1.0   Introduction	    1-1
           1.1   Purpose	    1-1
           1.2   Use, Content, and Format of This Manual	    1-1
           1.3   Other Guidanca Manuals 	    1-2
           1.4   Procedures for Updating and Revising This .-ianuai  .  .    i-2
     2.0   Overview of RCRA and the Regulations	    2-1
           2.1   RCRA and Subtitle C	    2-1
           2.2   The Code of Federal Regulations  . .	    2-4
           2.3   Regulations Addressed in the Manual and Their
                   Applicability  	    2-6
     3.0   Administrative Processing of Parmit Applications and
             Preparation of Draft and Final Permits 	    3-1
           3.1   Introduction	    3-1
           3.2   Initial Review of Permit Application 	    3-3
           3.3   Preparation of the Draft Permit	    3-11
           3.4   Procedures to Generate the Final Permit   	    3-17
     4.0   Model Permit for Hazardous Waste Treatment, Storage, and
                                                                         4-1
                                                                         4-3
                                                                         --9
                                                                         4-15
                                                                         4-20
                                                                         4-21
                                                                         4-26
                                                                         4-31
                                                                         4-35
                                                                         4-39
                                                                         4-42
                                                                         4-43
                                                                         4-48
     5.0   Ground Water Protection  	    5-1
                                                                         5-4

                   Characteristics  	    5-13
           5.3   Waste Management Area, Point of Compliance, and
                   Well Locations	    5-31
           5.4   Description of Any Ground Water Contamination   .  .  .    5-43
           5.5   Detection Monitoring Program 	    5-58
Lu-ap
4.1
4 2
4.3
4.4
4.5
4 6
4. 7
4 8
4.9
/. in
4.11
4 12
G pound
5.1
5.2



Module Va - Waste Pile Which Closes as Landfill , .





Module XIV - Land Treatment 	



Identification of Uppermost Aquifer and

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                         CONTENTS (continued)
      5.6   Compliance Monitoring Program  	    5-88
      5.7   Corrective Action Program  	    5-98
      5.8   References	    5-106
      5.9   Example Maps and Cross-Sections and Descriotion of
              Example Geology  	    5-108
      5.10  Technical Adequacy Checklist 	    5-115
6.0   Surface Impoundments 	    6-1
      6.1   Waste Description	    
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                         CONTENTS (continued)
8.0   Land Treatment	    8-1
      8.1   Treatment Demonstration  	    8-3
      8.2   Land Treatment Program	    8-63
      8.3   Design and Operating Requirements  	    8-119
      8.4   Food-Chain Crops Requirements  	 ....    3-151
      8.5   Establishment of Vegetative Cover at Closure ....    8-167
      8.6   Special Requirements for Ignitable or Reactive
              Wastes	    8-176
      8.7   Special Requirements for incompatible Vastas ....    3-L95
      8.3   Technical Adequacy Checklist 	    8-209
9.0   Landfills	    9-1
      9.1   Waste Description  	    9-3
      9.2   Design and Operating Requirements  	    9-10
            9.2.1   Liner System Design  	    9-10
            9.2.2   Laachate Collection and Removal System .  .   .    9-60
            9.2.3   Liner and Leachate Collection and Removal
                      System Ixeraption 	    9-109
            9.2.A   Control of Run-On	    9-113
            9.2.5   Control of Run-Off	    9-127
            9.2.6   Management of Units Associated With Run-On
                      and Run-Off Control Systems  	    9-134
            9.2.7   Management of Wind Dispersal	    9-136
            9.2.8   Subpart F Exemption	    9-142
      9.3   Inspection Requirements  	    9-147
      9.4   Landfill Closure and Post-Closure  	    9-187
      9.5   Handling and Disposal of Ignitable or Reactive
              Wastes	  ".	    9-203
      9.6   Special Requirements  for Incompatible Wastes ....    9-229
      9.7   Disposal of Liquid Waste in Landfills  	    9-242
      9.8   Special Requirements  for Containers and Lab Packs   .    9-265
      9.9   Technical Adequacy Checklist 	    9-279
10.0  Completeness  Checklist	   .   10-1
      RCRA Permit Application Completeness  Checklists
        for Parts A & B	   10-2
                                 vii

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Number                                                                  Page
 "  I '                                                                    —I |J.IM

 3.1.1    The RCRA permitting process	    3-2

 3.2.1    Form letter for request of Part B	    3-5

 3.2.2    Sample notice of deficiency for existing HWM facility .  .  .    3-9

 3.2.3    Sample form letter for informing the applicant that his/her
            application is considered to be complete  	    3-10

 3.0.1    Basic ground water monitoring and response program
            elements	    5-3

 5.1.1    Part 265 regulations  applicable to interim status
            ground water monitoring 	 ...    5-6

 5.1.2    Worksheet for evaluating the interim status monitoring
            program and results	    5-10

 5.2.1    Applicability of regulations to aquifer
            characterization	"	    5-15

 5.2.2    Worksheet for evaluation of the uppermost aquifer and
            flow properties	    5-23

 5.2.3    Worksheet for assessment of geological  information  ....    5-25

 5.2.4    Worksheet for assessment of hydrogeological information  ._.    5-26

 5.2.5    Worksheet for assessment of topographic base map
            information	    5-27

 5.2.6    Worksheet for assessment of geologic/hydrogeologic map
            information	    5-28

 5.2.7    Worksheet for assessment of bedrock information . . 	    5-29

 5.2.3    Worksheet for assessment of information included in a
            cross-section 	     5-30
                                     viii

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                               FIGURES  (continued)

Number                                                                  Page

 5.3.L    Applicability of regulations to waste management area,
            point of compliance, and well locations	    5-33

 5.3.2    Worksheet for asaessmenc of Information presented co
            establish the waste management area 	    5-34

 5.3.3    Possible ground water flow patterns 	    5-37

 5.3.4    Example flow patterns and facility orientations which
            influence location of monitoring wells   	    5-39

 5.3.5    Spacing of wells in uppermost aquifers of varying
            permeability contrast 	    5-40

 5.3.6    Compliance point monitoring for multipla  regulated
            units	    5-42

 5.3.7    Compliance point monitoring for facility  only partially
            utilized	    5-44

 5.3.8    Worksheet for evaluating the proposed location of down-
            gradient wells at the point of compliance	    5-45

 5.3.9    Worksheet for assessment of background well  information .  .    5-47

 5.4.1    Applicability of regulations-to characterization of the
            plume of contamination	    5-49

 5.4.2    Worksheet for evaluating the information  submitted regarding
            any existing plume of contamination 	    5-57

 5.5.1    Applicability of regulatory requirements  to  the detection
            monitoring program  	    5-60

 5.5.2    Worksheet for determining the adequacy of the selected
            indicator parameters  	    5-64

 5.5.3    Worksheet for evaluating background contamination values
            and procedures for their determination   	    5-67

 5.5.4    Worksheet for evaluating proposed statistical comparison
            procedures	    5-69

 5.5.5    Well  screens placed at various  elevations  	    5-72

 5.5.6    Dense contaminants  flowing below the screened portion of
            monitoring wells   	    5-73
                                       ix

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                               FIGURES  (continued)




Number                                                                  Page
5.5.7

5.5.8
5.5.9

5.5.10

5.5.11
5.5.12
5.5.13
5.5.14

5.5.15
5.6.1

5.6.2


5.6.3

5.7.1

5.7.2

5.9.1
5.9.2
5.9.3
5.9.4
5.9.5
Light contaminants flowing above the screened portion of
monitoring wells 	
Well screen located throughout full depth of aquifer . . .
Worksheet for assessment of information on well design
and cons true c_on . 	 	
Worksheet for assessment of well installation
information 	 	 	
Observation well construction summary ..... 	
Worksheet for assessment of well development method . , . .
Worksheet for assessment of sampling procedures 	
Worksheet for assessment of information on sample
analysis 	
Worksheet for assessment of chain of custody procedures . •
Applicability of regulations to the compliance monitoring
program 	
Worksheet for evaluating the" list of hazardous constituents.
proposed for incorporation in the ground water protection
standard 	 ........ 	
Worksheet for evaluating ground water performance standard
concentration limits 	 ...
Applicability of regulations to the corrective action
program 	 	 	
Worksheet for evaluation of proposed corrective action
procedures 	
Example surficial materials map 	
Example bedrock geologic map 	
Example ground water regime 	
Example geologic cross section A - A1 	
Example geologic cross section B-B* 	

5-75
5-76

j~ i i

5-79
5-80
5-81
3-83

5-84
5-85

5-91


5-93

5-94

5-101

5-103
5-110
5-111
5-112
5-113
5-114

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                               FIGURES  (continued)

Number                                                                  Page

 6.1.1    Worksheet for evaluating the adequacy of the listing of
            hazardous wastes for existing surface impoundments  . . .    6-3

 6.1.2    Worksheet for evaluating Che adequacy of :he lijciag JE
            hazardous wastes for new surface impoundments 	    6-9

 6.2.1    Applicability of Part 264 regulations to surface
            impoundment liners  ....	    b-13

 6.2.2    Evaluation of proposed liner systems  	    6-16

 6.2.3    Permeability of four clay soils to standard aqueous
            penneant	    6-33

 6.2.4    Relationship between permeability, density, and moisture
            content for an idealized clay soil	    6-41

 6.2.5    Worksheet for evaluation of liner location with respect to
            water table	    6-47

 6.2.6    Worksheet for evaluation of synthetic liners  	    6-48

 6.2.7    Worksheet for evaluation of clay liners	    6-51

 6.2.8    Worksheet for evaluation of admixed liners  	    6-54

 6.2.9    Worksheet for evaluation of foundation design and
            integrity	    6-56

 6.2.10   Worksheet for determining the adequacy of the applicant's
            submittal for a liner system exemption  	    6-63

 6.2.11   Applicability of Part 264 regulations to impoundment
            overtopping	    6-65

 6.2.12   Precipitation depth associated wich the 100-year,  24-hour
            storm	    6-67

 6.2.13   Worksheet for determination of the magnitude of the 100-year
            storm event	    6-68

 6.2.14   Solution of the SCS Runoff Equation 	    6-70

 6.2.15   Worksheet for evaluating run-on volume computations ....    6-73

 6.2.16   Worksheet to evaluate adequacy of applicant's plans to
            prevent overtopping 	    6-75
                                       xi

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                               FIGURES  (continued)

Number                                                                  Page

 6.2.17   Evaluation of structural integrity of dikes 	    6-80

 6.2.18   Worksheet for evaluating adequacy of dike design,
            construction,  and naintanance 	    6-84

 6.2.19   Applicability of Part 264 requirements to the subpart F
            exemption	    6-38

 6.2.20   Worksheet for determining adequacy of applicant's submittal
            for an exemption from Subpart F requirements	    6-90

 6.3.1    Standards applicable to surface impoundment inspection
            during installation 	    6-94

 6.3.2    Worksheet for determining the adequacy of general
            inspection information  	    6-96

 6.3.3    Inspection of liner and cover system materials before and
            during installation 	    6-97

 6.3.4    Worksheet for determining the adeauacy of inspection
            procedures before and during installation 	    6-108

 6.3.5    Inspection of syntnecic liners and covers after
            installation  	    6-113

 6.3.6    Inspection of soil-based and admixed liners and covers
            after installation	:	    6-115

 6.3.7    Moisture-density curve of a cohesive soil	    6-117

 6.3.8    Worksheet for determining the adequacy of inspection
            procedures after installation 	    6-112

 6.3.9    Systems or conditions to be inspected weekly and after
            storms	    6-125

 6.3.10   Worksheet for determining the adequacy of weekly and
            after storm inspection procedures 	 ...    6-129

 6.5.1    Worksheet for evaluating the applicant's  contingency plan
            for removinz nhe surface impoundment from service . ,  . .    6-139

 6.6.1    Applicability zz reguiac;    -quirements  to closure of
            surface impoundments  	    6-142

 6.6.2    Key steps in storage impoundment closure   	    6-145
                                       xii

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                               FIGURES  (con

Number

 6.6.3    Worksheet to evaluate the adequacy of the proposed storage
            impoundment closure plan  ................    6-148
                                '.:apounaraenc -ioaure .........    6-151
 6.6.5    Worksheet for evaluating the adequacy of the applicant's
            closure plan for disposal impoundments  .........    6-155

 7.1.1    Worksheet for evaluating the adequacy of the listing of
            hazardous wastes for existing waste piles ........    7-7

 7.1.2    Worksheet for evaluating the adequacy of the listing of
            hazardous wastes for new waste piles  ..........    7-3

 7.2.1    Aoplicability of Part 264 requirements to obtaining an
            exemption from the liner standard and ground water
            protection requirements .................    7-10

 7.2.2    Worksheet for evaluation of an application for exemption
            from liner standard (§264.251) and Subpart F
            requirements  ..... . ............ ,  ,  .   .    7-13

 7.3.1    Applicability of Part 264 requirements to liner design  .   .    '-20

 7.3.2    Evaluation of proposed liner system ............    7-21

 7.3.3    Permeability of four clay soils to standard aqueous
            permeant  ........................    7-23

 7.3.4    Relationships between permeability, density, and moisture
            content for an idealized clay joii  ...........    7-32

 7.3.5    Worksheet for evaluation of liner location with respect  to
            water table .......................    7-39

 7.3.6    Worksheet for evaluating clay liners  ...........    7-40

 7.3.7    Worksheet for evaluating admixed liners ..........    7-43

 7.3.3    Worksheet for evaluation of synthetic liners  .......    7-45

 7.3.9    Worksheet for evaluation of foundation design and
            integrity ........................    7-43

 7.3.10   Applicability of Part 264 requirements to leachate
            collection and removal systems  .............    7-53
                                      xiii

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                               FIGURES  (continued)




Number                                                                  Page




 7.3.LL   Evaluation of leachate collection and removal system
-> T i -.
7.3.13
7.3.14
7.3. 15
7.3.16
7 • 3 • I 7
7. 3. IS
7.3.19
7.3.20
7.3.21
7.3.22
7.3.23
7.3.24
7.3.25
7.3.25
7.3.27
7.3.28
7.3.29
Mtarr.ar. i-'-e -iraincaa svsca^ ^rian'-aLions considered Ln

Typical hazardous waste pile profile simulated using
HELP 	

Trench condition — bioe load coefficient 	 .

Worksheet cor calculation of load bearing capacity of
Illustration of prevention of piping bv graded filters . .
Worksheet to determine adequacy of design of drainage
Worksheet for determining the adequacy of filter fabrics
Worksheet for determining the adequacy of pipe perforation

Worksheet for evaluating a submittal for a liner and
Regulations applicable to the control of run-on and
Technical topics addressed EOT run—on control 	
Worksheet for determination of the magnitude of the
25-year storm event for evaluation of run-on control . .
Solution of the SCS run-off eauation 	 	 .
7-56
7-58
7-61
7-67
7-71
7-72
7-82
7-86
7-89
7-91
7-92
7-95
7-102
7-105
7-106
7-108
7-111
7-113
                                       xiv

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                               FIGURES  (continued)

Number                                                                  Page

 7.3.30   Worksheet for evaluation of calculated peak run-on
            discharge rate	    7-116

 7.3.31   Technical issues associated wich run-off concrol  	    7-119

 7.3.32   24-hour, 25-year rainfall event (inches)  	    7-120

 7,3.33   Worksheet for ivaluacing che .aagnicuae of che selected
            storm event	    7-121

 7.3.34   Worksheet for evaluating run-off volume computations  .  .   .    7-123

 7.3.35   Worksheet for determining che adequacy of the applicant's
            plan to manage units associated with run-on and run-off
            control .	    7-128

 7.3.36   Regulations applicable to the control of wind dispersal  of
            particulate matter at waste piles 	    7-130

 7.3.37   Evaluation of proposed wind dispersal control system  .  .   .    7-131

 7.3.33   Worksheet for evaluating the adequacy of wind dispersal
            control measures  	    7-133

 7.3.39   Standards applicable to Subpart F exemption 	    7-136

 7.3.40   Worksheet for evaluation of the adequacy of applicant's
            submittal for an exemption from Subpart F based on
            installation of a double-lined pile	    7-137

 7.3.41   Worksheet for evaluation of che adequacy of the applicant's
            submittal for an exemption from Subpart F based on
            inspection of the liner	    7-141

 7.4.1    Standards applicable to waste pile inspection 	    7-144

 7.4.2    Worksheet for determining the adequacy of the applicant's
            inspection plan	    7-147

 7.4.3    Inspection of liner and cover system materials before and
            during installation 	    7-148

 7.4.4    Worksheet for determining the adequacy of inspection
            procedures before and during installation 	    7-159

 7.4.5    Inspection of synthetic liners and covers after
            installation  	    7-164

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                               FIGURES  (continued)

Number                                                                  page

 7.4.6    Inspection of soil-based and admixed liners and covers
            after installation	    7-166

 7.4.7    Moisture-density curve of a cohesive soil	    7-168

 7.4.8    Plasticity chart  	    7-170

 7.4.9    Worksheet for determining the adequacy of inspection
            procedures after liner installation 	    7-174

 7.4.10   Inspections weekly and after storms 	    7-176

 7.4.11   Worksheet for determining Che adequacy of the applicant's
            plan for inspection during operation	    7-180

 7.5.1    Applicability of regulations to treatment of Che
            waste pile	    7-184

 7.6.1    Applicability of regulations to management of ignitable and
            reactive wastes 	    7-188

 7.6.2    Flow diagram for evaluating the technical adequacy of the
            application for -nanageraent of ignitable or reactive
            waste	    7-192

 7.5.3    Worksheet for evaluating the-applicant's  subraittal on
            ignitable and reactive waste identification ...'....    7-199

 7.6.4    Worksheet for evaluating ignitable and reactive waste
            treatment procedures  	    7-204

 7.6.5    Worksheet for evaluating management of ignitable or
            reactive wastes in containers 	    7-206

 7.7.1    Applicability of regulations to incompatible wastes ....    7-210

 7.7.2    Flow diagram for assessing the compatibility of hazardous
            wastes using procedures specified in EPA-600/6-80-076 . .    7-215

 7.7.3    Worksheet for determination of hazardous  waste
            compatibility 	    7-217

 7.7.4    Hazardous waste compatibility chart 	    7-218

 7.7.5    Worksheet for evaluating management procedures for
            incompatible wastes		    7-221
                                      xvi

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                               TTC'JRES  ' continue a)

lumber                                                                  Page

 7.8.1    Applicability of regulations Co waste pile closure  ....    7-224

 7.8.2    Worksheet for evaluating waste pile closure procedures  .  .    7-226

 8.1.1    Worksheet for evaluating the adequacy of listing hazardous
            wastes and constituents being or to be land treated at
            existing facilities 	    8-21

 3.1.2    Worksheet for evaluating Che adequacy of listing hazardous
            wastes and constituents Co be land treated at new
            facilities	    8-22

 8.1.3    Worksheet for items to be simulated by treatment
            demonstration cests/evaluacion  	    8-25

 3.1.4    Decision -hart co determine creatability of hazardous
            organic constituents—based on soil rsspiration
            studies	    8-44

 3.1.5    Effect of creatraent frequency on Che evolution of CO?
            from Norwood soil amended with petrochemical sludge
            and incubated cor 130 aays at 30°C and 18 percent
            moisture	    3-45

 8.1.6    Worksheet for evaluating the adequacy of field tests for
            demonstrating hazardous constituent treatment 	    8-48

 8.1.7    Effect of resting time before tilling on emissions after
            subsurface injection  , .  ,	    8-52

 8.2.1    Components of the land treatment program	    8-75

 8.2.2    Worksheet for evaluating completeness of description of
            wastes for land creaCment program 	    8-76

 8.2.3    Worksheet for assessing completeness of applicant's waste
            application rate and methods	    8-80

 8.2.4    Estimated storage days based only on climatic factors  . .  .    3-82

 8.2.5    Relationship between soil cexture and che amount of
            limestone  required Co raise Che pH of New York soils
            to 7.0	     8-90

 8.2.6    Worksheet for evaluating applicant's unsaturated zone
            monitoring plan	     8-97
                                      xvii

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                              FIGURES  (continued)

Number                                                                  Page

 8.2.7    General relationship between soil particle size and
            minerals content  	    8-107

 8.2.8    Atterberg limits	    8-110

 3.3.1    Worksheet for determination of the magnitude of the
            25-year storm event  	    3-123

 o.J.2    Typical intensity-duration-frequency curves 	    8-126

 8.3.3    Solution of the SCS runoff equation	    8-128

 8.3.4    Worksheet for determination of peak run-on discharge rate
            for evaluation of run-on control  	    8-131

 3.3.5    Technical issues associated with run-off control  	    8-134

 8.3.6    24-hour, 25-year rainfall event (inches)  	    8-135

 8.3.7    Worksheet for evaluating the magnitude of the selected
            storm event	    3-136

 8.3.8    Worksheet for evaluating run-off volume computations  .  .  .    8-138

 8.3.9    Worksheet for evaluating management of unit's run-on and
            run-off control systems . -»	    8-141

 8.3.10   Worksheet for evaluating wind dispersal control measures   .    8-143

 3.3.11   Worksheet for evaluating the applicant's inspection
            program	    8-145

 8.4.1    Worksheet to evaluate similarities of conditions under
            which food-chain crop demonstrations are made	    8-160

 8.4.2    Worksheet to assess food-chain crop demonstration made
            by greenhouse tests .......... 	    8-161

 8.4.3    Worksheet to assess food-chain crop demonstration made
            by field teats  . ,	    8-162

 8.4.4    Worksheet for evaluating adequacy of permit application
            where waste(s) containing cadmium will be or are
            being treated	    8-164

 8.6.1    Flow diagram for evaluating the technical adequacy of
            the application for disposal of ignitable or reactive
            waste	    3-180

                                      xviii

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                              FIGURES  (continued)

Number                                                                  Pa ge

 8.6.2    Worksheet to evaluate applicant's plan for handling
            ignitable or reactive wastes  	    8-192

 8.7.1    Flow diagram for assessing the comoatibilitv of hazardous
            vasce anir.g prccadaraa specified in A Method for
            Determining che Compatibility of Hazardous Wastes ....    8-201

 8.7.2    Worksheet for determination of hazardous vasta
            ^spauij! ::_•:•/	    8-202

 8.7.3    Hazardous waste compatibility chart 	    8-204

 8.7.4    Worksheet for evaluating applicant's submittal for meeting
            special requirements for incompatible wastes  	    8-207

 9.1.1    Worksheet for evaluating the adequacy of Che listing of
            hazardous wastes for existing facilities  	    9-7

 9.1.2    Worksheet for evaluating the adequacy of the listing of
            hazardous wastes for new facilities 	    9-8

 9.2.1    Applicability of Part 264 requirements co iiner systems .  .    9-14

 9.2.2    Evaluation of proposed liner systems  	    9-15

 9.2.3    Land subsidence in the Tular-e-Wasco area, California,  1926-
            1962, due to withdrawal of ground water	    9-34

 9.2.4    Example soil grain size analysis	    9-39

 9.2.5    Soil classification based on grain size	    9-40

 9.2.6    Atterberg limits  	    9-42

 9.2.7    Casagrande's plasticity chart showing several
            representative soil types 	    9-44

 9.2.8    Calculation of settlement from the phase diagram  	    9-47

 9.2.9    Profile of distortion settlement of a uniformly loaded
            flexible foundation on an elastic solid such as a
            saturated clay	    9-49

 9.2.10   Profile of distortion settlement of a uniformly loaded
            flexible foundation on a cohesionless soil  	    9-49

 9.2.11   Worksheet for evaluating design of liner system 	    9-51
                                      xix

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                               FIGURES (continued)

 Number                                                                   Page

  9.2.12    Applicability of  Part  264  requirements  Co  leachate
             collection and  removal systems   	    9-62

.  9.2.13    Evaluation of leachata collection  and removal
             jy3tam design  	    9-63

  9.2.14    Alternative drainage system orientations considered  in
             solving for maximum  leachara  depth  .....  	    9-66

  9.2.15    Relationship between h   /L and c  3 e/k   	    9-67
                                 max               3

  9.2.16    Hazardous waste  landfill profile simulated using HELP  .  .  .    9-70

  9.2.17    Pipe  installation - conditions  and loading   	    9-76

  9.2.13    Trench  condition  - pipe  load coefficient   	    9-80

  9.2.19    Projecting condition - pipe load coefficient   	    9-81

  9.2.20    Worksheet for calculation  of load  bearing capacity of
             underground leachate collection  system piping  	    9-91

  9.2.21    Illustration of  prevention of piping by graded filters   .  .    9-95

  9.2.22    Worksheet CO determine adequacy of design of drainage
             and filter layers .... -	    9-98

  9.2.23    Worksheet for determining  the adequacy  of  filter fabrics
             proposed by the applicant	    9-100

  9.2.24    Worksheet for determining  tha adequacy  of pipe perforation
             or  sloe design	    9-101

  9.2.25    General  purpose nozzle and penetrator nozzle   	    9-103

  9.2.26    Worksheet for determining  the adequacy  of the applicant's
             submittal for  a liner  and leachate collection system
             exemption	    9-111

  9.2.27    Regulations applicable to  the control of run-on and  run-
             off at  hazardous waste landfills  	    9-114

  9.2.28    Technical topics  addressed for  run-on control  	    9-115

  9.2.29    Worksheet for determination of  the magnitude of the  25-
             year  storm event for evaluation  of run-on control  ....    9-117
                                       xx

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                               FIGURES  Ccontinued?

Number                                                                  Page

 9.2.30   Typical intensity-duration-frequency curves 	    9-120

 9.2.31   Solution of the SCS run-off equation  	    9-122

 9.2.32   Worksheet cor evaluation of calculated peak run-on
            discharge rate	    9-125

 9.2.33   Technical issues associated with -vr.-^rf control	    9-128

 9.2.34   24-hour, 25-year rainfall event (inches)  	    9-129

 9.2.35   Worksheet for evaluating the magnitude of the selected
            storm event	    9-130

 9.2.36   Worksheet for evaluating run-off volume computations  .  .   .    9-132

 9.2.37   Worksheet for determining the adequacy of the applicant's
            plan to manage units associated *ith run-on and run-off
            control	    9-137

 9.2.38   Regulations applicable to the control of wind disoersal  of
            particulate matter at hazardous *aste landfills 	    9-139

 9.2.39   Wind dispersal control options  	    9-140

 9.2.40   Worksheet for evaluating the-adequacy of wind dispersal
            control measures  	    9-141

 9.2.41   Applicability of Part 264 requirements Co Che Subpart F
            exemption	    9-144

 9.2.42   Worksheet for determining adequacy of applicant's submittal
            for an exemption from Subpart F	    9-146

 9.3.1    Standards applicable to landfill inspection 	    9-149

 9.3.2    Worksheet for determining the adequacy of general
            inspection information  	    9-151

 9.3.3    Inspection of liner and cover system -natarials before
            and during installation 	    9-152

 9.3.4    Worksheet for determining the adequacy of inspection
            procedures before and during installation 	    9-163

 9.3.5    Inspection of synthetic liners  and covers after
            installation  	    9-169
                                       xxi

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                               FIGURES  ("continued)

Number                                                                  Page

 9.3.6    Inspection of soil-based and admixed liners and covers
            after installation	    9-171

 9.3.7    Moisture-density curve of a cohesive soil ....    ....    9-172

 9.3.3    Plasticity chart  	    9-174

 9.3.9    Worksheet for determining the adequacy ^f Inspection
            procedures alter installation 	    9-178

 9.3.10   Inspections weekly and after storms 	    9-180

 9.3.11   Worksheet for determining the adequacy of weekly and
            after storm inspection procedures 	    9-134

 9.4.1    Regulations applicable co closure of hazardous waste
            landfills	    9-190

 9.4.2    Examine background data	    9-191

 9.4.3    Characterize the cover system 	    9-192

 9.4.4    Evaluate post-closure plan	    9-193

 9.4.5    Worksheet for evaluating closure and post-closure
            procedures	 . ~.	    9-198

 9.5.1    Applicability of regulations to handling and disposal  of
            ignitabie and reactive wastes 	    9-205

 9.5.2    Flow diagram for evaluating the Technical adequacy or  the
            application for disposal of ignitabie or reactive
            waste	    9-210

 9.5.3    Worksheet for evaluating the applicant's aubmittal on
            ignitabie and reactive waste identification 	    9-217

 9.5.4    Worksheet for evaluating ignitabie and reactive waste
            treatment procedures  	    9-222

 9.5.5    Worksheet for evaluating disposal procedures for
            containerized ignitabie wastes  	    9-226

 9.6.1    Regulations applicable to handling and disposal of
            incompatible wastes at landfills  	    9-230
                                       xxii

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                              FIGURES  (continued)

Number                                                                  Page

 9.6.2    Flow diagram for assessing Che compatibility of hazardous
            wastes using procedures specified in EPA-600/2-80-076 . .     9-235

 9.6.3    Worksheet for determination -Ł hazardous waste
                          . . ........ .... ........     9-236
 9.6.4    Hazardous waste compatibility chart .......... .  .     9-238

 9-6.5    Worksneec tor evaluating disposal procedures for
            incompatible wastes ...................     9-240

 9.7.1    Regulations applicable to management of liquid wastes at
            landfills ........................     9-244

 9.7.2    Assessment jf cechnicai adequacy of the applicant '3 plans
9.7.3
9.3.1
9.3.2
9.3.3
Worksheet for evaluating disposal procedures for liquid
Applicability of regulations for containers ... 	
Technical aspects of container disposal in landfills . . •
Worksheet for evaluating disposal' procedures for containers
and lab Backs 	 ~. 	
9-261
9-267
9-270
9-276
                                       xxiii

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                                     TABLES
Number                                                                  Page

 2.1      The RCRA Table of Contancs   	    2-2

 2.2      Parts of Title 40 of Che CFR Regarding Permitting and
            Hazardous Waste Handling and Disposal 	    2-5

 3.3.1    Checklist of Documents to Include in Administrative
            Record	    3-18
 e •>
          Water Analysis Summary Report 	    5-8

 5.10.1   Technical Adequacy Checklist  	    5-116

 6.2-i    Effects of Exposure on Selected Polymeric Membrane Liners
            in Water Containing a Low Concentration }f a Dissolved
            Organic Chemical cor 17.2 Months  	    6-21

 6.2.2    Chemical Resistivity or Synthetic Liner Materials .....    6-22

 6.2.3    Synthetic Liner-Industrial Waste Compatibilities  	    6-24

 6.2.4    Relative Membrane Liner Permeability Based on Testing with
            Hazardous Wastes  	    6-27

 6.2.5    Failure Catagoriss	    6-28

 6.2.6    Polymeric Membrane Liner Resistance to Natural
            Elements	    6-32

 6.2.7    Swell Potential Versus Atterberg Limit Values in Three
            Clay Soils	    6-36

 6.2.8    Resistivity of Clay-Soil Liner Material to Specific
            Chemical Compounds  	    6-38

 6.2.9    Admixed Liner Industrial Waste Compatibilities  	    6-43

 6.2.10   Runoff Curve Numbers for Hydrologic Soil-Cover
            Complexes	    6-71

 6.2.11   Representative Values of Manning's Roughness
            Coefficient	    6-74

                                      xxiv

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                               7AI2Lw3  .ccmtinuea;




Number                                                                   Page




 6.3.1    Equivalence of Liner and Cover System  Layers  in
6.6.1

6.9.1
7.3.1

7.3.2

7.3.3
7.3.4
7.3.5

7.3.6
7.3.7
7.3.3

7.3.9

7.3.10
7.3.11
7.3.12
7.3.13
7.4.1

7.6.1
7.6.2
7.6.3
7.9.1
Compatibility of Selected Waste Categories with Different
Waste Solidification/Stabilization Techniaues 	
Technical Adequacy Checklist 	
Swell Potential Versus Atterberg Limit 'Mines in Three
Clay Soils 	
Resistivity of Clay-Soil Liner Material to Specific
Chemical Compounds 	
Admixed Liner Industrial Waste Compatibilities 	
Chemical Resistance of Plastics Used for Piping 	
Trench Transition Widths for 6- and 8-Inch Diameter
Pipes Installed in Sand and Gravel ... 	
Minimum Crushing Strength (3-Edge Bearing Strength ....
Maximum Long-Term Deflection of F/AY 46 psi PVC 	
Values of Load Coef f icients ,- Cg , for Concentrated Loads
Vertically Centered Over Conduit 	
Percentge of Wheel Loads Transmitted to Underground
Pipes 	
Values of Run-Off Coefficient, C 	
Retardance Coefficient, Cr 	
Run-Off Curve Numbers for Hydrologic Soil-Cover Complexes .
Representative Values of Manning's Roughness Coefficient
Equivalence of Liner and Cover System Layers in
Consideration of Inspection Requirements 	
Igni table Wastes 	
Reactive Wastes 	

Technical Adequacy Checklist 	
U 77
3-153
6-166

7-27

7-28
7-34
7-65

7-68
7-74
7-77

7-79

7-30
7-110
7-110
7-114
7-125

7-150
7-193
7-196
7-200
7-229
                                      XXV

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                                TABLES  <,continued)

Number

 3.1.1    Example Format for Listing Wastes that will be  Treated  in
8.1.2

8.1.3
8.1.4

8.1.5

8.1.6
8.1.7

3.1.8
8.1.9
8.1.10
8.1.11

8.1.12

8.1.13
8.1.14

8.1.15

8.1.16
3.1.17
8.1.18

General Information to be Included in Field Test
Descriptions 	 	 	 	
Required Information for Treatment Demonstration 	
' Treatment of Hazardous Constituents by Land Treatment
Processes 	
Qualitative Assessment of Che Land Treatability of
Hazardous Material Groups 	
Sources of Industrial Hazardous Waste Streams 	
Industry Groups Currantly Operating Hazardous Waste
Land Treatment Units 	
List of Pertinent Nonhazardous Constituents or Substances
Utility of Data Sources for Making Treatment Demonstration .
Key Land Treatment Reference Sources 	
Test Methods for Assessing Specific Waste-Site
Interactions 	 .........
Suggested Soil Parameters to Monitor Prior to and After
Waste Application 	
Interpretation of Soil Chemical Tests 	
Suitability of Various Textured Soils for Land Treatment
of Hazardous Industrial Wastes 	
Example Hazardous Waste and Hazardous Constituent

Pre treatment Methods for Hazardous Wastes 	
Rates of Degradation of Phenol and Phenolic Compounds . . .
Response of Soil Microbial Populations to Application of

o /
8-10
8-15

8-16

8-16
3-i3

3-19
8-20
3-24
3-27

3-30

3-32
. 8-33

8-34

8-35
8-36
8-40

8-41
 8.1.19   Response of Soil Microbial Populations to Application of
            Various Alcohols 	   8-41
                                      xxvi

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                               TABLES (continued)

Number                                                                   Page

 8.1.20   Decomposition of Carboxylic Acids in Soils  .........   3-42

 8.1.21   Percent Degradation After 10, 20, and 30 Years for Organic
            Constituents with Various Half-Lives in Soil .......   3-47

 3.1.22   Optimum Values of Selected Soil Factors for 3iodegradation  .   8-47

 8.1.23   Matrix of Experimental Conditions for Land  Treatment
            Simulation 3an          . .................   8-54
 8.1.24   Relative Ranking of Chemicals Potentially Released from
            Hazardous Waste Treatment, Storage, and Disposal Facilities
            by Vapor Hazard Ratio  ..................   8-55

 8.2.1    Format for Reporting Application, Rate, and Capacity
            Limiting Constituents  ..................   3-68

 8.2.2    Format for Identifying Limiting Constituents ........   8-68

 8.2.3    Example Waste Application Schedule .............   8-70

 8.2.4    Format for Reporting the Results of Soil Sampling and
            Analysis ...................... ...   8-73

 8.2.5    Waste Components :o be Compared in Determining Application,
            Rate, and Capacity Limitin-g Constituents .........   8-77

 3.2.6    Computation of Number of Applications Per Year Based on
            Organic Constituent Degradation  .............   8-78

 3.2.7    Advantages and Disadvantages of Various Systems of Waste
            Application  ... ....................   8-81

 3.2.3    Summary of Land Treatment Experiences in the Hydrocarbon
            Processing Industry  ...................   8-83

 3.2.9    Alternative Management Techniques to Replace the Role of
            Crop Cover in a Land Treatment System  ..........   8-86

 3.2.10   Normal Range and Toxic Concentration of Trace Elements
            in Plants  ........................   8-87

 8.2.11   Some Organics that Become Acidic When Wet  .........   8-92

 3.2.12   Suggested Unsaturated Zone Monitoring Sampling Scheme  .  .   .   3-99

 8.2.13   Examples of Possible Responses to the Detection of
            Hazardous Constituent Migration  .............   8-100


                                      xxvii

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                               TABLES (continued)




Number                                                                  Paze
8.2.14

8.2.15
8.2.16
8.2.17
8.2.18

8.2.19
8.3.1
3.3.2

3.3.3
3.3,4

8.4.1
8.4.2
8.6.1
8.6.2
3.6.3
8.7.1
8.8.1

9.2.1


9.2.2
9.2.3
9.2.4

Example of Soil Characteristics to be Included in Applicant's
Treatment Zone Description 	
Temperature and Precipitation Data ....... .....
Freeze Dates in Spring and Fall 	
Growing Season Length 	
United States Department of Agriculture (USDA) Soil
Textures 	
Interpretation of Soil Chemical Tests 	
Values of Run-Off Coefficient, C 	
Retardance Coefficient, C 	
r
Runoff Curve Numbers for Hydrologic Soil-Sover Complexes . .
Representative Values of n, Manning's Roughness
Coefficient . . , . 	
Example Cadmium Loading Rate Table 	
Plant Uptake and Translocatiun of Pesticides from Soils . .
Ignitable Wastes 	 	

Overview of Hazardous Waste Treatment Processes 	
Listing of Known Incompatible Waste or Waste Components . .
Technical Adequacy Checklist for Reviewing Part B Land
Treatment Permit Applications 	
Effects of Exposure on Selected Polymeric Membrane Liners
in Water Containing a Low Concentration of a Dissolved
Organic Chemical for 17.2 Months 	 ...
Chemical Resistivity of Synthetic Liner Materials 	
Synthetic Liner- Indus trial Waste Compatibilities 	
Relative Membrane Liner Permeability Based on Testing with
Hazardous Wastes 	

3-103
Q 1 f* ',
j I. -* -»
8-105
2-106

8-109
8-112
3-125
3-125

3-129

8-139
3-156
3-159
8-182
8-185
8-137
8-197

8-210


9-19
9-21
9-22

9-25
                                      xxviii

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                               TABLES




Number
9.2.5
9.2.6
9.2.7
9.2.3

9.2.9
9.2.10
9.2.11

9.2.12
9.2.13
9.2.14
9.2.15
9.2.16
9.3.1

9.4.1
9.5.1
9.5.2
9.5.3
9.7.1 .

9.7.2

9.7.3

9.9.1


Failure Categories 	
Polymeric Membrane Liner Resistance to Natural Elements . .
Chemical Resistance of Plastics Used for Piping 	
Transition Widths for 6-Inch and 8-Inch Pipe Installed
in Sand and Gravel 	
Minimum Crushing Strength . . „ 	
Maximum Long-term Deflection of F/AY 46 psi PVC 	
Values of Load Coefficients, C3 , for Concentrated Loads
Vertically Centered Over Conduit 	
Percentage of Wheel Loads Transmitted Co Underground Pipes .
Values of Run-Off Coefficient, C 	
Retardance Coefficient, C,. 	
Run-Off Curve Numbers for Hydrologic Soil-Cover Complexes
Representative Values for Manning's Roughness Coefficient
Equivalence of Liner and Cover System Layers in
Consideration of Inspection Requirements 	
Cover Material General Performance Criteria Evaluation . . •
Ignitable Wastes 	
Reactive Wastes 	
Overview of Hazardous Waste Treatment Processes 	
Compatibility of Selected Waste Categories with Different
Waste Solidification/Stabilization Techniques 	
Present and Projected Economic Considerations for Waste
Stabilization/Solidification Systems 	
Compatibility of Hazardous Liquids and Selected Sorbent
Materials 	
Technical Adequacy Checklist 	
RCRA Permit Application Completeness Checklists
for Parts A & B 	
9-26
9-30
O-7/i

9-77
9-83
9-86

9-88
9-39
9-119
9-119
9-123
9-133

9-154
9-196
9-212
9-215
9-218

9-250

9-255

9-259
9-280

10-2
                                      XXIX

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                                   SECTION  8.0

                                 LAND TREATMENT


     This Section presents guidance on evaluating application information
submitted 'in support of the Land rreairraenc Taciiicy standards specified in
Subpart M of Part 26*.  -The federal requirements are reproduced and the
application information requested by the Part B Permit Applicants' manual is
summarized.  This Section is subdivided into the following seven major subject
areas:

     8.1  Treatment Demonstration

     8.2  Land Treatment Program

     8.3  Design and Operating Requirements

     8.4  Food-Chain Crop Requirements

     8.5  Closure and Post-Closura Cara

     8.6  Special Requirements for Ignitable or Reactive Wastes

     8.7  Special Requirements for Incompatible Wastes

A Technical Adequacy Checklist is provided at the end of the Section in
subsection 8.8.  References cited in each of the first seven suosections are
listed at the end of the subsections.

     The  information requirements of §270.20 are reprinted* below to provide
an overview of the issues to be considered in reviewing a land treatment
permit application.

          §270.20  Specific Part B Information Requirements for Land Treatment
          Facilities
               "Except as otherwise provided in §264.1, owners and operators
          of facilities that use land treatment to dispose of hazardous waste
          muse provide the following additional information:
               (a)  A description of plans to conduct a treatment
          demonstration as required under §264.272.  The description must
          include the following information:
*A11 regulatory citations are reproduced or quoted from Che Federal Register.


                                        8-1

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     (1)  The wastes for which Che demonstracion will be -iade and
the potential aazaraous constituents in the waste;
     (2)  The data sourcas Co be used co raaKe cne demonstration
(e.g., literature, laboratory data, field data, or operating data);
     (3)  Any specific laboratory or field test chat will be
conducted, including:
     (i)  The type of test (e.g., column leaching, degradation);
     (ii)  Materials and methods, including analytical orocadures ;
     'iii)  "ixpect^d time 2o~ oorapietion;
     (iv)  Characteristics of the unit that will be simulated in the
demonstration, including treatment zone characteristics,  climatic
conditions, and operating practices.
     Cb)  \ ^ascription Df a land creacmenc program, as required
under §264,271.  This information must be submitted with the plans
for the treatment demonstration, and updated following the treatment
demonstration.  The land treatment program must address the
following items:
     (1)  The wastes to be land treated;
     (2)  Design measures and operating practices necessary to
maximize treatment in accordance with ^264.273(a) Including:
     (i)  Waste application method and rate;
     (ii)  Measures to control soil pH;
     (iii)  Enhancement of caicrobial or chemical reactions;
     (iv)  Control of moisture content;
     (3)  Provisions for unsaturated zone monitoring, including:
     (i)  Sampling equipment, procedures, and frequency;
     (ii)  Procedures for selecting sampling locations;
     (iii)  Analytical procedures;
     (iv)  Chain of custody control;
     (v)  Procedures for establishing background values;
     (vi)  Statistical methods for interpreting results;
     (vii)  The justification for any hazardous constituents
recommended for selection as principal hazardous constituents, in
accordance with Che criteria for such selection in §264.278(a);
     (4)  A list of hazardous constituents reasonably expected to be
in, or derived from, the wastes to be land created based on waste
analysis performed pursuant to §264.13;
     (5)  The proposed dimensions of the treatment zone;
     (c)  A description of how the unit is or will be designed,
constructed, operated, and maintained in order to meet the
requirements of §264.273.  This submission must address the
following items:
     (1)  Control of run-on;
     (2)  Collection and control of run-off;
     (3)  Minimization of run-off of hazardous constituents from the
treatment zone;
     (4)  Management of collection and holding facilities associated
with run-on and run-off control systems;
     (5)  Periodic inspection of the unit.  This information should
be included in the inspection plan submitted under §270.14(b)(5);
     (6)  Control of wind dispersal of particulate matter, if
applicable;
                           8-2

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               (d)  If f3od-chain crops are Co be grown in or on the treatment
          zone of the land treatment unit, a description of how che
          demonstration required under §264.276(a) will be conducted including
               (1)  Characteristics jf Che rood-chain crop for which the
          demonstration will be made.
               (2)'  Characteristics of the waste, treatment zone, and waste
          application method and rate to be used in the demonstration;
               (3)  Procedures for crop growth, sample collection,  sample
          analysis,  and data evaluation;
               (4)  Characteristics of the comparison crop including the
          location and conditions under which it was or will be grown;
               (e)  If food-chain crops are to be grown, and cadmium is
          present in the land-treated waste, a description cz how che
          retirements jf ! 254. ,:76(b,) will be complied with;
               (f)  A description of the vegetative cover to be applied to
          closed portions of the facility, and a plan for maintaining such
          cover during the post-closure care period, as required under
          §264.280(a)(8) and §264.280(c)(2).  This information should be
          included in the closure plan and, where applicable, the post-closure
          care plan submitted under § 270.14(b)(13);
               (g)  If ignitable or reactive vastes vill be placed in or on
          the treatment zone, an explanation of how the requirements of
          §264.281 will be complied with;
               (h)  If incompatible wastes, or incompatible wastes and
          materials, will be placad in or  on the same treatment zone, an
          explanation of how §264.282 will be complied with."

     In using this manual to evaluate permit applications it is important to
recognize that the recommended specifications and techniques presented are
guidance, not regulations.  During che permitting process there will be
considerable negotiation to determine best facility design and operating
practices for a subject land treatment unit.  Owners and operators  may design
and/or operate their facilities differently than the methods recommended
herein, which is acceptable as long as sufficient information is presented in
the permit application to demonstrate compliance with specified performance
requirements.

3.1  TREATMENT DEMONSTRATION

8.1.1  Federal Requirement

     Plans for conducting a treatment demonstration and presenting complete
demonstration results, unless applying for a two-phase permit, must be
included in the Part B permit application  for facilities that use land
treatment to dispose of hazardous waste.  Section 270.20(a) states  that the
Part B application must include:

               "(a)   A description of plans to conduct a treatment
          demonstration as required under  §264.272.  The description must
          include the following information:
               (1)  The wastes for which the demonstration will be  made and
          the potential hazardous constituents in the waste;
                                    8-3

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               (2/  The data sourcas ".o b^ u^ed :j .ISK.& cne aemonscration
          (e.g., Literature, laboratory data, field data,  or operating data);
               (3)  Any specific laboratory or field test  that will be
          conducted, including:
               (i)  The type of test (e.g., column caching, degradation);
               (ii)  Materials and methods, including analytical procedures;
               (iii)  Expected time for completion;
               (iv)  Characteristics of the unit that will be simulated in the
          demonstration, including treatment zone characteristics,  climatic
          conditions, and ooerating prscticas."

     Applicants who use existing available data to complete the treatment
demonstration or who are issued short-term demonstration permits must submit
the demonstration results with rhe ?art 3 porai; application.  Applicants who
are issued a two-phase permit are required to submit the demonstration results
upon completion of testing.  The following discussion addresses short-terra and
two-phase permits.

     The technical standards of Part 264 for the treatment demonstration,
covered under §264.272(a), (b),  and (c), are as follows:

               "(a)  ?or each waste chat will be applied to the treatment
          zone, the owner or operator must demonstrate, prior to application
          of the waste, chat Hazardous constituents in the waste can be
          completely degraded, transformed, or immobilized in :he treatment
          zone.
               (b)-  In making this demonstration, the owner or operator may
          use field tests, laboratory analyses, available  data, or, in the
          case of existing units, operating data.  If the  owner or operator
          intends to conduct field tests or laboratory analyses in order to
          make the demonstration required under paragraph  (a) of this section,
          he must obtain a treatment or disposal permit under §270.63.  The
          Regional Administrator will specify in this permit the testing,
          analytical, design, and operating requirements (including the
          duration of the tests and analyses, and, in Che  case of field tests,
          the horizontal and vertical dimensions of the treatment zone,
          monitoring procedures, closure and clean-up activities) necessary to
          meet the requirements in paragraph (c) of this section.
               (c)  Any field test or laboratory analysis  conducted in order
          to make a demonstration under paragraph (a) of this section must:
               (1)  Accurately simulate the characteristics and operating
          conditions for the proposed land treatment unit  including:
               (i)  The characteristics of the waste (including the presence
          of Appendix VIII of Part 261 of this chapter constituents);
               (ii)  The climate in the area;
               (iii)  The topography of the surrounding area;
               (iv)  The characteristics of the soil in the treatment zone
          (including depth); and
               (v)  The operating practices to be used at  the unit.
               (2)  Be likely to show that hazardous constituents in the waste
          to be tested will be completely degraded, transformed, or immobilized
          in the treeatment zone of the proposed land treatment unit; and
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               (3)  3e conducted in a manner thic procects auman health and
          -he environment considering:
               (i)  The characteristic.' of ;he waste Co be tested;
               (ii)  The operating and monitoring measures :a*en during the
          course jf che cesc;
               (iii)  The duration of the test;
               (iv)  The volume of waste used in the test;
               (v)  In the case of field tests, the potential for migration of
          hazardous constituents to ground water or surface water."

     When the applicant intends to conduct field or laboratory analyses to
make the treatment demonstration, the owner or operator must first obtain a
treatment or disposal permit.  Under such conditions, a short-term Detroit
covering only field testing and/or laboratory insiyses .oay be issued, or a
two-phase facility permit may be issued covering the treatment demonstration
and facility design, construction, operation, and maintenance.  Section 270.63,
presented below, defines the nature of these permits and the conditions under
which they should be issued.

     Section 270.63, Permits for land treatment demonstrations using field
test or laboratory analyses, states:

               "(a)  For the purpose of allowing an owner or operator to meet
          the treatment demonstration requirements of §264.272 of this
          Chapter, the Director may issue a treatment demonstration permit.
          The permit must contain only those requirements necessary to meet
          the standards in §264.272(c).  The permit may be issued either as a
          treatment or disposal perrai* covering only the fiej.d test or
          laboratory analyses, or as a.two-phase facility permit covering the
          field tests, or laboratory analyses, and design, construction,
          operation, and maintenance of the land treatment unit.
               (1)  The Director may issue a two-phase facility permit if he
          finds that, based on information submitted in Part B of the
          application, substantial, although incomplete or inconclusive,
          information already exists upon which to base the issuance of a
          facility permit.
               (2)  If the Director finds that not enough information exists
          upon which he can establish permit conditions to attempt to provide
          for compliance with all of the requirements of Subpart M, he must
          issue a treatment demonstration permit covering only the field test
          or laboratory analyses.
               (b)  If the Director finds that a phased permit may be issued,
          he will establish, as requirements in the first phase of the
          facility permit, conditions for conducting the field tests or
          laboratory analyses.  These permit conditions will include design
          and operating parameters (including the duration of the tests or
          analyses and, in the case of field tests, the horizontal and
          vertical dimensions of the treatment zone), monitoring procedures,
          post-demonstration clean-up activities, and any other conditions
          which the director finds may be necessary under §264.272(c).  The
          Director will include conditions in the second phase of the facility
          permit to attempt to meet all Subpart M requirements pertaining to
                                     8-5

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          unit design, construction,  operation, and maintenance.   The Director
          will establish these conditions In cne second phase of the permit
          based upon the substantial  but incomplete or inconclusive
          information contained in the Part 8 application.
               (1)  The first phase of the permit will be effective as
          provided in §124.15(b) of this Chapter.
               (2)  The second phase  of the permit will be  effective as
          provided in paragraph (d) of this Section.
               (c)  When the owner or operator wno nas been issued a two-phase
          permit has completed the treatment demonstration, he must submit to
          the Director a certification, signed by a person  authorized to sign
          a permit application or report under §270.11, that the field tests
          or laboratory analvses hav»>. K«en carried ouc in accordance with the
          conditions specified in phase one of the permit for conducting such
          tests or analyses.  The owner or operator must also submit all data
          collected during the field  tests or laboratory analyses within
          90 days of completion of those testa or analyses  unless the Director
          approves a later date.
               (d)  If the Director determines that the results of che field
          tests or laboratory analyses meet the requirements of ?264,272 of
          this Chapter, he *iil .nodify tne second phase of  the permit to
          incorporate any requirements necessary for operation of the facility
          in compliance with Part 264, Subpart M, of this Chapter,  based upon
          the results of the field tests or laboratory analyses.
               (1)  This permit modification may proceed as a minor
          modification under §270.42, provided any such change is minor, or
          otherwise will proceed as a modification under §270.41(a)(2).
               (2)  If no modifications of the second phase of the permit are
          necessary, or if only minor modifications are necessary and have
          been made, che Director will give notice of his final decision to
          the permit applicant and to each person who submitted written
          comments on the phased permit or who requested notice of the final
          decision on the second phase of the permit.  The  second phase of the
          permit then will become effective as specified in §124.15(b).
               (3)  If modifications  under §270.41(a)(2) are necessary, the
          second phase of the permit  will become effective  only after chose
          modifications have been made."

8.1.2  Summary of Necessary Application Information

     The following summarizes the information to be submitted in the Part B
permit application for land treatment facilities.  Information requirements
identified are those presented in EPA's Permit Applicants'  Guidance Manual for
Hazardous Waste Land Storage, Treatment, and Disposal Facilities.1  The
applicant is required to submit a treatment demonstration plan that describes
how hazardous constituents contained  in or derived from wastes to be disposed
of at the facility will be degraded,  transformed, or immobilized in the
treatment zone.  This applies to both new and existing facilities.   All
treatment demonstrations should contain two components; a plan and the results.
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3.1.2.1  Treatment Demonstration Plan—
     Items to be included in the plan .are:   (1) description of wastes for
treatment demonstration, (2) data sources to make demonstration, and  (3) when
used, a description of laboratory and field  test designs.

8.1.2.1.1  Wastes for Treatment Demonstration Plan—

Part 1 - The applicant must list the hazardous wastes that will be land
treated.  In addition, nonhazardous wastes that wi.il be applied ;o che same
treatment ione or plot as che hazardous waste(s) should also be listed.  The
Permit Applicant's Guidance Manual recommends that wastes be listed in the
format shown in Table 8.1.1.

                    2XAMPLS FORMAT FOR LISTING WASTES THAT WILL BE TREATED
                    IN THE HWLT UNIT
     Name  of waste
                         Generating  process
                             ::  source
    Monthly
   or annual
   quantity
 EPA hazardous
waste ID number
  Oil/Water  Separator
    Sludge

  Leaded  Tank  Bottoms
  Treated  Wastewater
Crude Topping Unit


Leaded Gasoline
  Storage

Refinery Wastewater
  Treatment Plant
    50 m Ton /Mo
   100 m Ton/Yr
     X051
     K052
50,000 m Ton/Mo    Nonhazardous
Part 2 - List hazardous constituents (see Appendix VIII, Part 261) present in
or expected to be derived from each hazardous waste to be land treated and
pertinent nonhazardous constituents of wastes to be applied to same portion of
the treatment zone.  "Pertinent" nonhazardous constituents means any
nonhazardous constituent that will likely affect the degradation,
transformation, or immobilization of hazardous constituents.

Part 3 - For each waste identified in Part 1 above, the following information
should be included in the application:

     •    concentration of each hazardous and pertinent nonhazardous
          constituent,

     •    concentration of volatile hazardous constituents,

     •    percent water content,

     •    specific gravity or bulk density,
                                     8-7

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     •    oH.

     •    electrical conductivity,

     •    total acidity or alkalinity, and

     •    total organic carbon.

8.1.2.1.2  Data Sources for Treatment Demonstration—Published literature,
laboratory studies, field c^sta, and existing operating data may be used to
make the treatment demonstration.  The applicant should explain which data
source will be used to make the treatment demonstration and expected results.

8.1.2.1.3  Laboraco-^ and Tisid last design—If laboratory and/or field tests
are used to make the treatment demonstration, the following information should
be provided, respectively.

Part 1 - An explanation covering the following information should be provided
for each laboratory test performed:

     «    name of test,

     •    objective of test,

     •    materials and methods,

     •    schedule of completion,

     •    list of experimental conditions, and

     •    description of data reduction, analysis, and presentation.

Part 2 - When field cests are to be used to make the treatment demonstration
the applicant should prepare a written description containing the following:

     •    objectives of test,

     •    scale drawings delineating number and size of plots,

     •    statistical design of the test(s),

     •    dimensions of each plot treatment zone,

     •    test plot preparation,

     •    waste application rate and method on each plot,

     •    irrigation methods and scheduling,

     •    methods  for establishing and maintaining vegetation (if vegetated),

     •    meteorological data collection and recording techniques,
                                     8-8

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     •    procedures cor ~oni^ori.;g JOI.L, son pore liquid, run-off,
          vegetacion, ground water, and ambient air, as applicable,

     •    schedule of daily events and activities,

     •    rationale for design and management of field tests,

     •    expected test results and data presentation, and

     •    clean-uo procedures apon completion of field tests.

8.1.2.2  Treatment Demonstration Results—
     Results obtained from the treatment demonstration should be submitted
with the Part B oermit ^opllr.stion.  Ihij Applies Co both single-phase and
cwo-phase permits, with submittal of results upon completion of testing for
the latter.

8.1.2.2.1  Wastes and Waste Composition—If wastes used in treatment
demonstration differ from those submitted in treatment demonstration plan, the
applicant should identify these wastes and provide physical and chemical char-
acterizations of each.  Pretreatment or mixing of vastas should also be noted.

8.1.2.2.2  Degradation/Trans formation—The applicant should provide the
results of any literature review, existing operating data, laboratory tests,
and/or field tests demonstrating the rate (time) and extent (percentage) of
specific organic hazardous constituent and bulk organic fraction degradation.

Part 1 - Review of existing literature - The applicant should provide a
concise discussion of how data contained in the literature are appropriate to
use to make the treatment demonstration.  .lost important factors to be
discussed are representativeness of data to proposed treatment facility.

Part 2 - Existing Operating Data - Applicant should submit the following
operating information as appropriate to make the treatment demonstration for
the proposed new or existing land treatment facility:

     •    description of existing facility,

     •    operational records,

     •    waste composition,

     •    waste application rate and methods,  and

     •    data demonstrating degradation of hazardous  constituents and/or bulk
          organics.

Part 3 - Laboratory Test Results - Applicant should submit the following
information when laboratory tests are used to demonstrate  organic hazardous
constituent degradation:

     •    name of test,
                                     8-9

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     •    ooiective of tast,

     •    test methods and materials and experimental conditions,

     •    test results (including visual presentations, i.e., graphs, figures,
          and tables), and

     •    accompanying discussion to aid interpretation of results.

Part 4 - Field Test Results - When field tests are conducted to demonstrate
hazardous organic constituent or bulk organic degradation or transformation,
the applicant should submit the following information:

     •    obiectiv*» ^,nd tr.-^s t(_ ),

     •    description of experimental design and procedures (applicant is
          directed to present information contained in Table 8.1.2),

     •    test results (including visual presentations, i.e.., graphs, figures,
          and tables), and

     »    accompanying discussion to aid interpretation of results.

   TABLE  8.1.2.   GENERAL  INFORMATION TO  BE  INCLUDED IN FIELD TEST DESCRIPTIONS
  Location of test  plots  relative
  to  the land treatment ^nic.

  Number and  size of  test ploto.

  Dimensions  of treatment zone for
  field test  plots.

  Preparation of field test  plots.

  Soil properties.

  Waste application rate  on  each
  plot.
Method of waste application and- soil
incorporation techniques.

Irrigation methods and frequency.

Rainfall and temperature data
collected during the test.

Sampling schedule and procedures.

Analytical methods.

Statistical methods.

Photographs of test plots.
8.1.2.2.3  Immobilization—The applicant should submit results from any
literature review, existing operating data, laboratory tests, and/or field
studies that demonstrate organic (for persistent compounds) and inorganic
hazardous constituent immobilization in the treatment zone.
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Part 1 - Review of existing literature - If the applicant elects to
demonstrate constituent .immobilization using iaCs raported in the literature,
a concise written analysis should be presented explaining 
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degradation, transformation, or immobilization.  Because it can result in t
release of untreated hazardous constituents, the extent of organic compound
volatilization must be examined to verify actual constituent creatment.

     The applicant should submit the vapor pressure (mm of Hg) of each organic
hazardous constituent present in the waste to be land treated.  Estimates or
test results of gaseous losses should be expressed as the mass or
concentration of volatilized compound per unit area of soil as a function of
time.  Data sources for estimating volatilisation include published
literature, existing operating data, laboratory tests, and field studies.

Part 1- Published literature - If existing literature is used to estimate
volatilization losses, the applicant should submit support materials, such as
tables or figures, any calculations, description of assumptions and their
rationale, and a discussion of data representativeness.

Part 2 - Operating data - The applicant should submit the following when
existing operating data are used to estimate hazardous constituent gaseous
losses :

     •    descriotion of the facility,

     •    pertinent operational records,

     •    waste composition,

     •    waste application ratas,  and

     •    results of hazardous constituent volatilization.

Part 3 - Laboratory tests - The following information should be provided in
the application if laboratory tests are used to estimate hazardous constituent
vaporization:

     •    name of test,

     •    test methods and materials, including experimental design,

     •    test results, including visual presentation, i.e., graphs,  figures,
          and tables, and

     •    accompanying discussion,  as needed, to interpret results

Part 4 - Field tests - When field tests are conducted, the applicant  should
submit a description of the following information:

     •    test objectives,

     •    test methods and materials, including experimental design,

     •    test results, including visual presentations,  i.e., graphs, figures,
          and tables, and
                                    8-12

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     «    accompanying discussion, as needed, Co interpret results.

     The information identified in Table 8.1.2 should be presented with the
discussion on test procedures.

8.1.2.2.5  Toxicity—

(a) Microbial Toxicity - Biological degradation and transformation are
fundamental processes of the treatment facility.  These processes are carried
out by soil microbes.  Microbial toxicity of the waste and hazardous
constituents must be determined to assess the extent of waste treatment.  If a
waste is highly toxic to the microbial population,  the waste will not be
biodegraded unless it is applied to the soil at a rate below the Chresnold of
toxic affects.  Daca sources that can be used to determine raicrobial toxicity
are published literature, existing operating data,  laboratory tests, and/or
field studies.

Part 1 - Published literature - The applicant should submit an analysis of the
scientific literature or previous studies that contain information concerning
the toxicity of the waste or hazardous constituents to soil microbes.

Part 2 - Existing operating data - For this data source, the applicant should
provide the following:

     •    a description of the existing facility,

     •    operational records,

     •    waste composition,

     •    waste application rates, and

     •    data assessing toxicity of the waste.

Part 3 - Laboratory tests - The applicant should submit the following
information when laboratory tests are conducted to  evaluate microbial toxicity:

     •    name of test,

     •    test methods and materials, including experimental design,

     •    test results, and

     •    accompanying discussion, as needed, to interpret data.

Part 4 - Field test - If field tests are conducted  to determine whether the
hazardous constituents of the waste will be toxic to soil microbes, the
following information should be provided:

     •    statement of test objective,
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     «    case rnetnods and macerials, including Che information identified in
          Table 8.1.2. and

     *    tast results, including visual presentations, i.e., graphs, figures,
          and tables.

(b) Phytotoxicity - If plants are to be grown on or in the treatment zone
during its active life, the applicant should submit data addressing the
phytotoxicity of nondegradable organics or immobilized inorganics to planted
crops.

Part 1 - Review of existing literature - A concise summary of the literature
review, including a description of specific plant species grown, waste
application races ana methods, waste composition, soil type, and test
procedures should be submitted by the applicant.

Part 2 - Existing operating data - For this data source, the applicant should
provide the following information:

     •    a description of che existing facility,

     •    operational records,

     •    waste application rates and methods,  and

     •    data assessing toxicity of the waste.

.-arc 3 - Greenhouse test results - If greenhouse studies are conducted to
assess phytotoxicity, the applicant should provide Che following:

     •    test results (identifying concentrations causing a decrease in plant
          growth),

     •    description of test methods and materials,

     •    experimental design,

     •    waste application rates and methods,

     •    waste application schedule, and

     •    plant species tested.

Part 4 - Field test results - When field tests  are performed to determine
phytotoxic levels,  test results identifying hazardous  constituent
concentrations that inhibit plant growth should be submitted.  A description
of the field test(s) addressing the issues identified  in Table 8.1.2 should
also be included in the written submittal, as well as  a statement  of test
objectives and an accompanying discussion, as needed,  to interpret test
results.
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8.L.3  Guidance on Evaluating Application  Information

     The owner or operator of the land treatment unit must demonstrate that
hazardous constituents in or derived from  the waste(s) applied on or in the
treatment zone soil will be completely degraded, transformed, or immobilized.
Land treatment of the hazardous constituents relies on the dynamic physical,
chemical, and biological processes occurring in the soil of the treatment
zone. Table 8.1.3 identifies the components of the treatment demonstration
that should be included in ""he ^arnit application.

         TABLE 8.1.3.  REQUIRED INFORMATION FOR TREATMENT DEMONSTRATION


         Treatment demonstration plan           Treatment demonstration results


 •  Wastes for treatment demonstration          •  Wastes and waste composition

 •  Data sources for treatment demonstration    •  Degradation/transformation

 »  Laboratory and field case aesign            •  Immobilization

                                                •  Volatilization

                                                •  Toxicity:  Soil Microbes
                                                              Plants
8.1.3.1  Wastes for Treatment Demonstration Plan—

Part 1 - List of hazardous wastes - The treatment demonstration must be made
for wastes that are representative of those that will be land treated at the
proposed disposal jite.  The applicant should identify the type and name of
the waste, process or source generating the waste, monthly or annual quanities
expected to be handled, and EPA Hazardous Waste ID number.  The list presented
by the applicant should be compared with the hazardous wastes identified in
Part 261, Subpart D, §§261.30 through 261.33; Appendix VII of Part 261; and
any applicable state hazardous waste regulation.

     Hazardous wastes will contain organic and inorganic compounds.  In
general, land treatment should be confined to wastes that are principally
organic.  These wastes are more readily treated by the primary soil processes
of biological degradation and chemical transformation.  Inorganic compounds
and heavy metals are unaffected or slowly affected by the degradation and
transformation processes.  These constituents must be immobilized in the
treatment zone.  With respect to persistent hazardous organic constituents,
these compounds must be immobilized in the treatment zone to enable complete
degradation.   Table 8.1.4 summarizes the processes involved in land treatment
of hazardous  constituents,  while Table 8.1.5 describes qualitatively the
treatability of major hazardous material groups.
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 TABLE 8.1.4.  TREATMENT OF .iAZARDOL'S CONSTITUENTS BY LAND TREATMENT ??
PROCESS!^

Hazardous
constituent
Organics
Metals
Inorganic Cations
Inorganic Anions

Degradation3/
transformation
X



Immobilization
Adsorption/ Ion
precipitation exchange
X
X X
X X
X

Plant uptake^*
X
X
X
X
alnciudes biological,  chemical,  and photochemical-dagradacion.

^Removal by crop harvesting.
        TABLE 8.1.5.  QUALITATIVE ASSESSMENT OF THE LAJTO T2Ł AT ABILITY3
                      JF HAZARDOUS MATERIAL GROUPS 2
         Hazardous material group                  Land treatability potential
Solvents and related organics such as                         High
  trichloroethylene, chloroform, and
PCBs and PBBs                                                Limited

Pesticides                                                    High

Inorganic chemicals such as ammonia, cyanide,                Limited
  acids, and bases

Heavy metals                                                 Limited

Waste oils and greases                                        High


aHigh land treatability does not infer immunity from environmental damage.
 Only through proper design and management of a land treatment unit can
 the desired level of treatment be obtained and the migration of hazardous
 materials be prevented.
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     In addition to listing hazardous wastes, the applicant should identify
nonhazardous wastes that will be treated in the same land treatment plot as
the hazardous waste.  Although a treatment demonstration is not required for
the nonhazardous waste, the presence of these wastes in the same plot may
affect hazardous constituent degradation, transformation, and/or
immobilization.

Part 2 - List of hazardous constituents - The applicant should identify the
hazardous constituents present in the waste.  This list should be based on the
results of a complete analysis of the wastes to be land treated at the
facility.  Analytical procedures described in Test Methods for Evaluating
Solid Waste^ should be followed for determining the presence of hazardous
constituents.  Appendix VIII of Part 261 identifies ccnsticuencs ciiac ii?A nas
determined co j& nazaraous.

     To verify the list of hazardous constituents identified by the applicant,
the reviewer should consult the Hazardous Waste Land Treatment (HWLT) manual
and Characteristics of Hazardous Waste Streams6 which provide lengthy
discussions of the general characteristics of various industrial waste
streams.  Table 3.1.6 lists the waste streams described in the referenced
documents.  Appendix A of she HWLT aanuai^ presents the results of a survey
of existing hazardous waste land treatment facilities in the United States.
Table 8.1.7 summarized industry groups currently operating land treatment
un i t s.

     The applicant should also provide information on the presence of
pertinent nonhazardous constituents in the wastes to be applied at the
treatment unit.  As previously described, pertinent nonhazardous constituents
can be any compounds or substance that may affect the degradation,
transformation, or inmooilization of hazardous constituents.   Table 8.1.8
lists the more common pertinent nonhazardous constituents or substances and
the impact they might have on hazardous constituent degradation,
transformation, or immobilization.   Section 6 of the HWLT manual5 identifies
waste streams that contain the pertinent nonhazardous constituents listed in
Table 8.1.8.   Worksheets for evaluating the adequacy of listing hazardous
constituents  to be land treated are presented in Figures 8-1.1 and 3.1.2 for
existing and new facilities, respectively.

Part 3 - Waste characterization - Analytical methods to determine the waste
characteristics identified in Section 8.1.2.1.1, Part 3 are described in
Section 5 of the HWLT manual^ and Test iMethods for Evaluating Solid Waste.^
The applicant should identify the specific test used to determine each waste
characteristic as well as sample collection and preparation techniques.  The
values reported for each characteristic will aid in determining application
rates and frequencies and whether soil conditioning (e.g.,  pH control, soil
moisture control) prior to and subsequent to waste application will be
required.

8.1.3.1.1  Data Sources for Treatment Demonstration—Treatment demonstrations
can be made using information derived from published literature,  laboratory
tests, field studies or existing operating data.  Applicants will frequently
make the treatment demonstration using data obtained from a combination of
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          TABLE 8.1.6.  SOURCES OF INDUSTRIAL HAZARDOUS WASTE STREAMS^
               Specific sources
              of hazardous waste
       Nonspecific sources
       of hazardous waste
Textile Mills
Lumber
Paper
Printing
Inorganic Chemicals
     Alkalies and Chloride
     Inorganic Gases
     Inorganic Pigments
     Other Inorganic Chemicals
Organic Chemicals
     Plastics
     Synthetic Rubber
     Synthetic Fibers
     Pharmaceuticals
     Soaps, Detergents, and Cosmetics
     Paint Formulation
     Gum and Wood Chemicals
     Cyclic Crudes and Intermediaries
          Cyclic (benzenoid) Intermediates
          Synthetic Organic Dyes
          Synthetic Organic Pigment
          Cyclic Crudes
     Other Organic Chemicals
Pesticides
Adhesives
Explosives
Inks
Petroleum Products
     Petroleum Refining
     Petroleum Re-refining
     Syncrudes
Rubber Products
Leather Tanning and Finishing
Stone, Clay, and Glass
Metal Smelting and Refining
Metal Finishing Industries
     Electroplating
     Metal Heat Treating
     Coating
     Solvent Degreasing
Machinery
Electronic Components
Batteries
Electric Utilities
Solvent Bearing Wastes
     Solvent Use in
       Degreasing Operations
     Solvent Use in Product
       Formulation and Synthesis
     Solvent Use in Dry
       Cleaning Plants
Paint Bearing Wastes
Heavy Metal and Cyanide Bearing
  Wastes
     Electroplating Operations
     Metal Heat Treating
     Metal Recovery
     Scrubber Sludges from
       Blast Furnaces and
       Coke Ovens
                                   8-18

-------
      TABLE 8.1.7.  INDUSTRY GROUPS CURRENTLY OPERATING HAZARDOUS WASTE
                    LAWD TREATMENT UNITS5
SIC Code*
29
28
49
34

97
24
36

20
22
39
35
26
13
44
76
02
30
33
37
51
82
Description
Petroleum refining and related industries
Chemicals and allied products
!71">"*ric -as, ana sani ca ry services
Fabricated metal products, except machinery
and transportation equipment
National security and international affairs
Lumber and wood products, except furniture
Electrical and electronic machinery,
equipment, and supplies
Food and kindred products
Textile mill products
Miscellaneous manufacturing industries
Machinery, except electrical
Paper and allied products
Oil and gas extraction
Water transportation
Miscellaneous repair services
Agricultural production - livestock
Rubber and miscellaneous plastics products
Primary metal industries
Transportation equipment
Wholesale trade - nondurable goods
Educational services
Xu.iber of unj.cs
105
" <•>
16

12
9
7

5
*f
4
3
3
3
2
2
2
1
1
1
1
1
1
aStandard industrial classification code.
                                   8-19

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   TABLE 8.1.8.  LIST OF PERTINENT MONHAZARDOUS CONSTITUENTS OR SUBSTANCES
Conscicuent or substance
               Potential impact
Organic Matter
Water
Inorganic Nutrients
  (Nitrogen, pnospnorus,
  boron, and sulfur)
Inorganic Acids and
  Bases

Inorganic Salts
Hal ides
  (Fluorine, chlorine,
  bromine, iodine)

Nonhazardous3 Metals
  (Cobalc, copper,
  lithium, managanese,
  palladium, zinc)
High organic content in waste stimulates microbial
activity, resulting in nutrient depletion if soil
is not fertilized periodically

Also increasing organic content of soil increases
water holding capacity which mav lead lo prolor.gaa
p<=ruas ana anaerobic conditions during wet weather

Excess water can create anaerobic conditions
resulting in reduced degradation

Also addition of excess water may result in
constituent leaching and/or increased surface
runoff

Wastes devoid of inorganic nutrients accelerate
nutrient depletion and must be countered by
increased soil fertilization

Alternatively, excessive concentrations in waste
applied may have detrimental effects on soil
microbes and plants and also may damage physical
properties, of soils

Additions of these constituents upset soil pH
balance such that pH management must be intensified

Soil accumulation of inorganic salts and halides
may retard microbial activity or inhibit plant
growth during active period

Also, salt accumulation will alter physical and
chemical characteristics of soil

Ealide accumulation due to application of excessive
concentrations can be toxic to soil microbes and
cover crops

Elevated soil metal concentrations can retard
microbial activity or inhibit plane growth
aNonhazardous means metal is not listed in Appendix VIII of Part 261,
                                    8-20

-------
         .ISTING Or ;UZARDOUS PASTES AND CONSTITUENTS—EXISTING FACILITY
Has this part of Che applicant's  subraittal been
reviewed and evaluated?
                                                          Ye s     No     Date
Does the Part B information agree completely with  che
information proviuea previously  in  the  Part A application?
                                                                 Yes     No

Are waste names and EPA LD numbers  identified?                   	   	
                                                                 if as     No

Are locations identified  showing where wastes are
or will be applied within the  land  treatment unit?               	   	
                                                                 Yea     No
If all answers are ves.  -his  part  31  :he  applicant's subraittal is adequate.
However,  if any differences exist  between che  Part  A and  °arc 3 applications
continue  below—


Are only  subsets of the  wastes  listed  in  the Part A
application going to be  iana  created?                            	   	
                                                                 Yes     No

Are previously identified  wastes  (in  Part  A) treated
or somehow transformed before  land treatment?                    	   	
                                                                 Yes     No

Have any  of the wastes been delisted?                            	   	
                                                                 Yes     No

Have any  of the treatment  zones or portions  thereof
been closed?
                                                                 Yes     No

Are all apparent discrepancies  explained  in  the Part B
application?                                                    	   	
                                                                 Yes     No

Has che applicant submitted  a  revised  Part A application?        	   	
                                                                 Yes     No

Describe any deficiencies  in the  applicant's submittal, if they exist.
     Figure  8.1.1.  Worksheet for  evaluating  Che adequacy of listing
                     hazardous wastes and constituents being or  to  be
                     land  treated at  existing  facilities.


                                       8-21

-------
           LISTING OF HAZARDOUS WASTES AND CONSTITUENTS—NEW FACILITY
Has this part of Che applicant's subraittal been
reviewed and evaluated?                                  	   	   	
                                                          Yes     No     Dace

Have both Part A. and Part 2 applicacions been submitted?         	   	
                                                                  Yes     No

Are waste names and EPA ID numbers identified?                   	
                                                                  Yes     No

Are locations identified showing where wastes
will be applied within the land treatment unit?                  	   	
                                                                  Yes     No

Are there any apparent discrepancies in the informacion
provided in the Part A and B applications?                       	   	
                                                                  Yes     No

Will only subsets of che wastes listed in the Part A
application be land treated?                          .           	   	
                                                                  Yes     No

Will any waatas liscaa in the Part A application be
treated or transformed prior to land treatment?                  	   	
                                                                  Yes     No

Describe any deficiencies in the applicant's subraittal, if  they exist.
        Figure  8.1.2.   Worksheet  for  evaluating  the  adequacy of  listing
                        hazardous  wastes  and  constituents  to  be  land
                        treated  at new facilities.
                                      8-22

-------
these sources.  Table 3.1,? i-anc.Jlcs -ne advantages and disadvantages
associated with the types of data sources to be used to make a treatment
demonstration.

     Laboratory tests or field studies conducted to demonstrate the
treatability of specific hazardous constituents must be performed under
conditions similar to those present or expected at the land treatment unit.
Also, if existing literature is used, data obtained from published documents
must be representative of conditions at the treatment facility.  The following
conditions/characteristics of che proposed or existing land treatment unit
must be described in the application if published literature is used or
simulated if tests are performed:

     (i)       characteristics of wastes co oe land-treated (see Part 3 of
               Section 8.1.2.1.1 above),

     (ii)      characteristics of the treatment zone, including depth,  soil
               texture, pH, cation exchange capacity, organic matter content,
               moisture content, and depth to seasonal high water table,

     (iii)     topography of the treatment zone including =-,lope,

     (iv)      local climate, including monthly temperature, precipitation,
               evaporation, and wind pattern data, and

     (v)       operating practices, including waste application method and
               rate, tilling depth and frequency,  and soil conditioning
               practices (e.g., prf adjustment, fertilization,  soil water
               regulation).

     The permit reviewer should verify that each of these items are addressed
in the treatment demonstration.  Figure 8.1.3 provides a worksheet to aid in
the review of these permit application information requirements.  In addition
to determining that the data used to make the treatment demonstration are
generated under conditions that are similar or representative of those  present
or expected at the land treatment unit, the reviewer should confirm that all
activities described in the treatment demonstration are going to be
implemented under the land treatment program.  This check is to ensure
completeness of the application and to verify consistency between
theoretical/experimental operation and actual operation of the land treatment
facility.

Literature Data Sources
     When treatment demonstration schemes are based on literature reviews,  the
permit reviewer must confirm that the information is represencative and
directly applicable to the proposed facility.  Treatment demonstrations based
on studies reported in the literature must be carefully examined to ensure
that climate, soil characteristics, waste types,  and application rates
associated with the proposed facility are similar to those reported in the
literature.  It is essential that the literature  data be representative of  the
proposed site characteristics.   Also, the information used to make the
                                    8-23

-------
    TABLE 8.1.9.   UTILITY OF DATA SOURCES FOR MAKING TREATMENT DEiMONSTRATION
 Data
source
            Advantage
        Disadvantage
Literature
When available, existing lit-
  erature is readily obtained
  and inexpensive.
Laboratory
Test
Field
Tests
Operating
Data
Can be well controlled; can
  simulate specific inter-
  actions at microcosm level.
Provides more holistic approach
  than laboratory studies, can
  closely simulate actual land
  treatment unit conditions.

Closest approximation of actual
  conditions.  Excellent for
  existing facilities.
Very little documentation/
  test results are presently
  available.  Also, informa-
  tion that is available may
  not be specific to waste(s)
  to be created, generaliza-
  tions have to be made to
  make extrapolations.

Small scale and generally
  unidimensional; one or
  two factor analysis limits
  utility.

Time consuming to obtain,
  environmental factors
  (e.g., precipitation, tem-
  perature) uncontrollable.

Not usually well documented,
  very site specific.  There-
  fore, utility is limited
  for other sites.
                                   8-24

-------
                                            Yes             No
Wa*t« Characteristics:

     Concentration of hazardous
     conatituents and pertinent
     nonh«zardou« -or»i::.:':».it~

     Concentration of volatile
     hazardous constituents
     W*cer c

     Specific gravity or bulk density

     pH or w*«ta

     Electrical conductivity

     Total acidity or alkalinity

     Total organic maroon

Tre»ca«ot 3on« Charact »rucic3 .

     Oapcn of zone

     Soil texture

     Soil pH

     Cation exchange capacity

     Organic ucter content

     Moisture content

     Depth to leaaonal high
     groundvacer table

     Surface slope of treatment  zone

Local Climate:

     Temperature range .monthly;

     Precipitation

     Evaporation

     Wind pattern*

Operating Practice*:

     Application rate

     Application method

     Tilling frequency and depth

     Soil conditioning

         pH adjmtment

         fertilization

         •oil  water control
  Figure 8.1.3.   Worksheet  for  items  to  be  simulated  by  treatment
                      demonstration  tests/evaluation.
                                          8-25

-------
demonstration should be derived from well designed scientific studies where
replicated experiments, employing representative sampling and experimental
controls, were conducted.  All statements and ~onclusions made within the
application should be documented with citations in the text and bibliography.

     In addition to providing information on hazardous constituent
degradation, transformation, or immobilization, published literature can be
us-ed (and is recommended) to design laboratory and field experiments.
Literature sources used t-> make portions of che treatment demonstration should
nave been subjected to a thorough peer review.

     References providing relevant information on the principles and
fundamentals of land trsat-rerc of industrial aad municipal wastes are
identified in Table 8.1.10.  Information presented in the cited references may
not provide specific answers for a particular application.  However, key
design and operating principles, measurement techniques, and various waste
characteristics are described that can be applied, through engineering and
scientific knowledge and professional experience, to determine the technical
adequacy of most permit applications to be reviewed.

     Because the land :rsatment of hazardous waste is an emerging field,
results of laboratory and field tests identifying chemical constituents tnat
are resistant to degradation or immobilization generally are not well
documented in the literature.  Therefore, pilot studies conducted in che
laboratory or field should be encouraged at the preapplication meeting,
particularly when dealing with unknown or uncommon wastes or hazardous
constituents.  During the preapplication meeting it should be made clear that
field tests or laboratory experiments be performed not only to identify
optimum operating conditions but also to define the 'jpper or lower values for
all factors that limit waste degradation, transformation, and immobilization.

Existing Operating Data

     When available, existing operating data provide an affective means of
making the treatment demonstration.  Because many of the initial Part B
applications are going to be submitted for existing land treatment units,
existing operating data will likely be used to demonstrate waste treatment.
Existing data presented in the application must include results from soil-core
(including treatment zone), soil-pore liquid, ground water, run-off, and air
monitoring.  The monitoring data submitted must be comprehensive and clearly
demonstrate hazardous constituent degradation, transformation, or
immobilization within the treatment zone.  It should be recognized that the
monitoring'data can be used to demonstrate the treatability of wastes that are
similar to those previously disposed at the treatment unit.  Additional
documentation will be required to demonstrate the treatability of new and
different wastes planned for disposal at the unit.  Such demonstrations will
likely involve laboratory and field studies, which are discussed below.

8.1.3.1.2  Laboratory and Field Test Design—Laboratory tests, field studies,
or greenhouse tests conducted by the applicant must be evaluated to determine
that they will be properly performed, conducted under conditions that are
                                     8-26

-------
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8-28

-------
similar or can be reasonaolv ^orrslstad to c.-.ose presenc at che land treatment
unit, and clearly demonstrate hazardous constituent degradation,
transformation, or immobilization.

     Table 8.1.11 identifies various test methods for assessing specific
waste-site interactions involving constituent degradation,  transformation,  or
immobilization.  Also identified in the table are the sections of the HWLT
manual that describe each test.  Note that the applicant is not required to
use these tests to make the treatment demonstration.   Although these test
methods have been recommended to the applicant in the Permit Applicants'
Guidance Manual,^ other test methods can be used as long as they are fully
described and sufficiently documented by the applicant and  satisfy the same
objectives.

     Soils in which laboratory, field test, or greenhouse studies are
performed should be similar to the soil of the actual or proposed treatment
zone.  In general, a soil series classification, including  a description of
the "A" horizon, will usually adequately define the necessary similarities  of
soils.  A soil series is a subdivision of a soil family.  The series
identifies a group of soils having similar thickness, texture, structure,
color, organic concent, and reaction (acid, neutral,  or alkaline).?

     The "A" horizon of a soil is the top mineral layer located at or adjacent
to the surface, just below the organic horizon.  The  characteristics of the
"A" horizon within and among soil series can vary (see Appendix G of HWLT
manual).  Therefore, treatment demonstration tests should be performed in
soils that have characteristics similar to the "A" horizon  of the treatment
zone soil.  The characteristics of the "A" horizon can be determined from a
local Soil Conservation Service (SCS), Soil Survey Report or consultation with
a SCS soil scientist.

     It is important to recognize that extrapolation of field test results
must be made with discretion because they are limited to the environmental
conditions existing during testing.  Testing should be performed under a wide
range of conditions that are expected at the units.  This includes seasonal
variations, where applicable.  vlso, replicate sampling to  statistically
verify test results should be conducted.  However, uncontrollable variables
such as temperature, precipitation, and wind speed and direction make testing
under reproducible conditions difficult, as well as data interpretation.

     Although it is not required, tests should be conducted or extrapolations
made to determine the limitations of the treatment unit.  Once the limits have
been identified, contingency plans can be developed to accommodate expected or
unexpected phenomena when they occur.  Examples of situations requiring a
contingency course of action include:  continued periods of heavy rainfall,
increasing surface ponding and run-off; ground freezing during winter months,
slowing or stopping waste degradation; or ice cover formation, resulting in
anaerobic soil conditions (note that when the ice cover melts an odor problem
can result due to anaerobic decomposition under reducing conditions).
                                    8-29

-------
  TABLE 8.1.11.   TEST METHODS FOR ASSESSING -SPECIFIC WASTE-SITE INTERACTIONS
                 VFROM HWLT MANUAL5)
     Waste-sice
                                    Tesc method
                                           aWLI manual
                                             section
Degradation of waste
Accumulation in soil
  of nondegradables •

Leaching hazards
Volatilization
  hazards

Acute toxicity
Chronic toxicity

Plant uptake

Pretreatment
Respiroraetry                                7.2.1.1
Field studies by soil testing               7.4.1

Waste analysis (inorganics)                 5.3.2.3.1
Respirometry (organics)                     7.2.1.1

Soil chin layer chromatography              7.2.2.1
Soil leaching columns                       7.2.2.2
Field soil leachate cesting                 7.4.2

Environmental chamber                       7.2.3
Field air testing                           7.4.4

Xespiroraetry (soil biota)                   7.2.1.1
Beckman MicrotexTM System                   7.2.4.1.1
Greenhouse studies (planes)                 7.3.2

Microbiological mutagenicity assays         5.3.2.4

Greenhouse studies                          7.3

Assessment of processes generating waste    5.2
                                    8-30

-------
      In  addition  Co demonstrating complete hazardous constituent degradation,
 transformation, or immobilization,  the  treatment  demonstration will aid in
 defining site management activities such as waste aoplication Tsthods ana
 rates, soil  pH and moisture control,  fertilization needs, and soil aeration.

      To  assess the impact of waste  applications on the test soil, it is
 suggested chat the parameters identified in Table 8.1.12 be measured prior  to
 and after each or a series of waste applications.  A detailed discussion of
 the importance of measuring each of the parameters identified and ctieir impact
 on the soil  processes involved in the treatment of hazardous waste is
 presented in the references cited in  the last column of the table.  A general
 interpretation of some of the more  important soil chemical tests is presented
 in Table 8.1.13.  Analytical methods  to determine each soil paraaecsr
 identified ars praaentaa ^a lesc Methods for Evaluating Solid Waste^ and
 Methods  of Soil Analysis.IP.^

      In  addition to assessing the parameters identified in Table 8.1.12, which
 are primarily chemical components, soil texture should also be evaluated.
 Section  3 of the HWLT manual provides a discussion of the suitability of
 various  textured soils for land treatment of hazardous industrial wastes.
 Table 8.1.14 (reprinted from the HWLT manual) identifies the advantages and
 disadvantages of applying hazardous waste to several soil texture classes.
 This  information can be used to identify operational concerns that should be
 addressed by the facility design (see subsection 8.3).

 3.1.3.2  Treatment Demonstration Results—
      The applicant must submit the results of any tests conducted to make the
 treatment demonstration.  The following discussion provides guidance for
 evaluating the data submitted to show hazardous constituent degradation,
 transformation, or immobilization.  To ensure that aach hazardous waste and
 hazardous constituent identified in the Part 8 permit application have been
 addressed by the treatment demonstration, a checklist should be prepared that
 identifies how each hazardous constituent will be degraded, transformed, or
 immobilized  in the treatment zone.  Table 8.1.15 presents an example checklist
 to be developed during the treatment demonstration review process.  Completion
 of such a checklist will provide an accounting of how each hazardous waste and
 hazardous constituent will be treated at the unit.  Emphasis should be placed
 on documenting the degradation,  transformation,  or immobilization of highly
 water soluble hazardous constituents that are leachable and compounds with
 high vapor pressures that may be lost through volatilization.

 8.1.3.2.1  Wastes and Waste Composition—If for any reason the wastes used in
 the treatment demonstration differ or have been pretreated or mixed, the
 applicant should have provided the same information outlined in
 Section 8.1.2.1.1.  In some cases, the applicant may pretreat the waste as
 part of the treatment demonstration to try to:  (1; improve treatability,
 (2) reduce waste volume, (3) add soil amendments, or (4) eliminate untreatable
or unacceptable waste constituents.  Pretreatment can be accomplished by
 physical, chemical,  or biological processes.  The reviewer is referred to the
 HWLT manual and references therein cited for a discussion of waste
 pretreatment.  Table 8.1.16 provides a synopsis of various pretreatment
 techniques as they relate to waste amendment prior to land treatment.
                                     8-31

-------
       TABLE 8.1.12.   SUGGESTED SOIL PARAMETERS  TO MONITOR PRIOR TO  AND
                      AFTER WASTE APPLICATION3

Prior to
After one or
serias jf
Pirametsr application applications
PH
Cation exchange capacity
Organic matter
Soluble salts (TDS or EC)b
Soil moisture content
Soil fertility (N,P,K)c
Yes
Yes
Yes
Yes
Yes
Yes
Yes,
Yes,
Yes,
Yes,
Yes,
Yas,
after series
after series
after series
after each
after each
after series
References
for discussion
of
2,
2,
2
2,
2,
2,
parameter
5
5
5
5
5
5
,7
,7
,7
,7
,7
, /
,8,
,8,
,8,
,3,
,8,
,8,
9
9
9
9
9
9
aAdapted from Reference 3.

''TDS—total dissolved solids, EC—electrical conductivity.

cNitrogen,  phosphorus, potassium.
                                   8-32

-------
                           INTERPRETATION OF SOIL CHEMICAL TESTS3
        Test result
                 Unterpretation
pH of saturated soil  paste

     <4.2


    4.2-5.5


    5.5-8.4

     >8.4
Too acid for most soil Tiicrobas and plants co
  do well

Suitable for acid-tolerant soil microbes and
  plants

Suitable for most soil microbes and plants

Too alkaline for most soil microbes and plants,
  indicates a possible sodium problem
Cation exchange capacity
(CSC) , raeq/100 g

      1-10

     12-20

      --20
Sandy soils (limited adsorption)

Silt loam (moderate adsorption)

Clay and organic soils (high adsorption)
Electrical conductivity
(ECe), mmhos/cm at 25°C,
of saturation extract

       2

      2-4

      4-8

      8-16
No salinity problems

Restricts growth of very salt-sensitive crops

Restricts growth of many crops

Restricts growth of all but salt-tolerant crops

Only a few very salt-tolerant crops make
  satisfactory yields
aAdapted from Process Design Manual for Land Treatment of Municipal
 Wastewater, U.S. EPA, Report No. 625/1-77-008, October 1977.
                                  8-33

-------
   TABLE 8.1.14.
    SUITABILITY OF VARIOUS TEXTURED SOILS FOR LAND TREATMENT
    OF HAZARDOUS INDUSTRIAL WASTES5
 Texture*
          Advantages
        Disadvantages
Sand
Loamy sand
Loam
Silt loam
Silt
Silty clay
  loam
Very rapid infiltration
Usually oxidized and dry
Low runoff potential
High infiltration
Low to medium runoff
Moderate infiltration
Fair oxidation
Moderate runoff potential
Generally accessible
Good CEC

Moderate infiltration
Fair oxidation
Moderate runoff potential
Generally accessible
Good CEC

Low infiltration
Fair to poor oxidation
Poor CEC
Good available water

Medium Co low percolation
Fair structure
High CEC
Silty clay    Good to high available water
Clay lo««     Medium to low percolation
              Good structure
              Medium to poor aeration
              High CEC
              High available water
Very low cation exchange
 capacity (CEC)
Very high hydraulic conduc-
  tivity rate
Low available water
Little soil structure

Low CEC
Moderate to high hydraulic
  conductivity rate
Low to medium available water

Fair structure
Some crusting
Fair to poor structure
High crusting potential
Poor structure
High runoff
Medium to low infiltration
Some crusting potential
                                  Moderate runoff
                                  Often wet.
                                  Fair oxidation

                                  Medium to low infiltration
                                  Moderate to high runoff
                                  Often wet
                                   (continued)
                                   8-34

-------
                            TABLE 8.1.14 fcontinued)
 Texture*
  Advantages
 Disadvantages
Clay          Low percolation
              High CEC
              High available water
Sandy clay    Medium to low percolation
              Medium to high CEC

Sandy clay    Medium to high available water
  loam        Good aeration
                          Low infiltration
                          Often massive structure
                          High runoff
                          Sometimes low aeration

                          Fair structure
                          Moderate to high runoff

                          Medium infiltration
a8ased on 'J.S.D.A. taxtarai classification scheme.
  TABLE 8.1.15.  EXAMPLE HAZARDOUS WASTE AND HAZARDOUS CONSTITUENT TREATMENT
                 DEMONSTRATION CHECKLIST
  Constituent
     Treatment process
      Data source
Phenol

Hexachloroethane

Cadmium


Chromium
Biodegradation

Adsorption by soil colloids

Adsorption


Ion exchange
Soil respirometer tests

Extractability tests

Laboratory soil column
  leaching test

Literature review
                                   3-35

-------















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     Hazardous constituents contained in wastes to be land treated should be
carefully evaluated to assure creacabiiicy.  Because biodegradation is the
principal treatment mechanism, wastes containing significant quantities of
halogenated organic compounds, inorganic acids, bases, salts, and heavy metals
are noc well suited for land treatment.  Wastes containing these types of
constituents are not readily biodegraded and will accumulate in the soil,
limiting a facility's service life and increasing the potential for ground
water contamination due to leaching.  The following discussion addresses the
various treatment methods and -najor environmental concerns associated with the
operation of a hazardous waste land treatment facility.

8.1.3.2.2  Degradation/Trans formation—Organic hazardous constituents aoolied
in or on the treatment zone tsav '->«» -^grcded by oioiogicai, cnemical,  or
pnococnemicai processes.  Biodegradation, however, is the principal treatment
mechanism.  Biodegradation is accomplished by soil microbes, and when a
vegetative cover, is present by plant metabolism.

     Chemical degradation or transformation of hazardous constituents results
from compound oxidation, reduction, hydrolysis, isomerization, and
polymerization.  Phung.-I. et al.8 provide a discussion of the factors
affecting chemical Cransformacion ana cite references for additional
information.

     Photochemical degradation is generally a minor component of land
treatment of hazardous wastes because the waste is usually incorporated into
the soil.  Photochemical degradation occurs only at the soil surface where
wastes that have been surface spread are directly exposed to incident
radiation.  Chemical reactions, primarily altering organic compounds, are
induced by solar radiation.  For a more'detailed discussion of photochemical
degradation see Phung, T. et al.8 and references cited therein.

     Because chemical and photochemical degradation play minor roles in
hazardous constituent degradation, these processes will only be briefly
addressed in the following discussion.  Principal determinations to be made by
the treatment demonstration are the rate and extent of organic hazardous
constituent degradation or transformation in the treatment zone.  The extent
of degradation will determine whether land treatment is an acceptable means of
disposal, whereas the rate of degradation will determine frequency of waste
application.

Part 1 - Existing literature - The reviewer should consult the literature and
possibly other (Federal, State, and local) regulatory agency personnel to gain
an understanding of potential problem waste constituents that resist
degradation or are difficult to immobilize.  Section 6 of the HWLT manual and
the Design of Land Treatment Systems for Industrial Wastes - Theory and
Practice? provide useful information on microbial degradation rates of
various classes of organic compounds (e.g. phenols, substituted biphenyls,
polynuclear aromatics, solvents,  and alcohols) and the mobility of various
metals in soil.  The following discussion highlights pertinent information
presented in the references (refer to the texts themselves, however,  for a
more detailed explanation).
                                    8-39

-------
     Table 8.1.17 presents a compilation of research rasulcd showing ricas  3
degradation of phenol and phenoli- compounds.   Trie results  are  expressed  in
te.rms of percent degradation occurring in a certain number  of days.
Application rates are also shown.   Although the information provided is based
on small scale analyses,  it can provide a starting point for estimating and
evaluating rates of degradation and application loadings more precisely.

     TABLE 8.1.17.   RATES OF DEGRADATION OF PHENOL AND PHENOLIC COMPOUNDS
                    (ADOPTED FROM  REFERENCE 9)
    Compound                 Application rate              Degradation  rate
Phenol
o-Cresol
m-Cresol
p-Cresol
2,4-xylenol
2,5-xylenol
3,4-xylenol
3,5-xylenol
Thymol
Pyrocatechin
Resorcinol
Hydroquinone
a-Naphthol
(3-Naphthol
1 , 4-Naphthoquinone
0.03* of soil weight
0.05% of soil weight
0.05%
0.05%
0.05%
0.05%
0.05%
0.05%
0.05%
0.05%
0.05%
0.05%
0.05%
0.05%
0.05%
100% in 6 days
100% in 8 days
100% in 11 days
100% in 7 days
100% in 4 days
100% in 14 days
100% in 9 days
100% in 11 days
100% in 3 days
100% in 1 day
100% in 2 days
100% in 1 day
100% in 5 days
Very little in 90 days
100% in 9 days
     It is noted that phenol rate of application reportedly has a strong
influence on microbial activity.9  phenol application rates equivalent to
0.01 to 0.1 percent of the soil weight have actually caused an increase in
microbial activity, resulting in complete degradation of the organic compound.
As the loading is increased to 0.1 to 1.0 percent of soil weight, however, an
increasingly strong inhibitory effect has been recorded.  Consequently,
treatment demonstration testa should be performed to assess the impact of
organic concentrations on soil organisms.  Organic hazardous constituent
concentrations similar to those expected in the waste to be applied at the
land treatment facility should be used during testing.

     Tables 8.1.18 and 8.1.19 identify relations between microbial activity
and application of various solvents and alcohols, respectively.  The phrase
'critical soil level* identified in the tables is the dose that causes a
reduction in vierobial numbers and diversity.  Doses above critical levels
result in long-term adverse soil response.  Application rates below the
critical level have little or no effect, and microbial populations are
actually stimulated by the addition.
                                     8-40

-------
TABLE 6.1.18.  RESPONSE OF SOIL MICROBIAL POPULATIONS TO APPLICATION OF
               VARIOUS SOLVENTS (ADOPTED FROM REFERZ^CZ: 3}

Solvent
Cyclohexane
Hexane
Heptane
Pentane
Formaldehyde
Chloroform
Ether
Acetone
Pyridine
TABLE 8.1.19.


Alcohol
Methanol
Ethanol
1-propanol
2-propanol
Critical soil level
(ppm)
840
4:0
10,000
",:co
150-300
590
7,^00
58,000
7,900
RESPONSE OF SOIL MICROBIAL
VARIOUS ALCOHOLS (ADOPTED
Critical soil level
(ppm)
32,000
46,000
12,000
12,000
Time period for recovery
at critical dose
Within 37 days
Within 19 days
Within 24-63 days
Within 30-53 days
Within 22 days
Within 12 days
Within 14 days
Within 12 days
Within 16-30 days
POPULATIONS TO APPLICATION OF
FROM REFERENCE 9)
Time period for recovery
at critical dose
Within 12 days
Within 11 days
Within 21 days
—
                                  8-41

-------
          respect to organic acids degradation,  Table 3.1.20 orasents the
percentage decomposition or various carboxylic acias.  Joseg of  1000  ppm were
appliea co ioamy sand.  The highest and lowest percent loss  are  shown after^
7 days and after 84 days.

            TABLE 8.1.20.  DECOMPOSITION OF CARBOXYLIC ACIDS IN  SOILS
                           (ADOPTED FROM REFERENCE 9)
                                                                   Tide  requirec
    Compound                 Percentage decomposition                 Cdays)
Acetic acid
Acetic acid
Pyruvic
Pyruvic
Succinic acid
Succinic acid
Glucose
Glucose
52-76
71-87
47-83
70-93
52-39
71-95
75
87
/
84
7
34
T
84
7
84 ^
     In general, organic compound groups may be ordered as follows based on
increasing ease of biodegradation:

               Halogenated Hydrocarbons (e.g.,  pesticides)
               Aromacics (e.g., polynuclear aromatica,  PNA)
               Alkanes, carboxylic acids
               Alcohols

Part 2 - Operating data - Demonstration of hazardous constituent degradation
using existing operating data will likely be based on analysis of soil-core
and soil-pore liquid samples.  Test results presented in the application
should identify the rate and extent of degradation of the organic hazardous
constituents present in the waste being land treated.  This means of making
the treatment demonstration will very likely be exercised by existing
hazardous waste land treatment facilities that have been collecting such
information since startup.

Part 3 - Laboratory tests - Waste degradation is principally accomplished by
aerobic microbial decomposition.  One method of assessing biodegradation is to
monitor microbial activity following waste application and measure waste
decomposition products.  A soil respirometer is one technique available to
                                     8-42

-------
evaluate the degradation of organic compounds in a waste-soil mixture.  A soil
respirometar can be used co indicate microoiai activity and relative waste
decomposition based on the rate of CQ^ evolution.  Figure 8,1.4 displays a
decision making process to determine hazardous waste treatability based on
soil respirometry studies.  Other raetnods to determine organic material
degradation are infrared gas analysis, and gas chromatography. 12  Results
obtained from these analyses can be used to gauge application rate and
frequency, rate of required nutrient (fertilizer) addition, and rate of waste
degradation in different soil types or temperatures.  The time required for
aerobic decomposition is primarily a function of waste composition and loading
and soil characteristics.°  More detailed explanations of biodegradation,
including soil respirometry and its methodology, are provided in the HWLT
manual.

     Laboratory tests allow the examination of soil treatment processes under
several different environmental conditions within a reasonable time period.
Although laboratory tests can be designed to simulate actual conditions, they
are somewhat one dimensional and do not reflect the complex interactions that
occur in the field.  As a result, field studies may be necessary to verify
certain laboratory generated data.

     Laboratory results should be clearly presented.  Data should show rate of
degradation, i.e., amount of orgnic decomposition over time, and extent of
degradation, i.e., percent degradation as a function of time (see Figure 3.1.5
as example).  Laboratory tests should determine the extent and rate of
degradation for all organic hazardous constituents, focusing on those
constituents which are less susceptible to degradation.  In addition, the
half-lives of each organic hazardous constituent should be determined, as
discussed below.

     Two basic techniques are used to assess organic constituent degradation.
They involve:  (1) measuring C02 evolution from the soil incubated in a
chamber and, (2) analyzing soil samples for organic constituents.  The former,
which .is not constituent specific, is used to determine the rate of
degradation of the bulk organic fraction of the waste applied to the soil.
The latter technique can be used to determine specific constituent degradation
by chemical analysis of a soil extract.  Sections 5 ana 7 of the HWLT manual
describe the analytical techniques and calculation methods for assessing
organic hazardous constituent degradation.

     To assess the amount of constituent that will accumulate due to repeated
applications, it is important to determine the half-life of each organic
hazardous constituent to be applied at the treatment unit.  Half-life is
defined as the time required to degrade 50 percent of the waste constituent.
Half-Ufa values should be used to determine acceptable yearly waste loading
rates.  The organic hazardous constituent with the longest half-life should be
used to calculate site loading rates.  Section 7 of the HWLT manual presents a.
detailed discussion of the techniques used to determine organic hazardous
constituent half-lives.
                                    8-43

-------
                                                                -J3


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     In general, application races for hazardous constituents vi'ch ha if-Lives
of no more Chan 1 year -an be twice Che amount applied annually so long as
applications are separated in time equal Co one half-life cor the
constituent.  Table 3.1.21 presents estimates of che nercenc degradation of
organic constituents vith various naif-lives after 10, 20,  and 30 years.  Note
that constituents with half-lives of 1 year or less are degraded by more than
99 percent after 10 years.  Although the information presented in Table 8.1.21
is- very general and not constituent or soil-specific, it illustrates how to
evaluate half-life degradation data submitted by the applicant.

     Table 3.1.22 presents values of selected soil factors  that are generally
considered optimal for biodegradation.  Note chat chese conditions are for'a
generic class of organic wastes, under an aerobic environment.  Other
conditions or values, as determined bv the trsataent aetaonscration, may be
•SOTS affsccive co creac che hazardou-s constituents applied.   Each land
treatment facility should be evaluated on a case-by-case basis.

Part 4 - Field studies - Field studies may be necessary to  confirm test
results obtained under laboratory conditions.  Field tests  should be conducted
to determine bulk organic fraction degradation.  In addition, field tests
should be performed co assess the degradation of any persistent compounds
identified by a laboratory :ast or literature search.  Recommended soil
sampling and analytical procedures to be employed as part of the field tests
are discussed in Sections 5 and 7 of che HWLT manual.

     Field test plots should be as small as possible, generally no more than
500 m^.  Larger plots may be necessary, however, Co accommodate specialized
waste application equipment or other machinery as required  to conduct the
field tests.

     Figure S.I.6 presents a worksheet that can be used for evaluating field
test designs submitted by the applicant.  Completion of the worksheet will
provide an assessment of the completeness and appropriateness of the
applicant's selected field tests to demonstrate hazardous organic constituent
degradation.  Test results provided by the applicant should include the
percent degradation or transformation as a function of time for each waste
application treatment.  Section 7 of the HWLT manual provides a lengthy
discussion of how to interpret degradability results obtained from laboratory
and field tests.

8.1.3.2.3  Immobilization—Inorganic hazardous constituents and organic
hazardous constituents that are resistant to degradation must be immobilized
in the treatment zone.  Even organic hazardous compounds that are readily
biodegraded must be retained in the treatment zone long enough to allow
complete decomposition.  Substance mobility  in the treatment zone depends on
compound solubility and certain characteristics of the soil, primarily soil
pH, organic matter content, and the types and amounts of clay.  With respect
to metals, most species are insoluble above soil pH of 7.  In addition to
insolubility, metals are immobilized by adsorption, precipitation, and
chelation and metal-organic complex formation.  The following identifies the
relative mobility of certain metals based on soil clay and mineral surface
adsorpfton:
                                     8-46

-------
  TABLE 8.1.21.   PERCENT DEGRADATION AFTER 10,  20,  AND 30  YEARS  FOR  ORGANI*
                 CONSTITUENTS «'ITH VARIOUS HALF-LIVES IN SOIL
                 (ADOPTED FROM HWLT MANUAL5)
Percentage of substance degraded
Half-life in soil
3
6
1
2
3
4
5
10
20
30
months
months
year
years
years
years
years
years
years
years
After 10 years
100
99.
99.
96.
89.
81.
75.
50.
25.
16.

9999
90
38
56
25
0
0
0
6
After 20 years

100
99.
99.
98.
96.
93.
75.
50.
33.


9999
90
96
83
75
0
0
3
After 30 years


;GO
99.
99.
99.
98.
37.
52.
50.



9999
90
39
44
5
5
0
  TABLE 8.1.22.  OPTIMUM VALUES OF SELECTED SOIL FACTORS FOR BIODEGRADATION
  Soil factor
                 Range of values or types
Texture

Temperature

Moisture content

Aeration

PH

Microbes
Sandy clay, silt loam, or sandy clay loam soils

10° to 30°C (ca 40° to 85°F)

Between wilting coefficient and field capacity

Periodic tilling will be adequate to promote soil aeration

6 to 7 pH

Natural populations in undistributed soils appear to be
  adequate; microbial inoculations may be required
                                    8-47

-------
yes      ao
               FIELD TEST DESCRIPTION FOR TREATMENT CEMCNSTiUTIOtf


 Does  the  field case description state Che test objective?        	


 Has  the applicant provided 4 scale drawing showing the
 location  of  test plot* relative to the proposed land
 treatment unit?                                                 	
                                                                 yes      no

 Are  the number *nd siz« of ;he ce*c plots indicated?           ______   	
                                                                 yea      no

 la the statistical design of the test stated?                           ______
                                                                 ye»      ao

 Are  the horizontal and vertical dimensions of the
 treatment zone of the test piot(s) provided?                   	   	
                                                                 yes      ao

 Has  the applicant described how the tsst plots vill be
 prepared  (e.g., tillage, liming, fertilizer, inatailacioa
 of monitoring squipmenc, jurface vater control)?               _______   _____
                                                                 yea      no

 Are waste application rates, methods of application,
 and  soil  incorporation techniques described?                   _______   ______
                                                                 yea      no

 If used,  art irrigation methods and scheduling described?       ______   	
                                                                 yes      no

 If plots will be vegetated, are methods for establishing
 and maintaining vegetation stated?                             _______   ______
                                                                 yea      no

 Are methods  for measuring and recording daily meteorological
 data presented?                                                ______    _
                                                                 yea      no

 Has  che applicant described procedures for monitoring soil,
 soil-pore liquid, runoff, vegetation, groundwater, and
 aabient air, a« -ppiicaola?                                    ______   _____
                                                                 yes      no

 Has a schedule of daily events and activities been presented?   _____   ______
                                                                 yes      no

 Has  the applicant described a design and management
 rationale to preclude the migration of hazardous
 constituents to ground or surface water?                        __       _____
                                                                 yes      no

 Are expected teat results"and data presentation described?      _______   ______
                                                                 yes      no

 Has  the applicant described the clean-up procedures
 to be implemented upon completion of field tests?              	   	
                                                                 yes      no


Figure  8.1.6.   Worksheet  for evaluating  Che adequacy  of field tests
                  for demonstrating hazardous constituent treatment.


                                     8-43

-------
                Most  Mobile:         ?b  and Cd

                Less  Mobile:         Mn,  Zn, Cu, Co, Ni, and Cr

                Least Mobile:        Al,  Fe, and Mg

 Metal  precipitation  occurs when concentrations of cations and anions in the
 soil solution become sufficiently high whereby specific  types will associate
 to form solid chemical compounds with  limited solubility.  Concentration
 levels at which precipitation occurs  is compound-specific.   Insolubilization
 of the precipitates  leads to metal  immobilization.

     Metals  fixation based on chelation and metal-organic complex formation
 may be generally ordered as follows:

     Order of chelate stability:  Hg > Cu > Ni > Pb > Co > Zn > Cd > Fe > Mn > Mg > Ca

     Decreasing order for organic bonding:  Cu >Fe >Zn >Ca

     To ensure  complete degradation or immobilization by adsorption or
 complexation, the hazardous constituent must remain in the treatment zone.
 With respect to organic hazardous constituents, the liquid infiltration rate
 and soil permeability must be determined to assess whether these compounds
 move through the treatment zone too quickly to allow complete degradation.
 Once an organic compound has leached below the zone of aeration where
 microbial degradation is most active,  subsequent degradation  in the lower soil
 horizons is markedly reduced.  Incompletely degraded organic compounds
 reaching these  zones can be l
-------
Pare 2 - Existing operating data - Section S.I.2.2.3 identifies  the  data
elements to be submitted by the applicant who elects to demonstrate
immobilization of hazardous constituents using existing operating data.
Important data to be compared are analytical results of collected leachate  and
composition of wastes applied.  Analytical techniques selected by the
applicant should be capable of detecting known hazardous constituents  of the
waste applied and any hazardous constituent expected to be derived from the
waste as a result of treatment.  Concentrations of any hazardous constituent
detected in the collected leachate should be coraoared with background  levels
to determine any significant difference.  Section  9 of the HWLT  manual
provides a discussion of various sampling techniques employed in monitoring
the soil-pore liquid.  Sampling and analytical techniques used by the
applicant should be evaluated by reviewing Sactirm e of ;he tiWLT manual and
Taat Mathodj for Evaluating Solid Waste Physical/Chemical Methods.4

Part 3 - Laboratory tests - Laboratory tests to assess constituent mobility or
potential leachability include soil thin-layer chromatography and column
leaching.  Soil thin-layer chroraatography is a technique used to assess the
relative mobility of a substance by comparing the  distance traversed by a
given compound to the distance traversed by the wetting front.  Column
leaching is a laboratory jr field measurement technique used to  assess
relative pollutant mobility under saturated soil conditions.  If the soil
profile of the treatment zone is nonuniform, laboratory mobility tests should
be performed under conditions reflecting the expected multilayered soil
profile.

Part 4 - Field tests - Demonstration of hazardous  constituent immobilization-
can be accomplished by studies performed on field  test plots.  A description
of the field studies should oe included in the application Chat  contains the
information identified in Table 8.1.2.  Specific field tests to  make this
(immobilization) demonstration are discussed in Section 7 of the HWLT manual.
Results submitted by the applicant should clearly  show the following:

     •    the concentration of hazrdous constituents in the soil as  a function
          of. depth at various times during the field test,

     •    the concentration of hazardous constituents in the soil-pore liquid
          at various depths, over time,

     •    the concentration of hazardous constituents in rainfall run-off as  a
          function of the depth of rainfall, and

     •    the concentration of hazardous constituents in the ground water
          underlying the field test plots.

Submittal of these results will provide an accounting of the migration of
hazardous constituents through and out of the treatment zone.

     Figure 3.1.6 presents a worksheet that can be used for evaluating field
test designs submitted by the applicant.  Completion of the worksheet will
reveal the completeness and appropriateness of the applicant's selected field
                                      8-50

-------
Cases to demonstrate hazardous constituent immobilization.  Section 7 of the
HWLT manual provides a discussion of the intarpratation of hazardous
constituent immobilization studies performed in the laboratory or field.

8.1.3.2.4  Volatilization—Volatilization of hazardous compounds can occur
during waste application and subsequent cultivation when underlying soil
layers are exposed to the atmosphere.  Surface spreading and subsurface
injection are Cwo common waste application techniques.  Studies have shown
that air emission releases are greater when wastes are spread on the surface
than when injected into the top soil layer.  IXiring surface spreading,
volatilization is a gas-phise resistance phenomenon,  whereas when wastes are
injected below the soil surface,  vaporization is governed by liquid-phase and
gaseous-phase resistance and diffusion through the porous soil.

     ^xperiaaca gained from cue xana treatment of refinery oily sludges,^
which presently is one of the most common waste types land treated,  indicates
that hydrocarbon emissions are released in proportion to the quantity of their
volatile hydrocarbon content.  It has also been learned that volatilization is
minimized by delaying tilling after subsurface injection.  Figure 8.1.7
displays test data revealing a marked decrease in atmospheric emissions by
delaying tilling 2 days, from 4 to 6 days after soil  injection.
                                                                         as
     Simulated laboratory tests should investigate  the following factors
they affect volatilization of the wastes applied:

     •    Volatility of waste (the most important parameter affecting
          emissions),

     •    Application method (subsurface injection  results in lower air
          emission release),

     •    Application rate (loading rate is inversely related to emission
          release, especially when waste contains high moisture content),

     •    Air temperature (emission release will  increase as temperature
          increases),

     •    Soil temperature (same as air temperature),

     •    Soil type (relationship to emissions  not  clearly defined, but
          differing release races from same waste applied to different soils
          have been recorded),

     •    Soil moisture (emission release tends to  increase with soil
          moisture),

     •    Air moisture (direct  relationship between relative humidity and
          emission release),

     •    Air flow (emission release directly related to  air velocity).
                                     8-51

-------
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                                                                      30
         8-52

-------
     Ail iaooracory experiments co oe performed as part of Che treatment demon-
stration should be conducted under.carefully controlled conditions using an en-
vironmental chamoer tnat assures quantitative sampling and exclusion of outside
interferences.  The experimental apparatus should include equipment co regulate
air flow, temperature, and moisture, and soil temperature ^nd moisture.

     Monitoring equipment and analyzers must be employed to record hydrocarbon
emissions (qualitatively and quantitatively), soil temperature and moisture,
and air flow, temperature, and relative humidity.  Table 3.1.23 presents an
example matrix of experimental conditions for land treatment simulation tests.
Replicate testing should be performed to determine statistical variations and
representativeness of data generated.  Section 9 of the HWLT manual provides  a
brief discussion of air monitoring at hazardous waste land treatment
facilities.  For a more detailed discussion, refer to references 13 through 17.
Beyond actual testing, theoretical aauations have been derived to estimate air
emission release rates from land treatment facilities.  Discussion of these
estimation techniques are provided in references 14 and 18.  The Office of
Solid Waste, Land Disposal Branch, is currently researching the viability and
accuracy of using mathematical equations to estimate air emission release
rates.

     Table 8.1.24 lists the vapor pressure of chemicals 'that are contained in
hazardous wastes representing 95 percent of the total U.S. hazardous waste
disposal volume.  The chemical listing resulted from a compilation of wastes
identified in EPA's RCRA Part A permit application data base.  Wastes disposed
of in amounts greater than 10,000 metric tons were reviewed with respect to
their chemical constituents and associated chemical, physical, and
toxicological characteristics.  The vapor hazard ratio (VHR) presented in the
table is useful for comparing the relative air hazards imposed by different
chemicals.   The VHR is defined as the ratio (ppra/ppra) of a chemical's
equilibrium vapor concentration ae 25°C (computed from vapor pressure data) to
its Threshold Limit Value (TLV); the lower the ratio, the lower the potential
hazard.  For example, if judged on the basis of TLV alone, ethyl ether, with  a
TLV of 400 ppm, might be deemed safer than 1,2-tr^ns-dichloroethylene, with a
TLV of 200 ppm.  When volatility is taken into account, it is apparent that
1,2-trans-dichloroethylsne, with a VHR of 2072, represents more of a potential
air hazard than ethyl ether, with a VHR of 1711.

     Presentation of these data should not be interpreted to mean that VHRs
have to be determined for the wastes to be land treated.  The information
provided in the table is for reference only.  The primary purpose here is to
list the vapor pressure of hazardous constituents frequently handled.

8.1.3.2.5  Toxicity—When biodegradation is relied on to treat wastes and/or a
vegetative cover is established during the active portion of the unit, waste
application races and frequency must be carefully evaluated to prevent acute
and/or chronic toxicity of soil microbes and plant populations.  It should be
recognized, however, that high intensity applications of inorganic
constituents or organic constituents that resist degradation may be applied to
the soil.  Under these circumstances, treatment is based almost completely on
substance immobilization.  Under such conditions, the toxic effects of the
constituents on soil microbes and vegetative cover are disregarded.
                                    8-53

-------
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                                                      8-54

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 (a)  Microbial  Toxicity  - The  likelihood of acute  coxicicv occurring can be
 evaluated  oy a review of the  Literature or laboratory testing, the latter
 involving  soil respiration experiments to demonstrate the effect of various
 concentrations or  toxic compounds on indigenous soil microbes.  Potential
 chronic  effects  impartad by long-term waste application and hazardous
 substance  soil accumulation must also be investigated.  Determination of
 chronic  toxicity effects by laboratory tests is very time consuming.
 Consequently,  the  applicant may refer to the literature to discover the
 effects  of long-term exposure to toxic compounds  on soil microbes.  Section 7
 of  the Hazardous Waste  Land Treatment manual provides informative discussions
•of  laboratory  cests cnat can be used to determine the effects of acute
 exposure to hazardous substances and techniques for assessing chronic
 effects.   Note that the microbial toxicity assessment can be made
 simultaneously with the hazardous constituent J3gradstion/;ransformation
 dasaoas cra
 (b)  Phytotoxicity  -  If plants, food-chain or nonfood-chain crops, are to be
 grown  in or on the treatment zone of the land treatment unit during its active
 life,  the  permit application should include a demonstration of the effects of
 waste  additions on seed germination and plant establishment and yield.
 Establishment of a vegetative cover may be part of the unit design to
 immobilize or transform 'hazard waste constituents or to control soil moisture
 content and wind dispersal of particulate matter.  Demonstration of the
 effectiveness of this treatment technique may be based on an analysis of the
 literature, laboratory or greenhouse studies, field tests, and operating
 data.  In addition to demonstrating adequate treatment, the applicant must
 provide an analysis  of plant viability in or on the treatment zone.
 Greenhouse studies investigating seed germination, root development, and above
 ground growth can be used to determine acute toxicity effects of plants to be
 grown  during the active period of the treatment unit or following closure.
 Section 7 of the HWLT manual provides guidance on acceptable experimental
 procedures and methods of assessing plant viability and potential
 phytotoxicity.

     Figure 8.1.6  provides a worksheet that can be used by the permit writer
 to evaluate the applicant's field test plan to assess whether waste
 applications will have a toxic affect on soil microbes or vegetative cover.

 8.1.4  Draft Permit  Preparation

     If the owner or operator intends to conduct field tests or laboratory
 analyses to make the treatment demonstration required under §264.272(a), he or
 she  muse obtain a treatment or disposal permit under §270.63.  This subsection
 describes the items  to be included in the draft permit as they pertain to the
 treatment demonstration.  Section 4 of this manual presents the Permit Module
 (XIV)  for Land Treatment Facilities which should be used in conjunction with
 Permit Module (XIII) for the Land Treatment Demonstration to prepare the draft
 permit for the entire complex.

     The Treatment Demonstration component (see Module XIII in Section 4) of
 the  draft permit is  comprised of the following three conditions:  Waste
 Identification (Condition A), Design and Operating Requirements (Condition B),
                                      3-58

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ana Testing dad analytical rroceaures vCondition C).  Condition A of Che
Permit Module specifies that the Treatment Demonstration -nus t ?a r^acie for :he
wastes and potential hazardous constituents in or derived from the wastes to
be treated, as identified by the applicant.  Note that only those wastes for
which it will be demonstrated are completely degraded, transformed, or
immobilized are allowed to be treated at the site.  If the owner or operator
plans Co treat wastes not listed in the application, he or she will have to
obtain another permit to demonstrate that they also can be completely
degraded, transformed, or immobilized by the land treatment unit.

     Condition A reads as follows:

          Waste Identification.  The Permittee must conduct a land treatment
          demonstration in accordance with the requirements of 40 CFR 264.272
          for the wastes listed in Attachment	.  nay field test
          or laboratory analysis conducted in order to make this demonstration
          must be likely to show that the hazardous constituents listed in
          Attachment	 will be completely degraded, transformed
          or immobilized in the treatment zone of the existing or proposed
          land treatment unit.

     Condition B of the Treatment Demonstration Permit Module XIII stipulates
treatment demonstration design and operating requirements when any field test
or laboratory analyses are conducted.  The draft permit should specify, at a
minimum, the following:

     •    the horizontal and vertical dimensions of the treatment zone,

     »    monitoring procedures,

     *    closure and clean-up activities, and

     •    description of conditions that accurately simulate the
          characteristics and operating conditions for the proposed land
          treatment unit.

     Condition B of Permit Module XIII reads as follows:

          Design and Operating Requirements.  The Permittee shall conduct the
          demonstration in accordance with the requirements pf
          40 CFR 264.272(c) as specified in the attached plans and
          specifications.

     Condition C of the Treatment Demonstration Permit Module specifies
testing and analytical procedures.  The condition can be implemented by
reference to the applicant's proposed testing and analytical program.  To be
acceptable for substitution as a written permit condition, the referenced
portion of the applicant's submittal should specify the following:

     •    type of test(s),  including duration,
                                    8-59

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•    -aara rid !,5 i.iu ia;.-^U6, including analytical procedures, and

•  '  expected time for completion of tests and analyses.

Condition C oi Permit Module XIII reads as follows:

     Teating and Analytical Procedures.  The Permittee shall conduct the
     demonstration using the testing and analytical procedures and data
     sources specified in Attachment                in accordance with
     requirements of 40 CFR 264.272(c).
                               8-60

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       .-.a ;arancas

 1.  U.S. Environmental Projection Agency.  Permit Applicants' Guidance Manual
     for Hazardous Waste Land Storage, Treatment, and Disposal raciiities.
     Draft Report.  Office of Solid Waste, Land Disoosal Branch,  Washington,
     D.C.  March 1983.

 2.  Spyridakis, D. E. , and E. B. Welch.  Treatment Processes and Environmental
     Impacts of Waste Effluent Disposal on Land.  I_ii Land Treatment and
     Disposal of Municipal and Industrial Wastewater, pp. 45-83.  Edited by
     R. L. Sanks and T. Asano.  Ann Arbor Sciatica, Ana .^rbor, MI.  1976.

 3.  U.S. Environmental Protection Agency.  Damages and Threats Caused by
     Hazardous Material Sites.  Oil and Special Materials Control Division.
     Washington, D.C.  EPA Report ilO/9-«0-00<.; ITSO.

 4.  U.S. Environmental Protection Agency.  Test Methods for Evaluating Solid
     Waste Physical/Chemical Methods.  U.S. Environmental Protection Agency,
     Office of Solid Waste, EPA Report SW-846.  July 1982.

 5.  U.S. Environmental Protection Agency.  Hazardous Waste Land Treatment,
     prepared by K. W. Brown and Associates, Inc. for U.S. Environmental
     Protection Agency, Municipal Environmental Research Laboratory, Solid and
     Hazardous Waste Research Division, Cincinnati, OH.  Report Mo. SW-874.
     1983.

 6.  U.S. Environmental Protection Agency.  Characteristics of Hazardous Waste
     Streams.  Prepared by K. W. Brown and Associates, Inc. for Municipal
     Snvironmencai Research Laooratory, Office of Research and Development.
     Cincinnati, OH.  December 1982.

 7.  Brady, N. C.  The Nature and Properties of Soils.  8th Ed.  MacMillan
     Publishing Company, Inc.  New York, NY.  1974.

 8.  Phung, T., et al.  Land Cultivation of Industrial Wastes and Municipal
     Solid Wastes:  State-of-the-Art Study.  Volume I, Technical Summary and
     Literature Review.  Prepared by SCS Engineers for U.S. Environmental
     Protection Agency, Municipal Environmental Research Laboratory,
     Cincinnati, OH, EPA Report-600/2-78-140a.  August 1978.

 9.  Overcash, M. R., and D. Pal.  Design of Land Treatment Systems for
     Industrial Wastes, Theory and Practice, Ann Arbor Science.  Ann Arbor,
     Michigan.  1981.

10.  Black> C. A., ed.  Methods of Soil Analysis, Part 1, Physical and
     Mineralogical Properties, Including Statistics of Measurement and
     Sampling, the American Society of Agronomy, Inc., Madison, Wisconsin,
     1965.

11.  Black,  C. A., ed.  Methods of Soil Analysis, Part 2, Chemical and
     Microbiological Properties.  The American Society of Agronomy, Inc.,
     Madison, Wisconsin.  1965.
                                    8-61

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12,  Van-Cleve, X., et al.  A Comparison of Four Methods for Measuring
     Respiration in Organic Material.  Soil Biol. Biochem. 11:237-246.
     1979.

13.  Minear,  R. A., et al.  Atmospheric Hydrocarbon Emissions from Land
     Treatment of Refinery Oily Sludges.  Prepared by Radian Corporation for
     the American Petroleum Institute, Washington, DC.  May 1981.

14.  Thibodeaux, L. J.,  and S. T. Hwang.  Landfarraing of Petroleum Wastes —
     Modeling the Air Emission Problem.  Snv'r, Prog. 7ol, i, No. i,
     February 1382.  pp. <+2-46.

15.  Hwang, S. T.  Toxic Emissions from Land Disposal Facilities.  Envir.
     Progr. Vol. No. 1.   February 1°82.  nn, '-6-5Z*

16.  Francke, H. C., and F. E. Clark.  Disposal of Oil Wastes by Microbial
     Assimilation, Oak Ridge National Laboratory.  Oak Ridge, IN.
     UC-11/4-1934, Contract No. W-7406-eng-26.  May 16, 1974.

17.  Sunoco Corporation, Summary of Results from Che Toledo, Ohio Refinery
     Landfarm Tests.  SUNTSCH Environmental Group, Marcus Hook, PA.  pp. 9-<+9,
     undated.

13.  Farino,  W., et al.   Evaluation and Selection of Models for Estimating Air
     Emissions from Hazardous Waste Treatment, Storage, and Disposal
     Facilities,  Draft  Final Report.  Prepared by GCA/Techno logy Division for
     U.S. Environmental  Protection Agency, Office of Solid '.Jaste, Land.
     Disposal Branch, Washington, D.C.  October 1982.
                                     8-62

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o.:  L.AND IREAIMENT PROGRAM

3.2.1  Federal Requirement

     As required by §270.20(b), the Part B oersi<: application muse include:

               "(b)  A description of a land treatment program, as required
          under §264.271.  This information must be submitted with the plans
          for the treatment demonstration, and updated following the treatment:
          demonstration.  The land treatment program must address Che
          following items:
               (1)  The wastes to be land treated;
               (2)  Design measures and operating practices necessary to
          maximize treatment in accordance with §264.273(a) including:
               (i)  Waste replication jecnoa ana rate;
               (ii)  Measures to control soil pH;
               (iii)  Enhancement of microbial or chemical reactions;
               (iv)  Control of moisture content;
               (3)  Provisions for unsaturated zone monitoring, including:
               (i)  Sampling equipment, procedures, and frequency;
               (ii)  Procedures for selecting sampling locations;
               (iii)  Analytical procedures;
               (iv)  Chain of custody control;
               (v)  Procedures for establishing background values;
               (vi)  Statistical methods for interpreting results;
               (vii)  The justification for any hazardous constituents
          recommended for selection as principal hazardous constituents, in
          accordance with the criteria for -such selection in §264.273(a);
               (4)  A list of hazardous constituents reasonably expected to be
          in, or derived from, the wastes to be land treated based on wasca
          analysis performed pursuant to $264.13;
               (5)  The proposed dimensions of the treatment zone."

     Fulfillment of the requirements of §270.20(b) necessitates compliance
with several Part 264 standards.  As identified above, §264.271 is Che
specific technical standard for the land treatment program.  The standard  is
as follows:

               "(a)  An owner or operator subject to this subpart must
          establish a land treatment program that is designed to ensure that
          hazardous constituents placed in or on the treatment zone are
          degraded, transformed, or immobilized within the treatment zone.
          The Regional Administrator will specify in the facility permit the
        •  elements of the treatment program, including:
               (1)  The wastes that are capable of being treated at the unit
          baaed on a demonstration under §264.272;
               (2)  Design measures and operating practices necessary to
          maximize the success of degradation, transformation, and
          immobilization processes in the treatment zone in accordance with
          §264.273(a); and
               (3)  Unsaturated zone monitoring provisions meeting the
          requirements of §264.278.
                                     8-63

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               (b)  The Regional Administrator vili specify in the facility
          permit the hazardous constituents that must be degraded,
          transformed, or immobilized under this subp^rt .   '.'azaraous
          constituents are constituents identified in Appendix '/III of
          Part 261 of this chapter that are reasonably expected to be in,  or
          derived from, waste placed in or on the treatment zone.
               (c)  The Regional Administrator will specify the vertical  and
          horizontal dimensions of the treatment zone in the facility permit.
          The treatment zone is the portion of the unsaturated zone below and
          including the land surface in which the owner ~r operator intends to
          maintain che conditions necessary for effective degradation,
          transformation, or immobilization of hazardous constituents.   The
          maximum depth of the treatment zone must be:
               (1)  No more than 1.5 metars <'5 faec) frcsj -:he iniciai soi.i
          suriaca; and
               (2)  More than 1 meter (3 feet) above the seasonal  high water
          table."

     Section 264.271(a)(2) states that the owner or operator must  design and
operate the land treatment unit to maximize treatment in accordance with
§264.273(a), which states:

               "(a)  The owner or operator must design, construct, operate,
          and maintain the unit to maximize the degradation, transformation,
          and immobilization of hazardous constituents in the treatment zone.
          The owner or operator must design, construct, operate, and maintain
          the unit in accord with all design and operating conditions that
          were useH in ;he treatment demonstration under §264.272.  AC a
          minimum, the Regional Administrator will specify the following in
          the facility permit:
               (1)  The rate and method of waste application to the treatment
          zone;
               (2)  Measures to control soil pH;
               (3)  Measures to enhance microbial or chemical reactions (e.g.,
          fertilization, tilling); and
               (4)  Measures to control the moisture content of the treatment
               11

     Section 264.271(a)(3) states that the owner or operator must  meet the
unsaturated zone monitoring requirements of §264.278.  This section requires
that:

               "(a)  The owner or operator must monitor the soil and soil-pore
          liquid to determine whether hazardous constituents migrate out of
          the treatment zone.
               (1)  The Regional Administrator will specify the hazardous
          constituents to be monitored in the facility permit.  The hazardous
          constituents to be monitored are those specified under  §264.271(b).
               (2)  The Regional Administrator may require monitoring for
          principal hazardous constituents (PHCs) in lieu of the  constituents
          specified under §264.271(b).  PHCs are hazardous constituents
          contained in the wastes to be applied at the unit that  are the most
                                     3-64

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 difficult ".:  : :2.;_   :cr._ __^ r-.".o -•"•= ooaioinea erreccs  of  degrada c ion ,
 crans format ion,  and immobilization.  The Regional Administrator  will
'establish PHCs  if he finds,  based on waste  analyses,  treatment
 demonstrations,  or other  data,  that effective degradation,
 transformation,  or immobilization of the PHCs will  assure  treatment
 at at least equivalent lavels  for the other hazardous constituents
 in the wsates.
      (b)  The owner or operator must install an unsaturated zone
 monitoring system that includes soil monitoring using soil cores  and
 soil-pore liquid monitoring  using devices such as lysimeters.   The
 unsaturated zone monitoring  system must  consist of  ^sufficient
 number of sampling points at appropriate locations  and depths  to
 yield samples that:
      (1)  Represent the quality of background soil-pore  liquid
 quality and the  chemical  make-uo of soil that has not been affected
 by laakaga from  ;ne treatment  zone; and
      (.2)  Indicate the quality of soil-pore liquid  and the chemical
 make-up of the  soil below the  treatment  zone.
      (c)  The owner or operator must establish a background value
 for each hazardous constituent to be monitored under  paragraph  (a)
 of this section.  The permit will specify the background values  for
 each constituent or specify  the procedures  to be used to calculate
 the background values.
      (1)  Background soil values may be  based on a  one-time sampling
 at a background  plot having  characteristics similar to those of  the
 treatment zone.
      (2)  Background soil-pore liquid values must be  based on  at
 least quarterly  sampling  for one year at a  background plot having
 characteristics  similar to chose of the  treatment zone.
      (3)  The owner or operator must express all background values
 in a form necessary for the  determination of statistically
 significant increases under  paragraph (f) of this section.
      (4)  In taking samples  used in the  determination of all
 background values,  the owner or operator must use an  unsaturated
 zone monitoring  system that  complies with paragraph (b)(l) of  this
 section.
      (d)  The owner or operator must conduct soil monitoring and
 soil-pore liquid monitoring  immediately  below the treatment zone.
 The Regional  Administrator will specify  the frequency and  timing  of
 soil and soil-pore liquid monitoring in  the facility  permit after
 considering the  frequency, timing, and rate of waste  application,
 and the soil  permeability.  The owner or operator must express  the
 results of soil  and soil-pore  liquid monitoring in  a  form  necessary
 for the determination of  statistically significant  increases under
 paragraph (f) of this section.
      (e)  The owner or operator must use consistent sampling and
 anal/sis procedures that  are designed to ensure sampling results
 that provide  a reliable indication of soil-pore liquid quality  and
 the chemical  make-up of the  soil below the  treatment  zone.  At  a
 minimum, the  owner or operator must implement procedures and
 techniques for:
                           3-65

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     v;.;  Sample collection;
     (2)  Sample preservation and shipmenc;
     (3)  Analytical procedures; and
     (b.)  Chain of custody control.
     (f)  The owner or operator must determine whether there is a
statistically significant change over background values for any
hazardous constituent to be monitored under paragraph (a) of this
section below the treatment zone each time he conducts soil
monitoring and soil-pore liquid monitoring under paragraph (d) of
this section.
     (I)  In determining whether a statistically significant
increase has occurred, the owner or operator must compare the value
of each constituent, as determined under paragraph (d) of this
section, to the background value for that constituent according >:o
the staEijticsl procedure .specified in the facility permit under
this paragraph.
     (2)  The owner or operator must determine whether there has
been a statistically significant increase below che treatment zone
within a reasonable time period after completion of sampling.  The
Regional Administrator will specify that time period in the facility
permit after considering the complexity of the statistical test and
the availability of laboratory facilities to perform the analysis of
3OJ.1 and soil-pore liquid samples.
     (3)  The owner or operator must determine whether there is a
statistically significant increase below the treatment zone using a
statistical procedure that provides reasonable confidence that
migration from the treatment zone will be identified.  The Regional
Administrator will specify a statistical procedure in the facility
permit that he finds:
     (i)  Is appropriate for che distribution of the data used to
establish background values; and
     (ii)  Provides a reasonable balance between the probability of
falsely identifying migration from the treatment zone and the
probability of failing to identify real migration from the treatment
zone.
     (g)  If the owner or operator determines, pursuant to
paragraph (f) of this section, that there is a statistically
significant increase of hazardous constituents below the treatment
zone, he must:
     (1)  Notify the Regional Administrator of this finding in
writing within seven days.  The notification must indicate what
constituents have shown statistically significant increases.
     (2)  Within 90 days, submit to the Regional Administrator an
application for a permit modification to modify the operating
practices at the facility in order to maximize the success of
degradation, transformation, or immobilization processes in the
treatment zone.
     (h)  If the owner or operator determines, pursuant to
paragraph (f) of this section, that there is a statistically
significant increase of hazardous constituents below the treatment
zone, he may demonstrate that a source other than regulated units
caused the increase or that the increase resulted from an error  in
                          3-66

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          3 amp l^ng, _ir.3./L_j,  ,.- = v2j.odc .on.  ^ni^e t.ie owner or operator m
          make a demonsCracion under this paragraph in addition to, or in 1
          of, submitting a permi: aodificacion application under
          paragraph (g)(2) of this section, he is not relieved of the
          requirement to submit a permit modification application within the
          time specified in paragrapn (gA2) or this section unless the
          demonstration made under this paragraph successfully shows that a
          source other than regulated units caused the increase or that the
          increase resulted from an error in sampling, analysis, or
          evaluation.  In making a demonstration under this paragraph, the
          owner or operator must:
               (1)  Notify the Regional Administrator in writing within seve
          days of determining a statistically significant increase below the
          treatment zone that he .intends to make a determination under this
          paragraph;
               (2>  Wicnin 90 aays, submit a report to the Regional
          Administrator demonstrating that a source other than the regulated
          units caused the increase or that the increase resulted from error
          in sampling, analysis, or evaluation;
               (3)  Within 90 days, submit to the Regional Administrator an
          application for a permit modification to make any appropriate
          changes to the unsaturated zone monitoring program at che facility;
          and
               (4)  Continue to monitor in accordance with the unsaturated
          zone monitoring program established under this section."

3.2.2  Summary of Necessary Application Information

8.2.2.1  Wastes for Land Treatment Program—
     The application should contain a listing of all hazardous wastes,
hazardous constituents, and pertinent aonhazardous constituents that will be
or currently are (for existing facilities) applied in or on the treatment
zone(s) of che subject land treatment facility.

3.2.2.2  Waste Application Rates and Methods—

Part 1 - For each waste constituent listed in Section 8.2.2.1, the applicant
should assess its application limit (AL), rate limit (RL), and capacity limit
(CL).  EPA1s Permit Applicants' Guidance Manual^ recommends that chis
information be presented in the format provided in Table 8.2.1.

Part 2 - For each waste constituent identified in Section 3.2.2.1, list
respective waste concentrations and quantity required (as per hectare basis)
to reach each constituent's AL, RL, and CL.  Table 8.2.2 shows the recommended
format for presenting this information.  An asterisk or other footnote should
be used to identify application limiting constituent (ALC), rate limiting
constituent (RLC), and capacity limiting constituent (CLC).

Part 3 — The application should include a monthly application schedule based
on the following:

     •    application limiting constituent,
                                    8-67

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   TABLE  8.2.1.   FORMAT  FOR  REPORTING  APPLICATION,  RATE,  AND CAPACITY LIMITING
                CONSTITUENTS
   Wasce
Constituent
Limit
     Value
          Discuss ion
Phenol
 AL
                 RL
1.1 x 103 kg/ha
          70 kg/ha/vr
Concentration _>_5GO ag/kg soil
are phytotoxic and inhibit
microbial activity

Optimum degradation rate is
70 kg/ha/yr
Lead


AL
RL
r* T
None
None
2.2 x 10- rcg/fta


Not to exceed 1000 mg/kg
  TABLE 8.2.2.  FORMAT FOR IDENTIFYING LIMITING CONSTITUENTS  (ALCs, RLCs, AND
                CLCs ARE MARKED WITH AN ASTERISK)



U-a a f A
was ce
Constituent
1. Water"
2. Phenol
3. Lead

Concentration
in Wast a


(mg/kg)
8.5 x 1Q5
200
500
Amount of
Waste to
Reach AL


kg/ha /Application

5.6 x 106*
N/A
Amounc of
Waste to
Reach RL


kg/ha/yr
3.53 x 106
3.5 x 105*
N/A
Amount of
Waste to
Reach CL


kg /ha
N/A
N/A
4.5 x 103*
N/A, not applicable.

 Pertinent nonhazardous substance.
                                   8-68

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                                     \
     *    race  limiting conscicuenc,

     •    capacity limiting constituent,

     •    waste generation rate,

     •    seasonal restrictions on application,

     •    expected life span of unit, and

     •    waste application -sethod.

     Table 3.2.3 shows the recommended format for presenting the waste
application schedule.

?art 3 - The application should contain a description of waste handling and
application methods that includes the following:

     •    methods and frequency of waste collection and transport,

     •    location, type, and capacity of onsite storage containers,

     •    waste application equipment,

     •    application restrictions (e.g. weather, rate of degradation), and

     •    plot configuration (plot rotation).

8.2.2.3  Measures co Control Soil pH—
     The following information addressing the control of traataent sone soil
pH should be presented in the permit application:

     •    current or antecedent soil pH (mean and range) of treatment zone,

     •    minimum and maximum treatment zone soil pH values that promote
          maximum degradation,  transformation, or immobilization, and

     •    description of soil monitoring scheme and amendment procedures to
          control treatment zone soil pH at optimum levels.

8.2.2.4  Measures to Enhance Microbial or Chemical Reactions—
     The applicant should describe how the treatment zone(s) will be
conditioned to enhance microbial or chemical degradation, transformation, or
immobilization of hazardous constituents applied with or derived from wastes
placed in th« land treatment unit.

8.2.2.5  M**«ures to Control Soil Moisture in the Treatment Zone—
     Estimate* of expected monthly waste gains and losses at the land
treatment unit should be included in the application.  Procedures for
estimating or data sources for each of the following should be described in
                                     8-69

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            TABLE 8.2.3.  EXAMPLE WASTE APPLICATION SCHEDL*LŁ
                                        Number of
                                      Hectares (ha)
                 [•ioucniy rfasce        Receive Wasce      Application
                Generation Rate       Applications          Rate
  Month            kg/month                ha            kg/ha/month
January
February
March
April
May
June
July
August
September
October
November
December
TOTALS             kg/yr                   ha             xg/ha/year

     Total Amount of Available Land:                   	ha
     Expected Life Span of the Unit:                   	years
     Expected total Quantity of Waste Applied per  ha:  	kg/ha
                              8-70

-------
cne application:  precipitation, avapocranspiracion, run-off, percolation,
irrigation needs, and storage requirements.  All support calculations and
assumptions should be included in the application.

8.2.2.6  Unsaturated Zone Monitoring—
     Under.1270.20(b)(3) the applicant La required to submit an unsaturated
zone monitoring plan that will demonstrate compliance with the requirements of
5264.278.  At a minimum, the plan should address the following nine parts.
Unsaturated zone monitoring is required for each plot placed in service.

Part 1 - Sampling location - On a scale drawing of the land treatment unit,
the applicant should show the location and depth of soil-pore liquid sampling
devices and locations and depths for taking soil samples.

Part 2 - Sampling frscuency - A jcnedule identifying the sampling frequency of
tne soil-pore liquid and soil below the treatment zone should be included in
the permit application.  Factors affecting sampling frequency such as waste
application rate, waste application schedule, climatic factors, and the
hydraulic conductivity of the treatment zone should be addressed by the
applicant.

Part 3 - Sampling equioment - The applicant should identify and describe the
equipment (.including procedures and materials) that will be used to obtain
both soil core samples and soil-pore liquid samples.

Part 4 - Equipment installation - A step-by-step description of the procedure
used for installing soil-pore liquid monitoring devices should be included in
unsaturated zone monitoring plan.

Part 5 - Sampling procedures - Explain in a step-by-step fashion how samples
of soil-pore liquid and soil will be obtained using the equipment described
above.  The number of samples taken at each sampling event, as well as
compositing procedures, if used, should be described.

Part 6 - Analytical procedures - Analytical procedures that will be used to
determine the concentration of each hazardous constituent in collected samples
and the name of the laboratory chat will perform the analyses should be
identified in the application.

Part 7 - Chain-of-custody control - The applicant should explain in a
step-by-step fashion the plan for maintaining chain-of-custody control
throughout sampling, transportation, analysis, and reporting.

Part 8 - Background - A detailed description of the procedures for determining
both soil background and soil-pore liquid background values, including the
location and depth of background samples, sampling procedures, analytical
methods, and results should be contained in the application.

Part 9 - Statistical methods - The statistical methods that will be used to
determine a significant difference between background sample concentration and
monitoring sample concentrations for both soil and soil-pore liquids must be
included in the unsaturated zone monitoring plan.
                                     8-71

-------
(a) Time Period for Determining Increases Over Background - In accordance wth
§264.278(f)(3), Che applicant must submit results that show a significant
increase over background values within a reasonable ciae frame.

(b) Principal Hazardous Constituents - The applicant can elect to monitor only
principal hazardous constituentsTPHCs) instead of all hazardous constituents
listed in Section 8.2.2.1.  If this is the case, the application should
identify the PHCs and supporting justifying documentation.

8.2.2.7  Treatment Zone Description—
     A description of the dimensions and soils of the treatment zone including
each of the following four Parts should be submitted in the permit application.

Part 1 - Soil survey - A mao ~.r plot plan of the land treatment unit that
delineates Che horizontal boundaries of the treatment zone(s) and labels the
series classification of the soils contained therein should be included in the
application.

Part 2 - Series descriptions - Soil series descriptions should be submitted
that include the following information (this applies to undisturbed native
soils, disturbed soils, fill materials, or previously waste-treated soil):

     •    soil profile description,

     •    physical setting with slope and climatic data,

     •    mineralogy,

     •    land use and vegetation cover,

     •    estimated soil properties including:

               USDA texture                 shrink-swell potential
               Atterburg limits             erosion factors
               permeability                 flood frequency and duration
               available water capacity     depth of seasonal high water
               pH                             table
               salinity                     frost action potential

Part 3 - Results of soil sampling and analysis - The applicant should submit
the results of analyses of the soils within the treatment zone.  The submittal
should also include sample location, collection and preparation, and
analytical methods.  Table 8.2.4 presents the recommended format for reporting
results of soil sampling and analysis.

Part 4 - Depth of treatment zone - For each plot of the treatment unit, the
applicant mu*t specify the dimensions of its treatment zone.  Vertical
dimensions should be expressed in meters below the initial soil surface and
meters above the seasonal high water table.
                                    8-72

-------






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8-73

-------
i._.j  Juiaanca jn Evaluating Application Information

     The applicant must develop a land treatment program chat is designed
ensure that hazardous constituents placed in or on che treatment zone are
degraded, transformed, or immobilized in the treatment zone.  Figure 8.2.1
identifies the required components of the land treatment program.
Establishment of operating conditions and work practices should be based on
results obtained from the treatment demonstration.

8.2.3.1  Wastes for Land Treatment Program—
     Evaluation of the wasceCs) capaole of being treated by the land treatment
unit should be based on the results of the treatment demonstration.  Wastes
containing hazardous constituents that have been shown to be completely
degraded, transformed, or immobilized under the treatment demonstration can je
disposed of. at fh*» pr?poaad or existing unit, as the case may be.  If the
owner or operator demonstrates similarities, specifically with respect to
hazardous constituents between broad classes of waste, it may not be necessary
to require analysis of each batch of waste that might be handled at the unit.

     Figure 8.2.2 presents a worksheet to assess the completeness of the
information provided by applicant with respect to wastes that are or will be
treated at the facility.

8.2.3.2  Waste Application Rates and Methods —
     Determination of waste loading rates should be based on three factors.
These factors are the rate limiting constituent (RLC), application limiting
constitutent (ALC), and capacity limiting constituent (CLC).  The rate
limiting constituent is the chemical substance or compound that controls
yearly loading rates.  The application-limiting constituent is the substance
that restricts the amount of waste chat can be spread in a single application^
although it may be rapidly degraded, transformed, or immobilized.  The third
restricting factor, capacity limiting constituent,  is an accumulating
substance, such as a heavy metal, that sets the upper boundary for the total
quantity of waste that can be applied at the site.   The CLC controls the
maximum design life of che treatment unit.

     Section 7 of che HWLT manual2 provides an informative discussion on how
these three factors are determined based on the composition of che wastes Co
be applied.  Appendix E of the HWLT manual provides sample calculations to
determine each value for a given waste.   Table 8.2.5 categorizes primary waste
constituents with respect to their potential application, rate, and capacity
limiting characteristics.

     The HWLT manual also provides a technique for assessing constituent
degradability as it relates to limiting application rates and frequency.  Two
management scenarios are discussed, one involving che maintenance of a plant
cover over the active treatment zone, and the second addressing systems
designed to function without a vegetative cover.  Table 8.2.6 presents the
computations that are required to determine the number of applications that
are acceptable under either scenario, based on the expected degradability of
the most persistent constituent.
                                    8-74

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                 LAND TREATMENT PROGRAM






 •  Waste for Land Treatment Program




 3  Vasca Application Rat^s and detnoas




 •  Measures Co Control Soil pH




 •  Measures to Enhance Microbial or Chemical Reactions




 •  Measures to Control Soil Moisture in Treatment Zone




 •  Unsaturated Zone Monitoring




 •  Treatment Zone Description
Figure 8.2.1.  Components of the Land Treatment Program.
                         8-75

-------
                        WASTES  FOR  LAND  TREATMENT PROGRAM
Is the following information provided for each waste
being or to be land treated?
                                                                   YES     MO
Part 1     Waste Name                                             	   	
           Waste Generating Process or Source                     	   	
           Monthly or Annual xusncity Handled                     	   	
           EPA Hazardous Waste ID Number (if applicable)          	   	

Part 2     Name(s) of Pertinent Hazardous Constituents            	   	
           Name(s) of Pertinent Nonnazardous Constituents         	   	

Part 3     Concentration of Each Hazardous Constituent            	   	
           Volatility of Each Hazardous Constituent               	   	
           Percent Water                                          	   	
           Specific Gravity or Bulk Density                       	   	
           PH                                                     	   	
           Electrical Conductivity                                	   	
           Total Acidity or Alkalinity                            	   	
           Total Organic Carbon                                   	   	
 Figure 8.2.2.  Worksheet for evaluating completeness  of  description of wastes
                for land treatment program.
                                     8-76

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    TABLE 3.2.5.   WASTE COMPONENTS TO 3Ł CChPARED IN DETERMINING APPLICATIC
                  RATE, AND CAPACITY LIMITING CONSTITUENTS3(2)
Potential
Constituenc ALCb
Organics X
- Volatilization X
- Leaching X
- Degradation
Waterc X
Metals
Nitrogen0 X
Phosphorus0
Inorganic Acids,
Bases, and Salts
Halides
Potential
RLC
X

X
X
X
Xd
X

X
X
Potanti
CLC



X

X

X
X

aThe actual comparison should be tabulated similarly, but using calculated
 loading rates and capacities in place of the X's.  The lowest value under ea
 category corresponds Co the respective limiting constituent.

''Depending upon prevailing site conditions, the ALC may vary seasonal-/.

cAlthough these constituents are not considered hazardous, they may be the
 ALC, RLC, or CLC for the treatment unit.

"^Metals may be the RLC when biodegradation is relied on for waste treatment
 and/or when a vegetative cover is maintained during active life.  Elevated
 metal concentrations may be toxic to soil microbes and plants.
                                  3-77

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TABLE 3.2.6.    COMPUTATION OF NUMBER OF  APPLICATIONS PER YEAR  BASED  ON
                  ORGANIC CONSTITUENT DEGRADATION  (ADOPTED  FROM REFERENCE  2)
     Scenario A
     Whan vegetation it a part of operational  management, toxic organics nay limit
     ch« loading rate.  Loading races Bust be  constant 30 chat che design facility
     area i* adequate  to handle each year's waste  production.  The following equa-
     tion applies:
                           ^     Cl/2

     where Cvr  "  the  race of aopl icat ion of  :iie  -oapound ar ..raccion of interest
                 co son (kg/ha/yr) ;

         ccnt  "  the  critical concentration  of the compound or fraction in soil at
                 which yield reductions occur (kg/ha); and

          cl/2  *  half-life (yr) •

               C                                                                (2)
     Then LA •  -g-
               w

     where LR • loading rate (kg/ha/yr) and

           Cw » concentration of  che  compound or fraccion of interest in the bulk
               waste (kg/kg.).

     If ti/2 is less  Chan one year, Chen che year's  loading rate should be
     applied in 00 re  Chan a single dose as follow*:

                     Let 1/C1./2  * cne smallest  integer   -/tl/2             ^

     Then MA
     where  NA * number of application* per year


     Scenario 8

     When a vegetation cover is desired only after  sice closure Begins,  chen
     applications  of wa«te nay grsaciy exceed ch« toxicity threshold value.   The
     only constraint would be that the site oust have a final vegetative cover
     after  a given number of years following the beginning of closure.  Calcula-
     tions  are as  follows:

                                                                         14)

     where  C^^ •  aaximua allowable concentration of the compound or fraction of
                  interest applied co the soil (kg/ha);

              n •  timber of years between final waste application and crop esta-
                  blishment (yr} ; and

           cl/2 "  half-life (yr) .

     Substituting  CgAX for Ccric in equation I, the  loading rate can be calcu-
     lated  using equation 2.
                                          8-78

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     Figure 3.2.3 presents a worksneet chat can be used  co assess whether all
of the information requested under Section 3.2.2.2 has been submitted in the
application.

     Table 8.2.7 identifies the advantages and disadvantages of various waste
application nsethods.  Method of application should be thoroughly reviewed to
determine that all disadvantages associated with the application technique to
be employed have been addressed by the applicant and ways to minimize their
negative impact (e.g. potential increased run-off) on the operation of the
unit will be instituted.

     Climatic conditions and geographical latitude will  affect the rate of
degradation and thus application rates and frequency.  During the winter
months and periods of excessive rainfall, the rate of biological degradation
will slow down.  *.lso. application rates are expected to be lower in the
northern climates compared to southern latitudes.  Figure 8.2.4 can be used to
make a preliminary estimate of the number of days that waste application
should be suspended based on geographical location.

     Contingency arrangements should be made for waste storage when waste
application is suspended.  Storage facilities will also  be necessary when
equipment breakdown occurs.  The permit application 3hould contain a.
description of the waste handling activities to be performed when waste
disposal is suspended or interrupted.  Note that storage of hazardous wasces
in containers or tanks are subject to the permit requirements of Part 270 and
technical standards of subparts I and J of Part _64, respectively.  If storage
of the waste is not feasible, alternate disposal methods such as placement in
waste piles, surface impoundments, or a landfill may be  praccicad.  Disposal
in any of these alternate facilities mandates conformance with the
requirements of the applicable subpart of Part 26
-------
                      RATE AND METHODS OF WASTE APPLICATION .


Has Che applicant listed  respective rate  limiting,  appli-       	     	
cation limiting, and capacity limiting concentrations  for         Yes        No
each hazardous constituent?

Has the rationale for determining each limit been provided?     	     	
                                                                  Yes        No

Has the necessary quantity of waste applied per hectare         	     	
to reach constituents respective RL, AL, and GL been              Yas        No
submitted?

Has the applicant suomitted a monthly waste application         	     	
schedule?                                                         Yes        No

Are the methods and frequency of waste collection and           	     _____
transport described?                                              Yes        No

lias che applicant described che location, type, and                _       	
capacity of waste storage units associated with the               Yes        No
land treatment unit?

Is waste application equipment described?                       	     _____
                                                                  Yes        No

Have restrictions on waste application been described?         ______     	
                                                                  Yes        No

Has the applicant described the planned  plot configuration?     	     	
                                                                  Yes        No
      Figure 8.2.3.  Worksheet  for  assessing completeness of applicant's
                     waste  application rate and methods.
                                      8-80

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TABLE  3.2.7.
ADVANTAGES  AND  DISADVANTAGES OF VARIOUS  SYSTEMS
APPLICATION"1
                    Advantage!
                                                               Disadvantages
         I.    Surface application

              a.)  spraying

         low labor requirement,
         low land preparation,
         wide selection or  equiaaent,
         operates on rougn  or wee Land
              b)  overland  flow  or controlled
                  flooding

        low labor,
        low land preparation,
        operate! on wet land
              -1   ridge  and  furrow

        rather simple system with low
        capital outlay,
        reasonably flexible,
        low "lergy requirement
              d)   tank truck  surface spreading

        low overhead,
        flexible,
        easily ragulated  application rate
        [I.    Subsurface  application
                  Mixing  of  sludge and loil,
        low odor and ponding problem*,
        !*•• chance of  runoff contamination
        III.
              Surface  spreading and nixing of
              dewatered sludge
        Can u«e conventional equipment,
        can apply at  higher rate*,
        doe* not cauae  flooding and ponding
        and aaaociated  problems
                              clogging of nozzles.
                              power cor pumpa,
                              .lerosoi police'.on,
                              must flush pipe when  stopping
                              application
                              clogging of  pipes  and  perforations,
                              poor atstribution  over i given area
                              or field due to  slope  and I  solid  in
                              sludge,
                              limited  rsapplication,
                              potential odor,
                              auaC flush pipea when  stopping
                              application
                              can only use sludge*  with  -«
                              or -=»*,
                              only United reapplication  po»*ibl«,
                              sol.da settle out  «c  heada  of  furrow*,
                              needs well  prepared site with  slop*
                              of only 1/2 to 1-1/22
                              ponding and odor problem*,
                              deteriorates soil  structure,
                              not good under wet soil condition*
                              limited in wet  weather  •  need  storage
                              or alternate  application  ayitea,
                              damage* soil  structure  resulting  in
                              compaction,
                              high bulk density,  and  low
                              infiltration
                              complex management,
                              require* specialized  equipment,
                              cannot be uaed  in wet soil
                              high energy co*t  to  dry  the  sludge,
                              high operational  coat* to  dry and
                              »ppiy.
                              difficult  to achieve uniform
                              application
        •(Adapted from KWL" aanual. U.S. EPA, EPA Report SU-874,  (2}j.
                                            8-81

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            O  L. —  C
            C  5J u •—  (j  O)
            
-------
     TABLE 3.2.3.  SUMMARY OF L/iND TREATMENT EXPERIENCES  IN  THE  HYDROCARBON
                   PROCESSING INDUSTRY  (5,6).
Waste Applied:
Application Method:
Application rates:
Frequency of application:

Percent oil in soil
following application:

Optimum soil moisure
content:

Run-off collection and
handling:
Oily sludge including API separator  sludge, DAF
float, biosiudge, and tank bottoms

surface spreading or subsurface injection
(15-20 cm)

100 to 120 barrels/acre/application, wich a
.naxijiuia or 2uO barrels under optimum conditions
(e.g. climate, soil moisture, degradation)

monthly,  up to a total of eight times per year
5 to 10, vith a maximum of 20
15 to 20 oercent
analysis of collected runoff reveals high oil and
grease content such that liquid must oe treated
prior to discharge or can be reappiied to
treatment zone during dry periods
                                     3-83

-------
The amount of land area required for -a jite can oa calculated as follows

                                PR
Required treatment area (Ha) * 7-5 -
                               LRRLC

Where     PR * waste production or handling rate (kg/yr); and

       LR_ „ * waste loading rate jased on the rate limiting constituent
         ru'°   RLC (kg/ha/yr)

                                      ha
          Exaraple:
              *     26,400 (k
If the required land area is greater than the area available for treatment,
then the proposed facility cannot accommodate all of the waste that is
produced or expected to be handled by the site.

     The maximum number of annual applications is based on Che rate limiting
constituent (RLC) and the application limiting constituent (ALC), and is
computed as follows:
                                                                    LR
     Annual number of applications * — - 3 the smallest integer   ——
                                     AL                           ~~ Ait

     Where  LR^C  = waste loading rate based on the RLC (kg/ha/yr); and

                AL * application limit based on the ALC (kg/ha/application).

                         26,400 (kg/ha/yr)
                      :  5.280
     Determination of facility life is based on accumulation of the capacity
limiting constituent (CLC) and loading rate of the rate limiting constituent
(RLC).  Expected facility life can be calculated as follows:

                               LCAPCLC
       Facility life (years) 3 —7-3 -
                                LRRLC

     where  LCAP    a waste loading capacity beyond which the CLC will
                      exceed allowable accumulations (kg/ha); and

                 LR * waste loading rate based on the RLC (kg/ha/yr).

          ,    i     264,000 (kg/ha)  _ . .
          B«-»U!   26.400 (kg/ha/yr)' 10 yea"

If the RLC is also the CLC, then the facility life is 1 year.  To increase
facility life the applicant must increase the available land area
proportionately.
                                     8-84

-------
      It  should be recognized ChaC waste application methods and rates employed
 by  facilities maintaining a vegetative cover uuring the unit's active life
 will  differ considerably from land treatment units choosing not to escaolish a
 plane cover.  Factors influencing the selection of the waste application
 method are:

      *    plant tolerance to physical disturbance,

      •    detrimental effect of ^asCa applied jn exposed vegetative matter, and

      •    impact on plant root system.

      The decision to establish i plant ;over 'e.g., fooa-chain crops} aay be
 based on two separate functions or a combination of both.  Vegetative cover
 can serve to 1) protect the surface soil from erosion, or 2) cycle and treat
 the waste material applied to the treatment zone.  Table 8.2.9 identifies the
 specific functions a vegetative cover can provide and alternative management
 techniques that can be instituted in cases when it would be inappropriate to
 maintain a vegetative cover.  The HWLT manual has identified the following
 concerns which may preclude establishment of a vegetative cover:

      (1)  Maintaining concentrations of waste in soil which are not phytotoxic
          may limit the allowable waste application rates to levels far below
          the soil's capacity to treat the waste, thus underutilizing the
          treatment capacity of the site.

      (2)  Where wastes are applied by spray irrigation,  hazardous constituents
          may adhere to vegetative surfaces.

      (3)  A crop cover may filter ultraviolet radiation which could have aided
          in the photochemical decomposition of certain compounds.

     Many factors will affect the successful establishment of a vegetative
cover.  These factors are essentially the same as those to enhance of
microbial activity (see Section 8.2.3.4).  However, the principal concern with
 respect to growth in or on the treatment zone is phytotoxicity, primarily
resulting from heavy metal accumulation.   Table 8.2.10 provides a limited
compilation of the normal range of trace element concentrations found in plant
 leaves and identifies levels that are toxic.  The information presented or
similar data obtained from other sources should be used together with a review
of the type and rate of hazardous constituents to be land treated at the
proposed site to identify potentially phytotoxic conditions.

     Plant species selection will depend on existing and altered soil
conditions,  local climate,  and intended function of vegetative cover.  Plant
species selected by the applicant should be evaluated with respect :o growth
potential and ease of maintenance.  This is best accomplished by consulting
regional agronomists from the State Agricultural Extension Service of the U.S.
Department of Agriculture or the agronomy department of nearby college or
universities.
                                     8-85

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 TABLE 8.2.9.   ALTERNATIVE  MANAGEMENT TECHNIQUES  TO REPLACE THE ROLE OF
               CROP COVER  IN A LAND TREATMENT SYSTEM3
  Plant function
           Alternative .nanagement
Protective:

     Wind aroaion
     Water erosion
Maintain a moist soil surface.

Wastes often provide the necessary
stability when mixed with the soil.

Minimize slopes and use proper
contouring to reduce water flow
velocities.

Some wastes, such as oily sludges,
repel water and stabilize the soil
against water effects.

Design run-off catchments to account
for increased sediment load.

Run-off water may need some form of
treatment before release into
waterways.
Cyc1i ng:

     Transpiration




     Removal
3ewacer the waste.

Control applications of wastewater
to a lower level.

Plants have only a very minor  role
in this respect; for organics,
manage for enhanced degradation;
for inorganics, reduce  loading
rates.
aAdapted from HWLT manual(2).
                                 3-86

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    TABLE 8.2.10.  NORMAL RANGE AND TOXIC  CONCENTRATION  OF
                   TRACE ELEMENTS  IN PL ANTSa
Concentrations
Element
A3
B
5a
3e
Cd
Co
Cr
Cu
F
Fe
HS
I
Li
Mn
Mo
Ni
Pb

Se
V
Zn
of Elements in
Range
0.01 -
5 -
10 -
1 -
0.2 -
0.01 -
0.1 -
4 -
2 -
20 -
0.001 -
0.1 -
0.2 -
15 -
1 -
0.1 -
0.1 -

0.02 -
0.1 -
15 -
Plant Laavaa '

i.O
30
100
40
0.3
0.30
1.0
15
20
300
0.01
0.5
1.0
150
100
1.0
5.0

2.0
10.0
150
o c m 0 ry We i g n t /
Toxic
>10
>75
—
>40
5 - 700
200
10 - 20
>20
20 - 1500
—
>10
>10
50 - 700
500 - 2000
>1000
50 - 200
Low plant
uptake
50 - 100
=•10
500
'Adopted from HWLT manual (2)  (see Reference  2  for
 original citations).
                          8-87

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 8.2.3.3  Measures  Co  Control Soil  pH—
     Soil  pH  is a.  controlling  factor  j.n determining  the nobility and
 solubility of many hazardous constituents and  plant  nutrients and will
 influence  soil microbial activity.  The pH value expresses the degree of
 acidity or alkalinity of a soil.   The Soil Conservation Service has classified
 soil pH values as  follows:

                      Extremely acid            Below 4.5
                      Very aCrongj./ acid        <+. 5-5.0
                      Strongly acid             5.1-5.5
                      Medium acid               5.6-6.0
                      Slightly acid             6.1-6.5
                      Neutral                   6.6-7.3
                      Mildly alkaline           7.4-7,8
                      Moderately alkaline       7.9-8.4
                      Strongly alkaline         8.5-9.0
                      Very strongly alkaline    9.1 and
                                                 higher

A soil pH  in the range of 6.0 to 8.0 la considered optiiaal for organic
compound biodegradation and heavy metal precipitation with subsequent colloid
adsorption (7-11).  It is noted that certain hazardous constituents
(e.g.,  selenium) are more available to plants in neutral pH soils than in
acids soils.   Consequently, the availability and mobility of hazardous
constituents  to be treated should be evaluated under various soil pH
conditions prior to actual application.  This determination should be made .
under the "raatment demonstration.   Management of soil pH consists of three
components:

     •    Initial determination of antecedent soil

     •    Periodic monitoring

     •    Addition of soil amendments to maintain optimum pH range

Soil sampling and analysis should be performed periodically to monitor changes
in soil pH and to predict the need for conditioning.  Section 8 of the HWLT
manual provides a discussion on the management of soil pH.  The manual
identifies three common methods for measuring soil pH.  They are:

     (1)  Titration with base or equilibration with lime,

     (2)  Leaching with a buffered solution followed by analysis of the
          leachate for the amount of base consumed by reaction with the soil,
          and

     (3)  Subtracting the sum of exchangeable bases from the cation exchange
          capacity (CEC).

     The_JEPA TRD (SW-846) Tests Methods for Evaluating Solid.JVaste-Physical/
Chemical Methods^ should also be  reviewed to evaluate the applicant's
sampling and analysis protocol.
                                     8-88

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     The  following discussion identifies raechods of controlling soil pH.  The
most frequently encountered situation will be to reduce soil acidity,

Reduction of Soil Acidity

     The most common method of raising the pH of an acidic soil to the neutral
level is liming.  Liming is a comprehensive term which includes the addition
of oxides, hydroxides, or carbonates of calcium or -aagnesiua.  liae
application rated will vary depending on the kind of lime to be used.  The
relative effectiveness of the three forms in raising soil pH are roughly in
the ratio 1 ton of representative finely ground limestone to 0.7 ton of
commercial hydroxide to a little over 0.5 ton of reorasentative oxide.  I: LJ
important to note thaC initial applications will be the heaviest.  Once the
desired pH level has been achieved, periodic liming at reduced loadings will
be required to maintain a neutral medium.  The frequency of liming will
increase in regions where water percolation is high such as in humid Eastern
sections of the U.S. and in arid locations that will require frequent
irrigation to control soil moisture content.  In both of these environments
calcium and magnesium are leached from the soil, increasing its acidity.

     Alchough derived from agricultural experiences, Figure 8.2.5 provides a
general guide to determine the amount of lime to apply to raise a soil pH to a
desired value.  The data presented are for the plow zone (15 to 23 cm).  When
the entire depth of the treatment zone, up to 1.5 meters, will be used to
treat the wastes, the applicant must employ techniques that will ensure the
maintenance of proper soil pH levels throughout the entire depth of Łhe
craatment zone.  This will require the incorporation of lime at depths lower
than the conventional plow zone.  Techniques that may be used include aurfaca
liming with subsequent deep plowing co a depth greater than the conventional
23 cm plow depth or for small plots possibly excavating the top surface layer
and applying a layer of lime well within the treatment zone itself.  The U.S.
Soil Conservation Service or the local agricultural extension service should
be consulted for specific assistance in evaluating an applicant's soil pH
management program.

Intensification of Soil Acidity

     Although the need to intensify soil acidity will not occur often, there
may be situations where it will be required.  The reduction of soil pH or
increase in acidity can be accomplished by:

     1.    addition of acid organic matter to the treatment zone soil,

     2.    addition of chemicals, or

     3.    application of acidic but compatible waste(s).

Note that records should be kept of all soil additions to ensure that the
assimilative capacity of the soil will not be altered or diminished.
                                     8-89

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   7.0
X
&
                                                   OM(%)  CEC
                                    (a)Sands
                                    (b) Sandy loams
                                    (c) Loams and
                                       silt loams
                                    'd)Silty  cioy
                                       loams
                                2.5
                                3
 5
12

18

23
             12        3456^89

          GROUND LIMESTONE  REQUIRED TO  RAISE SOIL pH TO 7.0 (fons/acrt)
     Figure 8.2.5.
Relationship between soil  texture  and che amount of
limestone required  to  raise  the  pH of New York
soils to 7.0.  Representative  organic matter (OM)
and cation exchange capacity (CEC)  levels are
shown.  Note that pH refers  to conventional plow
zone soil (15 to 23 cm).   [Adopted from Reference 7,.
                                  3-90

-------
Use of Acid Organic Matter

     The decomposition of soil organic matter forma both organic and inorganic
acids.  The presence of organic acids, such as carbonic acid (HoCC^),
causes Che dissolution of limestone or calcium carbonate resulting in the
removal of the bases by solution and leaching.  Inorganic acids formed, such
as H9S04 and HN03, are sources of hydrogen ions which increase soil
acidity.  Sources of acidic organic matter are pine needles, tanbark, sawdust,
and peat.  Sewage sludge is another 3ourca of organic matter.

Use of Chemicals

     When use of acid organic uattar \3 tot acceptable, chemicals such as
ferrous sulfate, aluminum sulfate, or other salts may be used to lower soil
pH.  The salt is hydrolyzed in the soil to form a strong acid (e.g. sulfuric
acid) which drastically lowers the pH.  Another compound used to lower pH in
agricultural environments is flowers of sulfur (a form of elemental sulfur).
The sulfur compound is oxidized by soil microbes producing sulfuric acid.  At
equivalent concentrations, microbial oxidation of the flowers of sulfur is
reportedly four or five times more effective in developing acidity than
ferrous sulfate.?

     No specific recommendation can be made as to amounts of ferrous sulfate
or sulfur that should be applied because sources of soil pH are so variable.
Brady7 reports that for certain plant species, 0.45 to 0.90 kilograms (1 to
2 pounds) of sulfur per 9.3 square meters (100 square feet) is required to
lower the pH 1/2 unit for a medium textured soil (e.g. loam, silt-loam, silt).

Use of Acidic Wastes
     When compatible wich other wastes being applied, incorporation of acidic
wastes into the treatment zone can be an effective method of reducing soil
pH.  Table 8.2.11 identifies organic compounds that hydrolyze in the presence
of water (e.g., soil water) to form strong acids.  The safe use of acidic
wastes for this purpose must be demonstrated prior to any application under
normal operating conditions.

8.2.3.4  Measures to Enhance Microbial or Chemical Reactions—
     Measures to enhance waste treatment include incorporating the waste in
the soil, soil aeration, microbial innoculations, fertilizer applications, and
establishment of a vegetative cover.

Waste/Soil Contact

     Generally, as the surface area of waste particles increases and the
amount of physical contact with the soil increases, biodegradation increases.
For liquid waste applications proper soil/waste mixing can be accomplished by
regularly scheduled tillage.  In caes where solid or semisolid wastes will be
applied to the treatment zone, material shredding or pulverization prior to
application will maximize the contacting surface area.
                                     8-91

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     a  3. 2. 11.   SOME  ORGANICS  THAT  BECOME  ACIDIC WHEN WET1-
Acetyl chloride - FL
Acetylene tetrachloride
Allyl chloride - FL
Ammonium citrate
Ammonium oxalate
Amy I chloride - "L
Amyl propionate
Benzaldehyde - CL
Benzotrichloride
Benzene hexachloride
Benzene sulfonic acid
Benzyl chloride - CM
Butyl chloride - FL
Carbon tetrachloride
Chloroform
Chlorophenol
Chicrosuifonic acid - CM
Citric acid
Dichlorodifluoromechane
Diethyl ether - CL
Dimethyl suifate - CM
Dinitrochiorobenzene - Poison 3
Ethyl chloride - FL
Łchylene dichioride - FL
Ethyl mercaptan - FL
Hexachlorobutadiene
Hexachloroethane
Hexaethyl cetrapnosphate - Poison 3
Lead acetate
Methylene chloride
Nitrophenols
Potassium oxalate
n-Prcpyl aicrate
Trimethyl phosohite
Vinyl chloride - FG
aDepartment of Transportation Hazardous Material classification:
  FL - Flammable liquid
  CL - Combustible liquid
  CM - Corrosive material
  FG - Flammable gas
                            3-92

-------
     The treatment zone surface should be cultivated by disking, plowing, or
rototilling just prior to and subsequent to waste application.  As one
example, experience in land treating oil refinery production wastes has shown
that six cultivations are required to adequately blend the waste and soil
between applications.5,6

Soil Aeration

     The presence of adequate free oxygen in the soil is essential to maintain
biodegradation and drive chemical reactions.  Soil conditioning involving
creation of good drainage, periodic cultivation, and proper waste loadings
will promote aerobic soil conditions.  It should be noted that under certain
conditions, some wastes, particularly nitrogenous wastes, will be degraded
only under anaerobic conditions.  Therefore, conditions that are most
conductive to waste degradation or transformation should be established and
maintained.

Mierobial Innoculations

     Although not always necessary, biodegradation may be improved by
innoculating the treatment zone with soil microbes.  This involves amending
the soil with cultured soil microorganisms indigenous to the region.

Soil Fertility

     Inorganic nutrients must be available in sufficient quantities to sustain
microbial populations.  The amounts required are dependent on the levels and
availability of nutrients in the waste, biodegradation races, waste
application rates, and persistence of added fertilizer in the treatment zone.
The availability of nutrients from a waste applied to the treatment zone, as
an example, nitrogen in certain cases, is expected to be low.  Consequently,
nitrogen or some other nutrient deficiency may occur as a result of the waste
application.  The addition of a fertilizer to the waste-treated soil will be
required to increase microbial activity.

Vegetation

     Establishment of a vegetative cover crop can serve to cycle and treat
certain hazardous constituents.  Treatment functions performed by plants may
include translocation of substances from the soil to vegetative matter and
transformations within the plant.  It should be noted that unless the plants
are harvested or substance transformation performed by the plant results in a
nonhazardous compound, the hazardous constituent taken up by the plant will be
returned to the soil following death and decay.  Under these conditions,
treatment is only in the form of temporary storage.  Area agronomists from the
State Agricultural Extension Service of the U.S. Department of Agriculture or
the agronomy department of nearby universities should be consulted to obtain
information on local cultivation practices that will be necessary to properly
evaluate the permit application.
                                    8-93

-------
     When a vegetative cover is established, Che owner ^r operator should
address the impact of growing crops during the active years of the treatment
unit.  Factors to be evaluated include nutrient depletion, water balance
impact, and effect of increased soil organic matter (i.e., root system and
stubble).

     The mechanisms associated with chemical degradation, transformation, and
immobilization are complex and multifaceted.  They cannot a
-------
 Measurement  of  Soil  Moisture

      Soil moisture content  can be measured  directly  or  indirectly.   Indirect
 techniques involve collecting a soil  sample  in  an  air tight  container  and
 transferring it to a laboratory where the sample is  oven dried.   The weight
 loss  by heating represents  the moisture content of the  soil  sample  taken  ia
 the field and is expressed  as a percentage  of the  oven  dry weight of the
 soil.  This  gravimetric  technique is  one of  the most common  methods used  to
 determine soil  moisture  content on  a  weight  percentage  basis."

      Direct  techniques measure the  moisture  concent  of  the soil  in  the  field.
 Two methods  for measuring soil moisture directly are electrical  resistance and
 neutron scattering.   These  methods  are described in  Tlia Nature and  Properties
 of Soils.?   These tecnniques allow  the operator to leave sampling devices in
 the soil for extended periods of time.  This reduces the time required  to
 determine soil  moisture  content considerably.   These techniques  are not as
 accurate as  the gravimetric method, but they will  provide the necessary
 information  on  a relative basis.

 8.2.3.6  Unsaturaced  Zone Monitoring—
      The purpose of  unsacuratad zone  monitoring is to provide prompt feed back
 on the success  of treatment in the  treatment zone.   Feedback information
 should be used  to adjust the unit operating  conditions  to maximize  hazardous
 constituents  degradation, transformation, and immobilization.  With respect to
 Part  264 requirements, the  unsaturated zone  refers to the layer  of  soil or
 parent material separating  the bottom of the treatment  zone  and  the seasonal
 high  water table or  ground  water table.  This soil layer is  usually found to
 have  a moisture content  of  less than  saturation.

      To avoid confusion, it is important to note that unsaturated zone
 monitoring and  ground water monitoring are both required at  a land  treatment
 facility.  The  distinction  between  the two  is that ground water  monitoring is
 design-'I to  determine the effect of hazardous waste  leachate on  the ground
 water, whereby  unsaturated  zone monitoring  is performed to provide  an
 indication of whether hazardous constituents are migrating out of the
 treatment zone.

      Identification  of hazardous constituents to be monitored should be based
 on the results  of the comprehensive waste analysis performed in  accordance
 with  §264.13.   Recommended  analytical methods that can be used to verify
 analyses performed by the applicant are presented  in Test Methods for
 Evaluating Solid Waste.12

     Hazardous  constituents to be monitored include  those contained in  the
waste and those derived following waste application.  Identification of
hazardous constituents that may be derived from the waste following soil
 incorporation should have been performed as part of the treatment demon-
 stration.   Analysis of leachate and soil collected from soil column tests
performed in the laboratory or field  tests using a lysimeter or  other similar
device should have been conducted to determine  whether hazardous constituents
will be derived from the waste(s) to be land treated.
                                    8-95

-------
     1C is noted that a. provision of the regulation states chat upon approval^
following sufficient documentation,  principal hazardous constituents (?HC),
which are hazardous constituents contained in or derived from the wastes  to  be
applied that are the most difficult  to degrade,  transform, or immobilize, may
be designated (as indicators) for unsaturated zone monitoring purposes in  lieu
of monitoring for all hazardous constituents contained in or derived from  the
waste.  A methodology for determining PHCs is provided in U.S. EPA's RCRA
Guidance Document for Land Treatment.15  At a minimum, a ?HC must be one of
the most mobila and/or taost concentrated and persistent constituents in the
treatment zone.  Meeting these criteria will assure that the constituents
provide a reliable indication of the success of  treatment or conversely
forewarning of incomplete or ineffective treatment.

     The applicant must provide a description of how the soil and soil-pore
liquid below the treatment zone will be monitored to determine whether
hazardous constituents migrate  from  the treatment unit.  The description
provided in the application should include the following:

     •    constituents to be monitored,

     »    Installation of monitoring system (equipment and locations),

     •    determination of background levels,

     •    implementation of monitoring programs,

               frequency
               sampling procedures
               analytical techniques

     •    determination of significant migration from treatment zone,

     •    notification of any significant migration,

               due to facility operation
               due to other 3ourcas(s).

Figure 8.2.6 presents a worksheet that can be used to help the permit writer
evaluate the applicant's description of the unsaturated zone monitoring
program.

     A fundamental concept of a land treatment facility is that it  is a
dynamic system.  Several parameters  must be monitored periodically  to ensure
optimization of hazardous constituent degradation, transformation,  and
immobilization.  Operation of the treatment unit will be modified over time as
monitoring data indicate the need for adjustments.

     The applicant must document conditions existing  (background) prior to  the
application of waste to the treatment zone.  Collection of the background data
provides a bench mark for comparison with subsequent monitoring results.  For
existing facilities, background levels can be determined by  monitoring
background or control plots operated near the treatment  units.  To  the extent
                                    8-96

-------
                           UNSATU3A7ED ZONE MONITORING
Has Che applicant identified, schematically, soil-pore          	     	
liquid and soil core sampling locations and depchs?              Yes       No

Has the applicant provided a rationale and statistical          	     	
assessment for sampling locations?                               Yes       No

Are sampling frequencies, caking into consideration             	     	
site operating conditions and climatic factors, seated?          Yes       No

Has che applicant described the equipment to be used to         	
take soil-pore liquid and soil core samples?                     Yes       No

Are the procedures for installing soil-pore liquid              	     	
monitoring devices described?                                    Yes       No

Has the applicant described how soil samples will be            	     	
taken, including sample collection, preparation,                 Yes       No
preservation, and transport?

Are analytical procedures specified?                            	     	
                                                                 Yes       No

Are the chain-of-custody procedures specified?                  	     	
                                                                 Yes       No

Has the applicant described how soit core and soil-pore         	     	
liquid background values will be determined?                     Yes       No

Are statistical methods to be used to determine whether         	     	
significant increases in hazardous constituent concen-           Yes       No
trations occur described?

Has the applicant identified the time period following          	     	
sampling to determine whether a significant increase             Yes       No
in constituent concentration has occurred?

Has the applicant identified the hazardous constituents         	~__     	
to be monitored?                                                 Yes       No

If the applicant has elected to monitor only principal          	     	
hazardous constituents (PHCs), has he or she provided            Yes       No
a satisfactory explanation for doing so?
      Figure  3.2.6.   Worksheet for evaluating applicant's unsaturated zone
                     monitoring plan.
                                      8-97

-------
possible, Che soils of Che control plocs monitored should be siraiiar Co c
of the unsaturaced layer immediately below the subject treatment zone.  In
addition, samples obtained to determine background levels and unsaturated zone
concentrations should be taken at similar soil depths.

     For new facilities, background levels can be determined by sampling the
unsaturaced zone prior to any waste application.  Unsaturated zone monitoring
involves taking and analyzing soil-core and soil-pore liquid samples for the
presence of hazardous constituents contained in or derived from the waste
applied.  These two samples are taken to complement one another.  Analysis of
soil-core samples will provide information on the movement of slow migrating
constituents while soil-pore liquid results will provide complementary data on
the movement of the -tor3 mobile hazardous constituents.

     Soil core and soil-pore liquid sampling should be random within a given
uniform area.  A uniform area generally refers to an area of the active
portion of a land treatment unit that is composed of soils of a similar soil
series (including similar "A" horizons) and to which similar wastes or waste
mixtures are applied at similar rates.

     The HWLT manual (.Section 9) and RCRA Guidance Document for Land
Treatment1^ provide informative discussions on unsaturated zone monitoring.
Table 8.2.12 presents a matrix indentifying recommended soil core and
soil-pore liquid sample locations, frequencies,  depths, and numoers.  The
concepts of sample compositing and uniform area sampling are proposed by EPA
as an attempt to minimize sampling and analytical costs and to assure
statistically reliable results.

     The frequency of soil core and soil-pore liquid sampling should be based
on waste application rates and frequency, soil permeability, and amount and
frequency of precipitation.  Sample preservation and shipment, and hazardous
constituent (or Principal Hazardous Constituents, PHCs) analysis should be
performed in accordance with the procedures included in Test Methods for
Evaluating Solid Waste.12  por eacn soil series or uniform area, as
applicable, an arithmetic mean and variance for each hazardous constituent (or
PHC) should be determined by pooling all composite measurements.

     As previously stated, one of the purposes for monitoring the unsaturated
layer beneath the treatment zone is to be able to detect pollution migration.
Hazardous constituent migration out of the treatment zone may result from
improper design or operating practices that can be altered to impede or halt
additional or continued pollutant movement.  Table 8.2.13 presents, as
examples, a couple of different scenarios where constituent increases were
recorded and what possible adjustments can be made.  Section 9 of the HWLT
manual identifies the following modifications to unit operations that should
be considered to maximize treatment within the treatment zone:

     1.   alter the waste characteristics;

     2.   reduce waste application rate;

     3.   alter the method or timing of waste applications;
                                     8-98

-------
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                                           8-99

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8-100

-------
     4.   cease application of one or more particular wasce(s) at the unit;

     5.   revise cultivation or management practices; and/or

     6.   alter the characteristics of the treatment zone, particularly soil
          pH or organic matter content.

1C is recommended that responses to detection of pollutant movement below the
treatment zone be discussed during preapplication conferences.

8.2.3.7  Treatment Zone Description—
     The treatment zone refers to a defined layer of surface and subsurface
soils used to degrade, transform, or iamobiiiia hazardous constituents
contained in or derived from the waste applied or the leachate passing through
the zone.

     Although the original treatment zone design will be made by the owner or
operator, the reviewing authority will specify the vertical and horizontal
dimensions of the treatment zone in the facility permit.  The depth of the
treatment zone must be:

     •    No more than 1.5 meters (5 feet) from the initial soil surface, and

     •    More than 1 meter (3 feet) above the seasonal high water table.

     Data sources available to evaluate whether these conditions are met are
identified below.

     Soils                    •    United States Department of Agriculture
                                   (USDA), Soil Conservation Service (SCS),
                                   Local Extension Service
                              •    United States Geological Survey (USGS)
                                   reports
                              •    Geology or Agriculture department of Local
                                   university or college

     Bedrock                  •    USGS reports
                              •    State Geological Survey reports
                              •    Professional geologists in the area
                              •    Geology department of local university or
                                   college

     Ground water                  USGS water supply papers
                                   State or regional water quality agencies
                                   USDA, SCS
                                   State or Federal water resources agencies
                                   Local health department

     Section 8.2.2.7 identified specific items that the applicant should
include in the permit application.   Sections 3 and 4 of the HWLT manual
provide explanation of each item and,  in some cases, typical ranges of
values.  Soil survey (Part 1) and series description (Part 2) information (see
                                     8-101

-------
Section 8.2.2.7) to be included in the application nay je JDtained from JSDA
Soil Conservation Service County Soil Surveys.  For soils that have not been
surveyed, the permit writer should contact a soil scientist of the regional
Soil Conservation Service office to obtain assistance in evaluating
information submitted by the applicant.  The following provides an explanation
of the treatment zone soil characteristics (Part 2) to be included in the
applicant's description of the treatment zone.  Table 8.2.14 presents, as an
example, relevant soil characteristics of five soils found Li Connecticut.
The information provided in the table is presented as it typically appears in
SCS County Soil Survey reports.

Profile Description

     Horizonation—Horizonation refers to the sequence of soil layers of the
soil profile.  Soils are characterized by the sequence and composition of
their soil horizons.  Specific properties that need to be described include
depth of each horizon and changes in textural properties.  In general, soils
have horizons of contrasting properties within the upper 1.5 to 1.8 metars
(5 or 6 feet).  The application should include a description of the depth to
the upper and lower boundaries of *a.ch horizon and aoce changes in textural
properties.  Textural properties of each horizon should be evaluated for their
suitability as the treatment medium (see Table 3.1.14 of Section 8.1.3).

Relief

     The slope gradient, aspect, and elevation of each craacaent plot should
be submitted in the application.  These characteristics influence surface
drainage of the unit.

Climatic Data

     Monthly temperature and precipitation data should be submitted with the
permit application.  These are the two most important climatic factors
affecting the treatment zone soil.  Ambient air temperature will influence the
extent and rate of hazardous constituent degradation, plants growing season,
and extent of frost action.  Precipitation will ar'fecc aerobic soil
conditions, the rate soluble chemicals are leached from the soil, and the
amount of surface water run-on and run-off.  Tables 8.2.15, 8.2.16, and 8.2.17
provide examples of temperature and precipitation data supplied by the SCS
Soil Survey reports.  This information should be used to help determine
application methods and frequencies, plant species selection, and design site
run-on and run-off control systems.

Mineralogy

     Soil mineralogy is closely aligned with soil texture.  Figure 8.2.7,
adopted from Brady,? presents the general relationship between particle size
and kinds of minerals present.  Quartz dominates the sand and coarse silt
fractions.  Primary silicates such as the feldspars, hornblende, and micas are
present in the sands but tend to disappear as one moves to the silt fraction.
                                     8-102

-------

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-------
           TABLE  8.2.16.   FREEZE  DATES  IN  SPRING  AND  FALL3
    Probability
                                     Temperature*3
 or lower
or lower
  32°F
or lower
Last freezing
  temperature
  in spring:

    1 year in 10
     later than—

    2 years in 10
     later Chan—

    5 years in 10
     later than—
   April  8     April 19         May 12
   April  4     April 15         May  5
   March 23     April  6       April 22
First freezing
  temperature
  in fall:

    1 year in 10
     earlier than-

    2 years in 10
     earlier than-

    5 years in 10
     earlier than-
 October 31   October 10   September 27
November  6   October 16     October  3
November 17   October 28     October 15
aSource:  Soil Survey of Middlesex County Connecticut, U.S.D.A.,
 Soil Conservation Service, L979.

bR«corded in the period 1951-73 at Middletown,  CT.
                               8-105

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        TABLE 8.2.17.  GROWING SEASON LENGTH3
Dailv minimum taraoeracura



Probability

9 years in 10
8 years in 10
5 years in 10
2 years in 10
1 year in 10
during
Higher
than
24°F
Da_ys_
212
219
233
247
255
growing
Higher
than
28°F
Jays
133
190
204
218
225
season'3
Higher
than
32°F
Days
147
156
1/4
192
202
aSource:  Soil Survey of Middlesex County Connec™
 cicut, U.S.D.A. ,  Soil Conservation Service,  1979.

bRecjrded in che period 1951-73 at Middlecown,  CT.
                        8-106

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                                           Secondary jiiicat«
                                               nin«rals
           SAND
                              SILT
                                                 CLAY
Figure 8.2.7.
General relationship between soil  particle  size
and minerals content.
                              8-107

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Secondary silicates dominate the fine colloidal, ciay.  Other secondary
minerals, such as Che oxides of iron and aluminum, are prominent in cne fine
silt and coarse clay fractions.

     Land Use and Vegetation—Soil Surveys describe soils with respect to land
use and suitability for crop cultivation.  The more important factor of the
two to evaluate is the suitability of soils to support vegetation.   In
addition to existing Soil Survey report3, local offices of the Soil
Conservation Service and the Cooperative Extension Service can be contacted to
provide information about vegetative management concerns, growing season
length, and productivity of the soils under review.

     Texture
     Soil texture refers to the percentages of sand, silt, and clay in the
soil material that are less than 2 millimeters in diameter.  If a soil
contains gravel or other particles coarser than sand, a modifier, for example
gravelly loara, is added.  Table 8.2.18 lists USDA soil texture
classifications.  Soil texture can be determined by laborato— T means or jimply
by touch for the experienced soil scientist.  Guidance for aetarraining the
suitability of various soil textures as the treatment medium is presented in
Table 8.1.14 (see Section 3.1.3).

Atterburg Limits

     Atterburg limits refer to the effsct or water on soil strength and
consistency.  Three states of consistency are defined based on the water
content of the soil.  The terra consistency refers to the degree of firmness
(e.g., soft, medium, firm).  The three states are the shrinkage limit, plastic
limit, and liquid limit.  These three limits correspond to the transition
points that occur when the water content of the soil increases such that the
soil passes from a solid state to a semisolid state, to a plastic state, and
finally to a liquid state.  Figure 8.2.8 graphically displays the Atterburg
limits.  Atterburg limits are determined in the laboratory using standard test
methods, such as ASTM D-423, D-424, and 0-427 for the liquid, plastic, and
shrinkage limits, respectively.

Permeability

     Permeability refers to the rate at which a liquid penetrates or passes
through a bulk mass or layer of soil.  Permeability should be determined to
provide an indication of the length of time mobile constituents applied to the
treatment zone will reside in the soil.  The treatment zone soil should be
permeable' enough Co minimize surface run-off but not so permeable that the
waste constituents percolate through the soil before adequate treatment.
Table 8.1.14 (s«e Section 8.1.3) describes the suitability of various textured
soils for land treatment of hazardous industrial wastes.  The information
presented should only be used as a preliminary step to determine waste
application suitability.  A more detailed analysis of soil permeability of the
proposed unit is recommended.  EPA's RCRA Land Treatment Guidance Document^
suggests that the treatment zone contain soils having one or more of the
following textures (USDA classification scheme):  loam, silt loam, sandy clay
                                    3-108

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TABLE 8.2.18.   UNITED STATES DEPARTMENT OF AOUCULATURE
               (USDA) SOIL TEXTURES
   1.   Gravel,  very gravelly loamy sand

   2.   Sand,  coarse sand,  fine sand

   3.   Loamy  gravel,  very  gravelly sandy loam,
       very gravelly loam

       Loamy  jana,  graveliy loamy sand, very
       fine sand

   5.   Gravelly loam,  gravelly sandy clay loam

   6.   Sandy  loam,  fine sandy loam, loamy very
     •  fine sand,  gravelly jandy loam

   7.   Silc loam,  very fine sandy clay loam

   3.   Loam,  sandy clay loam

   9.   Silcy  clay  loam,  clay loam

  iO.   Sandy  clay,  gravelly clay loam, gravelly
       clay

  11.   Very gravelly clay  loam,  very gravelly
       sandy  clay  loam,  very gravelly silty
       clay loam,  very gravelly silty clay and clay

  12.   Silcy  clay,  clay

  13.   Muck and oeaC
                          8-109

-------
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     LIQUID  «TiTZ
PLASTIC  STATE
SEMISOLiO  STATE
     SOLID  STATE
                      LIQUID LIMIT
                       PLASTIC LIMIT
                            SHRINKAGE  LIMIT
         Figure 8.2.8.  Atterberg limits.  (16)
                       8-110

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 loam,  sandy  loam,  silty  clay  loam, or  clay  loam.   Three  soil  textural classes
 inCo or  onco which hazardous  wasts(s)  should noc  be  applied are  sands, clays,
 and silts.   Sandy  soils  have  rapid infiltration and  percolation  potentials
 that could easily  lead to  ground water contamination.  Conversely,  clay  soils
 have extremely  alow infiltration rates.  This condition  would  increase the
 likelihood of surface water contamination due to  water and wind  erosion.
 Silty  soils,  which upon  drying have a  severe surface crusting  problem, would
 have similar surface erosion  concerns.

     Because wide  variations  in permeability are  common  even  in  a small  area,
 several  soil  samples and infiltration  and permeability tests  should be
 conducted to characterize  the treatment zone.  Section 4.1.1.5 of the HWLT
 manual describes methods for  determining soil oeraeability.   Nots chat
 penaeaoility shouia be aecermined for  each  soil horizon.

 Available Water Capacity

     This is  a  characteristic of the soil relating to its ability to hold
 water  and make  it  available to plants.  Available water  holding  capacity is a
 measure  of the  amount of water held in the  soil against  the pull of gravity.
 Section  3.4.3 of the HWLT  manual describes  differences in water  holding
 capacities and  their impact on the function of the treatment zone.  In
 general, the higher the water holding capacity, the lower the  likelihood of
 constituent  leaching.

 Soil pH

     Soil pH, which is the degree oŁ acidity or alkalinity of a  soil, has been
 discussed in Section 8.2.2.3.  Table 8.2.19 presents a general guide for
 interpreting soil  pH test  results as  they pertain to the viability of soil
microbes and plants.

Salinity

     Salinity generally refers to the electrical conductivity (EC) of a soil.
It is a measure of  a soil  solution salt content.  Section 4.1.2.6 of ".he HWL.T
manual discusses the importance of determining soil salinity and describes
test methods.  Table 3.2.19 provides  guidance on interpreting EC results as
they relate to establishing a vegetative cover during the active years or at
closure.

Shrink-Swell Potential

     This soil characteristic is influenced by the amount and kind of clay in
the soil.  Soils with a high shrink-swell potential can  increase constituent
leaching due to the formation of deep cracks in the soil during extended
periods of dry weather.   Obviously,  soils with low shrink-swell potentials are
preferred for hazardous waste land treatment.  The measurement of shrink-swell
potential can be made in the laboratory using undisturbed bulk samples or
estimated by soil scientists based on the kind and amount of clay in the soil
and extrapolation of tests  performed  on similar soils.
                                    8-111

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             TABLE 8.2.19.   INTERPRETATION OF SOIL CHEMICAL TESTS17
        Test Result
                 Interpretation
pH of saturated soil paste

    <4.2


    4.2-5.5


    5.5-8.4

    >8.4
Too acid for 20
Sandy soils (limited adsorption)

Silt loam (moderate adsorption)

Clay and organic soils (high adsorption)
Electrical Conductivity
(EC), mrahos/cm at 25°C
of saturation extract

     2

    2-4

    4-8

    8-16
No salinity problems

Restricts growth of very salt-sensitive crops

Restricts growth of many crops

Restricts growth of all but salt-tolerant crops

Only a few very salt-tolerant crops make
  satisfactory yields
                                     8-112

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 arosion  Factors

     Soil  losses due to erosion should be evaluated Co assess the pocancial
 for hazardous constituent release from Che sica.  Section 8.3.3.2 describes
 the Universal Soil Loss Equation technique for determining soil losses per
 unit area of land.

 Flood Potential

     The proposed site should be evaluated to assess the likelihood of
 flooding.  Soil surveys conducted by the Soil Conservation Service will
 identify flood-prone areas.  Flooding is rated in general terms Chat describe
 the frequency and duration of flooding and Che *:irne of /*»ar such flooding is
 3osc likely.  Taoie 8.2.14 presents an example of this site characteristic for
 some soils found in Connecticut.

 Water Table Depth

     In general, water cables are deeper in arid regions Chan humid regions.
 Water Cable depths also tend to follow surface topography; deeper beneath
 interstream areas and shallower :'.n lowlands. 3  rn addition, the water Cable
 generally coincides wich Che surface of perennial streams.  Furthermore, water
 cables are usually shallower in relatively impermeable soils (e.g., clays)
 Chan in relatively permeable soils (e.g., coarse sand).8

     The applicant should identify for Che treatment zone, Che depth to
 seasonally high water table.  The Soil Conservation Service defines high water
 Caole as Che highest level of a saturated zone more than 15 centimeters
 (6 inches) thick for a continuous period of more Chan 2 weeks during mosc
 years.  Estimates of depth to seasonally high water cable are based mainly Che
 relationship between grayish colors or mottles in che soil horizon and che
 depth to free water observed.  Information on depth to seasonal high water
 table may be obtained from regional offices of the Soil Conservation Service,
 U.S. Geological Survey, Water Resources Branch of U.S. Department of the
 Interior.

 Frost Action Potential

     The Soil Conservation Service states Chat the freezing and thawing action
accompanying frost affects soil structure and increases aggregate formation.
 The resultant increase in particle size increases the rate of water movement
 through the soils of the frost zone thereby increasing che likelihood of
 soluble chemical leaching.  Frost action potentials are typically provided in
 SCS County Soil Survey reports (see Table 8.2.14 as an example).

 8.2.4  Draft Permit Preparation

     Condition A of the Land Treatment Permit Module XIV contains chree
components.  The three parts, (1) list of wastes to be treated, (2) treatment
 zone operating conditions, and (3) treatment zone design can be stipulated by
 reference to segments of che applicant's submittal.  The first component of
                                    8-113

-------
Condition A requires chat Che permit: -ontain ;he j.ist of vasces Co be treated
chat have been demonstrated under §264.272 as being completely degraded,
transfortaed, or immobilized in the treatment zone.

     Part 2 of Condition A stipulates that the permit must specify the
following, which can be incorporated into the draft permit by reference to
that applicable part of the application:

     •    rata and method of waste application

     •    measures to control soil pH

     »    procedures Co enhance microbial or chemical reactions

     •    measures to control moisture content

     Part 3 of Condition A requires that the permit specify the vertical and
horizontal dimensions of the treatment zone.

     The three parts of Condition A of Permit Module XIV are as follows:

     1.   The Permittee shall establish a treatment program for the wastes
          listed in Table XIV-1 as required by 40 CFR 264.271(a).  The
          treatment program rausC include the design measures and operating
          practices specified in condition XIV.8 and the unsaturaced zone
          monitoring provisions specified in XIV.E.  The treatment program
          must be capaoie of degrading, transforming, or immobilizing the
          hazardous constituents listed in Attachment 	.

     2.   The Permittee shall design, construct, operate, and maintain the
          treatment unit in accordance with the requirements of 40 CFR
          264.273(a), as specified in the attached plans and specifications.

     3.   The Permittee shall construct the treatment zone as specified in
          Attachment 	.

     In addition to specifying the provisions of Condition A of Module XIV,
the permit writer must also stipulate unsaturated zone monitoring conditions
(see Condition D of Module XIV, as presented in Section 4).  These conditions
outlined below, may be incorporated into the permit by reference to applicable
parts of the Pare B permit application submittal.

     1.   The Permittee shall establish an unsaturated zone monitoring program
          for Che hazardous constituents listed in Attachment 	, as required
          by 40 CFR 264.273.

     [Note:   Unless the Regional Administrator requires monitoring for
     principal hazardous constituents (PHCs) in accordance with the provisions
     of §264.278(a)(2), this list of hazardous constituents should be the same
     as the  one specified in condition A of Permit Module XIV.7.]
                                     8-114

-------
2.   The Permittee shall install an unsaturaeed zone monitoring system as
     required by 40 CFR 264.278(b); as specified in the attached plans
     and specifications.

[Note:  The attached plans and specifications should demonstrate
compliance with the requirements of §264.278(b).  At a minimum, these
plans should contain the information required by §270.20(b)(3) including
sampling equipment, procedures, and frequency, and procedures for
selecting sampling locations.]

3.   The Permittee shall establish a background value for each hazardous
     constituent to be monitored Mnder Condition XIV.C.I as required oy
     40 CFR 264.278U), as specified in Attachment 	.

[Note:  The Attachment should demonstrate how the Permittee will comply
with the requirements of §264.278(c).]

4.   The Permittee shall conduct soil monitoring and soil-pore liquid
    'monitoring as required oy 40 CFR 264.278(d), as specified in
     Attachment 	.

[Note:  The Attachment should demonstrate how the Permittee will comply
with the requirements of §264.278(d).  The permit should specify the
frequency and timing of this monitoring in accordance with the conditions
outlined in §264.278(d).]

5.   The Permittee shall follow the sampling and analysis procedures
     specified in Attachment 	 as required by 40 CFR 264.273(c).

(Note:  This Attachment should demonstrate compliance with §264.278(e).]

6.   The Permittee shall determine whether there is a statistically
     significant change over background values for any hazardous
     constituent to be monitored under Condition XIV.E.I aach time the
     monitoring required by Condition XIV.E.4 is conducted, as required
     by 40 CFR 264.278(f).   This determination shall be made using the
     statistical procedures outlined in Attachment

[Note:  This Attachment should demonstrate compliance with the
requirements of 40 CFR 264.278(f).  The permit writer should specify the
time period for making the determination in accordance with
$264.278(f)(2).]

7.   If the Permittee determines, pursuant to Condition XIV.E.6, that
     there is a statistically significant increase of hazardous
     constituents below the treatment zone, he shall notify the Regional
     Administrator of this finding and apply for a permit modification in
     accordance with the provisions of 40 CFR 264.278(g).
                               8-115

-------
other than che regulated an 11^^^ <*« * source
increase resulted from an error in samnH         °T ChaC Che
« specified by 40 CFR 264.278(h)     mpUng'  analy^s,  or evaluation
                      8-U6

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8.2.5  Re ferences

 I.  U.S. Environmental Protection Agency.  Permit Applicants' Guidance Manual
     for Hazardous Waste Land Storage, Treatment, and Disposal Facilities.
     Draft Report.  Office of Solid Waste, Land Disposal 3ranch.  Washington,
     D.C.  March 1983.

 2.  U.S. Environmental Protection Agency.  Hazardous Waste Lana Treatment,
     prepared by K. W.  Brown and Associates,  Inc., for U.S. Environmental
     Protection Agency, Municipal Environmental Research Laboratory, Solid and
     Hazardous Waste Research Division, Cincinnati, OH.  Report No. SW-374.
     1983.

 3.  Black, C. A., ed.   Methods of Soil Analysis, Parts 1 and 2, The American
     Society of Agronomy, Inc., Madison, Wisconsin.  1965.

 4.  Whiting, D. M.  Use of Climatic Data in Estimating Storage Days for soil
     Treatment Systems.  Environmental Protection Agency, Office of Researcn
     and Development.  EPA-IAG-D5-F694.  1976.

 5.  Huddleston, R. L.   Solid Waste Disposal:  Landfarming.   Chemical
     Engineering, February 25, 1979.  pp. 119-124.

 6.  Landfarming Fills  an HPI Need.  Hydrocarbon Processing,  June  1980.
     pp. 97-103.

 7,  Brady, N. C.  The  Nature and Properties of Soils.  8th Ed.  MacMillan
     Publishing Company, Inc.  Mew York, NY.  1974.

 3.  Phung, T. , et al.   Land Cultivation of Industrial Wastes and  Municipal
     Solid Wastes:  State-of-the-Art Study.  Volume I, Technical Summary and
     Literature Review.  Prepared by SCS Engineers for U.S. Environmental
     Protection Agency, Municipal Environmental Research Laboratory,
     Cincinnati, OH.  EPA-600/2-78-140a.  August 1978.

 9.  Page, A. L.  Fate  and Effects of Trace Elements in Sewage Sludge When
     Applied to Agricultural Lands.  A Literature Review Study.
     EPA-670/2-74-005.   U.S. Environmental Protection Agency.  January  1974.

10.  Dowdy, R. H., and  W. E. Larson.  The Availability of Sludge-borne  Metals
     to Various Vegetable Crops.  J-. of Env. Quality, 4: 278-282.   1975.

11.  Chan«y, R. L., P.  T. Hundemann, W. T. Palmer, R. J. Small, M.  C. White,
     and A. M. Decker.   Plant Accumulation of Heavy Metals and Phytotoxicity
     Resulting from Utilization of Sewage Sludge and Sludge Composts on
     Cropland, pp. 86-97.  In:  Proc. Nat'l Conf., Composting Municipal
     Residues and Sludges.  Information Transfer Inc., Rockville,  MD.   1978.

12.  U.S. Environmental Protection Agency.  Test Methods for  Evaluating Solid
     Waste, Physical/Chemical Methods.  U.S. Environmental Protection Agency,
     .Office of Solid Waste.  Report No. SW-846.  July 1982.
                                    8-117

-------
13.   Kirby, G. N.  Corrosion Performance of Carbon Steel.  Chemical
     Engineering, March 12, 1979.

14.   Farino, W. J. and C.  W. Young.  Suitable Methods for Drum Disposal at
     Hazardous Waste Landfills, prepared by GCA/Technology Division for Office
     of Solid Waste, Hazardous Waste Management Division.  January 1933.

15.   U.S. Environmental Protection Agency.  RCRA Guidance Document Land
     Treatment, Draft: Report.  Office of Solid Waste, Washington, DC.  January
     1983.

16.   Cernica, J. N.  Geotechnical Engineering-  CBS Collie ?uoiisning.   1932.

17.   U.S. Environmental Protection Agency.  Process Design Manual for  Land
     Treatment of Municipal Wastewater.  EPA-625/1-77-008.  October  1977.
                                     8-118

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 3.3  DESIGN AND OPERATING REQUIREMENTS

 8.3.1  Federal Requirement:

      Section 270.20(c)  requires  the  applicant  Co  provide:

                "(c)   A  description of  how the  unit  is  or will  be  designed,
           constructed,  operated,  and maintained in  order to  meet  the
           requirements  of 5254.273.  This  suomission muse  address  the
           following  items:
                (1)   Control  of run-on;
                (2)   Collection and control of  run-off;
                (3)   Minimisation  oŁ  run-off  of hazardous constituents  from  the
           treatment  zone;
                (4)   Management of collection and holding facilities associated
           with run-on and  run-off control systems;
                (5)   Periodic  inspection of the unit.   This information should
           be  included in  the  inspection plan submitted under §270.14(b)(5);
                (6)   Control of wind  dispersal  of particulate matter, if
           applicable."

      The corresponding  Part 264 standards, which are contained in  §264.273(b)
 through (g),  stipulate  that:

                "(b)  The  owner or operator must design, construct, operate,
           and  maintain  the treatment zone to minimize  run-off of hazardous
           constituents  during the active  life  of the land  treatment unit.'
                (c)   "he owner or operator must design, construct,  operate,  and
           maintain a run-on control  system capable  of  preventing  flow onto  the
           treatment zone during peak discharge from at least a 25-year storm.
                (d)  The owner or operator must design, construct,  operate, and
           maintain a run-off management system to collect and control at lease
           the  water volume resulting from a 24-hour, 25-year storm.
                (e)  Collection and holding facilities  (e.g., tanks or basins)
           associated with run-on and run-off control systems must  be emptied
           or otherwise managed expeditiously after storms  ;o nsaintain che
           design capacity of the system.
                (f)  If the treatment zone contains particulate matter which
           may  be subject to wind dispersal, the owner or operator must manage
           the  unit to control wind dispersal.
                (g)  The owner or operator must inspect the  unit weekly and
           after storms to detect  evidence of:
                (1)  Deterioration, malfunctions,  or improper operation of
           run-on and run-off control  systems; and
                (2)  Improper functioning of wind dispersal  control measures."

8.3.2  Summary of Necessary Application Information

8.3.2.1  Surface Water Control Plans—
     A scale drawing of  the land  treatment unit depicting the location of
surface water and/or soil erosion control structures that will be used to
control run-on and run-off should be  included in the permit application.
                                    8-119

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Equipment design  features and specifications should be submitted along witn
calculations  for  sizing lurface *racer control structures based on specified
(see §264.273(c)  and (d)) storm frequency, duration, and intensity.

8.3.2.2  Minimizing Run-off of Hazardous Constituents—
     Specific measures to minimize the concentration of hazardous constituents
in surface water  run-off from the treatment zone should be identified in
permit application.

8.3.2.3  Management of Accumulated Run-off and Run-on—
     The applicant snould submit a monthly tabulation of run-off and run-on
storage requirements and a concise explanation of how the collected liquid
will be managed for disoosal.  Mota that "ha applicant must determine whether
:he collected iiquid is a hazardous waste or not according Co the criteria of
Part 261.

8.3.2.4  Control  of Wind Dispersal—
     A wind erosion control plan designed to minimize the wind dispersal of
soil, soil-waste  mixture, or waste particulate matter must be included in the
application.

8.3.2.5.  Inspection of Land Treatment Unit—
     The applicant should submit a schedule for periodic inspections of the
land treatment unit to determine the adequacy of surface watar control and
wind erosion control measures.  The name or title of the person(s) responsible
for conducting inspections, a list of items to be inspected, procedures for
responding to observed inadequacies, and records for inspection results should
also be included  in the application.

8.3.3  Guidance on evaluating Application Information

     To satisfy the facility design, construction,  operation, and maintenance
requirements, the applicant must provide a description of the following:

     •    Surface water control plans, addressing:

               "aciiicy surface run-on control system

               Facility surface run-off control and collection systems

     •    Minimizing run-off of hazardous constituents

     •    Management of accumulated run-off (and run-on)

     •    Control of wind dispersal

     •    Inspection of land treatment unit

     Where applicable, facility design and operating parameters should be
based on the results of the treatment demonstration.  Examples would include
surface water run-on and run-off experiences gained from field studies or
                                     8-120

-------
 existing units;  effectiveness of wind dispersal controls impieraencea during
 field tests or at existing units;  and procedures tested under field studies co
 minimize run-off hazardous constituents.

 8.3.3.1  Surface Water Control Plans —
      Because of their interrelationship,  evaluation of run-on and run-off
 control systems  are discussed together.   Water is  the  primary conduit for
 hazardous constituent release from the treatment zona.  Therefore,  the design
 and operation ,of surface  water control systems are  essential  in limiting
 ground water or nearby surface water  contamination.

      The land treatment unit  must  be  designed  to prevent run-on of  surface
 water during periods of intense rainfall.   The primary purpose for  controlling
 run-on is to prevent-excess water  from entering the  treatment zone.   Excess
 water,  resulting in soil  saturation,  will  create anaerobic  conditions that  will
 reduce  microbiai degradation,  hinder  waste application and  tilling  operations,
 and increase the likelihood of hazardous  constituent leaching from  the unit.

      Just as important as  controlling run-on,  the land treatment  unit must  be
 designed and operated to  control  run-off.   Uncontrolled run-off released from
 the site can,  if it contains  unacceptaole  levels of hazardous constituents,
 result  in contamination of nearby  soils and  surface waters.   The  RCRA Land
 Treatment Guidance  document^  and Chapter  8 of  the HWLT manual provide
 guidance on  the  design, operation, and maintenance of  run-on  and  run-off
 control  systems  for hazardous  waste land  treatment units.

      As  required under Part 264, the  land  treatment facility  operator or owner
 must  design,  construct, operate, and  maintain  a  run-on control system capable
 of  preventing  flow  onto the treatment  zone during peak discharge  from at  least
 a 25-year storm.  The  amount of run-on, and  also run-off, expected as  a  result
 of  precipitation will  depend on:

      •     soil cover (vegetated or nonvegetated),

      •    watershed  surface slope,

      •     soil permeability,

      •    antecedent  soil  moisture content,  and

      •    seasonal  temperatures (e.g., soil  freezing).

 The relationship  between run-on or run-off and these factors'  are  covered  in
 the HWLT manual  and  introductory hydrology text books.3,4

      Surfac* run-on can be effectively controlled by contour  grading
 surrounding  land  to divert surface overland  flow away  from the  treatment  zone.
 Diversion oŁ potential surface run-on will reduce excess infiltration  through
 the treatment zone, thus minimizing leaching during periods of  precipitation.

     Surface run-on diversion involves creating earth benns and excavating
diversion ditches along the upslope side of the treatment zone  that direct
 flow toward natural drainageways downs lope from the unit.  Diversion ditches
must be designed  to accommodate the characteristics of  the contributing
                                     8-121

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watershed such as area, annual  rainfall,  land use, soil  type, and  topography.
Aa required, they muse be designed to handle the 25-year storm  intensity.
Determination of peak discharge should be determined on a unit-specific basis,
taking  into consideration local rainfall  intensity and the size and terrain of
surrounding watershed.  The amount of rainfall expected  from a  local or
regional 25-year storm event can be obtained from the National  Oceanic and
Atmospheric Administration or local Agricultural Extension Service.

     The permit writer's worksheet for assessing the adequacy of the
applicant's determination of storm magnitude is present in Figure 8.3.1.

     Two methods commonly used  to calculate the volume of run-on or run-off
during  and after rainfall are the "rational method" and the Soil Conservation
Service (SC.S) method.

The Rational Method

     The rational method calculates peak  run-off based on the following
expression:

                                     Q » cia

where   Q a peak run-off rate in cubic feet per second (CFS)

        c * run-off coefficient which  is actually the ratio of the  peak run-off
           rate to the average  rainfall rate for a period known as the time of
           concentration

        i =» average rainiaj.1 intensity in  inches per hour for a  period equal to
           the time of concentration

        a = drainage area in acres

Use of  the rational method for determination of design run-on quantity is
appropriate since the Part 264  regulations require control of the  peak
discharge rata.  Q, as calculated using the rational method, is defined as the
peak discharge rate associated with the selected storm event.

     The rational method formula is based on the following assumptions:3

     (1)  the maximum run-off rate is a function of the average rate of
          rainfall during the time of concentration,

     (2)  the maximum rate of rainfall occurs during the time of
          concentration, and

     (3)  the variability of the storm pattern is not taken into consideration.

     The time of concentration  (tc) is defined as the flow time from the
most remote point in the drainage area to the point in question.   The  time of
concentration is calculated as  follows:
                                     8-122

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I	
Determination  of Magnitude of the
25-year Storm  Event
   -   Has  this part of the applicant's submittal been  read
      and  evaluated?                                            	   	
                                                                 Yes      No

   -   What storm magnitude was selected by  the applicant?       	
   -  What depth of rainfall is  this storm event
     equivalent Co?                                            	 inches
        based on what references?
    I                   I
   H  Independent Check j
  u  What is the local rainfall depth associated with  the
     25-year storm?                                            	 inches

        baaed on what reference?
      Is  the rainfall depth established by  the applicant
      at  least as great as this determination?                  	  	
                                                                 Yes      No

      Then, likewise, this aspect of  the applicant's
      submittal is or is not acceptable            	    	
                                                   is  acceptable      is  not
                                                                   acceptable
       Figure 8.3.1.  Worksheet for determination of the magnitude of the
                      25-year storm event.

                                       8-123

-------
                                        41b  I/' "
                                            0
Where   cc  »  cima  of  concentration  in minutes

        b  •  coefficient

        Lo  a  overland flow  length in feet

        c  a  run-off  coefficient (see Table 8.3.1)

        i  *  rainfall intensity in  inches  per hour during  :ime  -• f  concentration

The equation is valid only  for laminar  flow conditions where the  product  iL0
is less than 500.  The coefficient b is found as follows:

                                 0.0007i  •*• G                                 , „,.
                            b  . 	Ł
                                          sl/3
                                          o

whera   3O  a  surface  s Lope

        Cr  =  a coefficient of retardance

Values of  Cr, are given in Table 8.3.2.

     The runoff coefficient (C) is influenced by a number of variables, such
as infiltration capacity, interception by vegetation, and depression
storage.3  As used in che rational aethod, the coefficient C represents a
fixed ratio  of run-off to rainfall, while in actuality it is not  fixed and may
vary for a specific  drainage basin with time during a particular  storm, from
storm to storm, and  with change in season.  Table 3.3.1 lists  some values of
the run-off  coefficient for various soils and surface covers.

     The rainfall intensity (i) is derived from the average intensitv  (in/hr)
of a storm for a  given frequency (25-year in this case) for the time of
concentracion.   Following determination of tc, the rainfall intensity  is
usually obtained  by  making use of a set of rainfall intensity-duration-
frequency curves  such as shown in Figure 3.3.2.  Drawing a line from the
abscissa at  the appropriate value of tc and then projecting upward to
intersect the desired frequency curve,  i can be found by projecting this
intersection point horizontally to intercept the ordinate.3  if an adequate
number of years of local rainfall records is available, curves similar to
Figure 8.3.2 may be  developed.  Otherwise, data compiled by the National
Oceanic and  Atmospheric Administration, the Department of Agriculture, or
other local government agencies can be used.

     A more  indepth  discussion of surface run-on and run-off computations
using the rational method is presented in References 3 and 4.
                                    8-124

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                  TABLE 3.3.L.   VALUES OF RUN-OFF COEFFICIENT^1
           Earth Surface
Cover
Mm.
                                                                         Max.
Sand, from uniform grain size,
no fines, to well graded, some
clay or silt
Loam, from sandy or gravelly ca
clayey

Gravel, from clean gravel and gravel
sand mixtures, no silt or clay Co
high clay or silt content
Clay, from coarse sandy or
silty to pure colloidal clays

Bare
Light
Dense
Bare
Light
Dense
Bare
Lignt
Dense
Bare
Light
Dense

Vegetation
Vegetation

Vegetation
Vegetation

Vegetation
Vegetation

Vegetation
Vegetation
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
1 n
10
05
20
10
05
25
15
10
30
20
15
n.
0.
0.
0.
0.
0.
0.
0.
J.
0.
0.
0.
50
40
30
60
45
35
65
50
-t-0
75
60
50
NOTE:  Values of C for earth surfaces are further varied by degree of satura-
       tion,  compaction,  surface irregularity and slope, by character of sub-
       soil,  and by presence of frost or glazed snow or ice.
                   TABLE  8.3.2.   RETARDANCE  COEFFICIENT  Cr  (3)

                     Surface                                 Cr

              Smooch asphalt 	  0.007
              Concrete paving	0.012
              Tar and gravel paving	0.017
              Closely clipped sod	  0.046
              Dense bluegrass turf	0.060
                                     8-125

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  10
•±  6

z
U!

z
z


a:
                         100 year FREQUENCY


                            50 year FREQUENCY

                             20 year  FREQUENCY


                               10 year  FREQUENCY


                                 5 year FREQUENCY
                                        I
                     I
              20
40         60       fO

    DURATION,minutes
100
120
        Figure 8.3.2.  Typical intensity-duration-frequency curves.3
                               8-126

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 The  SCS  Method
      The  SCS  run-off  equation  is  a. method  of  estimating  direct  run-off  from
 storm rainfall  of  a duration of 1 day or less.
      The  equation  is:
                                 x    (P  -  Ia)  + S

where   Q  * accumulated direct  run-off

        P  « accumulated rainfall (potential maximum  run-off)

        Ia » initial abstraction  including surface storage,  interception,
            and  infiltration prior to run-off

        S  * potential maximum retention

     To simplify uae of the -aquation, the following  empirical  relationship  is
ofcen used in the SCS run-off equation:

                                  I» -  0.2S                               (4)

     Substituting 0.2S for Ia,  the equation becomes :


                                q .  (p  ~ °'2S)2                              (5
                                q    P  + 0.8S                                ^5

and is the rainfall run-off equation used for estimating direct run-off from
storm rainfall.

     S values have been transformed into curve numbers (CN) to allow for
graphical solution of run-off.  Figure  3.3.3, reprinted from Reference 6
(USDA, Soil Conservation Service, 1973), provides ihe graphical solution using
the curve number method.  Research has  been conducted to correlate curve
numbers with various hydrologic soil cover complexes, as illustrated in
Table 3.3.3,  also reprinted from Reference 6.  The information in the table  is
useful in determining run-off from a vegetated unit or closed facility, but
not from an unvegeCated active land treatment unit.  In that case, an estimate
of S is necessary to determine the appropriate curve number, from the equation:

                                  rv    100°
                                  CN
                                       S * 10                                  >

     The Part 264 regulations for run-on control require that the system be
"capable of preventing flow onto the active portion of the landfill during
peak discharge from at least a 25-year storm."  The SCS has developed the
following equation to estimate peak discharge:

                                 qp - (KAQ)/Tp                               (7)
                                    8-127

-------
I* <•
II
2 2

OO

0.0
OJOO

QO
: *
O.O.
Z
O
O
ui

u.
u.
O
Z


-------
Land use and treatment
or practice
Fallow
Straight row
Row crops
Straight row
Straight row
Contoured
Contoured
Contoured and terraced
Contoured and terraced
Small grain
Straight row
Straight row
Contoured
Contoured
Contoured and terraced
Contoured and terraced
Close-seeded legumes or
rotation meadow
Straight -row
Straight row
Contoured
Contoured
Contoured and terraced
Contoured and terraced
Pasture or range
No mechanical treatment
No mechanical treatment
No mechanical treatment
Contoured
Contoured
Contoured
Meadow
Woods


Farmstead*
Roads4
Dirt
Hard surface
Hydrologic
condition

	

Poor
Good
Poor
Good
Poor
Good

Poor
Good
Poor
Good
Poor
Good


Poor
Good
Poor
Good
Poor
Good

Poor
Fair
Good
Poor
Fair
Good
Good
Poor
Fair
Good
	

	
~
Hydrologic
A

77

72
67
70
65
66
62

65
63
63
6L
61
59


56
53
64
55
63
51

68
49
39
47
25
6
30
45
36
25
59

72
74
B

86

31
78
79
75
74
71

76
75
74
73
72
70


77
72
75
69
73
67

79
69
61
67
59
35
53
66
60
55
74

82
84
soil group
C

91

88
85
84
82
80
78

84
83
82
81
79
78


85
81
83
78
80
76

86
79
74.
81
75
70
71
77
73
70
32

87
90
D

94

91
89
88
36
82
81

38
37
85
34
82
31


89
35
85
33
83
30

89
84
80
88
83
79
78
83
79
77
86

89
92
alncluding rights-of-way.
                                  8-129

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where  qg = peatc rate jf iiscnarge

        A a drainage area

        Q » storm run-off (as determined from Figure 8.3.3)

        K " a constant, and

       In is Che time to peak flow and is calculated as:


                                 TP = -T + L                               (8)
where  D * storm duration,  and

       L * drainage area lag

     The value of q_ can be approximated by making some simplifying
assumptions.  For instance, Che value of q_ is maximized as  Tp is
minimized.  For a given storm event, say tne 25-year storm,  Tp is minimized
if L, the lag time, is arbitrarily set equal to zero.  Substituting a value of
484 for K will then provide the estimate of the upper bound  on peak run-on
discharge rate.  If the applicant's calculation of peak discharge is at least
as great using any procedure, the estimate should be conservative.  In other
cases, the permit writer will have to exercise judgment,  or  follow the exact
computation procedure proposed by SCS for estimating peak discharge rate.  In
the latter case, it is recommended that the permit writer refer to
References 6 (Kant, 1973) or 7 (Mockus, 1969).

     The permit writer's worksheet for evaluating che applicant's calculation
of -peak run-on rate is presented in Figure 8.3.4.

Erosion Control

     Erosion control is an important part of the surface water control plan.
Vegetation planted near and on the sides of diversion ditches will stabilize
the soil, securing their structural integrity.  However,  vegetation can cake
between 1 and 2 years Co become firmly established.  During  that period, mulch
and hay bales should be used to stabilize these areas.  Mulch can be pegged in
place on steeper slopes.  Erosion control also prevents siltation that can
clog diversion ditches, resulting in surface ponding which should be avoided.

     References 8 through 11 listed in subsection 8^3.5 should be reviewed to
obtain a more thorough understanding of the erosion control  techniques
described above.

8.3.3.2  Minimizing Run-off of Hazardous Constituents-
     Surface run-off must be controlled to minimize the release of hazardous
constituents from the unit.  Surface run-off from the treatment zone can occur
during waste application, periods of heavy rainfall, or following a moderate
to heavy snowfall with subsequent rapid melting.  Under normal conditions,
surface run-off should not occur during waste application.  Approaches  to
minimize surface water run-off include proper facility siting and design and
                                    8-130

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 Calculation of peak run-on rate for
 design a torn event
     Has this part of the appiicanc's sufamittal been read        _____
     and evaluated?                                               Yea

     What technique was used to calculate the peak.
  — Using this technique,  what quantity (note units) or
     rate and duration of run-on is the proposed system
     designed to handle?                                         	


    i Independent Check Using the Rational Method !


  "~ Define Necessary Parameter Values -

 1.   Surface slope,  So " __                   "N
 2.   Retardance coefficient, Cr « 	        '  Calculate che
 3.   Rainfall iatensity during tiae            / value of b
     of  concentration,  i *  ______ in*/hr       J  from Łq. 2; b m _^_^
     (noca data source)

 4.   Maximum overland flow  length,  LQ * 	 ft.

 5.   Run-off coefficient, C * 	 (from Table 8.3.1)

—»•> Calculate time  of concentration, tc from Eq. 1; tc « 	 min

     Is  the value of tc calculated from                          	    	
     the value used  in 3. to determine i?                         Yes      No

     If  yes,  recalculate i,  b-, and cc

 6.   Drainage area,  a » ______ acres

-H*- Calculate peak  run-on  rate,  Q - Cia * 	 cfs
  Figure 8.3.4.  Worksheet  for  determination of peak run-on discharge rate
                 for evaluation of  run-on  control.

                                 3-131

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implementation of good management practices, such as application scheduling
and periodic cultivation.  Noes cnac .-aanagement practices complement a
facility design and should not be considered as an alternative or suostitute.
The success of minimizing surface run-off from the unit is pradicated on a
carefully thought-out facility design.

     The land treatment unit should be designed such chat liquids contained in
the waste applied infiltrate the soil before moving laterally (overland flow)
to the perimeter of the site.  I.-, addition,  cue unit should be managed whereby
loading rates and frequency of application are scheduled such that:

     •    waste is noc applied during periods when the soil is saturated,

     •    waste is not applied to the treatment zone when the surface soil is
          frozen, or

     •    waste is not applied during periods of heavy precipitation.

     Surface run-off resulting from excessive precipitation can be minimized
by maintaining a relatively level treatment zone surface and periodic
cultivation.  I: 13 recommenced that the surface slope be less than
5 percent.  Grades greater than 5 percent will significantly increase overland
flow velocities with a subsequent increase in soil erosion.  However, it is
also important to avoid water and waste ponding.  Standing water can create
anaerobic conditions and/or excessive leaching of waste constituents.  In most
cases, a 1-percent grade should be sufficient to ensure noneroding run-off ind
prevent water and waste ponding.

     With respect to cultivation, contour tillage across the slope rather than
with it is preferred.  Cultivation improves soil granulation, which maintains
porosity, aids infiltration, and prevents surface crusting.  Tillage also
improves waste degradation by aerating the soil and increasing waste/soil
contacting.

     In addition to surface water run-off, hazardous constituents adsorbed to
soil particles or particles of the waste material themselves can be released
from che treatment zone by soil erosion losses.  Soil loss per unit area due
to water erosion can be calcuated using the Universal Soil Loss Equation.  The
equation is:

                                A-RKLSCP

where A, che computed soil loss per unit area, is the product of the following
factors:

     R a rainfall and run-off erosivity index

     K * soil erodibility factor, tons/acre

     L * slope-length factor

     S » slope gradient (steepness) factor
                                     8-132

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     C s crop rsanageraenc v/egecacive cover) factor

     P * erosion-control practice

     Input values for each factor and sample calculations are presented in
Evaluating Cover Systems for Solid and Hazardous Waste. ^-~

8.3.3.3  Management of Accumulated Run-off and Run-on—
     To avoid migration of contaminated run-off, land treatment facilities
muat be designed and operated to collect and subsequently manage surface
run-off from the treatment unit.  It should be noted that the run-off
standards do not distinguish between active areas,  undeveloped areas
(surrounding land), or closed areas of the land treatment facility.  Run-off,
as defined under 3260.10, .seans any rainwater, leachate, or other liquid that
drains over land from any part of a facility.  A facility, as defined under
§260.10 means all land and structures used for treating, storing, and
disposing of hazardous waste.

     Concerning the collection of run-off as required under §264.273(d), the
Agency proposes the following:13

     «    Active area run-off should definitely be collected and managed as a
          hazardous waste, as explained in the Permit Applicants' manual.^

     •    Run-off from closed areas should also be collected, although it need
          not be assumed to be a hazardous waste.

     *    Run-off from access roads and building roofs need not be collected.

The technical issues associated with the management of accumulated run-off are
identified in Figure 3.3.5.

Magnitude of the 24-Hour, 25-Year Storm Event

     Facilities must be designed to handle the run-off volume associated with
at least the 24-hour, 25-year storm.  Figure 8.3.6 indicates the depth of
rainfall for this event throughout che United States.  The permit writer's
worksheet for evaluating the magnitude of the selected scorm event is
presented in Figure 3.3.7.

Calculation of Run-off Volume

     The volume of run-off expected for this storm event can be calculated
using che SCS Method or the Rational Method, as described in
subsection 8.3.3.1.

     The Part 264 regulations for run-off require that the run-off management
system "collect and control at least the water volume resulting from a 24-hour,
25-year storm."  Because the rational method only calculates peak discharge,
use of the SCS method may provide a more straightforward approach to calcula-
ting' the total run-off water volume associated with the design storm event.
First, Q is estimated using the graphical method shown in Figure 8.3.3.  Then
the total run-off volume associated with the storm event is approximated as:


                                    3-133

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                              RUN-OFF CONTROL
    SYSTEM DESIGN
   AND CONSTRUCTION
SYSTEM OPERATION
AND MAINTENANCE
   DETERMINATION OF
  MAGNITUDE/INTENSITY
   OF 25-YEAR,  24-HR
      STORM EVENT
   INSPECTION
  REQUIREMENTS
CALCULATION OF RUN OFF
  VOLUME FROM DESIGN
     STORM EVENT
                                                 MAINTENANCE
   DESIGN OF RUN-OFF
  COLLECTION/DIVERSION
         SYSTEM
   MANAGEMENT OF
HOLDING FACILITY TO
  MAINTAIN DESIGN
     CAPACITY
   DESIGN OF RUN-OFF
 HOLDING OR TREATMENT
      FACILITIES
                             TANKS - SEE PART 264 SU8PART J
                      IMPOUNDMENTS - SEE PART 264 SU8PART K
                         AND SECTION 6.0 IN THIS MANUAL
      Figure 8.3.5.  Technical issues associated with run-off control.
                                   8-134

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8-135

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Determination of Magnitude/Intensity
of 24-hr, 25-year storm event
  -  Has this part of the applicant's aubmiccai been read
     and evaluated?
  -  What storm magnitude was selected by che applicant'

  -  What depth of rainfall is this storm event
     equivalent to?

        based on what references
     Independent Check
  -  What is the rainfall depth associated with Che 24-hr,
  I   25-year stora
     -  based on what reference
     Is the rainfall depth established by the applicant
     at least as great as this determination?
     Then,  likewise,  this aspect of the applicant's
     submittal is or  is not acceptable
                                                                Yes     No
                                                                Yes
                                               inches
                                               inches
                                                No
                                                   is acceptable     is not
                                                                   acceptable
         Figure 8.3.7.
Worksheet for evaluating the magnitude of the
selected storm event.
                                    8-136

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                                   v  »
                                        L2

where  V  is  in  fc3, and

       A  * area of the active land treatment unit  in square  feet

The average  flow rate can be approximated by assuming that this quantity of
run-off flows for a duration of 24 hours.  If peak discharge  is of concern or
used as a design basis in the applicant'=5 presentation, then  the computation
techniques specified for determining  peak run-on rate would be applicable.

     The  permit writer's worksheet for evaluating run-off volume computations
is presented in Figure 8.3.3.

Design of Run-off Collection/Diversion System

     This design will be site-specific depending on topography, site layout,
and other factors.  The design may include an open channel with an impervious
floor flowing by gravity to a collection or storage basin.  Alternatively, if
the topography is less favorable, collected run-off may have  to be puraoed tc
some point where continued gravity flow is aot Longer possible to lift the
collected run-off into a storage tank or impoundment.  Such storage is
envisioned to be necessary to allow for determination of whether the collected
run-off is hazardous*  A discussion of the management of these storage
facilities follows.

     If the applicant proposes Co divert and collect sconnwater run-off by
installation of an open channel or culvert, it will be necessary to check the
proposed dimensions to assure that the design run-off volume  can be carried
without overtopping of the channel.  Open channel flow can be calculated using
the Manning  formula, wherein:

                              Q3 _LAR2/3sl/2

where  n 3 Manning's roughness coefficient

       A * cross-sectional area of flow

       R. a A/WP, the hydraulic radius (where WP a the wetter  perimeter), and

       S - the channel slope.

Values of n for a variety of surface materials area listed in Table 3.3.4.

     Th* applicant is required to provide an explanation of now collecte-i
liquid will be managed for disposal.   As part of the submittal, the time
required to empty the facilities must be estimated and the method of disposal
of collected run-off (i.e.,  treatment, evaporation) must be described.
                                    8-137

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Calculation of run-off volume from
design scora event
     Has this part of Che applicant's .ubmictai oeen read
     and evaluated?
     Using this technique,  what quantity (note units) or
     rate and duration of runoff is the proposed system
     designed to handle
     Independent Check Using the SCS Method
     Define parameter values:

     •  Select a value of S
     •  Calculate CN from CN
                               10 + S
                                                                Yes     No

     What technique was used to calculaca riin-off
     Is the run-off volume prssented in terms consistent
     with the regulation,  i.e.,  the run-off volume
     associated with :he 24-hour,  15-year storm?               	   	
                                                                Yes     No
     •  Interpolate Q from Figure 8.3.3                   	 inches

     Calculate V,  volume of run-off:

     •  A * active portion area »                         	 sq.ft.

     •  V - QA/12  *                                       	cu.ft.

     Is the volume of runoff used as  the design basis
     at lease as great?                                        	   	
                                                                Yes     No
     Figure  8.3.8.   Worksheet for evaluating run-off volume computations,
                                     8-138

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TABLE 8.3.4.  REPRESENTATIVE VALUES OF n, MANNING'S ROUGHNESS
              COEFFICIENT16

Mature ;f curfaca
Neat cetnenc surface
Wood-stave pipe
Plank flumes, planed
Vitrified sewer pipe
Metal flumes, smooth
Concrete, precast
Cement mortar surfaces
Plank flumes, enplaned
Common-clay drainage tile
Concrete, monolithic
Brick with cement mortar
Cast iron
Cement rubble surfaces
Riveted steel
Canals and ditches, smooth earth
Metal flumes, corrugated
Cana 1 s :
Dredged in earth, smooth
In rock cuts, smooth
Rough beds and weeds on sides
Rock cuts, jagged and irregular
n
Min
0.010
0.010
0.010
0.010
0.011
0.011
0.011
0.011
0.011
0.012
0.012
0.013
0.017
0.017
0.017
0.022

0.025
0.025
0.025
0.035

Max
0.013
0.013
0.014
0.017
0.015
0.013
0.015
0.015
0.017
0.016
0.017
0.017
0.030
0.020
0.025
0.030

0.033
0.035
0.040
0.045
                             8-139

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     3-un-Trf :o I lac caa from cne  active  portion of  z  landfill  rnusc  be analvsad
no determine Che presenca ar.d concencration of hazardous  constituents.   If
coiLecced run-off proves hazardous,  as  defined in  Part  26L,  it must be managed
as a hazardous waste.  To do so  will often require storage of the  collected
run-off in a tank,  container, or surface impoundment.   If so, these facilities
must be designed, constructed, and operated in conformance with  "he Standards
of ParC 264.  The permit applicant must adequately demonstrate his proposed
method of emptying or otherwise  managing run-off collection  facilities after
storms to maintain the design capacity  of these systems.

     The regulations require diversion  of run-on as  opposed  cj  :o llaccion.
Therefore, an adaquati monitor ir.g -na inspection plan  for run-on facilities
will often be adequate to demonstrate proper management of  these systems.
However, some part of the applicant's submittal should designate how  the
system will be maintained if problems are found during inspection. The  permit
applicant should also identify what actions will be taken when systems are
found to be operating incorrectly or not at all.  In addition,  preventive
procedures to be implemented, such as routine maintenance,  should be
described.  Figure 8.3.9 provides a worksheet to assess the  management
practices associated wicn the Land treatment run-on and run-off  control
systems.

8.3.3.4  Wind Dispersal Control  Measures—
     Ihe land treatment unit must be designed and  operated  to prevent  wind
dispersal of particulate matter from che site that .-night contain nazardous
constituents.  Note chat control of wind dispersal also applied  during closure
and pose-closure care, as required by § § 264.280(a)(8)  and 264.280(c ) (2) ,  This
concern arises because hazardous waste  will generally oe placed  on or  just
below the soil surface.  Measures to control wind  dispersal  of particulace
matter include:

     •    timing of waste applications,

     •    maintenance of surface soil moisture content,

     •    use of chemical soil stabilizing agents,

     •    use of wind breaks, and/or

     •    establishment of a vegetative cover.

     Factors.that affect particulate matter dispersal are local  prevailing
wind direction, type of waste co be disposed, and  operating techniques being
or to be employed at the site.  Familiarization with each of these will  enable
proper steps co be taken co minimize the effects of wind dispersal.

     Scheduling of applications to avoid periods of excessive wind speed and
turbulence will minimize wind dispersal of particulate matter.   Also,  di.
-------
     MANAGEMENT OF UNITS ASSOCIATED WITH RUN-ON AND RUN-OFF CONTROL SYSTEMS


Has this part of Che applicant's submittal been read
and evaluated?                                                  	
                                                                  yes      no

Are Che provisions for maintaining the run-off design           	   	
capacity described?                                               yes      no

Are automatic control and/or alarm systems used to              	   	
initiate emptying procedures ana diert personnel to               yes      no
potential problems?

Does the run-off management plan include provisions for
testing run-off collected from active portions of the           	   	
site for hazardous constituents?                                  yes      no

Does the application describe how run-off found to be
hazardous will be treated or disposed?
Does the application describe how non-hazardous run-off
will be disposed of or discharged?
                                                                  yes      no
                                                                  yea      no
    Figure 3.3.9.   Worksheet for evaluating management of unit's run-on and
                   run-off control systems.
                                    •  8-141

-------
     In addition to implement!.-.3 ^ooa  .-nanagement  techniques,  Che soil should
be stabilized using either water to wet  the  surface  or  chemical soil
staoilizing agents.  Information about surface  soil  stabilizing techniques
using water or chemical agents  is presented  in  references  1  and 17.

     One method of maintaining  soil moisture content at effective  levels,  is
to apply accumulated run-off.   If chemical stabilizing  agents are  aoplied  to
the treatment zone, they should be carefully evaluated  to  determine that they
do noc adversely affect the treatment  process or  cause  environmental damage.

     Figure 8.3.10 presents a worksheet  to aid  in the evaluation of the
applicant's proposed wind disoersal control  -aeasuras.

8.3.3.5  Inspection of Land Treatment  Unit—
     Aa part of the inspection  plan required under §270.14(b)(5),  the owner or
operator of a land treatment unit must submit a schedule for periodic
inspection of the facility to determine  the  adequacy of surface water and  wind
dispersal control measures.  In addition to  the general inspection
requirements specified in §270.14(b)(5) , the inspection plan for land
treatment facilities must include provisions whereby the unit will be
inspected weekly and after storms to detect  evidence of the  following:

     1.   deterioration, malfunctions, or improper operation of run-on  and
          run-off control systems, and

     2.   improper functioning  of wind dispersal  control measures.

     The weekly inspection procedures  should be specific.  The applicant
should describe whac, how, and  where Che control  systems will be checked.
Specific criteria that will be  used to evaluate the proper operation of these
systems should be stated.  The  use of  a  form requiring  written completion  by
the person conducting the inspection should be  included in the application for
review.  Also, any employee responsible  for inspections should be  identified
by name or title.

8.3.3.5.1  Sun-on and Run-off Control  Systems—Inspections of run-on and
run-off control systems will vary in complexity in relation  to the complexity
of the systems' designs.  In general,  run-on control systems are simply
intended to divert the surface  water flow around/away from the treatment
unit.  In most cases, it will consist  of trenches that  may or may  not be
lined.  Alternatively, the run-off control system is primarily designed to
collect and contain all liquid  overland  flow from the active portion of the
treatment unit and deliver it to some  type of holding or treatment facility
prior to disposal or reapplication.  A run-off control  system is  likely to be
of a more sophisticated design  than a  run-on control system  since  it will  be
handling liquid that has been in contact with the hazardous  waste.  The
following two basic concerns should be investigated during any inspection:

     •    The physical integrity of the  system with respect  to original
          construction, and

     •    The capacity of the system compared to original design.


                                      8-142

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                            CONTROL OF rfIND DISPERSAL
Has this part of che applicant's submittal been read and        	   	
evaluated?                                                        yes      no

Are che methods to control wind dispersal described?
                                                                  yes      no

Are waste applications and subsequent disking going to be       	   	
scheduled to minimize wind dispersal of particulaCe matter9       ;'es      no

If wind breaks are going co be used, has the applicant          	   	
described what they are, where they will be located,              yes      no
and how maintained?

If a vegetative cover is going to be established,  has the
type of cover and associated maintenance been described?        	^   	
                                                                  yes      no
If soil moisture control will be implemented to minimize
wind dispersal, has the applicant described the frequency
of irrigation and vater supply source?	   	
                                                                  yes      no

If chemical agents will be used to stabilize the soil,
has the applicant identified wnat tney are, what impact         	   	
they may have on the treatment process and application            yes      no
schedule?

Has the applicant identified what actions will be caken
when control systems are found not to be operating as
intended?
                                                                  yes      no

Has the applicant provided a. description of -mat pre-
ventive measures will be implemented, such as routine           	   	
maintenance, to minimize or reduce the likelihood of              yes      no
malfunctions?
   Figure 8.3.10.  Worksheet for evaluating wind dispersal control measures.
                                      8-143

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     For either run-en or run-off  -oncroi  systems,  inspections of
integrity should address:

     •    The liquid collection trench,  the  slope  of  culverts or piping,
          breaches, and tight  joints.

     •    If the conveyance system is  lined,  the liner  material should be
          checked for adhesion tj  substrate,  holes, wear  points, and cracks.

     •    If mechanical equipment  are  part of the  system  'e.g., pumps, valves,
          gates) they should be checked  for  leaks,  malfunction, or other
          damage.

     For run-on control systems,  inspections  to confirm continuance of design
capacity should address:

     •    The presence of sedimentation,  debris, or other materials chat could
          inhibit system flow.

     »    The condition or cerrain dovmgradient  from  the  system exit chat
          could cause liquids  to back  up inco the  system.

     For run-off control systems,  inspections to confirm  continuance of design
capacity should investigate:

     9    The presence of sedimentation,  or  encrustation  in Che system.

     •    The operation of mechanical  equipment  in the  system.

     •    The status (full/empty)  of holding or  treatment systems downstream
          of the run-off control  system.

     To the extent that the holding/treatment equipment associated with a
run-off control system are identified  as storage,  treatment,  or disposal
facilities under Part 264, they too muse have an  inspection plan as required
by §270. 14(b)(5) and §264.15.

8.3.3.5.2  Wind Dispersal Control  Systems—As previously  discussed, there  are
various options to control wind dispersal of particulate  matter at a land
treatment facility.  In some cases, a  combination  of  methods will be
implemented.  AC a minimum, inspection procedures  should  include close visual
observation of all wind dispersal  control systems  on  a  weekly basis.  During
periods of high winds or when  wastes are very susceptible to wind dispersal,
the frequency of inspection should be  increased.   Any individual assigned  to
inspect Che facility should have the authority to  require immediate  repair or
cleaning of wind dispersal control systems.   Cleaning would be  necessary where
fences or burlap screens are installed to catch  wind  blown material.
Figure 3.3.11 provides a worksheet for assessing the  adequacy of  the
inspection plan, as it relates to the  referenced  two  control measures.
                                       8-144

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                            INSPECTION REQUIREMENTS
 Has)  this part of che applicant's aubmitcal  been  reviewed
 tad  evaluated?

 Does Che application include a schedule  identifying vnen
 Che  unit will be inspected to determine  Che  adequacy oc           yea
 surface water control and wind dispersal  control  aeasure*?

 Are  individuals responsible for conducting  Che inspections      _
 identified?                                                      yes

 Are  Che icems Co be inspected listed?
 Does the application describe  the  procedures  for  responding
 Co observed inadequacies?                                        yet

 Are recordkeeping procedures described?
                                                                 yes

 Do weekly and post storm run-on and  run-off inspection
 procedures address:

 I.  Inspection of liquid collection  trenches, culverts
    or piping systems for proper slope,  breaches and              yea
    tight joints?

 2.  Inspection of lined conveyance systems for  adhesion         _
    Co substrate, holes,  vear  points, and cracks?                 yes

 3.  Inspection of mechanical equipment for leaks,               _
    malfunction,  or  other damage?                                 yes

 Oo run-on control system inspection  procedures  include:

 I.  Inspection for the presence of sedimentation, debru,
    and other material chat could  inhibit flow?                   yes

 2.  Inspection of the downgradient terrain co identify           _
    potential causes of liquid backup?                            yes

 Do run-off control system inspection procedures include:

 I.  Inspection for Che presence of sedimentation or             _
    encrustation?                                                yes

 2.  Inspection* to determine  Che proper  operation of            __
    mechanical equipment?                                        yes

 3.  Inspeccions to determine the status  (full/empty)            _
    of holding or creataent systems?                              ye*

Wind Disp«rsal Control Systems:

 !•  Does Che inspection plan include procedures for weekly
    visual inspections of wind dispersal control systems'         yes

 2.  Dee* Che frequency of inspection increase during            _
    periods of high  winds?                                        yes
    Figure  8.3.11.   Worksheet  for  evaluating Che applicant's
                        inspection program.

                                     8-145

-------
     Although specific requirements  are  not  soecified  in  Par;  270 or  264,  Che
owner or operator of the unit  should,  ac a minimum,  initiate  the  following
response when surface water control  or wind  dispersal  control  measures  fail:

     1.   suspend waste application,

     2.   institute backup system or control measures,

     3.   contact local authorities  (state Hazardous Waste  Agency or
          Coordinator, and fire and  police departments, as  necessary),

     4.   once che prooiem is  under  control  determine  the reason  for  failure
          and take corrective  action.

8.3.4  Draft Permit Preparation

     Condition B of the Permit Module XIV (see Section 4) addresses design and
operating requirements of the  land treatment facility.  Condition  3 is
comprised of six components that address:  (1) minimization of run-off  of
hazardous constituents during  the active life of the land treatment unit,
(2) control of surface water run-on, (3) control and management of  run-off,
(4) management of run-on and run-off collection and handling systems,
(5) control of wind dispersal, and (6) plans to inspect site ac regular
intervals.  The components of  Condition  B may be implemented as permit
requirements by reference to a sermit attacnraent that includes the  design and
operating plans and specifications proposed  in the permit application.

     To be suitable for substitution in  the  permit condition attachment,  the
submitted application information should include the following for  each of the
six components:

     •    Minimization of run-off of hazardous constituents:

               plans to delay waste  application when treatment zone soil  is
               saturated

               plans to suspend application  when surface  soil is frozen

               plans to suspend application  during periods  of heavy
               precipitation

               schedule of surface soil  tillage or establishment of a
               vegetative cover

          [Note:  The attached olans and specifications should demonstrate
          that the treatment zone will be designed, constructed, operated, and
          maintained to minimize run-off of hazardous constituents during the
          active life of the land treatment  unit.]
                                        8-146

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Control of surface water run-on:

     designs for contour grading surrounding land

     construction of diversion terms or ditches

     all calculations of peak rate of discharge

(Note:  The attached plans and specifications snouid demonstrate
that the control system is capable of preventing flow onto the
treatment zone during peak, discharge from at least a 25-year storm.]

Control and aLanasretnent of run-o'f:

-    designs for minimizing run-off

     all calculations of peak run-off volume

     engineering plans for controlling run-off

[Mote:  Tha attached plans and specifications should demonstrate the
run-off management system will collect and control at least the
water volume resulting from a 24-nour, 25-year storm.]

Management of run-on and run-off:

     all calculations supporting tne design and sizing of run-off
     collection facilities

     management plans for holding or treatment facilities

     procedures for assessing whether run-off is a hazardous waste
     that must be handled accordingly

[Note:  The Attachment must demonstrate how the Permittee will
comply with §264.273(e).]

Control of Wind Dispersal:

     plans for timing of applications

     measures to maintain soil moisture content

     plans to use soil stabilizing agents or vegetative cover

-    design and construction of wind breaks

[Note:  This condition only applies if the treatment zone contains
particulate matter which may be subject to wind dispersal.  The
Attachment must demonstrate how the Permittee will comply with
S264.273(f).]
                           8-147

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Insoection of Land Treatment Unit:

     plans to inspect the unic weekly and after storms

[Mote:  §270.14 requires Che general inspection schedule submitted
under §264.15(b) to address the requirements of §264.273(g).  The
Attachment should demonstrate compliance with §264.272(s)-  Parme
condition VI.E (see Module II) requires the Permittee to remedy any
deterioration or malfunction discovered during an inspection and to
keep records of inspections.]
                           8-143

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8.3.5  References

 1.  U.S. Environmental Protection Agency.  RCRA Guidance Document,  Land
     Treatment, Draft Report, Office of Solid Waste.  Jaunary  1983.

 2.  U.S. Environmental Protection Agency, Hazardous Waste Land  Treatment,
     prepared by K. W. Brown and Associates, Inc. for U.S. Environmental
     Protection Agency, Municipal Environmental Research Laboratory,  Solid  and
     Hazardous Waste Research Division, Cincinnati, OH.  Report  No.  3W-374.
     1983.

 3.  Clark, J. W., et al.  Water Supply and Pollution Control.   2nd  ad.
     International Textbook Comoany, Scranton, P.\.  l?~1 ,

 4.  Viessnsan, W. Jr., et al.  Introduction to Hydrology, Intext  Educational
     Publishers, New York.  1972.

 5.  Seelye, E. E.  Data Book for Civil Engineers Design, John Wiley and  Sons,
     Inc.  New York, NY.  1960.

 6.  Kent, X. M.  A Method for Estimating Volume 2nd .late of Runoff  in  Small
     Watersheds.  U.S. Department of Agriculature, Soil Conservation Service.
     SCS-TP-149.  Revised April 1973.

 7.  Mockus, V.  National Engineering Handbook.  Section 4 - Hydrology.
     Chapter 10.  Estimation of Direct Runoff from Storm Rainfall.   U.S.
     Department of Agriculature, Soil Conservation Service.  Reprinted  witft
     Minor Revisions, 1969.

 3.  U.S. EPA, Erosion and Sediment Control, Surface Mining in the Eastern
     U.S., Part 2, Design.  EPA Report 625/3-76-006.  October  1976.

 9.  U.S. EPA, Design and Construction of Covers for Solid Waste  Landfills.
     Municipal Environmental Research Laboratory, EPA Report 600/2-79-165.
     August 1979.

10.  U.S. EPA, Process Design Manual for Land Treatment of Municipal
     Wastewater, EPA Technology Transfer Series, EPA Report 625/1-77-008.
     October 1977.

11.  Brady, N. C.  The Nature and Properties of Soils.  8th Ed.   MacMillan
     Publishing Company, Inc.  New York, NY.  1974.

12.  Lutton, R. J.   Evaluating Cover Systems for Solid and Hazardous  Waste,
     Prepared by U.S. Army Engineer Waterways Experiment Station  for  U.S.
     Environmental Protection Agency, Solid and Hazardous Waste  Research
     Division, Cincinnati,  OH.  EPA Report SW-867.  September  1982.

13.  U.S. Environmental Protection Agency, Internal Memorandum from  Art Day to
     Kenneth A. Shuster, Trip Report - Region V - Permit Applicant's  Program,
     June 13,  1983.
                                     8-149

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14.   U.S.  Environmental Protection Agency.  Psrrait Applicant: 3 Guidance Manual
     for Hazardous Waste Land Storage, Treatment, and Disposal Faciliries.
     Draft Report.  Office of Solid Waste, Land Disposal Branch.  Washington,
     D.C.   March 1983.

15.   U.S.  Weather Bureau, 1961b, Rainfall-frequency atlas of the United States
     for durations from 30 minutes to 24 hours and return periods from 1 to
     100 years, Tech. Paper 40.

16.   Daugherty, R. L., and J. 3. Franzini.  Fluid Mechanics and Engineering
     Applications, 6th Edition, McGraw-Hill Book Company, New York.   1965.

17.   Versar,  Inc.  Technical .VsaidCance j.n tne Coal BAT Review-II; Special
     Report:  Revegetation of Goal Strip Mines, U.S. EPA Contract
     No. 68-01-5149.  November 26, 1979.
                                     8-150

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8.4  FOOD-CHAIN CROPS .-LEQUIREMENTS

3.4.1  Federal Requirement

     Sections 270.20(d)  and  (e)  stace  that:

               "(d)   If  food-chain  crops  are  to  be  grown  in  or on  Che
          treatment  zone of  the  land  treatment unit,  a  description of  how  the
          demonstration  required under §264.276(a)  will be conducted  including:
               (1)   Characteristics of the food-chain crop for which  the
          demonstration  will be  made.
               (2)   Characteristics of the waste, treatment  zone,  and  waste
          application method and rate  to  be used in the demonscrat ion;
               (3)   Trocaduras  for  crop growth.,  sample  collection,  sample
          analysis,  and  data evaluation;
               (4)   Characteristics of the comparison crop including  the
          location and conditions under which it was  or will  be grown;
               (e)   If food-chain crops are to be grown,  and  cadmium  is
          present  in the land-treated  vaste,  a description of how  the
          requirements of $264.276(b)  will be complied  with."

     The  corresponding Part  264  standards,  covered  under  §264.276,  state thac:

               "The  Regional Administrator may allow  the  growth of food-chain
          crops in or on the treatment zone only if the owner or operator
          satisfies  the  conditions  of  this section.   The  Regional
          Administrator  will specify  in Che facility  permit  the specific
          food-chain crops which may be grown.
               (a)(l) The owner or operator  must demonstrate chat there is  no
          substantial risk to human health caused by  the  growth of such crops
          in  or on the treatment zone  by  demonstrating, prior to the planting
          of  such crops,  that hazardous constituents  other than cadmium:
               (i)   Will not be  transferred to the  food or feed portions of
          the crop by plant  uptake  or  direct  contact, and will not otherwise
          be  ingested by food-chain animals (e.g.,  by grazing); or
               (ii)   Will not occur in greater concentrations in or on  the
          food or feed portions  of  crops  grown on the treatment zone than  in
          or  on identical portions  of  the same crops  grown on untreated soils
          under similar  conditions  in  the same region.
               (2)   The  owner or operator must make the demonstration  required
          under this paragraph prior to che planting  of crops at the facility
          for all constituents identified in  Appendix VIII of Part 261 of  this
          chapter that are reasonably  expected to be  in,  or derived from,
          waste placed in or on  the treatment zone.
               (3)   In making a  demonstration under this  paragraph, the owner
          or  operator may use field tests,  greenhouse studies, available data,
          or,  in the case of existing  units,  operating  data,  and must:
               (i)   Base the demonstration on conditions  similar to those
          present in the treatment  zone,  including  soil characteristics  (e.g.,
          pH,  cation exchange capacity),  specific wastes, application  rates,
          application methods, and  crops  to be grown; and
                                     8-151

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      ', li.)   Describe  Che  procedures  used  in  conducting  any  tasts,
 including  the  sample  selection  criteria,  sample  size,  analytical
 methods, and statistical  procedures.
      (4)   If the  owner or operator  intends  to  conduct  field  tests or
 greenhouse studies  in order  to  make the  demonstration  required  under
 this  paragraph, he must  obtain  a  permit  for conducting  such
 activities.
      (b)   The  owner  or operator must  comply with the  following
 conditions if  cadmium is  contained  in wastes applied  to che
 treatment  zone:
      (l)(i)  The  pH  of the waste  and  soil mixture must  be  6,5 or
 greater at the time  of each  waste application, except  for  vasta
 containing cadmium ac concantrscions  of  2 ag/kg  ;dry  weight) or less;
      (ii)   The annual application of  cadmium from waste taust not
 exceed  0.5 kilograms  per hectare  (kg/ha)  on land used  for  production
 of  tobacco, leafy vegetables, or  root crops grown for  human
 consumption.   For other  food-chain  crops, the  annual  cadmium
 application rate  must not exceed:
                                           Annual  Gd  application rate
          Time  period                        (kilograms  per hectare)
 Present  to June  30,  1984	              2.0
 July 1,  1984 to  Dec.  31, 1986	              1.25
 Beginning Jan.  1,  1987	              0.5
      (iii)   The  cumulative  application of  cadmium from waste must
 not  exceed  5 kg/ha if the waste  and soil mixture  has  a pH of less
 than 6.5; and
      (iv)   If the  waste  and soil mixture has  a pH of  6.5 or greater
 or is maintained at a pH of 6.5  or greater during crop growth,  the
 cumulative  application of cadmium from waste  must not exceed:
 5 kg/ha  if  soil  cation exchange  capacity  (CSC) is less than
 5 meq/lOOg;  10 kg/ha if  soil CEC is 5-15 meq/lOOg;  and 20 kg/ha if
 soil CEC is  greater than 15 meq/lOOg;  or
      (2)(i)   Animal feed must be the only  food-chain  crop produced;
      (ii)   The pH  of the waste and soil mixture must  be 6.5 or
 greater  at  the time of waste application or at the time the crop is
.planted, whichever occurs later, and this  pH  level must be
 maintained  whenever food-chain crops are grown;
      (iii)   There  must be an operating plan which demonstrates how
 the  animal  feed  will be  distributed to preclude ingestion by
 humans.   The operating plan must describe  the measures to be taken
 to safeguard against possible health hazards  from cadmium entering
 the  food chain,  which may result from  alternative land uses; and
      (iv)   Future  property  owners must be  notified by a stipulation
 in the land record or property deed which  states  that the property
 has  received waste at high  cadmium application rates  and that
 food-chain  crops must not be grown except  in  compliance with
 paragraph (b)(2) of this section."
                            8-152

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 a.4.2   Summary  of  Necessary  Application  Information

 8.4.2.1   Food-Chain  Crop  Deraonscracion—
     If  food-chain crop3  are  to be  grown during  the active  life of  che
 treatment unit,  the  applicant must  demonstrate that hazardous constituents
 will not  be  transferred to food or  feed portions of che crop, or  that
 hazardous constituents will  not occur in greater concentrations in  or on  the
 food or  feed  portions of  crops grown on the treatment zone  than in  or on
 identical  portion  of the  same crops grown on untreated soils under  similar
 conditions in the  same region.  Under either option, the owner or operator
 must address  all potential food-chain contamination pathways including crop
 uptake,  physical adherence to crop, and direct ingestion of contaminated  crops
 by grazing animals.

     The  application should contain a description of how the food-chain crop
 demonstration will be made using information available from the literature,
 greenhouse tests,  field studies, or in the case of existing units,  operating
 data.  Note  that any tests conducted to measure crop uptake must be based on
 specific  waste and application rates used or expected to be used at the unit.
 The owner or  operator must obtain a permit prior to conducting any  field  Casts
 or greenhouse studies.

 Part 1 -  Existing  literature - When published Literature is used to make  the
 food-chain crop demonstration, the applicant should explain how the reported
 data relates  to the  treatment facility and can be extrapolated to make the
 demonstration.

 Part 2 - Greenhouse  tests - The following issues should be submitted by the
 applicant if  greenhouse tests are co be conducted :o make the food-chain  crop
 demonstration:

 Crop characteristics - The common and scientific name of the crop or crops to
 be grown  should be identified along wich the potential food or feed portions
 of the plant.

 Waste characteristics - If not previously submitted (see Sections 8.1.2.1.1.
 or 8.2.2.1),   the applicant should list hazardous constituents in the waste and
 their respective concentration.

 Assessment of potential crop uptake - The applicant should explain how the
 potential for crop uptake will be assessed.  If existing information from the
 literature will be used,  the applicant should state and describe the data
 sources.  If greenhouse or field tests will be used to evaluate plant uptake,
a description of proposed test procedures addressing the following should be
submitted:

     •    test location;

     •     test schedule;

     •     number and  size of   )ts or containers;
                                   3-153

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     •    number of treatment raplicat ions;

     •    number of treatments;

     •    rate of waste application;

     •    soil characteristics;

     •    soil preparation;

     •    sampling and sample preparation methods;

     *    analytical methods;

     •    data interpretation methods; and

     •    method of data presentation.

Potential for external contamination - The application should contain in
explanation of how external (surface) contamination of the food or feed
portion of the crop will be precluded and how this will be substantiated in
the demonstration.

Potential for ingestion by food-chain animals - A description of how food
chain animals will be prevented from ingesting hazardous constituents and how
this will be substantiated in She demonstration should be submitted by the-
applicant.

Part 4 - Field tests - If field tests will be used in the food chain crop
demonstration, the applicant should describe how each test will be designed
and conducted, including the information described below:

Plot configuration - A scale drawing showing the test plot layout, location,
and dimensions should be presented.

Crop characteristics - The applicant should identify the plant species and
variety of the crop, the edible portion of the crop, and existing information
concerning plant uptake of the hazardous constituents present in the waste by
the crop being tested or by similar crops.

Waste characteristics - The following information should be provided for each
hazardous constituent present in the waste to be used during the demonstration
(note that wastes used to make the demonstration should be similar Co those
proposed to be land treated):

     •    concentration,

     •    volatility,

     •    water solubility, and

     •    persistence.
                                    8-154

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 Treatment  zone  cnaracc2rij;i^c  - .'»r.  evaluation or  cna erfect of  che  following
 soil  properties have on plane uptake of hazardous  constituents shouia be Bade
 and presented in  the application:

      •     soil  pH,

      •     soil  organic matter,

      •     soil  texture, and

      •     soil  cation exchange capacity.

 Waste application rate and method - Application rates and method that will be
 used  in the  food-chain crap  iasonstracion jnouia be described in the
 application.

 Sample collection procedures - The following sampling procedures should be
 described  by the applicant: harvest or sample collection, method of
 collection, quantity of sample collected, methods  for obtaining  representative
 samples, and sample preservation and transport.

 Analytical procedures - A detailed explanation of  analytical methods,
 chain-of-custody control, and expected detection levels of Che constituents
 being analyzed  should be submitted as part of the  demonstration  program.  .

 Data evaluation methods - The following factors should be evaluated and
 results presented as part of the food-chain crop demonstration:

     •    dilution effects due to growth,

     •    variability between individual plants,

     •    variability between waste application rate,

     •    bioconcentration through plant uptake,

     •    quantity taken up by crops,

     •    persistence of hazardous constituents in plant tissues, and

     •    concentration of hazardous constituents  in edible portions.

3.4.2.2  Wastes Containing Cadmium—

Part 1 - If cadmium is contained in the wastes to be land treated on plots
growing food chain crops, the applicant must submit the information presented
in Table 8.4.1.
                                    8-155

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                IABLS 8.4.1.  EXAMPLE CADMIUM LOADING RATS TA3Lc

Waste name
and EPA ID No.
1.
2.
3.
Annual wasca Annual cadmium
Cd in waste application race loading
Bg/kg kg /ha kg /ha



Part 2 - The applicant should submit the following if animal feed is the only
food-chain crop to be grown:

     •    plant species and variety to be grown,

     •    antecedent or native soil pH,

     •    methods and frequency of soil pH adjustments (when required),

     •    management plan to control cadmium release from unit, and

     •    notice in land deed that soil has received cadmium-containing vastaal

     The following should be submitted if animal feed will not be the only
food chain crop grown:

     •    plant species and variety to be grown,

     •    antecedent or native soil pH,

     •    taechods and frequency of soil pH adjustments (when required), and

     •    an operating plan for controlling applications of cadmium-containing
          waste(s).

8.4.3  Guidance on Evaluating Application Information

8.4.3.1  Food-Chain Crop Demonstration—
     If food-chain crops, which include tobacco, crops grown for human
consumption, and crops grown for animals whose products are consumed by
humans, are Co be grown, the reviewer should first determine whether the owner
or operator plans to demonstrate:  (1) that hazardous constituents will not be
transferred to food or feed portions of the crop, or (2) that hazardous
constituents will not occur in greater concentrations in or on the food or
feed portions of crops grown on the treatment zone than in or on identical
portions of the same crops grown on untreated soils under similar conditions
                                    3-156

-------
 '..a ihe  same _-2giJn.   [Nccs ^nac ^rowcn of rood-chain crops during the active
 years is optional.]   As described in 8.4.2, Che applicant may make che
 demons eraCion using field cescs, greenhouse studies, available literature, or
 in che  case of existing units, operating data.  It  is noted, however, that in
 most cases, field  testing or operating data will be required to make the
 second  demonseration  option identified above.

     In evaluating the demonstration, it is particularly important to verify
 that test conditions  simulate actual or expected site operating conditions.
 Consequently, the permit reviewer should compare the site design and operating
 conditions described  in Section 8.3 and the conditions under which greenhouse
 or field studies to make the food-chain crop demonstration will be performed.
 Detailed discussions  of greenhouse and fiald test experimental designs *.re
 oresantad In •Ireenhouae T-jchniquas for 3oil-Plant-Fertilizer Research^- and
 the Hazardous Waste Land Treatment manual?, respectively.In addition, a
 qualified agronomist  should be consulted to help evaluate experimental designs
 and plant species selection.  Agronomists may be found at local colleges or
 universities or state agricultural experiment stations or extension service
 offices.  Results obtained from the demonstration must be statistically valid
 to ensure that the demonstration was thorough and adequate to confirm that
 there will be no substantial risk to human health caused by the growth or
 food-chain crops in or on the treatment zone.

     Part 270 requires that the owner or operator obtain a permit under
 $270.63 for conducting the food-chain crop demonstration.  (See Section 3.1
 for specific requirements for obtaining the demonstration permit.]  The
 demonstration must be made for all hazardous constituents (i.e., constituents
 listed  in Appendix VIII of Part 264) that are reasonably expected to be in or
 derived from the waste being or to be land treated.

     As stated above, any greenhouse study or field test performed to make the
 required demonstration must simulate conditions that are representative of the
 geographical location of the proposed or existing land treatment unit.  For
 existing units, it is likely that operating data will be used to make the
 required demonstration.  The following sources may be consulted to obtain
 representative values of the environmental parameters to be simulated and to
 gain an understanding of the effects of waste application on plant growth and
 constituent uptake:   Soil Conservation Service, Agricultural Extension Service
 and Experiment Stations; U.S. Weather Bureau; and local colleges and
 universities.  In addition, information on plant uptake of various substances
 can be  found in the literature (1,2,3,4,5,6), as required under §270.20(d)(1) .

     The applicant must provide a description of the plant species and
 varieties to be grown at the site.  The description should include an
explanation of the following for each plant species identified:

     •    tranalocation of hazardous constituents,

     •    growth season, and

     •    harvesting  techniques and ultimate disposal.
                                   8-157

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     Table 3.4.2 provides, for illustrative purposes, a orief listing of pl
uptake mechanisms involved in Che translocacion of pesticides fraa soils.
Similar information should be presented by the applicant.   If the hazardous
constituent is trans location within the plant, the applicant should document
where and how the constituent will be transformed to a nonhazardous form,  or
if not, how ic will be prevented from entering the food-chain such that it
will not cause a substantial risk to human health.

     If the owner or operator elects to demonstrate that the concentration of
hazardous constituent(s) in or on the food or feed portions of crops grown in
or on the treatment zone will not be greater than corresponding portions of
identical crops grown on untreated soils under similar -ondlcions in che same
region, thsy susc fully describe Che characteristics of the comparison
crop(s).  The comparison crop essentially reflects the control group of a
basic experimental design.  The comparison crop serves as  the base condition
whereby any significant deviation from it would constitute a statistically
meaningful change.

     Growth of the comparison crop(s) under field or greenhouse conditions.
should be identical to the growth of the demonstration crop(,d) with che
exception that the hazardous waste(s) under review is not  applied to the
soil.  The worksheet presented in Figure 8.4.1 or similar  list developed by
the reviewer, should be used to systematically determine that both groups of
plants are grown under identical conditions, except for the difference of
treated and untreated soils.

     Figure 3.4.2 and 8.4.3 present worksheets that can be used to evaluate
the adequacy of the permit application with regard to the  information required
for greenhouse tests and field tests performed to -nake the food-chain crop
demonstrations, respectively.

     With respect to identifying potential consumers or uses of particular
crops, the following sources should be consulted:

     •    Local Agriculatural Extension Service

     •    State Department of Agriculture

     •    State University Agriculture Department

     •    Buyers such as grain dealers and co-operatives

     •    Local farmers

8.4.3.2  W««tes Containing Cadmium—
     Special interest is paid to cadmium because of its potential transfer
through the food chain and adverse human health effects.  Land treatment of
cadmium-containing municipal and industrial wastes can result in an
accumulation of cadmium in the soil.
                                     3-158

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      TABLE 8.4.2.   PLANT UPTAKE AND TRANS LOCATION OF PESTICIDES  FROM SOILS

Insecticide
Aldrin
Dieldrin
Isodrin
Endrin
Hepcachlor
Hepcachlor
epoxide
Chlordane
Endosulf an
Toxaphene
SHC
Lindane
DDT
Diazinon
OimechoaCe
Disulfoton
Phorace
Parachion
Chloroneb
Arsenic
Lead

Aosor bed by
root
Ye 3
Ye 3
Yes
Yes
Yea
Yea
Yes
Yes
Probable
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes

Trans Located
from root
Yes
Yes
Probable
Yes
Yes
Yes
Improbable
Yes
Improbable
Ye 3
Yes
Probable
Yes
Probable
Yes
Yes
Probable
Yes
Yes
Yes
Compounds found <
Parent
Yes
Yes
Improbable
Yes
Yes
Yas
Unknown*
Yes
Unknown*
Yas
Yes
Probable
Yes
Unknown
Yes
Yes
Probable
Yes
Yes
Yes
after translocat ion
Metabolites
Yas
Probable
Yes
Yes
Yes
Unknown
Unknown
Unknown
Unknown
Yes
Yes
Yes
Probable
Probable
Yes
Yes
Unknown
Yes
	
—
*None, or has never been investigated.




 Adapted from Phung et al.  (3).
                                      8-159

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Untreated Soil Case
   znvironmencal
Parameter/Condit ion

  Plane Species
                                                         Treated Soil  Case
                            Air Tempera cure

                             Air Humidity

                            Soil Temperature

                             Soil Mo is Cure

                               Soil pH


                            Soil Fertility:

                               Nitrogen

                              Phosphorous

                               Potassium

                              Soil Texture

                         Cation Exchange Capacity

                               Soil Depch

                               Insolation
                              (hours daily)
Figure 8.4.1.  Worksheet to evaluate similarities of conditions under «/hich
               food-chain crop demonstrations are made.
                                    3-160

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 Has  the  applicant identified  the
 Ł«,.» -j	f   ,                     — — c- ~ j  •*. nw iijuincr r*rt^™«.to,;  i
                                                       -3 4.
         jr:.crr
             a
Fl8uce  8'4'2'
                             8-161
                                                                yes      n,
                                 the
                                                                yes      nc
                                                                       no
                                                              yes      no

-------
Has the applicant presented tne layout, location, and
dimensions of teat plots on a scale drawing?
                                                                  yes      no
Does Che application identify the species and variety of
the crop, the edible portion of the crop, and previous          	   	
information concerning hazardous constituent uptake?              yes      no"

Are the concentration of hazardous constituents in the
waste, the volatility, and water solubility of the
hazardous constituents,  and the persistence of chase            	    	
constituent in soil deacnoea in the application?                yes      no

Has the applicant presented an evaluation of Che soil
properties that will affect plant uptake of hazardous           _______   	
constituents?                                                     yes      no

Has the applicant described waste application rates and
methods of application?                                          	
                                                                  yes      no
Does the application contain a description of all sample
collection procedures associated with the demonstration?
                                                                  yes      no
Are analytical procedures and sensitivities described
in the application?                                              _
                                                                  yes      no

Has the applicant provided an explanation of the statistical
methods to be used to evaluate results and identified how       	   	
results will be presented?                                        yes      no
    Figure  8.4.3.   Worksheet  to  assess  food-chain crop demonstration made by
                   field  tests.
                                    3-162

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     The presence of cadmium in the waste to be applied will have been
decermined by the waste analysis required under the Treatment Demons t rat: ion
(see subsection 8.1).  If cadmium will not be present in the waste co be Land
treated, proceed to subsection 8.5.  However, if cadmium is present in the
waste continue with the review under this section.

     The owner or operator must comply with certain management practices that
are designed to limit the entry of cadmium into the food chain.  The specific
requirements of §264.276(b) chat oiust oe compiled with (if the waste to be
applied contains cadmium) are presented above.  To demonstrate compliance with
the requirements of §264.276(b), the owner or operator must describe how he
will maintain soil pH and cation exhange capacity at prescribed levels.
Section 8,2.3 provides infcraatijn on evaluating these two parameters.  An
informative discussion of the relationship between food-chain crops and
cadmium is presented in the Office of Solid Waste's Guidance Manual for the
Classification of Solid Waste Disposal Facilities? and U.S. EPA's Process
Design Manual for Land Treatment of Municipal Wastewater.^

     One of the more important concerns at a site where cadmium is contained
in the waste to be treated is the facility operating plan.  The operating plan
designed to preclude ingest ion by humans and prevent possible health hazards
resulting from alternative future uses of the land should be reviewed to
determine the chain of possession ot the crop after harvest.  The distribution
of any food-chain crop grown at the land treatment unit oiust be carried out
such that there is no chance of ingestion by humans (e.g., it could be sold
directly to a dairy farm or feed lot where it would be fed to cattle).

     Concerning possible health hazards from cadmium entering the food-chain
as a result of alternative future land uses, the site should not be used as
vegetable farms or home vegetable gardens that could result in significant
dietary increase of cadmium.  Acceptable provisions in the facility operating
plan could include dedication of the site as a puolic park following closure
or removal of the contaminanted soil.  Figure 8.4.4. presents a worksheet that
can be used to evaluate the adequacy of permit applications for land treatment
units that will or are handling cadmium-containing waste.

8.4.4  Draft Permit Preparation

     Condition C of Module XIV (see Section 4) outlines the conditions to be
specified in the permit.   Foremost in permit preparation is the requirement
that the permit writer specify that only those food-chain crops the owner or
operator has demonstrated will not have contaminated levels above those found
in similar crops grown on untreated soils under similar circumstances in the
same region may be grown at the land treatment facility.  Conditions of the
permit relating to food-chain crops may be stipulated in che permit by
reference to portions of the permit application.  This pertains specifically
to information describing:

     •    plant species,

     •    waste characteristics,
                                     8-163

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Has the applicant specified the concentration of cadmium
in wastes Co be applied, annual application rates, and
soil loading of cadmium resulting from the application          	   	
rates used?                                                       yes      no"

Does the application provide a description of the following:

  Species and variety of crop to be grown?                      	
                                                                  yes      no

  Initial or native soil pH?                                    ^^^^   	
                                                                  yes      no

  Methods and frequency for adjusting soil pH (if necessary)?   	   	
                                                                  yes      no

If animal feed is the only food-chain crop produced, has
the applicant provided a description of an operating plan
fcr preventing uirecc numan consumption of produced
animal feed and a plan to safeguard against cadmium
entering the human food-chain resulting from future             ______   _____
alternative land use?                                             yes      no

Also, has the owner or operator identified that the
land deed vili be changed :o indicate that the site
has received elevated applications of cadmium and that
food-chain crops should aot be grown except in accordance       _____   	
with §264.276(b)(2)?                                              yes      no

If animal feed will not be the only food-chain crop
produced, does the application include an operating
plan for controlling applications of cadmium to the             	   	
soil?                                                             yes      no
 Figure 8.4.4.  Worksheet for evaluating adequacy of permit application where
                waste(s) containing cadmium will be or are being treated.
                                    8-164

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     •    assessment of potential crop uptake,

     •    potential for external human contamination 3nd ingestion by
          food-chain animals,

     •    sampling and analytical procedures, and

     •    treatment zone characteristics (if field study).

     Jnaer the food-chain crop provisions,  the permit must specify how the
site will be managed to limit the entry of cadmium, when contained in the
waste, applied into the food chain.  The permit should specify loading rates
to prevent the build up of cadmium in the 'rroatrcent -one ioii.  As with trie
food-chain permit conditions, portions of the Part B permit application may be
referenced in the permit to stipulate conditions for controlling applications
of cadmium-containing waste.

     Condition C of Module XIV states that:

          If the Permittee has successfully demonstrated in accordance with
     40 CFR 264.276(a) and Cb5 chat there is no substantial risk to human
     health from the growth of food-chain crops in or on the treatment zone,
     the permit writer may allow the growth of such crops.  This decision
     should be documented in the administrative record.  When cadmium is
     contained in wastes applied co the treatment zone, the permit writer
     should include a condition that requires compliance with §264.276(b).
     This condition should refaranca the Attacnment required by §270.20 which
     must demonstrate how the requirements of §264.276(b) will be complied
     with.
                                     8-165

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8.4.5  References
 1.   Allen, S. Ł., et al-.   Greenhouse Techniques for Soil-Plant-Fertilizer
     Research.  Bulletin Y-I04, National Fertilizer Development Center,
     Tennessee Valley Authority, Muscle Shoals.  Alabama.  May 1976.

 2.   Brown, K. W., et al.   Hazardous Waste Land Treatment.  Prepared by
     K. W. Brown and iasociataa, Inc. for LI.a. Environmental Protection
     Agency, Municipal Environmental Research Laboratory.  Solid and Hazardous
     Waste Research Division.  Cincinnati, OH.  Report No. SW-374.
     February 1983.

 3.   Phung, I., et al.  Land Cultivation of Industrial Wastes and Municipal
     Solid Wastes:  State-of-the-Art Study.  Volume I, Technical Summary and
     Literature Review.  Prepared by SCS Engineers for U.S. Environmental
     Protection Agency, Municipal Environmental Research Laboratory,
     Cincinnati, OH.  EPA-600/2-78-140a.  August 1973.

 4.   Sanies, R. L., and T.  Asano, eds.  Land Treatment and Disposal of
     Municipal and Industrial Wastewater.  Ann Arbor Science, Ann Arbor,
     Michigan.  1976.

 5.   Overcash, M. R., and D. Pal.  Design of Land Treatment Systems for
     Industrial Wasces - Thee    nd Practice, Ann Arbor Science, Ann Arbor,
     Michigan.  1981.

 6.   Sidle, R. C., et al.   Heavy Metals Application and Plant Uptake in a Land
     Disposal System for Waatewater.  J. Environ. Qual., Vol. 5, No. 1.
     1976.  pp. 97-102.

 7.   U.S. Environmental Protection Agency.  Guidance Manual for  the
     Classification of Solid Waste Disposal Facilities.  Office  of Solid
     Waste.  Washington, D.C.  November 1979.

 8.   U.S. Environmental Protection Agency.  Process Design Manual for  Land
     Treatment of Municipal Wastewater.  EPA Report-625/1-77-008.
     October 1977.
                                    8-166

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 8.5   ESTABLISHMENT OF VEGETATIVE COVER AT CLOSURE

 8.5.1  Federal Requirement

      Section 270.20(f) requires Che owner or operator to include in Che permit
 application (as part of the facility closure plan):

               "A description of the vegetative cover to be applied to closed
          portions of the facility, and a plan tor maintaning such cover
          during the post-closure care period, as required under
          §264.280(a)(8) and §264.280(c)(2).  This information should be
          included in the closure plan and, where applicable, the oost-ciosur. ;

     The corresponding Part 264 standards, $264.280(a)(8) and §264.280(c)(2),
 require that the owner or operator:

     §264.280(a)

               "(8)  Establish a vegetative cover on the portion of the
          facility being closed at such time that the cover will not
          substantially impede degradation, transformation, or immobilization
          of hazardous constituents in the treatment zone.  The vegetative
          cover must be capable of maintaining growth without extensive
          maintenance."

     and,

     §264.2SO(c)

               "(2)  Maintain a vegetative cover over closed portions of the
          facility;"

8.5.2  Summary of Necessary Application Information

     [Note:   This item should also be included in the closure and post-closure
cara plans described in Sections IV 2(c) and (d) of Chis document].  In
addition to providing the following information, the applicant should submit a
written description of procedures employed to establish and maintain a
vegetative cover on closed portions of the land treatment unit:

     •    common and scientific name and species and variety of plants to be
          established as the cover crop,

     •    documentation of selected plant species viability, and

     •    identification of minimum percentage of cover that will be
          maintained.
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8.5.3  Guidance on Evaluating Application Information

     The primary purpose of establishing a vegetative cover at closure is to
minimize wind and water erosion.   Plant root systems stabilize the surface
soil, minimizing erosion.  Secondarily, the plane cover can aid in the
treatment of hazardous constituents.

     Section 264.280(a)(8) requires the owner or operator to establish a
vegetati'/e cover a- sucn time that the cover will noc substantially impede
degradation, transformation, or immobilization of hazardous constituents.
Because certain operating practices to maximize treatment, such as tilling,
cannot be performed without damaging or destroying Che "egatative cover, cne
owner or or»eriŁ3r zusc postpone seeaing until sufficient waste treatment has
occurred following the last application.  Results from unsaturated zone
monitoring, treatment zone analyses,  and data on run-off liquid quality,
should be uaed in judging the degree of treatment achieved.  Correspondingly,
once the cover is established, operating practices to enhance waste treatment
that are inconsistent (e.g., tilling) with establishment and maintenance of
the vegetative cover should be discontinued.

     1C is important co note that the owner or operator can be exempted from
the vegetative cover closure requirement of §264.280(a)(8) and post-closure
care requirements of §264.280(c)(2) if it is demonstrated that the level of
hazardous constituents within Che treatment zone is not significantly greater
than background values.  Procedures to make this demonstration are similar to
corresponding standards used for  unsaturated tone monitoring under §264.278
(see Section 8.2.3.a),  tiowever,  only soil core monitoring is necessary, not
soil-pore liquid monitoring.

     The RCRA Guidance Document for Land Treatment 1- describes a scheme  for
demonstrating that no statistically significant increases in hazardous
constituents over background levels exist in the entire treatment zone.  The
document also describes the sampling protocol for unsaturated zone monitoring
during the post-closure care period.  The suggested scenario, for soil-core
monitoring, involves a geometrically progressive sampling schedule at 1/2, 1,
2, 4, 8, 16, and 30 years after the pose-closure care period begins.

     Soil core samples should be  taken at various depth increments- within  the
treatment zone, rather than just  below the treatment zone as required for
unsaturated zone monitoring during the active years.  Concerning soil-pore
liquid monitoring, which only continues for 90 days after the last waste
application, at least two sampling events should occur.  The reason for this
latter condition is that the Agency expects that the fast-moving constituents
that the soil pore liquid monitoring system is designed to detect should
migrate out of the land treatment zone soon after cnese constituents  are
applied if they are to migrate at all.

     The owner or operator of the land treatment unit may be exempted from
Subpart F requirements (see Section 5) if he or she can demonstrate the
following:
                                    8-168

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      1.    that hazardous constituents are no longer present  in  :he c'reaciaent
           sone at statistically significant amounts, and

      2.    that no hazardous constituents (or PHCs) have migrated below the
           treatment zone during the active life of the land  treatment unit.

As mentioned above, results from unsaturated zone monitoring and treatment
zone  analyses may be used to document these conditional requirements.

      Although §270.20(f) only specifically calls for information on the
establishment and maintenance of a vegetative cover, the applicant must also
submit information on all of the other closure and post-closure requirements
of §264.280^.1) for closure and J264.^oO(c/ for post-closure.  The application
snouid contain a description of how these requirements will be complied with.
In general, these requirements simply specify that design and operational
activities performed during the facility's active years be continued or
maintained during closure and post-closure care periods.  Briefly, the
operations, other than establishment and maintenance of a vegetative cover, to
continue are:
     Closure

•    Sustain waste degradation
     transformation, and
     immobilization*

«    Continue to minimize run-oft

•    Maintain run-on control system

•    Maintain run-off management
     system

•    Continue to control wind
     dispersal (if needed)

•    Continue food-chain crop
     management

•    Continue unsaturated zone
     monitoring7
     Post-Closure

•    Sustain waste degradation,
     transformation, and
     immobilization*

•    Maintain run-on control system

•    Maintain run-off management system

•    Maintain wind dispersal controls
     (if needed)

•    Continue food-chain crop
     management

•    Continue unsaturated zone
     monitoring"
*Except Co Che extent that such operations are inconsistent with che
 establishment of a vegetation cover.  Operations include tilling of
 the soil, control of soil pH and moisture content, and fertilization.

 Soil-pore liquid monitoring may be terminated 90 days after the last
 waste, application.
                                    8-169

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            or operators of land treatment facilities must also comply vith
the general closure requirements provided under Subpart G.  these requiremen
address the closure performance standard (§264.111),  the closure plan
(§264.112), time allowed for closure (§264.113),  disposal or decontamination
of equipment (§264.114), certification of closure (§264.115),  post-closure
care period ($264.117), post-closure plan (§264.118), and notices (§264.119
and §264.120).   In addition, the applicant must also  comply with the
applicable general information requirements of §270.14(b)(13).

     Even though the exemptions identified above may  be implemented,
establishment of a vegetative cover is a good management practice.   A
vegetative cover will control wind dispersal of particulate matter  and provide
soil stabilization which will minimize erosion.

     The purposes of establishing and maintaining a vegetative cover are to:

     *    physically stabilize the soil,

     •    reduce infiltration of precipitation,*

     •    retard surface run-off,

     •    minimize wind and water soil erosion, and

     •    enhances site appearance.

     The success of establishing 3. vegetative cover hinges on selecting plant
species that have good seed germination and growth characteristics  and are
indigneous to the area.  In order to ensure continued compliance witti the
post-closure requirement, plant species selected must also be easily
maintained without extensive maintenance (e.g., frequent fertilization,
liming, and watering).

     To provide an opportunity for plant species to become established, the
top soil layer comprising the root zone must be conditioned both physically
and chemically to ensure a high success rate of seed  germination and vigorous
growth.  The soil oiuac provide adequate moisture, nutrients, and aeration.
Many treatment zone soils may require conditioning prior to seeding and some
level of periodic maintenance following germination.   Soil conditioning
includes:

     •    addition of organic matter,

     •    periodic cultivation,

     •    chemical nutrient addition, and

     •    soil pH and moisture control.
*Infiltration is seasonally reduced by intercepting and evapotranspiring some
 of the precipitation.
                                     3-170

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In cases wnere cne treatment zone soli  is  act  acceptable,  even  after
condicioning,  for vegetative growth,  :-~  "ay be amended ay  the addition  of
clean top soil.   Actually,  in some- situations,  factors promoting  plant  growth
and thus improve the likelihood for che  establishment  of a vegetation cover
will be enhanced by the waste applications.  For example,  the  following
benefits can result from the waste disposal activity:   an  increase in soil
organic matter content, soil pH,  and potassium, calcium, magnesium,  and zinc
levels.

     In order to determine types  of vegetation that would  be suitable  for  a
particular site, soils analyses must be  conducted.   Investigations should  be
made to determine pH and fertility of the  treatment zone surface  soil  (down  to
5 to 10 cm) or soil brought into  be used for cover.  Methods for  performing
chase analyses are generally available  from county offices of the Soil
Conservation Service.

     Experiences gained with the  land cultivation of municipal  solid waste and
industrial wastewater and sludges have  revealed that nitrogen and phosphorus
deficiencies can occur in the soil which will adversely affect  seed
germination, growth, and metal uptake by plants.2,3 ,4, 5  in order to
establish and maintain Che vegetative cover required,  soil amendments  using
chemical or natural fertilizers will likely be necessary.

     Chapter 3 of the Hazardous Waste Land Treatment Manual? presents  an
in-depth discussion on che establishment of a vegetative cover  at closure.
Issues addressed in the manual include  management objectives,  species
selection, seedbed preoaration, seeding and plane establishment,  and soil
fertility.

     To ensure successful establishment and ease of maintenance,  plant  species
selection should be based on suitability with local climatic (seasonal) and
soil conditions.  Information regarding plant species selection and
cultivation practices can be obtained from agronomists of  the State
Agricultural Extension Service, U.S.D.A. or plant science  professors at nearby
colleges and universities.

     A^ discussed in tne ACRA Guidance Document,^ the Agency believes  that,
in many cases, the closure activities at land treatment units and
establishment of a vegetative cover may be accomplished within 180 days.
However, each facility will be unique and should be evaluated on a
case-by-case basis.

     A .key concern when establishing the vegetation is  to assure adequate
cover.  The surface soil should be completely covered to avoid bare spots  that
may initiate soil erosion which could expand to the extent that widespread
erosion and elimination of portions of the vegetative cover results.

     The first steps to assuring adequate cover are seeding rate and timing.
The seeding rate, that is the quantity of seed applied  per arce,  depends on
the seed species, method of seeding, and surface soil conditions at the time
of closure.  The current practice  for calculating seeding rates is based on
the quantity (pounds) of seed required to produce 20  live seeds per foot.2
                                    8-171

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Other seeding races -ay ze .iccepcaoie,  aowever.   The reviewer should concacc
the Local agricultural extension service office  or Soil Conservation Service
for information on proven seeding rates for the  region.

     The timing of seeding will depend on whether1the plant species selectad
is a cool or warm season species.  Cool season species do best when planted in
late summer or early fall.  Warm season species  are generally planted during
lace winter or early spring.2

     The chosen mixture of ^eeda ana soil amendments can be hydroseeded, that
is, sprayed onto Che land surface in a water mixture.  Hydroseeding is one of
Che least expensive and Che most coat-effective  method of seeding a landfill.
Following seeding, a mulch consisting of hay, straw, or vood chips c.tn be
blown onto the 3,4,5,8,9,10  Disease and insect resistance should also be
considered during vegetation selection.

     Although it is not a specific requirement,  field studies investigating
seed germination, root development, vegetative growth, and plant viability
should be conducted on small plots of tne treatment zone during its active
life.  Results obtained from such studies will be valuable for the selection
of the best vegetative cover to »3tablish during closure.  It is suggested
chat this topic be discussed during Che pre-appiication meeting.

     EPA has developed a 39-step approach for evaluating the adequacy of
closure and post-closure plans and engineering reports with respect to
hazardous waste landfills.^  The review procedure is specifically intended
for use by staff members in Che Regional EPA offices and state offices.
Although the cover evaluation procedures are directed towards landfills,
certain aspects relate directly Co the closure of land treatment  facilities.
Specifically, these include steps 25 through 39, described as follows:

Closure:       Step 25.  Evaluate Soil
               Step 26.  Evalute pH Level
               Step 27.  Evaluate Nitrogen and Organic Matter
               Step 28.  Evaluate Other Nutrients
               Step 29.  Evaluate Species Selection
                                     8-172

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                                         ana Trees
               Seep 31.  Evaluate Time of Seeding
               SCep 32.  Evaluate Seed and Surface Protection

Post-Closure:  Step 33.  Evaluate Design/Maintenance
               Step 34.  Evaluate Maintenance of Vegetation
               Step 35.  Evaluate Provisions for Condition Surveys
               Step 36.  Evaluate Plan for Erosion Damage Repair
               Step 37.  Evaluate Plan for Vegetation Repair
               Step- 33.  Ivaluace Plan for Drainage Renovation
               Step 39.  Evaluate Plan for Other Cover Deterioration

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

     Evaluate maintenance procedure (Steps 33-35) - Regular maintenance
intervals should be planned to repair erosion damage and to maintain the
vegetative cover.  Provisions should also be made for site monitoring by a
qualified individual to periodically inspect the cover condition.

     Evalute contingency plan (Staps 36-39) - A contingency plan should be
established to deal with future unforeseen problems such as excessive wind and
water erosion, loss of vegetation, and drainage system failures.  The permit
reviewer should evaluate the effectiveness of the applicant's post-closure
plan to address such prooterns in a timely manner.

8.5.3  Draft Permit Preparation

     In addition to compliance with Che closure plan requirements of §264.112,
the permit issued must specify that the land treatment unit be closed in
accordance with 40 CFR §264.280.  If the Permittee successfully demonstrates
in accordance with §264.280(d) that the level of hazardous constituents in the
treatment zone soil does not exceed the background value of those constituents
by a statistically significant amount, he is not subject to regulation under
§§264.280(a)(8) and (c).  The Permittee who satisfies the requirements of
§264.280(d) is also not subject to regulation under Subpart F, if the
monitoring program established under Condition E of Permit Module XIV
indicates that hazardous constituents have not migrated beyond the treatment
zone during the active life of the land treatment unit.  Condition M of Permit
Module II outlines general facility closure requirements.

     Conditions of the permit, which can be implemented by reference Co
portion* of Che Part B permit application, should specify che following:

     •    plant species to be grown,

     •    procedures to ensure vegetative establishment, and

     •    techniques to maintain the cover during the post-closure care period,
                                    8-173

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Jepenaing on the sice and hazardous constituents applied,  particularly
persistent organic compounds,  the permit writer may wish Co state  in the
facility permit, the level of  treatment, specifically degradation  or
transformation,  required prior to start of post-closure care.   The degree of
treatment achieved may be determined from unsaturated zone monitoring results,
treatment zone analyses, and run-off liquid quality data.
                                     8-174

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 1.  U.S. Environraencai Protection Agency.  RCRA Guidance Document, Land
     Treatment.  Draft Report.  Office of Solid Waste.  January 1983.

 2.  U.S. Environmental Protection Agency.  Hazardous Waste Land Treatment.
     Prepared by K. W. Brown and Associates, Inc., for U.S. Environmental
     Protection Agency, Municipal Environmental Research Laboratory, Solid and
     Hazardous Waste Research Division.  Cincinnati, OH.  Report No. SW-374.
     1983.

 3.  Phung, T., et al.  Land Cultivation of Industrial Wastes and Municipal
     Solid Wastes:  State-of-the-Art Study.  Volume I, Technical Summary and
     Literature Raviaw.  rraparea oy SCS Engineers for U.S. Environmental
     Protection Agency, Municipal Environmental Research Laboratory,
     Cincinnati, OH.  EPA-600/2-78-140a.  August 1978.

 4.  Overcash, M. R.,  and D. Pal.  Design of Land Treatment Systems for
     Industrial Wastes, Theory and Practice, Ann Arbor Science.  Ann Arbor,
     Michigan.  1979.

 5.  Parr, J. r., et ai.  Land Treatment of Hazardous Wastes, Noyes Data
     Corporation, Park Ridge, New Jersey.  1983.

 6.  Tolman, A. L., et al.  Guidance Manual for Minimizing Pollution from
     Waste Disposal Sites.  Prepared by A. W. Martin, Associates,  Inc. for
     U.S. Environmental Protection Agency, Municipal Environmetal  Research
     Laboratory, Cincinnati, OH.  EPA Report No. EPA-600/2-78-142.  August
     1978.

 7.  Lutton, R. J.  Evaluating Cover Systems for Solid and Hazardous Waste,
     Prepared by U.S.  Army Engineer Waterways Experiment Station for U.S.
     Environmental Protection Agency, Solid and Hazardous Waste Research
     Division, Cincinnati, OH.  EPA Report SW-867.  September 1982.

 8.  Page, A. L.  Fate and Effects of Trace Elements in Sewage Sludge when
     Applied to Agricultural Lands.  A Literature Review Study.   U.S.
     Environmental Protection Agency, EPA-670/2-74-005.  January 1974.

 9.  Allaway, W. H.  Agronomic Control Over Environmental Cycling  of Trace
     Elements, Adv. Agron.  20:235-274.  1968.

10.  Chaney, R. L., and P. M. Giordano.  Microelements as related  to plant
     deficiencies at toxicities.  pp. 234-279.  In:  L. F. Elliot  and
     R. J. Stevenson (ed.) Soils for Management of Organic Wastes  and Waste
     Waters.  American Society of Agronomy, Madison, WI.  1977.

11.  U.S. Environmental Protection Agency.  Evaluating Cover Systems for Solid
     and Hazardous Waste, Second Edition.  EPA Report No. SW-867.
     September 1982.
                                     8-175

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3.3  .SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTES

B.b-l  Federal Requirement

     Section 270.20(g) states:

               "If ignicable or reactive wastes will be placed in or on che
          treatment zone, an explanation of how the requirements of §264.281
          will be complied with."

     The corresponding Part 264 standards, §264.281 states that the owner or
operator must not apply ignitable or reactive waste to the treatment zone
unless:

               "(a)  The waste is immediately incorporated into the soil so
          that:
               (1)  The resulting waste, mixture,  or dissolution of material
          no longer meets the definition of ignitable or reactive waste under
          §§261.21 or 261.23 of this chapter; and
               (2)  Section 264.17(b) is complied with; or
               (b)  ""he waste is managed i.n such a way that it is protected
          from any material or conditions which may cause it to ignite or
          react."

     Section 261.21 states:

               "(a)  A solid waste exhibits the characteristic of ignitability
          if a representative sample of the waste has any of the following
          properties:
               (1)  It is a liquid, other than an aqueous solution containing
          less than 24 percent alcohol by volume and has flash point less than
          60°C (140°F), as determined by a Pensky-Martens Closed Cup Tester,
          using the test method specified in ASTM Standard D-93-79 or D-93-80
          (incorporated by reference, see §260.11), or a Setaflash Closed Cup
          Tester, using the test method specified in ASTM Standard D-3278-78
          (incorporated by reference, see §260.11), or as determined by an
          •equivalent case method approved by the Administrator under
          procedures set forth in §§260.20 and 260.21.
          [261.21(a)(D amended by 46 FR 35247, July 7, 1981]
               (2)  It is not a liquid and is capable, under standard
          temperature and pressure, of causing fire through friction,
          absorption of moisture or spontaneous chemical changes and, when
          ignited, burns so vigorously and persistently that it creates a
          hazard.
               (3)  It is an ignitable compressed gas as defined in
          49 CFR 173.300 and as determined by the test methods described in
          that regulation or equivalent test methods approved by the
          Administrator under§§260.20 and 260.21.
               (4)  It is an oxidizer as defined in 49 CFR 173.151.
               (b)  A solid waste that exhibits the characteristic of
          ignitability, but is not listed as a hazardous waste  in Subpart 0,
          has the EPA Hazardous Waste Number of D001."
                                     8-176

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     if a representative sample of ;he *ascd nas any oi che following
     properties:
          (1)  It is normally unstable and readily undergoes violent
     change without :etonating.
          (2)  It reacts violently with water.
          (3)  It forms potentially explosive mixtures with •;a."3r.
          (4)  When -ni::ad »i:h wacer,  ic generates toxic gases,  vapors or
     fumes in a quantity sufficient to present a danger to human health
     or the environment.
          (5)  It is a cyanide or sulfide bearing waste which.  vHen
     exposed to pH conriiti^r.c j«cweea 2. ana j.2.5, can generate  toxic
     gases, vapors or fumes in a quantity sufficient to present a danger
     to human health or the environment.
          (6)  It is capable of detonation or explosive reaction if it is
     subjected to a strong initiating source or if heated under
     confinement.
          (7)  It is readily capable of detonation or explosive
     decomposition or reaction at standard ".eraoerature and pressure.
          (3)  It is a foroidden explosive as defined in 49 CFR 173.51,
     or a Class A explosive as defined in 49 CFR 173.53 or a Class 3
     explosive as defined in 49 CFR 173.38.
          (b)  A solid waste that exhibits the characteristic of
     reactivity,  but is not listed as a hazardous waste in Subpart D, has
     the EPA Hazardous Waste Number of D003."

Section 264.17(b) states:

          "(b)  Where specifically required by other Sections of this
     Part, Che owner or operator of a facility that treats, stores or
     disposes ignitable or reactive waste, or -aixes incompatible waste or
     incompatible wastes and other materials, must take precautions to
     prevent reactions which:
          (1)  Generate extreme heat or pressure, fire or explosions, or
     violent reactions;
          (2)  Produce uncontrolled toxic mists, fumes, dusts,  or gases
     in sufficient quantities to threaten human health or the environment;
          (3)  Produce uncontrolled flammable fumes or gases in
     sufficient quantities to pose a risk of fire or explosions;
          (4)  Damage the structural integrity of the device or facility;
          (5)  Through other like means threaten human health or the
     environment.
          (c)  When required to comply with paragraphs (a) or (b) of this
     Section, the owner or operator must document thac compliance.  This
     documentation may be based on references to published scientific or
     engineering  literature, data from trial tests (e.g., bench scale or
     pilot scale  tests), waste analyses (as specified in §264.13), or the
     results of the treatment of similar wastes by similar treatment
     processes and under similar operating conditions."
                                3-177

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       Summary or Necessary Application Information

     The applicant should submit a derailed written plan for managing
ignitable or reaccive wastes that will be placed in or on che treatment zone.
The plan should include:

     •    name and chemical composition of waste,

     •    provisions for immediate sail ;.acorporacion of waste,

     •    test results showing chat wastes are no longer ignitable or reactive
          following soil incorporation, and

     v    handling proceaures and safety precautions for preventing conditions
          which may cause the waste to ignite or react.

8.6.3  Guidance on Evaluating Application Information

     The provisions of 5264.281 require good operating practice to ensure the
safe handling of any ignitable or reactive wastes that might be applied Co che
land treatment unit.  As ^tatad in :he /art 264 standard, the owner or
operator must handle such waste such that it is incorporated into the soil
immediately, or managed in a way such that :he material will not ignite or
react.  The management techniques to meet the latter condition Jill vary
depending on specific waata cypes.

     If an applicant provides information cnat none of the wastes intended for
land treatment are reactive or ignitable, the provisions discussed in this
section do not apply.  Information chat vould be acceptable includes the
re-julca of Casts or analyses conducted on the wastes by the land treatment
facility owner or operator, or the waste generator.  Documentation based on
information or data in the scientific or engineering literature is also
acceptable.  If the applicant has demonstrated that all wastes are neither
ignitable nor reactive, the permit writer must indicate in the permit that
ignitable or reactive wastes are not permitted for receipt or application at
the land treatment facility.

     The characteristic of ignitability is exhibited by a solid waste if it
has any of the four properties listed in §261.21(a) (see Section 8.6.1
above).  Specifically, §261.21(a)(1) addresses liquids, §261.21(a) (2)
addresses nonliquids, §261.21(a)(3) addresses compressed gases, and
§261.21(a)(4) addresses oxidizers.  The provisions of  §261.21(a)(1) identify
three ASTM standard methods that can be used to determine ignitability.  They
are:

     •    ASTM Standard D-93-/9

     •    ASTM Standard D-93-80

     •    ASTM Standard D-3278-78
                                     8-178'

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 These -sechods  1:2 aijo iascrioea  in  Secc^oi 1*1.1  :: TJS.. .-leiinoas  tor
 Evaluating  Solid Waste, Physical/Chemical Methods.^  Descriptions  and  Cesc
 methods  for  ignitable compressed gases and oxidi^srs are also described  in
 Section  2.1.1  of the referenced report.

     The characteristic of reactivity is exhibited by a. solid waste  if it has
 any of the eight properties listed in §261.23(a) (see Section 3.6.1  above).
 Those properties are based largely on the definition employed by the National
 Fire Protection Association.  The NFPA's headquarters are in Batterymarch
 Park, Quincy,  MA  02269 and there is also a Washington, D.C. Office.
 Telephone numbers are:

     General and Executive Offices     (617) 328-9290

     Publication Saxes                 (617) 770-3002

     Washington, D.C. Office           (202) 484-8200

 Detailed information on identification and testing of reactive wastes  is
 provided in Section 2.1.3 of Test Methods for Evaluating Solid Waste,
 Physical/Chemical Metho'ds.

     In addition to using the methods referenced in the regulations, the
 permit applicant may use other methods to determine ignitability or reactivity
 if he has petitioned and received approval from the Administrator, as  allowed
 under §260.20  and §260.21.  If che permit reviewer encounters methodologies
 whose acceptability can not be determined, the Manager of the Waste Analysis
 Program  (WH-565), Waste Characterization Branch, Office of Solid Waste,
 Washington, D.C.  20460 (202) 755-9187 should be contacted for assistance.

     Documentation that the precautions of §264.17(b) will be effective  is
 required by §264.17(c).  Specifically, §264.17(c) requires that;

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

 The owner or operator of a land treatment facility who is treating ignitable
or reactive wastes must document that the treatment employed will not  itself
be hazardous.  The permit application may be judged deficient if the required
documentation  is not submitted or if it is judged co be inadequate.

     Figure 8.6.1 presents the major topics that are discussed in  this
 section.   The permit reviewer should first determine which of the  technical
 topics are applicable to the facility and operation of concern.  For instance,
 if the applicant proposes to manage the waste in conformance with  the
 requirements of §264.281(b), than the discussion about treating, rendering, or
                                    8-179

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                                 LIST OF
                        IGNITABLE AND/OR REACTIVE
                                 WASTES
    IMMEDIATE INCORPORATION
      OF WASTE INTO SOIL
                                      MANAGEMENT OF
                                     WASTE TO PREVENT
                                     IT FROM IGNITING
                                       OR REACTING
    METHODS TO TREAT, RENDER
    OR MIX THE WASTE 30 THAT
        IT IS NO LONGER
     IGNITABLE OR REACTIVE
            TEST FOR
         COMPATIBILITY
       TEST TO DETERMINE
    IF WASTES ARE IGNITABLE
          OR REACTIVE
Figure 8.6.L.
Flow diagram for evaluating Che tecnnical adequacy of  Che
application for disposal of ignicable or reactive waste.
                                   3-130

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mixing Che waste so that it is no longer ignitaoie does  noc  applv.   if  anv ?f
the associated copies are noc adequately adarsssea by -ne applicant,  ;he
application and the proposed disposal methods may be tecnnically deficient.

8.6.3-1  Lists of Ignitable and Reactive Wastes —
     In Part 261, Subpart D, (Lists of Hazardous Wastes], ignitable wastes are
denoted by an "(I)" and reactive wastes are denoted with an  "(R)".
Table 8.6.1 lists the hazardous vastss, by SPA Hazardous Waste number,  that
are identified in Subpart D as being ignitable.  Table 8.6.2 lists  the
hazardous wastes, by EPA Hazardous Waste number, that are identified in
Subpart D as being reactive.  At a minimum, if the applicant indicates  that
any of these wastes will be treated ac "ha facility, ae  .aust document TOW
compliance with §264.281 will be achieved.

     The permit reviewer should refer to A Method for Determining the
Compatibility of_Hazardous. Wastes2 for assistance in evaluating the
application.  This reference provides a list of 174 chemicals which are
extremely reactive and therefore should not be mixed with ^atar, or other
chemicals or waste materials.  If these "extremely reactive" compounds  are
mixed with water or -nost other compounds, heat may be generated, or toxic
and/or flammable gases may be produced.  In addition, explosions may occur,  or
highly unstable mixtures may result.

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

     «    Metals, such as sodium and potassium

     *    Nitrides

     •    Sulfides, Inorganic

     •    Strong Reducing Agents

     Reference 2 also provides a list of materials which ara combustiole  and
flammable and a list of materials which are explosive.

8.6.3.2  Methods to Treat, Render, or Mix Waste so that  it is no longer
         Ignitable or Reactive—
     There are a number of methods available to treat, render, or mix wastes
so that they are no longer ignitable or reactive.  Several treatment processes
which previously were only used in the organic or inorganic  chemical industry
are being considered for broader applications in the treatment of hazardous
waste.  Over 50 processes have been demonstrated to be aoplicable *.o hazardous
waste treatment, although the technical and economic feasbility of a number of
these processes has not been demonstrated on a commercial scale.  Table 8.6.3
identifies several of the most promising nonbiological treatment methods  along
with general information regarding feed stream requirements, output streams,
and the current state of technology.3-8  xhe applicant may propose to employ
one or a combination of these methods to treat ignitable or  reactive wastes
prior to, application.
                                      8-181

-------
              lABLS 3.6.L.  IGNITABLE WASTES
EPA hazardous
  waste No.
             Hazardous waste
    F003
    F005
    U001
    U002
    U003
    LJ008
    'JO.12
    UO12
    U019
    U239
    'JO 5 6
    •J055
    U169
    U085
    U0.31
    U159
    U074
    U031
    U156
    U055
    U056
    U057
    U074
    U085
    U092
    uuo
Spent nonhalogenacea soivencs
Spent nonhalogenated solvents
Acataldehyde
Acacic acid, ethyl aster
Acetone
Acetonitrile
Acrylic acid
Aniline
^enzenamine
Benzene
Benzene, dimethyl-
Benzene, hexahydro-
Senzene, (1-metnylethyl),
Benzene, nitro-
2,2-bioxizane
t-butanol
2-butanone
2-butene, 1,4-dichloro-
n-butyl alcohol
Carbonochloridic acid, methyl ester
Curanene
Cyclohexane
Cyclohexanone
I,4-dichloro-2-butene
1,2:3,4-diepoxybutane
Dimethylamine
Dipropylamine
                         (continued)
                            8-182

-------
                    TASL
                        r  a
              .concinuea;
EPA. hazardous
  waste No.
             Hazardous waste
    U001
    U008
    U117
    'J112
    LJ113
    U115
    U117
    U125
    U213
    U125
    U124
    U140
     152
    U092
    U045
    U153
    U154
    U154
    LJ186
    U045
    UL56
    U159
    U161
    U162
    U161
    U169
    U171
Ethanol
Ethanenicrile
Echane, 1,1-oxybis
Echyl  acacaca
Echyl  acrylace
Echlene oxide
Echyl  echer
2-curancarboxaldehyde
Furan, cecrshydro-
Furcura1
Furfuran
Isobucyl alcohol
Me ehacry tonic rile
Mechanamide,  N-mechyl
Mechane, cnloro-
Mechanethiol
Mechanol
Mecnyl alcohol
1-mechyl oucadiene
Methyl chloride
Methyl chlorocarbonate
Methyl ethyl  ketone
Methyl isobutyl ketone
Methyl tnethacrylate
4-methy1-2-pentanone
Nitrobenzene
2-ni tropropane
                        (concinued)
                            3-183

-------
                     TABLE 8.6.1 (continued)
EPA hazardous
  waste No.
             Hazardous waste
    U115
    U186
    U194
    JLiO
    U171
    U140
    LJ002
    'J152
    J008
    I'll 3
    U162
    U194
    J213
    IJ15 3
    U239
Jxirane
1,3-pentadiene
1-propanamine
1-propanamine
Propane,  2-nicro
1-propanol,  2-raechyl-
2-propanone
2-propenenicriLe, 2-mechyl
2-propenoic acid
2-propenoic acid, ethyl aster
2-propenoic acid, 2-mechyl-, methyl ester
n-propylamine
Ie trahydrofuran
Thiomethanol
Xylene
                             8-184

-------
                          TABLE 8.0.2.   REACTIVE  WASTES
EPA hazardous
waste number
                   Hazardous waste
    F007

    F008

    F009

    F010

    F011

    tcon

    K013

    K027
    K045



    KOA7

    P009

    P065

    P112

    P081

    P009

    PI 12

    P112
Spent cyanide plating oatn solutions ...

Plating bath sludges ...

Spent stripping ^nd cleaning oacn solutions  ...

Quenching bath sludge ...

Spent cyanide solutions from salt bath  ...

Sotcom stream from wastawater ... aeryionitrile

Bottom stream from the acetonitrile column ...

Cencrifuge and distillation residues from toluene

  dusocyanate production

Wastewater treatment sludges from the manufacturing and

  processing of explosives

Spent carbon from the treatment of wastewater containing

  explosives

Pink/red water from TNT operations

Ammonium picrate

Mercury fulminate

Methane, tetranitro-

Nitroglycerine

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

Tetranitromethane

Zinc phosphide
                                  (continued)
                                     8-185

-------
                           TABLE 8.6.2 fcontinued)
EPA hazardous
waste number
                   Hazardous waste
    U006

    U223

    •JO 20

    U023

    U024

    U023

    LT160

    LF033

    U033

    U133

    U096

    U006

    U133

    U086

    U189

    U205

    U189

    U205

    U223

    U234
Acetyl chloride

Benzene,  1,3-diisocyanacomechyL

oenzenesulfonyl chloride

Benzene,  (crichloromecny1)

Benzene,  1,3,5-trinicro-

Benzotrichloride

2-buCanone peroxide

Carbon oxyfluoride

Carbonyl  fluoride

Examine

Alpha, alpha-dimechyI benzylhydroperoxide

Echanoyl  chloride

Hydrazine

Hydroperoxide, 1-mechy1-1-phenyethyl-

Phosphorous sulfide

Selenium disulfide

Sulfur phosphide

Sulfur selenide

Toluene diisocyanate

Sym-crini trobenzene
                                      8-186

-------











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                           8-189

-------
     The applicant may pro-pose to render ignitable or reactive compounds
nonignitable or nonrsactive by diluting :ha -asce wi.cn ocner compatible
material.  However, dilution has the obvious disadvantage in that hazardous
reactions may result if the materials being mixed are incompatible.  In
addition, dilution with liquids is undesirable because of added liquids to the
land treatment unit and greater attendant leachate generation.  If other than
a small quantity of waste requires dilution, the reviewer may elect to require
an alternative treatment process to ainimize che application of liquids that
might affect the units water balance.

     There are a number of data sources which may assist the reviewer in
evaluating an applicant's oropos«d method of waste treatment, when required,
including references 3 through 17 listed in subsection 8.6.5.  The reviewer
should refer to Chapters 8 and 9 of Metry9 which lists an additional 200
references on physical and chemical treatment of hazardous waste.

8.6.3.3  Test for Compatibility—
     The permit reviewer should refer to A Method for Determining the
Compatibility of Hazardous Waste^ which addresses hazardous waste
compatibility.  A hazardous waste compatibility chart (see subsection 3.7.3 of
this manual) is presented which illustrates the compatibility of 41 binary
combinations of hazardous chemical wastes.  The reason for incompatibility is
also noted for each combination.  Further discussion of incompatible wastes is
presented in subsection 3.7.3.

3.6.3.4  Testing of Ignitable and Reactive Waste—
     After a treatment process has been employed, the applicant must test or
document by some other means that che waste is no longer ignitable or
reactive.  If testing is to be employed, the applicant must specify what
testing procedures he will use.  Available methods to test for ignitability
are set forth in §261.21.  Two test methods are acceptable for determining the
flash point: Pensky-Martens Closed Cup Tester using the test method specified
in ASTM standard D-93-79 or D-93-80, or a Setaflash Closed Cup Tester, using
the test method specified in ASTM Standard D-3278-78.

     To test if a treated waste has the characteristics of reactivity, the
applicant should base his demonstration on tests for: water reactivity, flash
point/flamability, oxidation/reduction potential, pH, and the presence of
cyanide or sulfide.  The testing procedures employed should conform with the
ASTM standards and test methods incorporated in Test Methods for Evaluating
Solid Waste.1

8.6.3.5  Site Management to Prevent Ignition—
     Th« applicant must specify handling methods to avoid heat, sparks,
rupture, or any other condition that might cause ignition of the waste.  The
applicant should specify the types of handling equipment and management
procedures that will be employed.  All equipment should be constucted of
nonsparking materials.
                                   8-190

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     If an applicant proposes to place an ignitable wasta Ln the sase
treatment unit with another waste cype, it aus t be determined whether thi-s
other waste type may react exothermicaily vith water and generate sufficier.c
heat to cause ignition.  However, wastes which are reactive with water shoul.
not be treated at the unit.  Section 264.281(a) requires that any reactive
waste be incorporated into the soil immediately after application so that th.
resulting waste, mixture or dissolution of material no longer meets the
definition of ignitable or reactive waste under §261.21 or §261.23.
Nonetheless, the reviewer should check to be certain that any wastes which  i
to be co-disposed with an ignitable waste are nonreactive.  In Part 261,
Subpart D - Lists of Hazardous Wastes, the wastes that are reactive are
designated by an "(R)" hazard code.  Also, any waste which has an SPA
hazardous waste number of 2:002 ^xnibits trie characteristics of reactivity.
rhe reviewer should cross-check those wastes which will be co-disposed with  i:
ignitabla waste with the wastes in the Subpart D list which are reactive
(listed in Table 8.6.1 of this section).  However, not all of the waste in  t:v
Subpart D list which are designated to be reactive, will react exotherraical !•-•
with water.  A wasta is reactive if it exhibits any of the eight properties
listed in §261.23.

     Figure 3.5.2 presents A worksheet that can be used to evaluate the
applicant's plan to properly handle ignitable or reactive wastes to be
disposed of at the land creatment unit.

3.6.4  Draft Permit Preparation

     Condici-n G of Permit Module XIV (see Section 4) covers the special
requirements for ignitable or reactive wastes, if chey are to be handled a~
the land treatment facility.  Permit conditions co be specified may be
implemented by reference to applicable sections of the Part 3 permit
application.  Items covered by Condition G are as follows:

     G.I. The Permittee shall not place ignitable or reactive waste in a land
          treatment unit unless the practice described in Attachment   are
          followed, as required by 40 CFR 264.231.

     (Note:  The attachment must demonstrate how the facility will handle
     ignitable and reactive wastes as required by 40 CFR 264.281.  If the
     application does noc address this, the permit writer should write
     specific conditions co implement this provision or should condition the
     permit so as noc to allow this practice.]

     G.2. The Permittee shall document compliance with Condition G of Perai:
          Module XIV as required by 40 CFR 264.17(c) and place this
          documentation in rhe operating record (see Module II, Condition L.I

     [Note:  Condition G of Module XIV applies only to facilities that store
     ignitable or reactive waste in land treatment units.]
                                   3-191

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              SPECIAL  REQUIHfMINTS  JOR  IGNITA3LE  OR  REACTIVE WASTES


Are any wastes Co be land created ignitable or reactive?        	
                                                                  yes      no
If ignicahle or reactive wastes are going to be created,
has the applicant provided a description of how the waste
will be incorporated into the soil and how the waste/
soil mixture will be tested to determine that it is no              •
longer ignitable or reactive?                                     yes

Does the application provide a description of how the
requirements of §264.17(b) will be net?                         	
                                                                  yes      no

If the owner or operator elects co comply with §264.281(b),
does che application describe how tne site will be managed      	   	
to prevent tne waste aoolied from igniting or reacting?           yes      no
        .gure 3.5.2.  Worksnaet to evaluate applicant's plan  for handling
                     ignitable or reactive wastes.
                                  3-192

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8.6.5  References

 1.  U.S. Environmental Protection Agency.   Test Methods for Evaluating Solid
     Waste,  Physical/Chemical Methods.  U.S.  EPA, Office of Solid Waste.
     Second Edition.   SW-846.  July 1982.

 2.  Hatayama, H. K.,  et. al., A Mathod for Cecermining the Corapatability of
     Hazardous Wastes.   U.S. Environmental  Protection Agency, Municipal
     Environmental Research Laboratory, Cincinnati,  Ohio,  EPA-600/2-80-076.
     April 1980.

 Z.  JRB Associates,  Inc., Techniques for Evaluating Environmental Processes
     Associated with  the Land Disposal of Specific Hazardous Materials,
     Volume I: Fundamentals.  EPA Contract  No. 68-01-5052, March 31, 1982.

 4.  DeRenzo,  D. J.,  Unit Operations for Treatment of Hazardous Industrial
     Wastes.  Noyes Data Corp., 1978.

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

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

 7.  Edward,  B. H., et al.  Emerging Technologies for the Destruction  of
     Hazardous Waste.  Ultraviolet 10 Zone Destruction.   In:   Proceedings of
   •  the Seventh Annual Research Symposium on Land Disposal  of Hazardous
     Wastes.  Philadelphia.   U.S. EPA—Municipal Environmental Research
     Laboratory.  (EPA-600/9-81-002b),  1981.

 8.  Miller,  R. A., et al.,  Evaluation of Catalytic Wet Oxidation  for
     Treatment of  Hazardous Wastes.   In:  Proceedings of  Seventh Annual
     Research Symposium on  Land Disposal of Hazardous Wastes.   Philadelphia.
     U.S. EPA—Municipal  Environmental Research  Laboratory.
     (EPA-600/9-81-002b),  1981.

 9.  Metry, Amir,  A., The Handbook of  Hazardous  Waste Management.   Technomic
     Publishing Company,  Inc., Westport, CT., 1980.

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

 11.  EPA-600/2-82-001C, Treatability Manual.  Volumes  I-IV.   U.S.
     Environmental Protection Agency,  Washington, D.C., Sept.  1981.
                                      8-193

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

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

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

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

16.   Nfermerow, N.L., Liquid Waste of Industry: Theories, Practice, and
     Treatment.  Addison-Wesley Publishing Co., Reading, MA, 1972.

17.   Toxic and Hazardous Industrial Chemicals Safety Manual  for Handling and
     Disposal, with Toxicity and Hazard Data.  The International Technical
     Information Institute, Torahoraon-Tachikawa Bldg. 6-5, 1 Chome,
     Nishi-Shimbashi,  Minato-KW, Tokyo, Japan, 1975.
                                      8-194

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3.7  SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTES

8.7.1  Federal Requirement

     Section 270.20(h) states:

               "If incompatible wastes, or incompatible wastes and material;
          will be placed in or on the same treatment zone, an explanation j,
          how §264,282 vill be complied with."

     Section 264.232 states:

               "The owner ->r operator iusc not piace incompatible wastes, or
          incompatible wastes and materials (see Appendix 7 of this part for
          examples), in or on the same treatment zone, unless §264.17(b) is
          complied with."

     Section 264.17(b) states:
                     Where specifically required by other Sections of this
          Part, the owner or operator of a facility that treats, stores or
          disposes ignitable or reactive waste, or mixes incompatible waste o
          incompatible wastes and other materials, must take precautions to
          prevent reactions which:
               (1}  Generate extreme heat or pressure, firs or explosions, or
          violent reactions;
               (2}  Produce uncontrolled coxic aiists, fumes, dusts, or gases
          in sufficient quantities to threaten human health or the environment
               (3)  Produce uncontrolled flammaola fumes or gases in
          sufficient quantities to pose a risk of fire or explosions;
               (4)  Damage the structural integrity of the device or facility;
               (5)  Through other like means threaten human health or the
          environment.
               (c)  When required to comply with paragraphs (a) or (b) of this
          Section, the owner or operator must document that compliance.  This
          documentation may be based on references co puoiishea scientific or
          engineering literature, data from trial tests (e.g., bench scale or
          pilot scale tests), waste analyses (as specified in §264.13), or the
          results of the treatment of similar wastes by similar treatment
          processes and under similar operating conditions."

8.7.2  Summary of Necessary Application Information

     The application must include a written plan thac explains the procedures
and precautions for handling incompatible wastes and -naterials if such wastes
will be placed in or on the same treatment zone.  The plan must contain the
following information:

     •    name of incompatible materials or wastes,

     •    explanation of incompatibility,
                                  8-195

-------
     •    composition  of  incompatible  iacari?lj  i-d  «a_,u3,

     •    rate  and  schedule  of  incompatible waste  or material  applications  co
          the treatment zone,

     •    step-by-step procedures  for  managing incompatible  wastes  or
          materials to prevent  undesirable  reactions or  effects,  and

     •    laboratory or  field  data demonstrating that  incompatible  wastes  can
          be safely managed  at  the land  treatment  unit using Che  proposed
          procedures.

8-. 7 . 3  Guidance on Evaluating  Application Information

     If wastes from different  waste streams are to be  applied to  the  same
treatment zone, che owner or operator  must  demonstrate prior to application
that  the waste from different  streams  are compatible.   Table 8.7.1, adapted
from Appendix 7 of Part 264, presents  a  partial listing  of potentially
incompatible vastes, -'asta components, ana  materials,  along with  the  harmful
consequences which result from mixing  materials in one group with materials in
another group.

     The potential consequences identified  may result  from mixing of  an A
material with a B material within the  same  Group number.  Under certain
conditions, waste identified as being  incompatible may be applied to  the same
treatment zone.  For example:

     •    adding acid to water, then wacar Co acia, or

     •    a strong acid mixed with a strong base.

     Characterization of wastes to be  land created is  required of the
applicant under §264.13.   Waste analysis methods employed by the applicant can
be verified using Test Methods for Evaluating Solid Wasta.-

     Published scientific or engineering literature, data from actual testing,
or results  from the treatment of similar waste by similar treatment processes
and under similar operating conditions can be used to  determine that  the
applicant will comply with the requirements of §264.17(b).

     There  is no characterization of incompatibility in 40 CFR 261.  Rather,
Appendix V  of Part 264 presents examples of potentially incompatible wastes.
A definition of incompatible wastes is provided in §260,10 of  Suboart B of
Part 260.   Technical references are also available that identify incompatible
waste combinations, as discussed below.

     It is  the responsibility of the land treatment owner or operator to
identify whether or not wastes are compatible.  For commercial off-site land
treatment facilities, the variety of wastes received will likely result in
                                   3-196

-------
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                              8-197

-------
some cases of incompacibilicy.  For on-site land treatment facilities,  those
operated by the waste generator,  it is more likely thac the wastes will be
compatible.  If it is shown chat  all wastes are compatible with each other and
wich other materials treated at the site, the permit application is sufficient
with respect to the requirements  of §264.282.

     Based on a literal interpretation of the regulations, only a waste that
has already been identified as a  hazardous waste can be further identified as
an incompatible waste.  Specifically, the §260.10 definition states than an
incompatible waste "means a hazardous waste which..." and Aopendix 7 of
Part 264 states "Manv hazardous vsatas, whan auxed with...."  The intent of
cne regulations is fairly clear,  however, if any two (or more) materials or
wastes cannot be formed into a homogeneous mixture that neither separates nor
is altered by chemical interaction (Webster), they are incompatible and must
not be placed in or on the same treatment zone, unless the requirements of
§264.17(b) are met.  Thus, it is  the responsibility of the permit applicant to
compare each waste (hazardous and nonhazardous) to be treated at the facility
for compatibility with each other.

     Documentation that the precautions of §264,17(b) will be effective is
required by §2S4.l7(c).  Specifically, §264.17(c) requires that:

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

The owner or operator of the land treatment facility must supply documentation
that the procedures employed will not allow incompatible wastes to be placed
in or on the same treatment zone.  The permit application is deficient if the
required documentation is not submitted or if it is judged to be inadequate.
If the application indicates that incompatible wastes will not be placed in or
on the same treatment zone, then  procedures to insure that they will not
should be stated.  Also, if an application indicates that a waste will be
treated so that it is no longer incompatible prior to application,
documentation that the treatment  complies with §264.17(b) is required.

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

     A Method for Determining the Compatibility of Hazardous Wastes
(EPA-600/2-80-076, April 1980)2 was prepared for the EPA's Municipal
Environmental Research Laboratory bv researchers at the California Department
of Health Services.  The abstract of the report states:
                                   8-198

-------
           ''This  report  describes a method  for  determining  che  compatibility  of
      che  binary  combinations  jf hazardous  wastes.   The  method  consiacs  of  Cwo
      main parts,  namely:   (1)  Che step-by-scep compatibility analysis
      procedures,  and  (2)  the  hazardous wastes  compatibility chart.  The key
      element  in  the use of  the method  is the compatibility chart.  Wastes  Co
      be combined  are  first  subjected through the  compatibility procedures  for
      idnetification and classification, and the chart is used  Co predict che '
      compatibility of the wastes on mixing.

           The chart consists  of 41 reactivity  groups of hazardous wastes
      designated by Reactivity Group Numbers (RGN).  The RGN ara  •Ksolayed  ..-.
      binarv combinations  ;n :he jhart, and che compatibility of  the
      combinations is  designated by Reaction Code  (RC).

           The mechod  is applicable to  four categories of wastes  based on
      available compositional  information:  (1) compositions known
      specifically, (2) compositions known nonspecifically by chemical classes
      or reactivities, (3) compositions known nonspecifically by  common or
      generic names, of- wastes, and (4) compositions unknown requiring chemical
      analysis.''

The  79 references and 5 appendices provide a significant amount  of data on the
compatibility of various chemical wastes.

      The  other document, Techniques for Evaluating  Environmental Processes
Associated vith Land  Disposal of Specific Hazardous Materials, Volume II,
Incompatible Wastes,j March 31,1982, was prepared  for  the EPA Office of
Solid Waste by JRB Associates, Inc., McLean, Virginia.  This document
discusses  processes that enhance pollutant migration potential through  the
liquid phase in soils.  Three general processes were identified.  They are:

      •    direct solubility effects between waste constituents,

      •    chemical reactions between waste constituents which generate
          reaction products which ara -aore mobila than  the original waste
          constituents,  and

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

Conclusions and 18 references are included.

Razardoua Waste Compatibility

     Because many types  of hazardous wastes are extremely reactive, the
compatibility of hazardous wastes to be combined must be thoroughly
evaluated.  Combining wastes which are incompatible may result in: 3
(1) heat generation,  (2) fire, (3) toxic gases, such as HCN or ^S,
(4) flammable gases,  such as H2 or C2H2,  (5) explosion due to extremely
vigorous reactions or reactions producing enough heat to detonate unstable
reactants or reaction products, (6)  violent polymerization resulting in
generation of extreme heat and flammable gases, and (7) solubilization of


                                  8-199

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toxic substances including metals.   Consequencly,  the applicant TIUSt idanrirv
Che methods he vill 3rsploy for estimating the potential consequences of nixins
different classes of wastes.

     Insufficient or inaccurate information about  a waste or wastes  is the
primary cause of inadvertently combining incompatible wastes.  Regardless of
efforts to adequately characterize wastes via the  waste analysis plan,
properties of some wastes may change with time and temperature, thereby
producing acre or different hazardous components.3  A second cause of
accidents is indiscriminate handling of waste, such as haulers "topping off"
their load on the way to the disposal site.

     As previously mentioned, A Method for Determining the Compatibility of
Hazardous Wastes^ i3 a valuable resource document  for determining the
compatibility of binary waste combinations.

     The method provided in this report consists of two main parts:
(1) stepwise compatibility analysis procedures, and (2) use of a hazardous
waste compatibility chart.  Wastes under consideration are first identified
and classified and then the compatibility chart is used to assess the
compatibility of the wastes upon mixing.  The remainder of this section
provides background information for employing the  compatibility analysis
presented in the cited reference (2).  The five general steps necessary to
determine the compatibility of two waste types are summarized below.
Discussion of implementation of these steps is as  reported by Hatayaraa,
•sc al.4  Figure 3.7.1 summarizes the steps to be taken to determine
hazardous waste compatibility.

Step 1:  Waste Characterization

     The first step in determining the compatibility of two different waste
types is to accurately characterize the wastes.  The applicant should provide
as much information as possible about waste composition as required for
compliance with §264.13 (Waste Analysis Plan) and as part of the list of
hazardous wastes incorporated in the application [§270.20(a)(1) and (b)(l)].

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

     "Starting with one waste, Waste A, list the names of or the classes of
compounds found in the wastes, or list its generic name on the vertical axis
of the Worksheet for Determination of Hazardous Waste Compatibility
(Figure 8.7.2).  The composition of a waste is Known Specifically when the
constituents are listed by chemical names such as ethylene glycol,  sodium
nitrate, etc.  The composition is Known Nonspecifically by Classes when the
constituents are identified only by chemical classes or reactivities  such as
alcohols, caustics, mercaptans, etc.  The composition is Known Nonspecifically
by Generic Name when the waste is classified as spent caustic, tanning sludge,
copper plating waste, etc."
*Quoted from Hatayaraa, H. K., et al.  EPA-600/9-80-010, March 1980.
 (Reference 4.)

                                  8-200

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PROCEDURE FOR
HAZARDOUS WASTE


STEP
DETERMINING
COMPATIBILITY

1 :
WASTE CHARACTERIZATION

STEP

2:
LIST NAME OF COMPOUNDS OR
CLASSES OF COMPOUNDS OR
GENERIC NAME OF WASTE

STEP

3:
DETERMINE REACTIVITY
GROUP NUMBERS

STEP

4:
REPEAT STEPS 2 AND 3 FOR
OTHER WASTES OF CONCERN

STEP

5:
USING COMPATIBILITY CHART,
DETERMINE CONSEQUENCES OF
COMBINING TWO WASTES

Figure 8.7. 1.
Flow diagram for assessing che compacibilicy of hazardous
wasce using procedures specified in A Method for Determining
the Compacibility of Hazardous Wastes.  (Reference 2)
                                8-201

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Waste A

Waste B
Name of Waste
  EvaJ nation
                             Source

                             Source
                                       Date
WASTE A
Name
Reactivity
Group No.
   Figure 8.7.2.
       Worksheet  for  determination of hazardous
       waste compatibility.

       Source: Reference  2

                8-202

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5cep 3:*  Determine Reactivity Group Mumpers

     "When Che composition of Waste A is Known Specifically by chemical names,
consult the List of Chemical Names [in Appendix  I of Reference 2]  to obtain
the Reactivity Group Number (RGN) for each chemical constituent.   The  RGNs are
then noted on the Worksheet.  If a compound is not on the  list, a  synonym can
be found in various chemical references (Merck, 5 Hawley^).  When a.
sui-sola synonym cannoc oe found, the RGN of the component may alternatively
be determined baaed on its chemical class or reactivity.

     When the composition of the waste is Known  Specifically Hy ll.tsa^s,
•-.on -"•',.-. ths Ll.;c :f "/,'aai.a Constituents oy Chemical Class and Reactivity [in
Appendix II of Reference 2] to determine the corresponding RGN.

     When the composition of the waste is Known  Nonspecifically by Generic
Name, go to the Industry Index and List of Generic Names of Wastes  [in
Appendix III of Reference 2] to obtain the corresponding RGN and note  it on
the worksheet."

Step 4.:*  Repeat Steps 2 and 3 for Other Wa3te(a) of Concern

     "Repeat Steps 2 and 3 for Che second waste, Waste 8,  and note  the
information on the horizontal axis of Che Worksheet."

3tap 5:*  Using Compatibility Chart, Determine Consequences
3 f ComDining Two Was tes

     "Consult the Hazardous «aste Compatibility  Chart (Figure 8.7.3) and note
the Reaction Codes (RC) between all binary combinations of RGN of  Waste A and
Waste 8.  If any RC corresponds to any binary combination  of RGN between
Wastes A and 3, then Wastes A arid 3 are incompatible and should not be mixed."

Limitations of the Method

     Although this procedure jhould provide a useful aid in determining the
compatibility of hazardous waste, the method must be used with caution because
there are numerous factors which will influence waste component reactions.
Among these are temperature, catalytic effects of dissolved or particulate
metals, soil reactions, and reactions between the waste and surfaces it may be
in contact with.3  Consequently, the reviewer may elect to require  that the
applicant perform laboratory compatibility analysis prior  to actual
co-disposal of wastes.

Compatibility with Treatment Zone Processes

     In addition to assessing the compatibility of wastes  to be applied at the
treatment facility, it is important to evaluate  the impact of wastes applied
on the soil processes responsible for hazardous  constituent degradation,
*Quoted from Hatayama, H. K., et al.  EPA-600/9-80-010, March  1980.
 (Reference 4.)
                                   8-203

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          A/o Cumpt/undt Oti/n
                              s ind Hs  ij  rn  '
                                                                         f   F   M.  F
                                                                         CT CT  '  CT
         R«*KMf AfHIII. SffOAf
                                                           CT of  ar\  *i

10*
         **tMr Mrt Mix turn Com«iM«if *it«r
(07
         Wl«r (nct»« Sy*>
                                                                                .exTREMCLT
                                                                                   » ! 10
                                                                                          nu! "
        Figure  8.7.3.   Hazardous  waste  compatibility chart.

                             Source:  Reference  1
                                      8-204

-------
REACTIV TY CODE CCNSEQLENCES
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          8-205

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transformation, and immobilization.  Although this consideration should be
addressed under the Treatment Demonstration (see subsection S.I), it is mencionec
hera because it rauac be considered wnen assessing the compatibility of wastes
to he handled at the land treatment facility.

     Issues to be addressed include the effect of co-disposal of wastes on
soil microbes, soil pH, soil fertility, adsorption properties (e.g., CEC) of
treatment zone soil, and increased volatilization of organic constituents.

     Reactions between different waste types may result in increased soil
acidity, decreased soil fertility, increased soil temperature, and possibly
destruction of soil microbe populations.  All of thase concerns snouici oe
addressed by c.'.e hazardous waste treatment demonstration conducted in
accordance with §264.272.

     Figure 8.7.4 presents a worksheet to be used by the permit writer for
evaluating an applicant's submittal for meeting special requirements for
incompatible wastes.

3.7.4  Draft Permit Preparation

     Condition H of Permit Module XIV (see Section 4) addresses the special
requirements for incompatible wastes if they are to be treated at the land
treatment facility.  Permit conditions to be specified may be implemented by
reference to applicable portions of the Part 3 permit application.  Items
covered by Condition H are as follows:

     H.I  The Permittee shall not place incompatible wastes, or incompatible
          wastes and oiaterial, in or on the same treatment zone unless the
          procedures specified in Attachment 	 are followed, as required by
          40 CFR 264.17(b).

     [Note:  The attachment must specify how the Permittee will handle
     incompatible wastes so as to comply with 40 CFR 264.17(b).  If the
     application does not address this, the permit writer should write
     specific conditions to implement this provision or should condition the
     permit so as not to allow this practice.]

     H.2  The Permittee shall document compliance with Condition H.I of Permit
          Module XIV as required in 40 CFR 264.17(c) and place this
          documentation in the operating record (see Module II, Condition L.I).

     [Note:  Condition H of Module XIV applies only to facilities chac store
     incompatible wastes in land treatment units*]
                                   8-206

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                  SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTES


Have acceptable procedures been used Co accurately              	   	
characterize the wastes?                                          yes      no~

Were wastes properly catagorized by reactivity group            	
numbers?                                                          yes      no"

Was waste compatibility identified using the Reference 2        	   	
compatability chart or other acceptable means7                    yes

Does the compatibility assessment include all wastes            	
identified in Section 8.1?                                        yes
no
no
If wastes are incompatible and will be placed in or on
che same treatment zone, will che requirements of               	
§264.17(b) be mec?                                                yes
no
   Figure 8.7.A.   Worksheet for evaluating applicant's submittal for meeting
                  special requirements for incompatible wastes.
                                      8-207

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 1.7.5  References
1.   U.S. Environmental Protection Agency.  Test Methods for Evaluating Solid
     Waste, Physical/Chemical Methods.  U.S. Environmental Protection Agency,
     Office of Solid Waste, EPA Report SW-846.  July 1982.

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

3.   JRB Associates, Inc.  Techniques for Evaluating Environmental Processes
     Associated with Land Disposal of Specific Hazardous Materials, Volume II,
     Incompatible Wastes.  Prepared for the U.S. EPA Offica jŁ Solid Waste.
     March 31, 1?32.

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

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

5.   Hawley, G. G.  1971.  The Condensed Chemical Dictionary.  8th Edition.
     Van Nostrand Reinhold Company, New York, Cincinnati, Toronto, London,
     Melbourne.
                                   8-208

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3.3  TECHNICAL ADEQUACY CHECKLIST

     The cecnnical adequacy checklist presented in Table 8.8.1 provides a
summary of Che basic information needed to determine the completeness and
merit of Part B permit applications submitted for new and existing land
treatment facilities.  The checklist is organized according to the Part 270
permit requirements.  Completion of the checklist will enable determination of
application deficiencies,  whera '•hey ray exijc.  Deficiencies should be noted
and identified in the Notice of Deficiency (NOD) Co be issued to the applicant
pursuant to §124.3(c).
                                   8-209

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                                   SECTION 9.0

                                    LANDFILLS


     This  -.3<-~.^n pr«is
-------
      "5270.21  Specific Part 3 Information Requirements -sr Landfills
 Except as otherwise provided in 5264.L, owners and oserators
 of facilities chat dispose of '".^zaricuo -asLe ..n ianuciij.s must
 provide the  following additional information:
      (a) A list of the hazardous wastes placed or to be placed in
 each  landfill or landfill cell;
      (b) Detailed plans and an engineering report describing how the
 landfill is  or will be designed, constructed, operated and
 maintained to comply with the requirements of §264.301.  This
 submission must address the following items as specified in §264.301:
      (1) The liner system and leachate collection and removal system
 (except for  an existing portion of a landfill).  If an exemption
 from  the raquirsraancs e-r : linsr and « j.eachate collection and
 removal system is sought as provided by §264.301(b), submit detailed
 plans and engineering and hydrogeologic reports, as appropriate,
 describing alternate design and operating practices that will, in
 conjunction  with location aspects, prevent the migration of any
 hazardous constituent into the ground water or surface water at any
 future time;
      \2) Control of run-on;
      '2) Control at run-orf;
      (4) Management of collection and holding facilities associated
 with  run-on  and run-off control systems; and
      (5) Control of wind dispersal of particulace matter, where
 applicable;
      (c) If  an exemption from Subpart F of Pare 264 is sought, as
 provided by  5254.202(a), ;he owner or operator must submit detailed
 plans and an engineering report explaining the location of the
 saturated zone in relation co the landfill, the design of a
 double-liner system that incorporates a leak detection system
 between the  liners, and a ieachate collection and removal system
 above the liners;
      (d) A description of how each landfill, including the liner and
 cover systems, will be inspected in order to meet the requirements
 of §264,303  (a) and (b).  This information should be included in the
 inspection plan submitted under 5270.14(b)(5).
      (e) Detailed plans and an engineering report describing the
 final cover which will be applied to each landfill or landfill cell
 at closure in accordance with §264.310(a), and a description of how
 each  landfill will be maintained and monitored after closure in
 accordance with §264.310(b).  This information should be included in
 the closure  and post-closure plans submitted under §270.14(b)(13) .
      (Ł) If  ignitable or reactive wastes will be landfilled, an
 explanation of how the standards of §264.312 will be complied
 with;
      (g) If  incompatible wastes, or incompatible wastes and
materials will be landfilled, an explanation of how §264.313 will be
 complied with;
      (h) If  bulk or noncontainerized liquid waste or wastes
 containing free liquids is to be landfilled, an explanation of how
 the requirements of §264.314 will be complied with;
                              9-2

-------
               (i) If containers of hazardous waste are to be Landfillaa,  ^n
          explanation or how cne requirements of 3264.3L5 or §264.216, as
          applicable, will be complied -i;h."

9.1  WASTE DESCRIPTION

9.1.1  The Federal Requirement

     The Part 270 information requirements are:

               §270.21  "Except as otherwise provided in §264.1, owners and
          operators of facilities that dispose of hazardous waste in 1andf\l 1-
          must provide -_hs following aaaicionai  inrormation:  (a) A list of
          the hazardous wastes placed or to be placed in each landfill or
          landfill cell"

     Sufapart N, Landfills (§§264.300-264.339) of Part 264 does  not contain
specific requirements for waste identification.   However, in Subpart 3,
General Facility Standards,  the orovisions of §264.13, General  Waste Analysis,
require owners and operators of all waste facilities to identify ail wastes
handled.  Specifically, cne  requirements of §264.13(a),  (b), and (c) apply to
landfills and those requirements are:

               §264.13  General waste analysis
               "(a)(l) Sefore an owner or operator treats,  stores, or disposes
          of any hazardous waste, he must obtain a detailed chemical and
          physical analysis  of a representative  sample of the waste.  At a
          minimum, this analysis must contain all the information which must
          be known to treat, store, or dispose of cne waste in  accordance  with
          the requirements of this Part or with  the conditions  of a permit
          issued under Part  270, and Part 124 of this Chapter.
               (2) The analysis may include data developed under Part 261  of
          this Chapter, and  existing published or documented data on the
          hazardous waste or on hazardous waste  generated from  similar
          processes.
               (3) The analysis must be repeated as necessary to ensure that
          it is accurate and up to date.  At a minimum,  the analysis must  be
          repeated:
               (i) When the  owner or operator is notified,  or has reason to
          believe, that the  process or operation generating the hazardous
          waste has changed; and
               (ii) For off-site facilities, when the results of the
          inspection required in paragraph (a)(4) of this Section indicate
          that the hazardous waste received at the facility does not match the
          wa*ce designated on the accompanying manifest  or shipping paper.
               (4) The owner or operator of an off-site  facility must inspect
          and, if necessary, analyze each hazardous waste movement received at
          the facility to determine whether it matches the identity of the
          waste specified on the accompanying manifest or shipping paper.
                                       9-3

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               (b)  The owner or operator mist develop and follow 3 written
          waste analysis plan wni.ch describes che procedures which he will
          carry out to comply with paragrapn (a.j of this Section.  He must
          keep this plan at the facility.  At a minimum, the plan must specify:
               (1) The parameters for which each hazardous waste will be
          analyzed and the rationale for che selection of these parameters
          (i.e., how analysis for these parameters will provide sufficient
          information on the waste's properties to comply with paragraph (a)
          of this Section;
               (2) The test methods which will be used to tast for these
          parameters;
               (3) The sampling method which will be used to obtain a
          representative sarsplj it ;ne 
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 The  a DO I icant  Is  idv^jaa  rr.ac  .'a^cie  inai-'sis  .r. rcr-ia: icr.  -j  .-^qjirec  in  tae
 Par!:  A application  Bander  }270.tJ!j)) and  in  response  to  the  general  facilinv
 information  requirements  (under  5270.li(b)(2)).  The  Pare A  application  muse
 include:

      •     Specification of  the hazardous wastes  to be  disposed of

      •     Quantity  of wastes to  be disposed at the facility

      •     Quantity  of wastes to  be disoosed annually

      •     General description of processes  to be used  for such wastes

 If an existing  facility with interim  status submits a  Part 3  -.pplication which
 indicates  a  aifrerent listing than in the  original Part A application, a
 revised  Part A  application  is also required.  In this  case, the Part  B
 application  should  note the changes.

 9.1.3  Guidance on  Evaluating Application  Information

      The requirement for  3. waste description  is applicable to existing and new
 landfills  and  is  intended  to assure  that che  facility  can adequately  dispose
 of the proposed waste materials.

      For existing facilities operating under  interim  status,  the list of
 current and  expected wastes should include ail the wastes shown on the
 previously submitted Part A of the permit  application.  If the list shows
 fewer wastes than the Part  A, then sitEer  "he waste must have been
 specifically delisted since the  Part A_ was submitted  or the applicant must
 state in the application  that the wasce will no  Longer be accepted for
 disposal at  the landfill.   rhe list should be judged  inadequate if neither of
 these criteria are met.   For existing facilities operating under interim
 status, if the  list contains more wastes than indicated on the previously
 submitted  Part A, then the application must include a  revised Part A.  The
 application  is  incomplete if the revised Part A is not included.

      If the  landfill is a unit of a larger facility,  the Part A application
 will  incorporate a  listing of all wastes handled in all portions of the
 facility by  EPA ID number.  The wastes to be landfilled may be a subset  of
 this  list, or may result  from processing or treatment  of the noted wastes.
 Consequently, some or all of the wastes to be landfilled may not have an EPA
 ID number.

     An applicant could have difficulty supplying a detailed list of wastes
 that-have been placed in areas of an existing facility that have been inactive
 for long periods of time.  (If such a facility portion is closed before
 January 26, 1983, it is not a regulated unit and, therefore, the information
 requirement is not applicable unless ground water contamination is evident.)
 For existing active portions, the applicant should be  expected to indicate
whether the wastes were bulk or containerized, solid or liquid.   The owner's
records may also indicate 'the type of waste (e.g., empty raw materials
packages) or the type of process or operation that generated the waste (e.g,
                                     9-5

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distillation column bottoms).   In some cases, "he landfill may still be
disposing of wastes from the same company or processes and :!-,e owner or
operator can use that current information to help identify and characterize
the wastes placed in inactive areas of the facility.

     Experience in the review of historical records indicates that a
disposer's records will typically contain enough information to determine the
physical characteristics of wastes disposed and a generic description of the
waste.  However, records do noc usually supply much information on where at
the site a specific waste was buried or information that would allow a
definitive hazardous/nonhazardous determination.2  Thus, a judgement on the
adequacy of a list of wastes previously disoosed of at a facility may nave to
be .aade on a .ase-oy-case oasis after discussions with the owner or operator.

     New facilities must submit a Part A application with their Part 3 permit
application.  The information on waste types and quantities contained in the
Part A will generally be sufficient to meet the listing criteria for Part B.
However, unless the permit application for a new facility includes both a
Part A and a Part 3, the subraittal ^ust be judged incomplete.

     The regulations require a list of only the hazardous wastes.  However,  in
some cases it may be advantageous to have information on the nonhazardous
wastes that will be disposed.  This is especially important if hazardous and
nonhazardous wastes are to be intermingled, because a showing of compatibility
must be provided in the permit application.

     The most frequent reasons for listing a waste as hazardous will be that
the waste exhibits a characteristic identified in Subpart C of Part 261, that
it is specifically listed in Subpart D of Part 261, or chat it contains a
compound listed in Appendix VIII of Part 261.  However, the applicant may list
a waste as hazardous based on his knowledge of the waste or on the generator's
knowledge of the waste, even if it does not meet any of the criteria in
Part 261 that would require it to be listed.  Sampling and analytical
procedures recommended for hazardous waste characterization are presented in
SW-346—Test Methods for Evaluating Solid Waste.3

     For wastes placed in portions of a facility that have long been inactive,
the applicant may be unable to identify hazardous constituents in that waste.
Because the information on hazardous constituents is used to determine the
adequacy of other parts of the permit application (especially ground water
monitoring), the permit application reviewer will have to make case-by-case
judgements of adequacy whenever such situation's are encountered.

     Worksheets for evaluating the technical adequacy of the applicant's waste
listings are presented for existing facilities and new facilities in
Figures 9.1.1 and 9.1.2, respectively.  Completion of these worksheets will
allow the permit application reviewer to proceed through the first part of the
Technical Adequacy Checklist provided in subsection 9.9.
                                      9-6

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                  LISTING OF  HAZARDOUS  WASTES--EXIST I.VG JACILITY
Has cms part of che applicanc's subrniccal  been
reviewed and evaluated?                                   	   	   	
                                                           Ye s     No     Dace

Does che Pare B information agree completely  with  che  listing
information provided previously in  che  Part A application?        	   	
                                                                   Yes     No

Are waste names and EPA  ID numbers  identified?                    	   	
                                                                   Yes     No

Are locations identified wichin the  landfill  co  show where
wastes are or will be disposed of?                                	   	
                                                                   Ye s     No
If all answers are yes, this part of  the  applicant'3  jubmictai  is aaequace.
However, if any aifferences exist between the  Part  A  and  Part B applications-
Are only a subset of the wastes listed  in  Part  A co  be
landfilled?                                                       	   	
                                                                   Yes     No

Are one or more of the previously identified wasces  (in  Pare  A)
to be treated or somehow transformed j?efore  landfill ing?          	   	
                                                                   Yes     No

Have any of che wasces been delisted?                             	   	
                                                                   Yes     No

Have any of the subject landfill portions  been  closed?            	   	
                                                                   Yes     No

Is che apparenc discrepancy explained in che Part  B  application?  	   	
                                                                   Yes     No

Has che applicant submitted a  revised Part" A application?         	   	
                                                                   Yes     No

Describe any deficiencies in che applicanc's submittal,  if they  exist.
      Figure  9.1.1.   Worksheet for evaluating che adequacy of che  liscing
                     of hazardous wasces for existing facilities.
                                       9-7

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                    LISTING OF HAZARDOUS WASTES— MF>' TACILIIV
Has this part of Che applicant's submittal  been
reviewed and evaluated?                                   	   	
                                                           Ye s      No     Dace

Have bocn Part A and Part B applications been  submitted?          	   	
                                                                   Yes     No

Are waste names and EPA  ID numbers  identified?                     •       	
                                                                   Yes     No

Are locations identified within the landfill to  show where
wastes are or will be disposed of?                                	   	
                                                                   Yes     No

Are there any apparent discrepancies  in information provided
in Parts A and 3?                                                 	   	
                                                                   Ye s     No

Are- only a subset of the wastes listed in Part A to be
landfillad?                                                       	   	
                                                                   Yes     Mo

Will any wastes listed in Part A be created or transformed
to different wastes that will ultimately be landfillad?           	   _____
                                                                   Yes     No

Describe any deficiencies in  the applicant's submittal,  if  they exist.
       Figure 9.1.2.  Worksheet  for  evaluating the adequacy of the
                      lisring  of hazardous  wastes for new facilities.
                                       9-8

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 9.1.4  Draft Pennit  Preparation

      As noted in Module  XV,  Condition A,  the  pennit  writer imst  specify the
 wastes  that  can be disposed  of in  given landfill  units  at  the  applicant's
 facility.   In the body of the pennit, rather  than by attachment,  the wastes or
 classes of wastes that are allowed for disposal must be stipulated.   If any of
 these wastes are currently identified by EPA  identification numbers, these
.numbers should be included in the  listing of  wastes.

      If any  special  requirements are  attendant with  the noted  wastes because
 of reactivity, ignitability, incompatibility, or  other  concerns,  applicable
 permit  conditions or attachments should be cross-raŁ'»ranc3d a- ^naicton A.
 Permit  condition >*  -sd a-^acniaencs related to liner  selection  based  on
 waste/chemical resistance should also be referenced  at  permit  condition A.

      The fact sheet  (or  statement  of  basis) accompanying the draft permit
 should  include a paragraph at the  beginning to summarize the waste description
 or list incorporated as  condition  A in permit module XV.  Other  information
 wnich may  be appropriate to  explain briefly at this  point  in the  fact sheet is
 the amount of waste  expected to be handled on an  annual oasis.

 9.1.5  References

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

 2.    Telephone conversation.  J. McNeish,  Intera  Environmental -Consultants,
      Inc., and S. Caoone,  GCA/Tachnolo^y Division.   February 7,  1983.

 3.    U.S.  Environmental  Protection Agency. Test  Methods for Evaluating Solid
      Waste—Physical/Chemical Methods.   SW-846.   Second Edition.  July, 1982.
                                       9-9

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 9.2  DESIGN AND OPERATING REQUIREMENTS

     Section  264.301 specifies design and operating standards for Landfill
 components such as liners, leachate collection facilities, run-on and run-off
 control  facilities, and wind dispersal control systems.  Because of che broad
 coverage of the design and operating standards, the forthcoming discussion is
 subdivided to address each of these system components.  The remainder of this
 subsection is presented in the following manner:

     9.2.1  Liner System Design

     9.2.2  Leachate Collection ind ^e^oval i/ic-am

     9.2.3  Liner and Leachate Collection and Removal System Exemption

     9.2.4  Control of Run-on

     9.2.5  Control of Run-off

     9.2.6  Management of 'Jnitj Associated with Run-on and Run-off Control
            Systems

     9.2.7  Management of Wind Dispersal

     9.2.3  Subpart F Exemption

     The following subsections are incorporated under each of these sections:

     9.2._. 1  The Federal Requirement

     9.2._.2  Summary of Necessary Application Information

     9.2._.3  Guidance on Evaluating Application Information

     9.2._.4  Draft Permit Preparation

     9.2._.5  References

     The third subsection of each of the first eight sections provides guidance
on evaluating the technical adequacy of the application and includes worksheets
 for making this determination.  The fourth subseccion incorporates guidance on
 preparing Che draft permit based on the submitted application information and
model permit modules presented in Section 4 of this manual.

9.2.1  Liner System Design

9.2.1.1  The Federal Requirement—
     Paragraph(b) of §270.21 requires that the applicant's plans and/or
engineering report on landfill design, construction, operation, and
maintenance must address:
                                      9-10

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                . -1  The iiner systam. .  .

     The liner standards of 5264.301 stace  cnac:

               "(a) A landfill (except for  an existing portion of a landfill)
          must have:
               (1)  A liner that is designed, constructed, and installed to
          prevent  any migration of wastes out of  the landfill to the adjacent
          subsurface soil or ground water or surface water at anytime during
          the active life (including the  closure  period) of the landfill.   The
          liner must be constructed of materials  that prevent wastes from
          passing  into the liner during the active life of the facility.  The
          liner must be:
               (i)  Constructad of aac«rial3 znat nave appropriate chemical
          properties and sufficient strength and  thickness to prevent failure
          due to pressure gradients (including static head and external
          hydrogeologic forces), physical contact with the waste or leachate
          to which they are exposed, climatic conditions, the stress of
          installation, and the stress of daily operation;
               (ii) Placed upon a foundation or base capable of providing
          support  to the liner and resistance to  pressure gradients above and
          below the linar co prevent failure of the liner due to settlement,
          compression, or uplift; and
               (iii)  Installed to cover  all surrounding earth likely to be in
          contact  with the waste or leachate; ..."

9.2.1.2  Summary of Necessary Application Information—
     The Part 3 Permit Applicants'  Manual'1  directs the applicant to provide
the following information on liner system design:

     (a)  Hydrogeologic Data, including:

          •    the location of the landfill bottom wich respect to the water
               table

          •    data showing seasonal variation and highest recorded level of
               the water table

     (b)  Material of Construction

     (c)  Chemical Properties of Liner

     (d)  Physical Strength and Thickness

     (e)  Foundation Design/Integrity, including:

          •    regional and site geologic data

          •    summary of seismic conditions at the site

          •    hydrogeological data describing aquifers at the site
                                         9-11

-------
          •    an evaluation of surface water run-on and run-off

          •    geotechnical data on foundation soils

          •    a summary report, including:

                    Detailed boring logs
                    Typical soil profiles
                    Site and regional geology
               -    Fault map
                    Results of analyses and description of methods
                    Sol-ution cavity potential
                    Sinkhole potential
                    Liquefaction potential
                    Uplift potential

          •    description of liner bedding material

     (f)  Areal Extent of Liner

     ''g)  Liner System Integrity, considering:

          •    waste/liner compatibility

          *    internal/external pressure gradients

          •    climatic conditions

          •    installation stresses

          •    daily operational stresses.

     The foundation investigation is expected to incorporate subsurface
exploration by means of test borings, trenches,  or geophysical surveys.  Other
field testing may also be appropriate, such as pumping, permeability testing,
and tests for density, shear strength, and bearing capacity.  Soil testing in
the laboratory is appropriate to classify the soil and establish index and
engineering properties such as Atterberg limits, grain size distribution, and
soil compressibility.  Settlement analyses should be conducted and reported to
demonstrate total and differential settlement, primary and secondary
consolidation, creep, and liquefaction.  This foundation analysis is expected
to be prepared by a local foundation expert (e.g., civil or geotechnical
engineer).

     To illustrate liner system integrity, the applicant is asked to submit
compatibility testing results.  This information should include the test
method, description of procedures, chemical and physical waste
characteristics, raw test results, and interpretation of results.  Perspective
is provided in the Part 5 Manual on primary and secondary leachates and
physical classes of wastes.  These latter factors influence the selection of a
method for collecting representative samples of leachates and wastes.  The
                                      9-12

-------
 Agencv  has  deveU-oad  "jsc  ''.at::o-z  '-'j-iC  ;:..r  as-esirer.:  . f  -aste/synthetic  liner
 compatibility.   .-i  copy  of  cne  procedure  is  included as an  Appendix  Co  ihc.  RORA
 Technical Guidance  Document  for Landfills^.

      A  detailed  engineering  report  is  requested  in  the Part  B  Manual Co
 illustrate  the proposed liner  system's ability to withstand  internal and
 external pressure  gradients  during  the active life  of the  landfill.  To
 demonstrate adequate  strength  and thickness, the applicant  is  asked to
 consider waste/liner  compatibility, bottom  heave or blow out,  slope stability
 and creep,  strength loss due to several  factors, possible  puncturing or
 tearing of  the Liner, and  live loads on  the  liner.

      Finally, if the  facility  has a projected active  life  of greater than  30
 years,  the  applicant  is asked  to provide information  on the  aOil  uner
 proposed is low :ha  .yncnecic liner  (in keeping with guidance in  the RCRA
 Technical Guidance  Document^).  in  this  case, the application  information
 requirements are as stated for clay liners  in Section 6.0, Surface
 Impoundments.

      It is  recommended  that  the permit writer review  subsection  2.1.3 of the
 landfill chapter of the Part B Permit Applicants' Manual!  because the Agency
 has requested extensive information on liner system design.

 9.2.1.3 Guidance on  Evaluating Application  Information—

 9.2.1.3.1   Introduction—Figure 9.2.1_Ls a  flow chart that indicates the
 applicability of tne  Part  264  requirements  to the design of  liner systems.
 This  section provides technical guidance :o assist in answering  the major
 questions posed  in  the  cnart.  An overview of the related  subject matter
 addressed in this section  is presented in Figure 9.2.2.  Each  topic presented
 in Figure 9.2.2  is  discussed to provide a general understanding  of  liner
 design, installation, and performance factors which must be considered in
 evaluating  the technical adequacy of an applicant's proposed liner  system.
 Synthetic liners are  emphasized because, if properly  selected and installed,
 they  will minimize  the  volume of waste which passes into the liner  during  the
 active  life and, therefore,  will promote leachate collection and  removal
 through the leachate  collection system.  The reader is referred  to  the
 Technical Resource  Document  (TRD) on "Lining of Waste Impoundment and Disposal
 Facilities" (SW-870)3 which  provides a comprehensive  treatment of this
 subject.  Much of the following text is based on information from the TRD.

 9.2.1.3.2   Seasonal Variation of Water Table and Maximum Recorded Height-
 Information Requirement (a)—Several basic ground water hydrology references
 are available which discuss  the concept of the ground water  table and seasonal
variation in ground water table elevation.  These include  Chow (1964),*
Bouwer  (1978),5  and Freeze and Cherry (1979).*

      The ground  water table  is the location of transition  from the  unsaturated
zone  near the ground  surface to the saturated zone at depth.  Since a
capillary fringe often exists at this location, the water  table  is best
defined as the surface at which fluid pore pressure is equal to  atmospheric
pressure.
                                       9-13

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9-15

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     Water cable  location is assessed based on well Level measurement.*.  State
water  resource departments are the best source of historical records for
ground water elevations in localized areas.  These agencies -nay be affiliated
with Che U.S.G.S. or state environmental departments.   Often, conservation
commissions may keep such records for their city or town.  State water
resource departments install and maintain monitoring wells to collect ground
water  table elevation data.  In some states, records may cover as many as 100
ye.ars  of measurements.  In most states, measurements are made on a monthly
basis.

     These information sources should be used as the basis for the applicant's
demonstration of maximum recorded water table elevation, as well as seasons'.
water  table variatio".

9.2.1.3.3  Liner Materials, Chemical Properties, Strength and Thickness -
Information Requirements (b), (c), (d), (f), and (g)—Topics grouped under
this heading are discussed together because of strong interrelationships which
exist among them.  The chemical makeup of the liner is a determining factor in
waste/liner compatibility.  Incompatibility between the iiner and waste or
leachate may manifest itself as a reduction in liner strsngth, 3r as an
increase in liner penneaoiiicy.  The strength of a synthetic liner may also be
influenced by internal or external pressure gradients, stresses during
installation and operation, or climatic conditions.  These topics and
associated evaluation methods are addressed in the next 4 subsections.

Waste/Liner Compatibility

     Use of synthetic membrane liners for containment of hazardous wastes in
landfills is an emerging technology.  In past applications, synthetic liners
have been used for lining of surface impoundments holding relatively
homogenesous wastes in comparison to the range of wastes and leachates that
could be generated in a landfill cell.  Manufacturer's compatibility data may
be adequate for single wastes and specific synthetic material blends, but will
be of  little value in evaluating the compatibility of a given liner with
several different waste types or leachates generated from mixing of several
different wastes.

     In recognition of the fact that selection of synthetic liners for
hazardous waste landfill applications is tenuous based on currently documented
data, the EPA has established a laboratory test method for assessing
waste/liner compatibility.  Test Method 9090, currently in draft form and
subject to revision, is incorporated as an Appendix to the RCRA Technical
Guidance Document for Landfills.2  As stated there, the EPA prefers chemical
testing of liners using this method to account for the possible interaction of
many waste or leachate types with the liner.  Therefore, in all cases, except
the most straightforward applications, it is incumbent upon the owner/operator
to conduct such testing to provide evidence of waste/liner compatibility.
Applicants will often require expert assistance in conducting this testing and
in evaluating the results to assure that a proposed liner can be used with
success.
                                      9-16

-------
 Tesc  .iethoa  9090—in  cnis  :ese,  i  ^ampl^  of  cne  iiner nacerial  is exposed  Co
 che expected chemical environment  for  a period of  120 days and  physical
 properties,  tested before  and  after  liner exposure, are  compared.  The
 physical  parameters tested include tsar rssisc.ir.ca, puncture resistance,
 cansne strength, hardness,  and  elongation at break.  Appendix  VIII of the
 Liner TRD (SW-870) incorporates  tabulations  of ASTM test methods used to
 measure all  physical  properties  specified in method 9090.  Any  significant
 change in these properties after sample exposure is considered  to be
 indicative of incompatibility  between  the waste and liner.

      An important aspect of  the  test is collection and use of a representative
 sample of the waste or  leachate.  Collection of a  representative sample will
 be difficult  in the case of  a  new facility where the owner/operator plans  to
 combine several wastes  in  the  same call-   In chic  ^aae,  cne permit reviewer
 jiiouia carefully evaluate  the  owner/operator's proposal  for generation of  a
 representative sample of waste or leachate.  In the case of an  interim status
 facility  with existing  units,  leachate collected from an existing unit may be
 representative of leachate generated in a unit to be opened if waste types to
 be accepted  are documented as  similar.

      Taar cesiatance measures  Che force required to tear a specimen of the
 liner  with or without a controlled flaw,  and serves as an indication of che
 mechanical strength of  the sheeting.   Puncture resistance measures the force
 required  to  puncture che liner sheet with a  standard probe.  It is intended to
 indicate  che  susceptibility  to puncture from poorly graded materials above and
 below  che  liner.  Hardness  is  a measure of the ability of the liner to resist
 indentation  by a small  probe of specified shape and dimensions.

      Tests of  tensile strength and related properties may include the
 following measurements, depending on she  type of polymeric sheeting tested:

      •    tensile strength at  fabric break (if fabric-reinforced),

      •    elongation at fabric break (if  fabric reinforced),

      •    tensile strength at  yield  (if a  crystalline liner),

      «    elongation at yield  (if a crystalline liner),

      •    tensile strength at break of sheeting,

     •   elongation at break  of sheeting,

     •    modulus of elasticity at specified elongations, e.g., 100 percent
          and  200 percent.

     These ceats are performed according  to  ASTM and FTMS protocols (see
Appendix VIII and Table 3-7 in SW-870).   Results are plotted over the time
period 0 to 120 days.   Submitted data should include raw, tabulated, and
plotted results.   Saw data are particularly important to allow the permit
reviewer to assess the validity of the applicant's  interpretation of results.
                                       9-17

-------
     Discussions in cne RCRA Technical Guidance Document for Landfills2
suggest chat any significant deterioration in any of cnese measured properties)
should be considered aa evidence of incoraoatibility -in I as? i -cr.v Dicing
demonstration is tnaae to show Chat deterioration exhibited by Che test results
will noC impair liner integrity over the facility's life.  The cumulative
effects of possible deterioration should be extrapolated over the facility's
operating Life in any determination such as this.

Existing Compatibility Test Results—The liner TRD (SW-370) reports test
resuiCd for liner exposure and immersion in hazardous wastes.  In one series
of tests, liners were exposed to strong acid wastes, a strong alkali waste, an
oil refinery tank bottom waste, a lead waste from gasoline, saturated and
unsaturated hydrocarbon wastes, and a oesticide v.ista

     Significant changes in ultimate elongation of butyl rubber (see
Table 4-21 in SW-870) w«re found after 3 years of exposure to strong acids or
caustic.  Minor changes were noted for all waste/liner combinations although
the statistical significance of the changes is uncertain.  The S-100 modulus
was noted to change for CPE and CSPE liner specimens exposed to caustic
solution.  Deterioration was also noted for other combinations.

     Several physical properties were tested to determine the compatibility of
several liner types with a dilute aqueous organic waste  (0.1 percent tributyl
phosphate in deionized water).  Those results are worth  noting here because
they reflect the type of data that would be reported in  performing Test
Method 9090 (although the test period _i_s longer than required under
tfethod 9090).  Table 9.2.1 reprints information from TaDie 4-28 or the Liner
ISD.  Some fairly significant changes tn physical properties are evident.  The
tear resistance of all liner types suftered significantly.  Tensile strength
and elasticity ara also noted to have deteriorated.  These results would
indicate that use of CPE, CSPE, or PVC with this waste would be unacceptable
considering the significant changes in physical properties noted.  Even use of
butyl rubber or HDPE would be uncertain based on these test results, for the
specific liner/waste combination considered.

Factors Affecting Liner Deterioration—Liner deterioration is aost often
caused or associated with one or more of the following:7

     •    Swelling of the coating compound used on the liner,

     •    Degradation of the polymer used in the liner fabrication,

     •    Crosslinking of the polymer in the coating.

Swelling of the liner compound may lead to softening, a  reduction in tensile
strength, « loss of elasticity or possible elongation, and an increase in
permeability.  Degradation of the membrane polymer can increase swelling.
Crosslinking of the polymer causes stiffening, usually loss of tear strength,
and sometimes loss of tensile strength as well.  Although fabric reinforcement
may enhance liner tensile strength, the reinforcement may be affected by
wastes which can permeate the coating.
                                     9-18

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    TABLZ 9.2.1.   EFFECTS  OF  EXPOSURE  ON  SELECTED  POLYMERIC  MEMBRANE  LINERS  IN
                  WATER  CONTAINING  A LOW  CONCENTRATION  OF  A  DISSOLVED ORGANIC
                  CHEMICAL* FOR  17.2 MONTHS
                  SOURCE:  TABLE  4-^3  OF  SW-870-5
Polymer
Type of compound^
Liner number
Initial thickness, mil
Analytical properties:
•/aignc jam, ",
Physical properties:0
Final chickness, rail
Change, %
Butyl
XL
44
63.0

21.9

64
+ 2
CPEd
TP
77
30.0

107.2

48
+60
C?Ed
XL
100
35.8

34.4

41
+ 15
CS?Ed
TP
^, C
33.1

31.6

38
+ 15
?vcd
T?
59
33.1

46.2

36
+9
HDPEd
CX
105
31.9

0.56

31.5
-1
  Tensila strength, %
   retention                     107       10      b3      <*3       31      88

  Elongation at break, 7,
   retention                     115      155      79      79       89      101

  Stress at 100% elongation,
   % retention                    74        6      46      30       13    "  52

  Tear resistance, %
   retention                     ...       14      29      39       23      81

  Hardness change, Durometer
   points                        ~2A     -60A    -20A    -14A     -33A      -1A

Puncture test:
  Stress, Z retention             73       20      85     112       48     101
  Elongation, % retention        126      127     125     131      133     107


a0.1% Tributyl phosphate in deionized water.

bTP=thermoplastic, XLacrosslinked, CX3partially crystalline thermoplastic.

cData for tensile, elongation, S-100, and tear are the averages of measurements
 made in both machine and transverse directions.

dCPE  - chlorinated polyethylene
 CSPE - chlorosulfonated polyethylene
 PVC  - polyvinyl chloride
 HOPE - high-density polyethylene
                                        9-19

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Preliminary Selection of Synthetic Liner Material^—Given che emerging scaCus
of synthetic liner use for hazardous waste management,  2 ccmprenensive and
reliable guide on waste/liner compatibility is not currently available.
However, some existing knowledge can be summarized to provide some general
information on liner selection.  To date, quite a bit of data has been
compiled on liner swelling (i.e., weight gain) after immersion or exposure  to
wastes.  Table 9.2.2 provides a summary of some of this information (based  on
References 3, 8, and 9) and indicates wasce/liner combinations of high,
medium, or low resistivity.  The results from Reference 3 are based on
immersion tests (of up to 81 days) using reagent grade  chemical baths
according to the ASTM D471 Immersion Method.  Resistivity ratings presented in
the table were defined on the following basis:

                    Resistivity           % Weight Loss or
                      Rating              	Gain	

                     High                   0.1 - 11.5
                     Moderate               7.0 - 23.0
                     Low                   20.0 - 250+, and
                                            dissolution or
                                            deterioration

     Qualitative rankings (good, fair, poor) of waste/liner compatibility are
presented for generic industrial waste cypes (caustic petroleum sludge, acidic
steel-pickling waste, etc.) in the Liner TRD (SW-870).   Rankings for synthetic
liner/generic waste combinations ara caproducad here in Table 9.2.3.  This
information is presented for general guidance only.  If a situation arises
which is apparently covered by one of the ratings, it should not relieve the
applicant of conducting laboratory tesfing.

     Compatibility information is available through che flexible membrane
liner industry.  Considerable data on the use of polymeric materials has been
collected.  Generally, however, this information is representative of
situations which are not as complex as those that may arise in permitting
situations.  Generally, the compatibility of the liner  and one constituent  are
considered in manufacturer's information.  However, some liner fabricators  may
be willing to share previous experience or case history information which they
have on file.

     Manufacturer's waste/liner compatibility data have been summarized and
statistically evaluated by A. T. KearneylO for the EPA Office of Solid
Waste.  Liner ratings provided by manufacturers were converted to numerical
scores and were also ranked using a pass-fail system.

     EPA is continuing research of liner characteristics and will issue
updates on existing data as information becomes available.  The RCRA Technical
Guidance Manual "Landfill Design - Liner Systems and Final Cover" should be
consulted in addition to SW-870, the Liner TRD.

     Additional information sources that may be of value in assessing
waste/liner compatibility are listed in subsection 9.2.1.5, References,
numbers 11 through 15.
                                       9-20

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 Synthetic  Liner  Permeability

     The regulations require use of  a  liner :hac prevents wastes from passing
 into the liner during  the active life  of the facility.  Synthetic liners come
 closest to meeting the condition of  impermeability, although none have been
 identified which are completely impermeable.

     A review of manufacturer's literature indicates that liner permeability
 is rarely  specified.   In some cases, the percent water absorption is specified
 but the associated test period is not.

     The TRD on  liners (SW-870)3 reports a variety of test results for
 synthetic  membrane liners exonsed :o '-.asardous waste leachates which are
 indicative of liner susceptibility to waste or leachate permeation.   These
 tests were designed, in part, to measure changes in volatile and extractable
 content of exposed liners, changes in weight,  and changes in other measured
 parameters, as discussed below.

     In these experiments, membrane  liner samples were exposed co hazardous
 waste leacnate in immersion tests, pouch tests, and tub tests.  The wastes
 included cvo strong acid wastes, a strong alkali waste, an oil refinery tank
 bottom waste, a  lead waste from gasoline, saturated and unsaturated
 hydrocarbon wastes, and a pesticide waste.

     As part of  the immersion tests, eight membrane liners were exposed below
 1 foot of waste.  After 1 year and 3.i_years of exposure, the membrane samples
 were analyzed for voiaciias and axtraczabies (i.e., the higher the percentage
 of extractables and volatiles, the greater the membrane permeability).  The
 results of this testing showed that butyl rubber, elasticized polyolefin,
 polyester and polyvinyl chloride contained a lower percentage of volatiles
 (2.9-4.3 percent) Chan chlorinated polyethylene, chlorosulfonated
 polyethylene, athylene propylene rubber, and neoprene (6.3-13.6 percent) when
 exposed to a pesticide waste.  Exposure to other wastes produced similar
 results.

     Concurrent with these tests, supplemental liners were hung in the wastes
 and the effects of exposure were evaluated by determining the increase in
 weight, analyzing the exposed specimen, and measuring selected physical
 properties.  The amount of pesticide waste absorbed by butyl rubber,
 elasticized polyolefin, fabric reinforced ethylene propylene rubber,
 polyester, and PVC was less than 5.1 percent.   Chlorinated polyethylene,
 chlorosulfonated polyethylene, non-fabric reinforced elasticized polyolefin,
 and neoprene shoved significantly higher absorption of pesticide waste,
 ranging fro* 11.4 to 20.4 percent.  Absorption rates were similar for other
wastes with some exceptions.  One notable exception was the butyl membrane.
This membrane exhibited low absorption for the pesticide, acidic, and caustic
wastes but a high absorption capacity for the  oil wastes.  In the immersion
 tests,  measurement of the volatile content of  the membranes were analogous to
 the results of the absorption test.
                                       9-23

-------
     la a pouch cesc, small pouches were fabricated o_ut of chlorinatad
polyethylene, chlorosulfonatad polyethylene, eiasticized polyolefin,
polybutylane and polyvinyl chloride.  (At the praser.c ciae, only poucnes made
of thermoplastic and crystalline sheetings have been successfully fabricated
into pouches and tested.)  These pouches were filled with wastes and other
test fluids and Chen sealed and immersed in deionized water.  The
permeabilities of the membranes to water and to pollutants were determined by
observing, respectively, the change in weights of the bags and the pH and
electrical conductivity of the daionizad water.  After 552 days of testing,
measurements of the electrical conductivity and average flux showed that PVC
lining materials had the greatest permeability of the membranes tested.
Chlorinated polyethylene and chlorosulfonated polyethylene were found to hava
less permeability than PVC but greater oerraability ;;-4an etnyiene propylene
ruboar ana poiyoucylene.  An analysis of the physical properties of the pouch
wall materials after 1150 days of exposure confirm the above conclusions.

     As part of the tub tests, two samples of polyolefin liner were exposed to
an oily waste; failure occurred by cracking at the folds of the sheet.  In a
preliminary immersion test, this liner had appeared to perform satisfactorily
with the waste, althougn the manufacturer had not recommended the liner for
use in waste oil impoundments.  Performance was noted to vary significantly
depending on location of the liner specimen in the tub.  The worst performance
was noted when the sample was located at the waste - air interface.  The
unexposed sample retained its properties during the 43-month exposure period.

     Based on all testing reported in the TRD (SW-370), Che following general
conclusions are noted regarding ralative permeaDiiity of membrane liners.  PVC
liners exhibit relatively high perraeatrility in the presence of some hazardous
wastes in spite of the fact that they have shown low permeability in the
presence of sanitary wastes.  PVC membranes are attacked by many organic
chemicals including hydrocarbons, solvents, and oils.  Other liners which
appear to have a relatively high permeability are chlorinated polyethylene and
chlorosulfonated polyethylene.  Ethylene propylene rubber, polybutylene,
polyester, and butyl rubber appear to be the least perraeaole of the membranes
tested.  Neoprane and elasticized polyolefin appear to have a medium level of
permeability.  These results are summarized in Table 9.2.4.  Because chey are
general in nature, they should not be used as the basis for accepting or
rejecting a liner proposed for use in containing a particular waste.

Resistance to Pressure Gradients and Stresses During Installation and Operation

     EPA believes (R.CRA Technical Guidance Document on landfills)2 that
synthetic membrane liners should be at least 30 mils thick; thinner liners are
reported to b« readily damaged.  One of the primary reasons for failure is
tearing, puncture, or stretching during installation or operacion.

     In general, damage may result from physical, biological, or chemical
failure, as presented in Table 9.2.5, from section 4.6 of the liner TRD.  The
following discussion briefly describes each category and provides
recommendations on how to avoid such failure.  Additional information may be
found in SW-870^ and the RCRA Technical Guidance Document.2  The previous
discussion of waste/liner compatibility can be referenced for guidance on
chemical damage.
                                      9-24

-------
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     TABLE  9.2.0.  POLYMERIC MEMBRANE  LINER RESISTANCE TO
                    Co u re a:   j * -o 7 6.
                                               Resistance Co:

      Liner type         Temperature    Weathering         Sunlight            Ozone
Butyl rubber            High tolerance  Good                  -              Good
                        for extremes
                        in temperature

CPE                            -   '     Good                  -              Poor

CSPE                    Good heat       Good        Tends to shrink;  some    Good
                        resistance                  also tends to harden
                                                    on aging due to cross-
                                                    linking ay ultraviolet
                                                    radiation*

alasticized polyolefin  Some diffi-     Excellent
                        culties in low
                        temperature
                        and high wind

Spichlorohydrin         Good thermal    Good                  -              Good
rubbers ("3 and ICO)    scaoiiity—
                        high tolerance
                        for tempera-
                        ture extremes

Ethylene propylene      Tolerates       Excellent   Excellent resistance to  Excellent
rubber (EPDM)           extremes of                 ultraviolet radiation
                        temperature

Polyethylene                   -                              b
(HDPE, LOPE)

PVC                            -        Poor        Poorc


'Fabric reinforcement reportedly reduces distortion resulting from shrinkage
 when exposed to the heat of the sun.

^Unprotected clear polyethylene degrades readily with outdoor exposure, but
 the addition of 2 to 3 percent carbon black can improve ultraviolet light
 protection.

cThe PVC polymer is affected by ultraviolet exposure.  The sun's heat
 volatilizes the plasticizer; although the addition of carbon black prevents
 deterioration from exposure to ultraviolet light, it causes increased
 absorption of solar energy, thus vaporizing more of the plasticizer.  Soil or
 other cover materials may be used to bury the liner and protect it from ultraviolet
 exposure.
                                         9-30

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 ?.2.1.3.-»  Foundation  design  and  Ir.tagr.rv  •  lajonac-on  Requirement  ve)~~
.Following confirmation of  waste/liner  compatibility  and  inherent  liner
 strength, acceptance of the  proposed liner  system  will rest on evaluation of
 the foundation design  and  analysis.  Si.nca  compression,  sectieraenc, or uplift
 of the foundation could cause  liner damage, the applicant must establish the
 long term stability of the liner  foundation.  This section addresses  essential
 factors  in this analysis,  including:

      •    regional and site  specific geologic conditions

      •    seismic conditions,  location of faults

      •    hydrogeologic conditions, description of aquifers

      •    evaluation of surface run-on or run-off

      •    geotechnical engineering, classification,  and characterization of
           foundation soils

 Geologic Conditions

      Regional  «nd site-specific geologic data submitted with  the  application
 should include:

      •    geologic setting

      •    type(s) of bedrock and  depth(s)

      •    subsidence history,  and

      •    potential for sinkholes.

      Information on geologic setting and bedrock characteristics  will  likely
 be presented in the form of geologic maps as well as aerial photographs and
 descriptions.   Subsidence  history could be  shown by  a historical  map  sequence
 or through research.   The  potential for sinkholes  is partially derived based
 on the type of bedrock underlying the  area  in conjunction with other  site
 specific conditions such as surface water characteristics, soil types,
 rainfall,  wells  and ground water  consumption, etc.

      The scope of technical information expected to be submitted  in support of
 this  information requirement is reviewed here.  Various considerations, such
 as  data  qua' Lty  and data interpretation are noted.   It is recommended that the
 permit reviewer  refer  to the basic references sited  in this discussion for
 more  detailed  information.

 Geologic Setting and Bedrock Description--A detailed discussion of applicable
 information on geologic  setting is provided as part of the ground water
 section  of this  document (see  Section  5.0).  Specific technical information
 which  pertains to foundation design and integrity is summarized.
                                        9-31

-------
     Geologic raaps snouia be included in che application co  indicate  bedrock
and gurficial geology of the area.   In addition,  tne  applicant  should have
consulted with a certified geologist concerning local -onaicions  which might
not appear on a general map, or which might appear in a different location.
The application should include as much site specific  geologic information as
possible*

     Bedrock information provided should include:

     •    the physiographic province in which the  bedrock is located  (Coastal
          Plain, Appalachian Highlands, etc.),

     •    rock name, group, and type (for example, liiaascone +a in tne
          -arnonate .-OCK group wnicn falls into the sedimentary rock  type,
          granite is an igneous rock type in the granite-granodiorite family),

     •    formation name,

     •    age (the era, period, or epoch which best describes the age of the
          rock),

     «    thickness of eacn type of bedrock unit,

     •    texture—size and shape characteristics, such as fine,  sub-rounded,
          angular, etc.  Also, the fabric/matrix make-up (elastic, sorted,
          fissile, shaley, etc.),

     »    structural features of note., such as georaorphologic characteristics
          (faults, joints, salt domes, geosynclines,  karst,  caves, etc.) and
          petrologic characteristics  for igneous and metaraorphic rocks:
          lava, dikes, veins, cones, craters, batholiths, plutons, etc.).  For
          sedimentary structures this would include:   dunes, clastic  dikes,
          cross-bedding, deformation, etc.; and

     •    Orientation—the altitude and direction of the formation in terms of
          strike and dip.

     Surficial information should include:

     •    The soil type designated according to the unified soil
          classification system notation (for example "GW" represents
          well-graded gravels and gravel-sand mixtures with little or no
          fines; "SC" represents clayey sands or poorly graded sand-clay
          mixtures).  Sediments may also be classified into several sediment
          group*, for example, alluvium is in the group comprised of
          terrigenous elastics,

     •    The physical characteristics of the soil (i.e., is it dry,  moist,
          compacted, cemented, man-made, etc.),

     •    Formation name for the soil deposit,

     •    Depth of surficial deposits,
                                       9-32

-------
     «    Age of the soil,

     •    Thickness of Che deposit,

     9    Texcure of Che deposit,

     •    Genesis of the surficial deposits should be noted, such as whether
          it was organic in origin, volcanic, glacial, eolian, evaporitic,
          chemically precipitated, detrital, etc.; and

     •    The environment in which the soil formed should be defined:
          fluvial, lacustrine, glacial, marine, eolian,  evaporitic,  deltaic,
          estuarine, alluvial fan, etc.

     This information, along with mapping of the geologic units (both bedrock
and surficial deposits), will enable the applicant's geologise to assess the
geologic setting for the landfill.  Specific characteristics of the  area's
soils and bedrock, such as permeability and ability to hold water, should be
assessed in the application.

Subsidence History—Subsidence of an area may oe linked to various geologic
features as well as human activity.  Therefore, both geologic and human
influence should be carefully evaluated for each site.  For landfills, the
permit reviewer should be concerned with possible subsidence resulting from
several causes, as discussed later in chis subsection under Foundation
Analysis.  Subsidence directly related to human activity and geohydrologic .
conditions may occur in an aquifer system intar-layerea with plastic clays if
che aquifer system is developed to the extent that the ground water  table is
significantly lowered.

     Subsidence will also be dependent on the existing and potential amounts
of water withdrawn for the area.  This will depend on the size and capacity of
the aquifer, its potability or suitability for industrial uses, and  potential
future uses.

     Although subsidence potential is site-specific, there are certain areas
in which the phenomenon of subsidence has been demonstrated in rather extreme
fashion.  These include Long Beach, California; the San Joaquin Valley in
California; and Mexico City, Mexico.  In these instances, subsidence has been
shown to occur at races of almost 1 meter every three years.  These  situations
involved aquifer systems containing layers of soft clay, silt, or peat.  Upon
development of the aquifer systems, the cohesive layers compacted causing the
ground to sink.  Subsidence cannot be avoided if the water table is
continually lowered in areas containing compressible, cohesive soils.
Consequently, landfills should not be located in such areas.  Figure 9.2.3
illustrate* the degree of subsidence which occurred due to ground water
withdrawal over a period of 36 years in an area of California.22

Potential for Sinkholes—Sinkholes occur in areas referred to as karst
topography.  They are formed as depressions on the ground surface overlying
soluble rock material which has collapsed or dissolved.   In some cases,
limestone immediately below the soil may be dissolved due to seepage of
                                       9-3 j

-------
                                          JO
                                        .10
Figure 9.2.3.
                     km
Land subsidence in Che Tulare-Wasco area, California,
1926-1962, due co withdrawal of ground water.  Lines
show equal subsidence in meters and are dashed
where approximate.

Source:  Reference 22.
                                 9-34

-------
 water.  This process oiay be accaieracaa 37 ^ocai factors sucn as abundanc
 rainfall or limestone solubility.  More rcicsoniy, o^nKnoies form wnen the
 surface collapses into a large cavity below.   Surface water may drain through
 the sinkholes Co the ground water table.  Lakes may oe formed when
 subterranean outlets become clogged or if the sinkhole forms in an area with a
 high ground water table.  The most notable karst areas are in regions where
 limestone deposits underlie the surface.  However, in some localities,
 dolomites or dolomitic limestones, gypsum ana rock salt of limited areal
 extent may also develop such features.  Because limestone deposits are
 abundant in nature, it might be expected that karst topography is widespread.
 In actuality, however, only a relatively small number of localities experience
 full development of karst.

     Four conditions that contribute to the development of karst should be
 examined by Che permit reviewer.  They are:^

     1.   The presence of soluble rock near the surface, sucn as limestone;

     2.   Soluble rock wnich is dense, highly jointed, and thinly bedded;

     3.   Areas where entrenched major valleys exist below uplands which are
          underlain by soluoie,  well-jointed rock; and

     4.   Areas with at least a moderate amount of rainfall.

     3y far the -aost common ana widespread topographic form in a karst region
 is the sinkhole (other names which might be used for associated forms of
 sinkholes include solution pans, jvaiasf poljes>.  Often,  such sinkholes may
 be present in great numbers and may vary greatly in size.   In fact, thousands
 of sinkholes exist in the karst  terrain" of southern Indiana,  Florida,  and
other states.-^

     Lowering of the ground water table due to development of aquifer systems
 has been known to cause rapid subsidence which may result in sinkholes.  In
 one example, an area underlain by dolomite covered with a tnicx layer of
 weathered material developed sinkholes after lowering of the water table as
 part of a mining program.  These sinkholes developed over zones where the
 surface of the dolomite was irregular and characterized by pinnacles of
 unweathered rock separated by accumulations of weathered material and debris
 from mining.  Sinkholes started to form with the development of large voids
 between the pinnacles.  This was due partly to drying of the debris resulting
 from lowering of the water table.  In addition,  the debris was washed into the
dolomite openings at deeper levels.

     Because sinkholes form in karst topography, locations in such areas
 should be carefully evaluated.   Locations where sinkhole formation is of
concern are those which have humid climate, limestone bedrock, and ground or
 surface waters which contain carbon dioxide from vegetative soures or are
under pressure.   These locations include Florida, the Great Valley area of
 Virginia and Tennessee, southern Indiana, west-central Kentucky, and
                                       9-J5

-------
nortn-centra1 Tennessee.   Aerial photographs aav be checked tc  ISSI^L  in
evaluating trie sinkhole potential or a s_ite.  Additional information  on
evaluating the potential for sinkholes can o< ^juna in References  23  and 2-+,

Seismic Conditions

     The applicant must provide data and interpretative discussion concerning
the potential for ground shaking and surface rupture at the site.   A  ^aa
.showing fault areas should be submitted, especially for sites located in areas
listed in Appendix VI to Part 264 (Political Jurisdications in  which
Compliance with the Seismic Standard must be Demonstrated).  Such  a map  may be
compiled using aerial photographs of the site, published information,  a
walking tour of the site, and/or 3 jubjurface investigation of  the site.
Ihese techniques are briefly described in this section.

     The submitted map should show distances to known faults and summarize
seismic activity to date.  Activity occuring in Holocene time is especially
important (approximately the last 11,000 years).  The application should
demonstrate the location of faults with, respect to che site in  question; most
importantly, if faults are located within 3,000 feet of the site.   Pertnic
reviewers should evaluate cne existence of faults based on the  most
conservative interpretation of the information presented.

     Permit applications covering sites in areas where seismic  activity  is of
concern .nay include aerial pnotos or they may be requested as additional data
needed for sufficient review.  Aerial photo analysis should be  oerfor~ed ^y
one trained in aerial photographic interpretation.  Because aerial photos vary
with season of flight, type of film, photo scale, cloud cover,  etc.,  review
will necessitate analysis of such factors.  Aerial pnocos will  be mosC useful
if they cover a 5 mile radius around the site.

     Published information which would aid in seismic interpretation  should
also be included in the application and should have been interpretated by one
skilled in seismic studies.  Sources of data should be noted and referenced in
the application.  If there is doubt in regard to data quality or seismic
evaluation techniques, a site tour should be recommended.

     Applicants with sites which appear to be within 3,000 feet of a  fault
must provide information showing that no faults (or lineations) pass  within
200 feet of portions of the facility where treatment, storage,  or disposal of
hazardous waste will be conducted.  Such evidence might be available  from a
comprehensive geologic analysis which would likely include a seismic  survey.
If this is not conclusive, a subsurface investigation should be conducted.  A
comprehensive geologic analysis entails surface geophysical surveys,  evaluation
of borehole records, ground-penetrating radar, seismic refraction techniques,
and other methods to determine exact fault location.  A map should be included
in the application showing results of the study.  Seismic surveys can provide
elevations and thickness of hydrogeologic units, as well as fault/lineation
location.  Such information is useful in the geologic analysis as well.
                                       9-36

-------
      2or2noi.es  nay oe  installed by tne applicanc Co supplement knowledge of
 site  geology  gained  from  the coranrshansive geologic analysis.  In addition,
 some  sore of  digging,  such as  trenchine, -nay pr^v.d; /.dcasdary information.
 Trenching aay be  required in cases where the comprehensive geologic analysis
 or borehole logs  do  noc provide conclusive evidence of the absence of faults
 within 200 feet of the portions of the facility where treatment, storage, or
 disposal of hazardous waste is proposed.  The permit reviewer should check
 trenching maps  to verify  that  trenching has been performed oeroendi.cular to
 known faults  that were found to -sas.s viihir: 5,000 feet of such portions of the
 facility.

      In evaluating seismic data, the permit writer should be aware that such
 data also pertain to geologic  ?nd hvdri1 -".';: -.cnsiiieraCiOns.  Therefore, as an
 indir.acirn jjj •j^p^c-iLion integrity, the application should document that
 seismic daca  were evaluated by a geologist familiar with the area and with
 seismic analysis.  References  25 through 30 contain data which may aid in the
 application review process for seismic conditions.

 Hydrogeologic Conditions

      The application information should present definitive characterization of
 aquifers directly below the site and within proximity of the site.  Througn
 the use and presentation of test borings, trenching results, geophysical
 surveys, and  published information, the applicanc should be expected to define
 potentially impacted aquifers  to Che following extent:

     »    Aquifer dimensions

     •    Aquifer elevation and seasonal fluctuations

     •    Aquifer flow characteristics including velocity, volume and
          directions

     •    Ground water uses and potential uses (e.g., drinking or industrial
          consumption)

     •    Relative locations and permeability of confining strata

     «    Test data such as pump tests, drawdown curves, hydraulic
          conductivity, transraissivity, hydraulic gradient determinations, etc.

 The information submitted to establish ground water monitoring plans under
 Jubpart F should be comprehensive enough to support this information
 requiremenC.

 Surface Water Run-on and Run-off

     Characterization of overland flow patterns is an important consideration
 in the foundation anaysis to account for the potential liner damage resulting
 from foundation erosion.   The permit applicant should conduct a hydrologic
study to evaluate run-off quantities and patterns upgradient of and within the
                                       9-37

-------
 site  boundaries.   Such  faccors as precipitation, irifi Icrac ion capacity, area
 of  Che  drainage basin,  overland flow  lengtn, ana arainage basin gradient are
 used  CO calculate  overland 6'ow.

      The peak rate of overland flow across the landfill can be estimated using
 the Rational Method or  the Soil Conservation Service (SCS) method.  A detailed
 discussion on applying  these techniques is provided in subsection 9.2.4.3 to
 address the regulatory  requirements of §264.301(c) and §264.301(d) for run—?n
 and run-off management, respectively.

 Geotechnical Evaluation

      The permit loolicatfon -•>" •'=?v. -T  j.ioul-i c:va>.aace cne applicant's
 geocecnnicai data  submitted co demonstrate the stability of the liner
 foundation and subgrade (or liner bedding material).  Information provided on
 soil  classificacion, soil engineering properties, solution cavity potential,
 sinkhole potential, liquefaction potential, and uplift potential must be
 evaluated.

      References 31 cnrougn 35 are valuable basic reference sources on soil
 mechanics and ~eotechnical engineering.  They should be reviewed for a more
 thorough understanding  of the subject matter presented here.

      The permit applicant should conduct sufficient testing to classify
 foundation soils and characterize the engineering properties of the soil.
 Index properties that should be evaluated include grain size distribution,
 Atterbers; li.-?.i;a,   rpecific gravity, density, and moisture content.
 Engineering properties  that should be evaluated include strength,
 permeability, compressioilicy  ^nd others.  A settlement analysis is required
 to estimate total  and differential secc4eraent, immediate settlement, primary
 and secondary consolidation,  creep, and liquefaction.   Bearing capacity and
 stability of foundation soils can then be assessed based on this information.

 Index Properties—
     A  sieve or mechanical analysis is performed to determine the grain size
 distribution of a soil.  A typical grain size analysis Is plotted in
 Figure  9.2.4, reprinted from the SCS  Engineering Field Manual.33
 Information which can be obtained from this chart includes the total
 percentage of a given size, the total percentage larger or finer than a given
 size,  and the uniformity or range in size of a given soil.

     Soils are classified as coarse or fine based on the amount of material
 passing a number 200 sieve (0.074 mm opening).  A material is coarse if more
 than 50 percent (dry) is retained on  the ?200 sieve; fine if more than
 50 percent passes the sieve.   Coarse materials consist of sand ana gravel and
 possibly some small portion of fines.   If the fines content is less than
 5 percent,  the engineering properties will be a function of the coarse
materials only.
                                     9-33

-------
    I           M - ,
    i         •   '
—*"f~'—r—^-*._

        9-39

-------
Soil ; lass i. Ł icacion 3 /scans  :r.ac
                                                          anc. iave found -nose
widespread use include Che AASHTO  (American Association of State Highway and
Transportation Officials) system and the Unified Soil Classification System,
These and others and their definition by grain size  fractions are illustrated
in  Figure 9.2.5, after Cernica  (1982). 34
Cla«ifi«iion
Syuem K
Unified
,«*,o
MIT
ASTW
LSDA
X) 10
i
C.ra»«l
75 4
4
Grain Sue i nm i
! 01 0 0 1 0 X) 1 ) OiX
Sind Fines IN<|I jnd Jay i
'5 0075
(jnvel
b^no 1 Silt •' 'r.
rs : 
-------
                   n = ~ x 100 (expressed as a percentage)

The void racio cnanges as a function of the volume of voids because che volume
of solids is generaily assumed to remain constant.  The void ratio may range
from 0.5 to 0.9 for sands or gravel and between 0.5 to 1.5 for clays,  although
higher values can be encountered for clays.

Soil Moisture Content—The water or moisture content, w,  is defined as the
ratio of the weight of water (Ww) to the weight of soil (*'3), or:

                      W
                       W
                   wa — x 100 (expressed as a percentage)                  (3)
                       3

     The degree of saturation, S, is defined as the ratio of Che volume of
water (Vw) to the volume of voids (Vv), or:

                       V
                   S 3 ~ x 100 (expressed as a percentage)                 (4)
                        v

A soil will never be fully saturated, aven if submerged,  because a certain
amount of air will remain within the soil mass.  However,  the water content
can exceed 100 percent, especially for fine grained soils  and will have a
significant effect on the engineering properties of clays.  The optimum
moisture content is the value of w where the soil reaches  maximum density
under a given compactive force.

Soil .Density—Relative Density, D^, is defined as:


                                               .   « 100                     (S)
                                       max    mm

     where v     - dry unit weight of soil in densest state

           Y  .   a dry unit weight of soil in loosest state
            rain               *

The relative density may be considered as an indication of the stability of a
soil.   For instance,  a granular soil with low density may  be subject to
settlement upon vibration.   In the field, density is characterized using the
Standard Penetration  Test described later.  Cernica (1982) presents the
following relationships for soil density:

                      SR (%A           Soil Designation

                       0-15                very loose
                      15 - 35                  loose
                      35 - 70               medium dense
                      70 - 85                  dense
                      85 - 100              very dense
                                      9-41

-------
                           iric  jraviry,  --,  15  cae ratio oc cne unit weignt •
                che  unic weight  of water  (vw) ac 4°C.  Most soil particles
                                       .6 Co 2.8.  Organic soils (silts) may
oc che son co
have specific gravities  ranging from
have a lower specific gravity.
 Atterberg  Limits—The Accerberg Limits provide a great deal of information for
 cohesive soils.   The concept was introduced by A. Atterberg and modified and
 amplified  by  Terzaghi and Casagrande.  As water is added to a dry clay, it
 will  be transformed from a solid or seraisolid state to a plastic state and
 then  to a  liquid  state.  The water contents ac these points of change are
 termed the shrinkage limit (SL), plastic limit (PL), and liquid limit (LL)
 (e.g., the Atterberg limits) as demonstrated in Figure 9.2.6.
               DRY
                           SL
PL
LL
                                SI
                                           PI
                  PERCENT  WATER
                  IN  THE SOI L
                        Figure 9.2.6.  Atterberg limits.
     The shrinkage limit is che maximw» water content ac which a reduction in
water content will not cause a decrease in the volume of the soil mass.  The
plastic limit is the watar content at which a soil will begin to crumble when
roiled into a thread approximately 1/&. inch in diamter.  The liquid limit is
the water content at which a pat of sail, cut by a groove of standard
dimensions, will flow together over a distance of 1/2 inch under the impact of
25 blows in a standard liquid limit apparatus.

     The Shrinkage Index (SI) is the difference between the plastic and
shrinkage limits, or:
                                 SI
                                      PL - SL
                                        (6)
The Plasticity Index is the difference between the liquid and plastic limits.

                                 PI * LL - PL                               (7)

and indicates the range of water content over which the soil will remain
plastic.

Engineering Properties—It will be important to evaluate the applicant's
assessment of soil engineering properties to ensure the acceptability of the
liner foundation and subgrade materials.  The soil index properties should be
reported, especially Atterberg limits and moisture content for cohesive soils
that may be part of foundation soils.  The liner subgrade will generally be a
cohesionless soil such as sand and tae grain size distribution should be
                                      9-42

-------
 rsporcea.   in  -sr.sral, ;ne engineering properties of Che in-s itu or iraolaced
 foundation soils below the subgrade will be the ,-nosc important Co the
 stability of the liner system.  Therefore, TIOSC of cr-.* -•*-.;: i.-.l.ig uiscussion
 addresses these types of founuation soils.

     This discussion of soil properties and their affect on the engineering
 behavior of soils is based on information presented in:

     Engineering Field Manual for Conservation ?r-acc i: as .  U.S. Department of
     Agriculture, Soil Conservation Service.  April, 1975.33

     If the soil is coarse (either sand or gravel) but has a fines content of
 from 12 to 50  percent, the behavior characteristics -* :u,« portion smaiier
 than the J/4Q sieve will -iic^rnii.ia *.ne secondary characteristics of the
 material.  If  this portion of the material is clayey,  the material is coarse
 grained with clayey fines.  If not, it is coarse grained with silty fines.  To
 determine whether the material is classed as clay or silt, the plastic limit
 and liquid limit are measured.

     A Plasticity Chart, Figure 9.2.~ from Cernica (1982)^4,  is made with
 che LL as the  abscissa-and ?I as the ordinata.  A line 
-------

 50
         For ciauilnahon 01 iiiK-jrjmc
         soils 4nU nntr tr4t.tKm ut >.o.irsv
         Allerrwrp lipnn pludinj in h.i
         irca are ^orOrrlinc dauiiujno
         requiring uiŁ ot dual *v tnbols

             Lqullion ul ,1 lints
                       '0     -K)     50      6"0
                                LiQuid iimii LL
90     100
         CH  Inorganic clays of  high plascicity, fat clays

         CL  Inorganic clays ot  Low  co medium plasticity, gravelly
             clays, sandy clays,  siity clays. Lean :.jvs

         MH  Inorganic silts, aicacaoua or diacomacac-us fine  sands
             or silts, elastic silcS

         ML  Inorganic silts, very fine sands, rock r.our,  silty
             or ciav«y fine sands

         OH  Organic clays of nedium co high plasticity
         OL  Organic silts and organic silcy clays jf .ow plasticity
Figure  9.2.7.   Casagrande's  plasticity chart  showing
                   several  representative  soil types.

Source:    Cernica  (1982),  Reference 34.
                                   9-44

-------
      Shear  strangch  j-  jCii  leoenas  on  "vo  a iercencj,  ;rj.c:ion ana cohesion.
 rriccion  is  the  resistance to sliding of one block of nonplastic soil against
 another.  The  friction  in soil  is complicated by sucn factors as the
 irregulaCiry of  the  planes,  interlocking of ^pposit.-!  particles, ana size and
 shape of  tne son grains.

      Cohesion  is the result  of  the tnagnetic-1ike attraction of particles that
 manifests itself as  the plasticity and  stickiness of soils.  It resists one
 particle  of  soil sliding on  another, but cohesion resistance does not increase
 with  increased load.  Both friction  and cohesion of soils increase with
 increased density.

      Resistance  to internal  erosion  or  piping is correlated with resistance to
 surface erosion.  Soils vith a  si?h  jnsc^r^ibiiicy Jj jiieac erosion also have
 a  hign piping pocential ana, therefore, are critical to earth structure
 safety.   In  contrast, soils  with a low  susceptibility to surface erosion such
 as  the more  plastic  soils do not present an internal erosion problem.

      Cracking may be caused  by  dewatering of a soil.  As the soil dries, it
 shrinks and  develops cracks.  The finest materials hav« the highest cracking
 potential.   Plasticity is only  an indirect indicator of cracking potential
 because higher plasticity leans finer .-aacanal.  If nonplastic materials have
 the same  grain size  as plastic  materials their cracking potential is
 essentially  equal.

      Cracking due to movement of embankments is a result of both the amount of
 movement and the deformability  of "-he material.  Deformabilicy of embankments
 is a  result  of both  the olasticity of the aiaterial and the water content at
 which  the embankment is built.  Generally, the lower the water content when
 compacted, the more  brittle  the embankment and Che higher the cracking
 potential.

      Permeability depends on both the size and volume of pores in a soil.
 Hence, it increases  as grain size increases and decreases as density increases.

      Compressibility of a soil  is a measure of decrease in volume when
 subjected to load.   Compressibility depends on the volume of voids in the
 soil, and increases with decreasing density.  The amount of settlement that
 will occur in a soil depends on its compressibility and on the magnitude of
 the load to be placed on it.  Because of grain-to-grain contacts, coarse
 grained soils may be nearly incompressible under static loads but may settle
 from shock or vibration.  The finer grained soils are susceptible to
 settlement if dewatered.

     Highly plastic soils may swell under low loads if moisture content
 increases.  The swelling capacity may be estimated from the plasticity index
 of a soil.  Soils with a plasticity index of more than 20 usually have a
medium to high swell potential;  those with a plasticity index more than 35
 normally fall in the very high swell category.   The strength of soils after
 swelling is  greatly reduced.
                                      9-45

-------
     Upon drying from saturation to the shrinkage limit, soils with a low
shrinkage Limit will shrink more than those with a high shrinkage limit.

     If possible, the placement of soils with a high shrink-swell potential
should be restricted to zones where moisture content will remain fairly
constant.

    • The ultimate bearing capacity of a soil is the average load per unit area
rsquirad to produce failure by rupture of a supporting soil mass.  Bearing
capacity is important in evaluating the ability of the foundation to
successfully support the liner, wastes, and cover materials at closure.

   1_C T 3t! r' -' -~ ~— TV ,-.  ,,-• '  ,,,-r- _, ,
                   jppjL*v.^uC wxi.i. conduct an engineering analysis based on
laboratory or field testing of soils.  Laboratory tests are necessary to
determine soil index properties and include:
         Tesj:

     Grain Size
     Analysis
   ASTM
Designation

0421,' 0422
D2217
D1L40
        Purpose of Test

Soil classification
     Atterberg
     Limits
     Water Content

     Compaction
     Unconfined
     Compressive
     Strength

     Triaxial
     Compress ive
     Strength

     Direct
     Shear
D423
0424
D427
D2217
D2216, 02974

D698
D1557
02166
D2850
D3080
Determine the plasticity and
shrink-swell characteristics.
Assess sensitivity to changes
in moisture content.  Results may
be considered as part of all
engineering analyses.

Measure water content

Identify the characteristic
moisture/density relationship
for the soil.

Measure cohesive soil shear
strength
Measure characteristic stress-
strain relationship for soil
Measure soil shear resistance
     In-s itu or field tests that the applicant may conduct during performance
of borings or excavation of test pits and trenches include:
                                       9-46

-------
                          ASTM
                       Des igna
     Standard
     Penetration

     Vane Shear
     Pressuremetar
     Saturated
     Hydraulic
     Conductivity
     Plate Load

     Cone Penetration
 D1586
 D2573
                      .-•urpose or iest

                Measure relative soil density;
                indicaca bearing capacity

                Measure shear strength of
                cohesive soils; sensitivity to
                remolding
Not currently   Measure stress-strain, Young's
specified       Modulus, cohesive strength

Several - See   Measure saturated hydraulic
Appendix to
RCRA Technical
Guidance
Documents

D1194
                Measure bearing capacity

                Soil classification, strength,
                compressibility, and bearing
                capacity.
Foundation Analysis—The permit applicant must conduct a settlement analysis
to estimate primary and secondary consolidation,  creep, and differential
settlement.

     Consolidation occurs when a load is imposed  on a highly compressible
porous saturated soil (e.g., clay) forcing excess water to drain from the
soil.  Primary consolidation is governed by soil  permeability which controls
the flow of draining water.   Secondary consolidation is believed to result
from slippage between gra is bonded by adsorbed water.

     Settlement due to consolidation can be calculated from the relationships
illustrated in Figure 9.2.8, a phase diagram from Holtz (1981).
                            T
                                 VOIDS
                                 SOLIDS
                   I
4-
                                                     1
                                                          VOIDS
                                  jsouosK
                                             AH
        Figure  9.2.8.
Calculation of settlement from the phase diagram.
Source:  Reference 35.
                                      9-47

-------
At Che initial time condition (middle of figure),  the  volume  of  solids,  V
is equal to 1 (and remains 1 at the end of consolidation).  The  vcl-irae  of
voids changes from the initial value, eQ)  by the amount   e, to ef,  the
final volume of voids.  It can be demonstrated that  the  settlement,  S,  is
equal to:
                                     H  = €  H                            (8)
                              1 > e   o    v  o

     The stresses, changes in void ratio,  percentage of settlement,  or  amount
of settlement must be computed for each compressible stratum.   The  sum  of  the
estimated settlements for each stratum is  equal to the total  settlement for
the soil dapch of concern.  The confined compressibility test  is  the
laboratory method used to evaluate consolidation.31

     Creep is a term used to define deformation of clay soils  in  response  to
shearing stress.  The creep strength identifies the sheering  stress which  will
result in continuous progressive deformation.   Shear tests  should be used  to
evaluate the potential for creep.

     Differential settlement in cohesive soil  can be attributed to
consolidation as discussed above.  Differential settlement  of cohesive  soils
can also result from distortion in which a load on the soil causes the  soil
mass to deflect downward and bulge laterally,  as shown in Figure  9.2.9.  The
shape of the curve can be computed by methods  of elasticity.36

     differential settlement of cohesionless soils by distortion  results in  a
downward deflection curve as shown in "Figure 9.2.10.  The soil near the edge
of the loaded area is unconfinea laterally and is pushed aside by the lateral
pressure of the sand nearer the center of the  area.   Methods  for  calculating
the slope of the settlement curve are not available.  However, experiments
show that the wider the loaded area, the flatter the curve  at the center.

     Cohesionless soils are also susceptible to excessive settlement if the
soil is subject to vibrations.  The greatest settlement will  occur from a
pulsating frequency between 500 and 2500 impulses per minute.31  The
frequency of unbalanced forces in many types of machinery,  such as steam
turbines, diesel power trim units, and air and gas compressors lie within this
range.  Ordinarily the settlement will be small if the relative density is
greater than 70 percent, but if the vibration  is severe, settlement can occur
until the relative density is nearly 90 percent.36  The potential for
settlement should be carefully evaluated using density determination
techniques previously described in this section.  Vibration compaction
techniques can be used during installation to  minimize the  potential for later
settlement during facility operation.

     Other causes of settlement include shrinkage due to drying,  consolidation
due to lowering of the water table, structural collapse, erosion  into openings
and cavities, biochemical and chemical attack, mass collapse  of drainage
systems, and expansion due to frost and clay expansion.  Predictive models for
                                       9-48

-------
Figure 9.2.9.
Profile of distortion settlement of a uniformly loaded flexible
foundation on an elastic solid such as a saturated clay.

Source:  Reference 36.
        o. Narrow load
                                6.  Wide load
Figure 9.2.10.
 Profile of distortion  settlement  of  a  uniformly loaded  flexible
 foundation on a cohesionless soil.

 Source:  Reference  36.
                                    9-49

-------
         ng cne amount of iat:lament are generally unavaiiaole.  However,
standard foundation and geocachnical analyses can be used to estimate Che
suscepcibility to settlement from such causes.

     The technical adequacy worksheet for evaluating the suitability of the
liner system design is presented in Figure 9.2.11.  The worksheet should be
completed before addressing the technical adequacy checklist in subsection 9.9.

9.2.1.4  Draft Permit Preparation—
     Condition B.I of Permit Module XV addresses design, construction and
installation of the liner system for new portions of the landfill.  The
condition is implemented through reference to a permit attachment that
includes plans and specifications for the proposed liner system.  The
submitted application information :an be insercaa as cne permit condition
actacnraent provided the applicant has adequately addressed the following:

     •    Hydrologic data

     •    Construction materials

     •    Liner cnemical properties

     »    Physical strength and thickness

     •    Foundation analysis

     •    Liner systam integrity considerations

The attachment should demonstrate that Che wastes will be prevented from
entering the liner throughout the active tifa of the facility.

9.2.1.5  References—

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

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

      3.  U.S. Environmental Protection Agency.  Lining of Waste Impoundment
          and Disposal Facilities.   Prepared by Matrecon for the U.S. EPA.
          Second Edicion.  SW-870.   September 1982.

      4.  Chow, V. T.  Handbook of  Applied Hydrology.  McGraw-Hill,  New York.
          1964.

      5.  Bouwer,  H.   Ground Water  Hydrology.  McGraw-Hill,  New York.  1978.
                                        9-50

-------
                           EVALUATION OF LINER SYSTEMS


 Liner Location Versus Water Tabls Slavation

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

 Did the applicant address:

 •  Seasonal variation in the water table height?                 	   	
                                                                  Yes     No

 •  Maximum water ^abl* haign;?                                   	   	
                                                                  Yes     No

 •  Liner location in relation to water table?                    	   	
                                                                  Yes     No

Were onsite monitoring wells used to identify ground water       	   	
 levels?                                                           Yes     No

Was water table information obtained from state and local        	   __^_
 agencies?                                                         Yes     No
  and, if so:
How do these data compare with onsite monitoring data? 	
What is the minimum distance expected between the liner and the water table?
Does this distance insure that damage will not occur through     	   	
uplift?                                                           Yes     No
       .Figure 9.2.11.  Worksheet  for evaluating design of  liner  systems.
                                        9-51

-------
Synchecic Liner/Wasce Compatibility

Was EPA Test Method 9090 used Co evaluate comoacib il i:-/"1         	
                                                                  Yes     No

What steps were taken to insure representativeness of the waste(s) and
leachate(s) tested?
Were the measures adequate?                                      	
                                                                  Yes     No

What lab(s) performed the test(s)?	
Was liner manufacturer compatibility daca used in place of       	   	
laboratory test data?                                             Yes     No

If yes, ia the landfill intended for only one type of waste?     	   	
                                                                  Yes     N'o

Was liner manufacturer corapatibility data compared co            	   	
laboratory test results?                                          Yes     No

Was compatibility evaluated in terras of:

•  Tear resistance?                                              	   	
                                                                  Yes     No

•  Puncture resistance?                                          _____   	
                                                                  Yes     No

•  Tensile strength?                                             	   	
                                                                  Yes     No

«  Hardness?                                                     	   	
                                                                  Yas     No

•  Elongation?                                                   	   	
                                                                  Yes     No

Describe any differences in liner properties listed above resulting  from
exposure to waste or leachate. 	
                            Figure 9.2.11 (continued)
                                      9-52

-------
 If deterioration  is indicated, che liner should be judged  inadequate unless
 the applicant can demonstrate chat Che decarioration w'.ll  r.ct affect liner
 integrity.

 Synthetic Liner Permeability

 Did the applicant address synthetic liner permeability?          _____   	
                                                                  Yes     No

 What laboratory test procedures and/or data sources were used? ______________
Describe any properties identified that indicate susceptibility to waste or
leachate penetration (e.g., changes in volatile or extractable liner
materials, swelling, changes in weight, etc.). 	
Are data supplied by Che applicant consistent with               	   	
permeability data contained in SW-370?                            Yes     No
                            Figure  9.2.11  (continued)
                                       9-53

-------
Resistance of Synchecic Liners  to  Pressure  Gradients   Strssjcs,  and
Environmental Factors During Installation and Operation

Is the liner at least 30 mils chick?                             	  	
                                                                   Yes      No

Is che liner protected from physical failure by at  lease         	  	
6 inches of bedding material above and below the liner?            Yes      No

Did che applicant document that the bedding material is no       	  	
coarser than sand?                                                 Yes      No

Were herbicides proposed for use to prevent possible             	  	
punccure from plant growth?                                        Yes      No

Does che liner design allow for shrinkage and expansion          	  	
due Co freeze-chaw and wet-dry cracking?                           Yes      No

Did che applicant address liner abrasion vear?                   	  	
                                                                   Yes      No

Does che liner material contain a bactericide to prevent         	  	
microbial attack?                                                  Yes      No

Did che applicant address liner exposure co sunlight or          	  	
ultraviolet light?                                                 Yes      No

Are any scaps taken co .ainimize any poterrtially harmful          	  	
effects of temperature extremes?                                   Yes      No

Are chere any techniques used to prevent liner abrasion          	  	
from windblown particles?                                          Yes      No

Are exposed liner ends securely held in place to prevent         	  	
wind damage?                                                       Yes      No

Describe any data gaps relating to the questions listed above. 	
                            Figure 9.2.11 (continued)
                                         9-54

-------
 •Foundation Design and Incagri:y

 Did Che applicant define Che following index properties for      	   	
 liner foundation materials?                                       Yes     No

 •  Grain size distribution?                                      	
                                                                   Yes     No

 •  Atterberg limits  (for cohesive soils)?                        	   	
                                                                   Yes     No

 •  Specific  gravity?                                                     	
                                                                   Yes     No

 •  Density?
                                                                   Yes     No

 •  Moisture  content?
                                                                   Yes     No

 Has  the  applicant  addressed  Che  following engineering properties:

 •   Bearing capacity?
                                                                   Yes    ~No"

 •   Shear  strength?
                                                                   Yes    ~No~

 *   Cohesion?
                                                                   Yes     No

 •   Permeability?                                                  	   	
                                                                   Yes     No

 •   Compressibility?                                               	
                                                                   Yes     No

 Did the  foundation analysis  provide  an  adequate  evaluation of:

 •  Erosion potential?
                                                                   Yes     No

•  Cracking potential?                                            	   	
                                                                   Yes     No

•  Secondary consolidation?                                       	   	
                                                                   Yes     No


                            Figure 9.2.11 (continued)
                                      9-55

-------
«  ^rea p'
                                                                   Yes      N'cT

•  Differencial sec clementr                                       	   	
                                                                   Yes      No

Did Che applicant address:

«  Solution cavity potential?                                     	
                                                                   Yes "    ~~No~

•  Sinkhole potential?                                            	   	
                                                                   Yes      No

•  Uplift potential?                                              	   	
                                                                   Yes      No

•  Liquefaction potential?                                        	   	
                                                                   Yes      No

Did che applicant's foundation analysis include an estimation  of:

•  Consolidation?                                                 	   	
                                                                   Yes      No

•  Creep?                                                         	   	
                                                                   Yes      No

•  Differential settlement?                                       	   	
                                                                   Yes      No

Describe any data inadequacies relating to the questions  listed  above.  	
                            Figure 9.2.11 (continued)
                                        9-56

-------
 -i.  ~raa"3, '..  '-.. J.HC  .'. .-..  .rherry-   3* cur. ^  -'^ le r.   ."ranci.ce  naii.,  New
     Jersey.  1979.

 7.  Latter Correspondence  from Mr, Henry Haxc  'Matrecori)  co :ir.  Arthur
     Day (2PA Office of Solid Waste).  February  13,  1983.

 8.  Lee, J,, Selecting Membrane Pond Liners, Pollution  Engineering,
     January, 1974.

 9.  Kumar, J. , and J. A. Jedlicka.  Selecting and  Inscailing  Synthetic
     Pond-Linings.  Chemical  Engineering, February  5,  1973.

10.  Kearney Management Consultants.  Chemical Property  Data and
     Liner/Waste Cotaoatibilitv Data-  'rc-'.: A-sslgm-enc  .iOG-Cu6,  Ł?A
     Contract »
-------
 19.  Haxo, H. Ł. , Jr.  Preservation on Synthetic .ler.brane  uiners.
     Conducted at the U.S. EPA Training  Projr-.n:  ~-r  ?.I?.A ?er-nic
     Applicants.  Ł?A Region VI.  Dallas, TX.  April  2S, 1983.

 20.  Gascon, L.  (Gascon Containment: Co., El Dorado,  KA) , and 5. Wright
     (Wright and Kohli Construction, Houston, IX).   Membrane Liner
     Installation:  Criteria and Techniques.  Presented at the Watersaver
     Company, Inc.  Flexible Membrane Lin<2j Seminar.  oraintree, MA.
     Marcn lo, 1983.

 21.  Correspondence from J. P. Stevens Company,  Inc., to Wacersaver
     Company.  September 1973.

 22.  Leet, L. D. and S. Judson.  Physical Geology.   4th Edition.
     Prentice-Hall, Inc.   Englewood Cliffs, NJ.  1971.

 23.  Thornbury, W. ?.  Regional Geomorphology of the  United States.  John
     Wiley and Sons, Inc., Mew York, June 1967.

 24.  Thornbury, W. ?.  Principles of Geomorphology.   John Wiley and Sons,
     Inc., Mew York, 1966.

 25.  Earth Manual, U.S. Department of Interior, U.S.  Government Printing
     Office, Washington,  D.C., 1974.

 26.  Zohdy, et al.  Aoplication of Surface Geopnysics to Groundwater
     Investigations, U.S.  Geological Survey Techniques of Water Resources
     Investigations.  Book 2, Chapter D.I, 1974.

 27.  Roux.  Electrical Resistivity Evaluations at Solid Waste Disposal
     Facilities.  SW-729.   U.S. Environmental Protection Agency, 1978.

 28.  Telford, et al.  Applied Geophysics, Cambridge  University Press,
     Cambridge, 1977.

 29.  Dobrin.   Introduction co Geophysical Prospecting, McGraw-Hill, Inc.,
     New York, 1976.

 30.  Keys and McCary.  Application of Borehole Geophysics to Water
     Resource Investigations, U.S. Geophysical Survey Techniques of Water
     Resource Investigations.  Book 2,  Chapter E.I,  1971.

 31.  Terzaghi, K. and R.  B. Peck.  Soil Mechanics in  Engineering
     Practice.  Second Edition.  John Wiley & Sons,  Inc.  Sew York.  1967.

32.  Scott, R. F.  Principles of Soil Mechanics.  Addison-Wesley
     Publishing Company,  Inc.  Reading, MA.  1963.

33.  Engineering Field Manual for Conservation Practices.  U.S.
     Department of Agriculture, Soil Conservation Service, April 1975.
                                9-58

-------
34
35.
Arnica, John N.

Winston.  1982.
                        Gsocechnical  Engineering.   Hole   Rin^   ^    ,
                        - ' -- - ^*-   noic'  tUnehart  and
36.   Sowers, G. B.

     Foundations.

     York.   1970.
                             9-59

-------
9.2.2  Leachate Collection and Removal Sv;cam

9-2.2.1  The Federal Requirement —
     Paragraph(b) of §270.21 requires thac Che applicant's plans and/or
engineering report on landfill design, construction,  operation, and
maintenance must address:

              "(1) The ... leachate collection and removal .system ... '

     The landfill standards of Part 264 scace that:

              "(a) A landfill (excaot for an ^xiseinz; ;.orc~on 31 a landfill)
          muse nave:
               (1)  ....
               (2)  A leachate collection and removal system immediately above
          the liner that is designed, constructed, maintained,  and operated to
          collect and remove leachate from the landfill.   The Regional
          Administrator will specify design and operating conditions In trie
          permit to ensure chat the Leachate depth over the liner does not
          exceed 30 ~m (one foot).  The laachate collection and removal system
          mu s t be:
               (i)  Constructed of materials that are:
               (A)  Chemically resistant to the waste managed in the
          landfill and the leachate expected to be generated; and
               (3)  Of sufficient strength and thickness  co prevent collapse
          under tne pressures exerted by overlying wastes, waste cover
          materials, and by any equipment used at the landfill; and
               (ii) Designed and operated to functir- without clogging through
          the scneduied closure of the- landfill."

9.2.2.2  Summary of Necessary Application Information—
     The Part B Manual^- instructs the applicant to suomit engineering
reports and detailed drawings to support the proposed design of the leachate
collection and removal system.  Specific information requested includes:

     (a)  System design and maceriala of construction

          •    detailed drawings; facility layout, slope, spacing, design of
               sumps

          •    type of collection pipes

          '•    calculations illustrating maintenance of less than I foot of
               leachace head except during storm periods.

     (b)  Chemical resistance

          •    compatibility of pipes and sumps with leachate and wastes
                                     9-60

-------
      !,c)   Strengtn and tnickness

           •    demonstrate chat the system can withstand  incurred live and
               dead Loads, accounting  for pipe perforations or slots.

           •    account for pipe deflection, buckling, and compression

      (d)   Prevention of clogging

           •    engineering design calculations to assure  functioning without
               clogging through closure.

9.2.2.3  Guidance on Evaluating Aoolication Tr.iormatijn—
      figure 9.i.i2 is a Clow chare which indicates the applicability of the
Part  264 requirements to laachate collection and removal systems.  The
guidance which follows on evaluating the technical adequacy of Che applicant's
proposed leachate collection system addresses the major regulatory
requirements identified in the flow chart.  Subsection 9.2.3 provides guidance
on evaluating an sapLicant's submittal in cases where an exemption from che
Leachate collection system requirement is sought.

      At Least four aspects of leachate collection system design and operation
will  be addressed by che applicant and should be rigorously reviewed by the
permit writer.  These include:

      •    System design and materials of construction

               design drawings

               pipe materials                           ,

               calculation of Leachate head above the bottom liner

      •    chemical resistance of system materials

      •    strength and thickness of materials, and

      •    leachate collection system clogging

      Figure 9.2.13 presents a summary of technical topics addressed in the
remainder of this section to assist the permit reviewer in evaluating the
applicant's proposed design.

9.2.2.3.1  Leachate Collection System Design and Materials of Construction--

System Design

     The applicant should have submitted engineering drawings illustrating the
full areal  extent of the leachate  collection system and profiles of all piping
and appurtenant structures such as manholes or cleanouts.  The inside diameter
                                    9-61

-------
                                                                            71


                                                                            3


                                                                            73
                                                                           >-,
                                                                           •Jl
                                                                           U
                                                                           1.
                                                                         o
                                                                         *J

                                                                         V)



                                                                         3

                                                                         3
                                                                        u
                                                                        •*4
                                                                        3
                                                                        O"
                                                                        a
                                                                        u


                                                                       ~3-
                                                                       vO
                                                                       U

                                                                       -5
                                                                      .a
                                                                       ^
                                                                       •j
                                                                     u
                                                                     3
                                                                     Ł0
9-62

-------
     .EACHATE ;CL.ŁC7;CN 3YSTE.1
        DESIGN AND  MATERIALS
           OF CONSTRUCTION
         SYSTEM MATERIALS
     STRENGTH AND THICKNESS
      JF SYSTEM MATERIALS
     LEACHATE SYSTEM CLOGGING
        MECHAN/SMS
  •  PHYSICAL

  •  CHEMICAL/BIOCHEMICAL

  •  BIOLOGICAL
                                                               RECOMMENDED TECHNIQUES
                                                               •  PLANS AND PROFILŁ

                                                               •  PIPE MATERIALS

                                                               *  CALCl'L.-TiC.V :f ,ŁAC,-iArE
                                                                  DEPTH ABOVE LINER
                                                                              CuNSiOESEO
                                                              •   PLASTIC
                                                              •   CLAY
                                                              •   CONCRETE
                                                              *   ASBESTOS-CEMENT
                                                             ASPECTS OF THE OETcRMIMAT!ON
                                                              •  COMPRESSION

                                                              •  DEFLECTION

                                                              •  SUCKLING
      PREVENTION
•  SIZING/SELECTION OF
   FILTER AND  DRAINAGE
   MEDIA

•  SELECTION OF  PIPE
   PERFORATION OR  SLOT
   SIZE

•  MONITORING  AND
   INSPECTION
                                                                        CORRECTION
MECHANICAL OR
CHŁMIC-   CLEANING
Figure 9.2.13.   Evaluation  of leachate collection and removal  system design.
                                            9-63

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of  che pipe snould be indicated along with slot or perfo'-acicn size.   These
plans and  orociles should be drawn co scale, such as I" - 2C' or -C',  so cnac
che details of Che design are clear.  The profiles should indicate  che
location,  depth, and thickness of foundation, subgrade, filter, and drainage
layers, and the orientation of collection pipes with respect co che synthetic
liner.  The slope of all piping should be indicated in terms of percent slope
(rise/run  x 100) or inches of rise or fall for each foot of pipe length.
References 2  (Metcalf and Eddy) and 3 (ASCE Manual of Practice 37)  provide
detailed information on design of subsurface piped drainage systems.

     The spacing of all pipe laterals and interceptor piping should be visible
from the plans and/or profile drawings, wnichever orovides a -ord
straightforward view.  The verti-^i sxtsnt of wastes and soils to be placed
aoove the  collection system should be indicated on the profile drawings.

     Calculations should be provided that illustrate that the flow  capacity of
the collection system is capable of handling expected leachate flows over the
life of the facility.  Appendix V of the Liner TRD (SW-870)4 presents a
method of  designing or evaluating che capacity of leachate collection
systems.   Selection of the design leachate flow rate snould demonstrate
consistency wich che storm event selected for designing the run-off collection
system facilities.

Pipe Materials

     The selected pipe materials should be indicated, preferably on the plans
and drawings.  Possible materials inclTKle clay, PVC and other plastics,
asbestos-cement, concrete, and others.  The pipe class and wall thickness and
bedding materials should be indicated so that pipe strength can be  evaluated.
If additives or special treatments or cpacings will be used in pipe
manufacture, these factors should als<3 be specified.

Leachate Depth Above the Bottom Liner

     The S.CRA Technical Guidance Document for landfills^ expresses  the
Agency's perception that "a [leachana collacrion system] design incorporating
4-inch diameter cues on 50 to 200 foot (15 to 60 meter) centers will
effectively minimize head on the liner system."  However,  the guidance manual
recommends that the owner/operator incorporate design calculations  in his
application to demonstrate that no more than 1 foot of head will exist above
the liner at any time,  except during storm periods.

     The EPA TRD (SW-868), Hydrologic Simulation On Solid Waste Disposal
Sites,6 provides a procedure for estimating the amount of moisture
percolation through different types of landfill covers and, therefore, is only
applicable for determining leachate depths after landfill closure.  The EPA
TRD (SW-869),? Landfill and Surface Impoundment Performance Evaluation,
provides an analytical  technique for determining the flow capacity  of sand or
gravel drainage layers.
                                     9-64

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                           -W-oo?—."toore
	          :W--f  one torn  slope.7  Clearly, bo t ton  slope  iws  little influence at  slope
greater than  5 or 6 percent, but such slopes are expected to be
                                      9-65

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                3 =LŁACHATE (LIQUID) IMPINGEMENT RATE
'    *    *
                             I   I    I   i
                                             « DRAIN LAY^R






                                             - LINER  SLOPE
     I   *    M    i   I    I    I    )
                                           !i =LŁACHATE  DEPTH




                                                                          I
                                           L = DISTANCE  BETWEEN LATERALS


Figure  9.2.14.  Alternative drainage system orientations considered

               in solving for maximum leachate depth.
               Source:  Reference 7.
                           9-66

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      0.10
      0.08
     0.08 h
     0.04
    0.02
                                                        0.4
Figure 9.2.15.  Relationship between h
                                       max
/L and c = e/k
                Source:  Reference 7.
                            9-67

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uncommon.  At slopes expected in practice of I to 2 percent, h^ax/Tu will be
sensitive to minor changes in slope and will increase as the impingement rate,
a, increases or as the permeability, kg, decreases.

     In applying these equations, SW-869 assumes steady state liquid
impingement over 1 year's time.  The permit reviewer should recognize that the
worst case may be represented by estimating h.,jax attendant with a rare storm
event (say 25 or 50 years'1 ovsr a 24-hour period.  The applicant should
estimate shore term leachate depths expected in such instances so that the
adequacy of the system design can be better evaluated.  If unacceptably high
leachace depths are shown to occur in such instances, the oermit reviewer
should request resolution DŁ the prooLera, possibly by requesting installation
of a more permeable drainage layer or closer positioning of the lateral
drainage pipes.  The permit reviewer should also closely consider the
applicant's assumptions regarding the fraction of rainfall which infiltrates
to the drainage layer or rainfall losses attributed to evapotranspiration.

     Underestimation of tne leachate production rate (e) could result from the
following:

     •    Failure to account for drainage of sludges placed in the facility.

     •    Poor maintenance and operation of the run-on and run-off control
          system during the active phase of operation.

     «    Failure of the impervious cap after closure.

In addition, the impingement rate couW be altered locally (in one cell for
example) by the propagation of channel-s through the waste materials which
might deliver the leachate to one area of the leachate collection system and
overload it.

     Since observation of hydrostatic head is the criterion by which clogging
of the collection system is determined, it is critical that these factors ara
accurately assessed in the initial design phase.

HELP - The Hydrologic Evaluation of Landfill Performance Model—The following
discussion is based on two documents which present documentation and a user's
guide for the HELP model.  Both are currently in draft form and were prepared
at the U.S. Army Corps of Engineers Waterways Experiment Station by:

     •    Walski, T. M., et al. - User Guide for the HELP Model^

     •    Schroeder, P. R., et al. - Documentation for the HELP Model9

The presentation provided here is intended as an introduction and overview
only.  If the permit applicant has used the HELP model or if the application
reviewer chooses to use it as an independent check on the applicant's
calculations, then it is strongly recommended that the permit application
reviewer obtain copies of the User Guide and the Documentation.
                                    9-68

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      The  -iyarcicgic  {valuation  ?'  .ar.zzi*'.  TT r :^ rrr.ar.cu  , .i^Lr;  computer  Program
 is  a  quas i-two-dimens ional  hydrologic model or water movement  across.  'Inco.
 chrough,  and  out  of  landfills.  The  "noaal  uses c i imatoiogic, soil, and
 landfill  design data  and  incorporates a  solution  technique wr.icn accounts  for
 the effects of surface  storage, run-off,  infiltration,  percolation,
 evapocranspiration,  soil  moisture storage, and lateral  drainage.   The  program
 estimates run-off drainage  and  leachate  expected  to result from a  vide  variety
 of  landfill designs,  including  open, partially open, and closed landfill
 cells.  Most  importantly, in consideration of  this topic, the  model can be
 used  to estimate  the  buildup of leachaca  .ibove ;he bottom iiner of trie
 landfill.  The following  discussion  is from Reference 9:

          "The HELP model performs a sequential daily analysis to  determine
      run-off, evapotransoiration, ^rcoiation, iau ".jceral drainage  cor  the
      landfill ^cap, cell, leachate collection system, and liner) and obtain
      daily, monthly,  and  annual water budgets.  The model does not account for
      lateral  inflow and surface run-on.
          "The HELP model requires cliraatologic data, soil characteristics,
      and design specifications  to perform  the analysis.  Climatologic  input
      data consist of daily  precipitation values,  mean monthly  temperatures,
      Tiean monthly solar radiation values,  leaf area indices, root  zone or
      evaporative ~one iepths, and mincer cover factors.  Soil  characteristics
      include  porosity,  field capacity, wilting point, hydraulic conductivity,
      water transmissivity evaporation coefficient and Soil Conservation
      Service  (SCS) run-off  curve number  for antecedent  moisture condition  II.
      Design specifications  consist of the number of layers and their
      descriptions including type,  thickness, slope, and maximum lateral
      distance to a drain, if applicable,  ana whether syntnecic merabrances are
      to be used in the cover and/or liner.  The HELP model maintains five
      years of default climatologic dat-a  for 102 cities  throughout  che  United
      States.  Any of seven  default options for vegetation may be specified.
      The model also stores  default soil characteristics  for 21 soil types  for
      use when measurements  or site specific estimates are not available.
          "The model  is ordinarily used in the conversational mode.  This
      enables users to interact directly with the program and receive output
      through  the terminal immediately.  Use of the model does not  require
      prior experience with  comouter programming;  "hough, some experience would
      assist the user in logging on the computer system  and manipulating data
      files.  The model can also be run in the batch mode; however, this
      requires more computer programming experience and  extreme care in
      preparation of input data  files."

      Figure 9.2.16 illustrates  the landfill layers and  profiles that can be
considered in applying HELP.9   in Che current case, the evaluation is
concerned with open, active landfill portions.   If the  topmost layer is
identified as a waste layer, the program assumes  that the landfill Is open.
For this case, an SCS run-off curve number* must  be specified as well as the
fraction of the potential surface  run-off that is  collected and removed from
the landfill surface.
*The SCS method for calculating run-off is discussed in subsection 9.2.5.
                                    9-69

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PRECIPITATION
                                     EVAPOTRANSPtRATION
                          r- VEGETATION       f   RUNOFF




                           iNFiLTRATION
       VEGETATIVE  LAYER
       LATERAL  DRAINAGE  LAYER
                      LATERAL DRAINAGE
                                         (FROM COVER)
       BARRIER  SOIL  LAYER
                                     (FROM BASE OF COVER)
or
a.
09
I
       LATERAL  DRAINAGE LAYER
                       LATERAL DRAINAGE

                    (FROM 3ASE OF LANDFILL)
       BARRIER  SOIL  LAYER
                                       OflAJN
                                MAXIMUM  DRAINAGE DISTANCE
                                              a:
                                              UJ
                                   PERCOLATION (FROM BASE Of  LANDFILL)
  Figure 9.2.16.   Hazardous wasce landfill profile simulated  using HELP,



                 Source: Reference 9.
                             9-70

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      T'-.a  -iEL?  -noael  perrorns  =.  i3i_/  - equfep.t iai.  analysis  co  compute  ail  output
 :at3.   As  nany as  9  soil  or waste  Layers  can  be  simulated  chroujr.out  a  :i~e
 period  from  2  co  20  years.  The  noaei  incorporates  a  lateral  ctrainaee sc".^.c-,
 which was  developed  co  cover  a vide range  cf  Landfill  jcctom  cesign
 specifications, namely, slopes  from 0  co  10 percent,  drainage layer  lengths
 from  25 to 200 feet, and  SCS  run-off curve numbers  from 20 to 100  (see
 subsection 9.2.4.3.2).  The liner  leakage  fraction  and Che fraction  of  run-off
 from open  sites can  vary  from 0  to 1.

     Optional  forms  of  input  and output are possible  using the  HELP  program.
 Input climatological and  soil data can be  formulated  by the user or  default
 values can be  used.  Leachate system design data must be specified by the
 program user.

     Output  can be obtained in the form of daily values or monthly totals,
 each with  a  summary  of  the simulation.  To obtain results  indicating  the head
 of  leachate  above  the bottom  liner, output must be  formulated in terms of
 daily values.   The accompanying simulation summary  prints annual totals,
 monthly and  annual averages,  and peak daily values.

      In summary, the HELP program can be used co estimate the depth  of
 leachace dbove  the bottom liner  for a variety of landfill designs, time
 averages,  and  storm events.   The results may be used  to compare designs or to
 design leachate drainage ana  collection facilities.  Review of  the two
 referenced documents is recommended.

     Assistance in running Che program can be received from the developers at
 Che Waterways  Experiment Station.  They can be reached by commercial  telephone
 at  (601) 634-3710 or via the  FTS system at 542-3710.

 The DRAINFIL Model—The DRAINFIL model is a landfill water balance technique
 developed  by Wayne Skaggs at  North Carolina State University.10  Calculations
 conducted by EPA illustrate close comparison in results between DRAINFIL and
 HELP.11  ORAINFIL can be used co determine leachate depth above the bottom
 liner of the landfill cell.

 9.2.2.3.2  Chemical Resistance of System Materials—The components of the
 leachate collection system which snould be evaluted for their resistance to
chemicals  in the landfill are the bottom liner and drainage tiles or  pipes.
 The chemical resistance of liners is discussed in subsection  9.2.1.3.
Chemical resistance of drainage conduit is discussed below.

     The following types of pipe are commercially available for collection
system drain construction.12

     •    vitrified clay

               Clay drain tile

               Clay pipe (standard  and extra-strength perforated)
                                    9-71

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          concrete (bell and spigot or coneue ^nd groove join

               Perforated concrete

          Asbestos -cement

               Perforated sealed joint

          Plastic

               Acrylonitrile-Butadiene-Styrene (ABS)
               SCyrene-rubber (SR)

               Polyethylene (PE), straight wall or corrugated
Vitrified Clay
     Vitrified clay cila or pipe is an excellent choice for leachata
collection systems due co its resistance to chemical attack.  Vitrified clay
is resistant to internal and external attack from gases, solvents, and
alkalies.  This type of pipe has demonstrated long service life in both sewage
conveyance and drainage collection applications.  It should be noted, however,
that some mineral components of clay pipe may be attacked under acid
conditions.  To evaluate resistance to" acid attack,  representative sample of
pipe material could be tested by the ajrplicant using a method such as :he
acid-soluble extraction zachnique specified by ASTM 301-79.

Asbestos-Cement and Concrete Pipes^

     Asbestos-cement and concrete pipes are susceptible to corrosion under
acid conditions.  Although some corrosion is acceptable, excessive acidity can
result in premature failure of the pipe.  There are three oossible uechoas of
avoiding corrosion failure when asbestos-cement or concrete pipe are planned
for use:

     •    Alter the composition of Che pipe materials

     •    Apply acid resistant barriers

     •    Increase the wall thickness.

     Type II Portland cement is superior Co Type I in resisting sulfate attack
in sewer systems*  However, the type of cement does not seem to be a factor in
the resistance of concrete pipe to acid attack.

     For concrete pipe, extra wall thickness can be used to increase pipe life
under acidic conditions.  Another method is to use limestone or dolomite
aggregate co increase Che amount of acid soluble material in Che concrete,
chereby prolonging Che life of the pipe in corrosive environments.  The
                                     9-72

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 "rrc-s-on  rtts  .'-  -oi^mice or  ii:nescone  aggregate  can  3e  exoected  co  be
 approximately one-fifth  as great  as  granite  aggregate.  ">a  ^rac: ;.:j;
 us ing  li.f.es ton» ^r dolomite aggregate  in  pipe varies with  the  acid if  -f  -  ~
 leachate ind The  ^.viil^b ili^y  ana alrcaj. j.nicy or  cne aggregate.

     Protective barriers have  been used  on concrete and asbestos-cement pipe
 with varying success.  Available  coating  and lining materials  include
 bituminous and coal tar  products,  vinyl  and  epoxy  resins,  and  paints.   The
 linings must be applied  such that the  pipes  are  comolecelv laalad.    '-.ny  _,:ia
 seepage or diff^j.^ri  chrougn cne  lining  ac any point,  even through a  pinhole,
 will react with the cement, thereby  destroying the effectiveness  of  the
 liner.  In leachace collection systems designed  with cement  and concrete  pipe,
 linings may have  lo be applied to both  the inner and outer surfaces.

 Plastic Pipel3,14

     Plastic pipe  is well established  in  the drainage  industry primarily  due
 to low cost and ease of  installation.   In addition, quality  control of  joint
 construction is usually better than  for  other materials.   In general,  plastics
 have excellent Tesistance to veak nineral acids  and are unaffected by
 inorganic salt solutions.  Since  olascics do aot corrode  in  Che
 electrochemical sense, they are not  affected by  slight changes in  pri, tiinor
 inpurities, or oxygen content.  Table 9.2.7, from Reference  13, identifies  cne
 chemical resistance of ABS, PVC,  and PE  to selected chemicals.

     Aeryionitrila butadiene styrene polymers (ABS) have good  resistance  to
 weak acids but are not satisfactory  wi-ch oxidizing acids.  They should not  be
 •:sad vich j.i Icrinacea nyarocarbons but nave  good resistance  to aliphatic
 hydrocarbons.

     Polyvinyl chlorides have excellent resistance to  non-oxidizing and weak
 acids, but should not be used with oxidizing acids.  Resistance is also good
 to weak and strong alkaline materials.  PVC  has  poor resistance to chlorinated
 hydrocarbons.

     Styrene rubber is resistant  to  attack by ozone, sunlight, oils, gasoline,
 and aromatic and halogenatad solvents.  Styrene  rubber -an 2e attackea by
 oenzene and ketones.

     Polyethylene is the lowest cost plastic commercially  available.
Mechanical properties are relatively poor and such pipe must be fully
 supported.   Carbon-filled grades  are the most resistant to sunlight and
weathering.  Polyethylene has excellent resistance to acids ana bases.
 However,  ic is readily attacked by aromatics  and derivatives), alcohols,
ketones,  and hydrocarbons.

 9.2.2.3.3  Strength and Thickness of Leachate Collection System Materials—The
 leachate  collection system design must recognize that  the  drainage pipe may be
 the weakest structural component of  the overall system.  Therefore, materials
selection and wall thickness  design must account for expected dead and live
 loads above the pipe.
                                    9-73

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        TABLE 9.2.7.
CHEMICAL RESISTANCE OF PLASTICS USED FOR PIPING3
Source:   Reference 13.
                                                                Polypropylene
                                                                polyethylene
10% H2S04
50% H2S04
10% HC1
10% HN03
10% Acetic
102 NaOH
50% NaOH
NH^OH
NaCl
FeCl3
CuSC4
NH4H03
Wee H2S
Wet C12
Wet S02
Gasoline
Benzene
CC14
Acetone
Alcohol
Excellent
Excellent
Excellent
Good
Excellent
Excellent
Excellent
Excellent
Excellent
Excellent
Excellent
Excellent
Excellent
Excellent
Excellent
Excellent
Poor
Poor
Poor
Excellent
Excellent
Excellent
Excellent
Excellent
Excellent
Good
Excellent
Excellent
Excellent
Excellent
Excellent
Excellent
Excellent
Good
Excellent
Excellent
Poor
Fair
Poor
Excellent
Excellent
Excellent
Excellent
Excellent
Sxcaiiant
Excellent
Excellent
Excellent
Excellent
Excellent
Excellent
Excellent
Excellent
Poor
Excellent
Poor
Poor
Poor
Poor
Poor
aRatings are for long-term exposures at ambient temperatures (less than 1003F)

^Acrylonitrile butadiene scyrene polymer.

cPolyvinyl chloride, type I.
                                    9-74

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      i?A TRD ^W-"?''"1-  -r-r'-^s  i  : :-.sr 2--:" = -. v= 	:. ;; --j.^r. criteria :or
 ,„ ..-ecc-_jn  p-ps=s  -onsiaering ^oads  :rom overlying waste fill.   The following
 discussion  is  based on  chat  rererenca  .-SCŁ  '-'3? 3",-' inzortiat ion presented
 .a  'Clogging of  Leacnate  Colleccion Systems  'J-ed \^  Ja:-zri3-J3  <'dsc = -aru
 7i.3posai Facilities',-^ ;ne  Clay  Pipe Zn^n^ering Manual,1-0 and
 manufacturer's liceracure.^' > ^

      In  the analysis  of structural  stability under an imposed  Loading, the
 pipe  is  considered  to be  either  rigid or flexible.   Examples of rigid oipe
 include  clay and  concrete.   Plastic and fiber glzsz  *>:& examples of flexiole
 pipe  construction material.   For  rigid, pipe,  corapressive strength is tne
 overriding  design loading  criterion.   Deflection and buckling  of pipe walls
 are more important considerations  for flexible pipe.

      Ijivia  ire gan
-------
            Soil llnvr
                                    WO«f«
                                                (w)
                             S«  •
                     a)  T«ŁNCH CONDITION
              wa»i« fill
              a 1/2 s.
21/2 9,
                                     • 3cssri!
                   6) PROJECTING CONDITION
Figure  9.2.17.   Pipe installacion  -  conditions  and loading.




                  Source: Reference  4  (SW-870)
                           9-76

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TABLE 9.2.8.  TRANSITION WIDTHS FOR 6-INCH AND 8-INCH PIPE
              INSTALLED IN SAND AND GRAVEL

--•orh , r ".c:-.i:.., f 1~]
5
6
a
'0
L2
14
16
'.3
20
22
24
26
28
30
Transition
6-inch pipe
1.59
1.69
1.86
2.02
2.17
2.31
2.44
2.56
2.68
2.80
2.91
3.01
3.12
3.22
widch (ft)
8-inch pipe
1.93
2.03
2.22
2.40
2.56
2.71
2.86
3.00
3,13
3.26
3.38
3.50
3.62
3.73
                         9-77

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-"ere:  -V - vertical load per unit length acting on •:.-.» ?;re  ::;^  :.-,
            earth loads ;r. Lb/:C

        v = unit weignt of earth per unit volume in Lb/ft^

        B * Trench width or pipe width, depending on installation conditions,
            in ft

        C a Diraensionless coefficient to account for:

            (1) Ratio of the fill height to the width of the  trench or conduit.
            (2) Shearing forces between the earth prism directlv  ^bov? -he  -;ra
                and adjacent orisms.
            \jy uirection and amount of relative settlement between interior
                and adjacent earth prisms.

Allowable Load for Rigid Pipes

     Loads must be calculated for either crench or  Jroj^cting conditions.
Marston'3 formula for calculating loads on rigid oioe in trench -oncutions  ,s:

                                 W = C. w 3,2                               U4)
                                      d    d

'jhars:  '<«' and w are previously defined

        3j = Trench vidth ac :he top oJL the pipe in ft

        C^ - Dimensionless coefficient  tnat is a function of  tne  ratio of
             fill height to the width of the crenc.n and of the  friction
             coefficient between the Uackfill and :he sides of  the  trench.
             Cd is computed as:

                                      -2Ku(Z/B,).

                           Cd'^^lK-	^                           (15)

^nere:  e is the base of natural logarithms

        K = Rankines ratio of lateral pressure to vertical pressure

        Z s height of backfill above pipe (see Figure 9.2.17)

        u * coefficient of friccion between backfill material and sides
            of the trench

     In land based nazardous waste management applications, the pipe  load  is
caused by both the waste fill and the trench backfill.  (Live loads are
discussed later.)  These two components of the total vertical pressure are
computed separately and then added to obtain the total vertical pressure
acting on the pipe.  The modified Marston's equation used is:
                                     9-78

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wnere:  W, B   w, and C, are previously defined
            d          d
        w, * unic weight of waste fill (values range from 45 Co 55 Ib/fc
             for municipal waste with soil cover)
                                                                        3
        H, * height of waste fill, ft, and
                                     -2Ku(2/3)
                              C   - a        d
                               us

Tho cerni C.^s, a Load coefficient, is a function of the ratio of che depth of
the trench," Z, to the width of the trench, Bd (see Figure 9.2.17), and che
friction between the backfill and the sides of the trench.

     With che exception of coefficients -K and u, terras used in Equation 15 are
identified by the density of che cover materials and by che dimensions of che
installation.  The coefficients K and u, used in determining Cj and ~,s,
are dependent on the type of backfill -.acenaii usea.  Typical values of che
product Ku are:

     •    0.19 - granular materials without cohesion

     •    0.165 - sand and gravel

     •    0.13 - unsaturated clay

     •    0.11 - saturated clay

     •    0.15 - saturated topsoil

To expedite the calculation of pipe loads under trench conditions, graphical
techniques can be used to determine Cd and Gys.  Working graphs for
calculating Cd and Cus are provided in Figure 9.2.13 and Figure 9.2.19,
respectively.  Load can then be determined using the modified Marston equation.

     Projecting conditions exist whenever the pipe is covered with fill above
the ground surface or when the trench width is wider than the "transition
width."  Under projecting conditions, the load can be calculated using che
modified Marston equation by assuming che trench width, Bd, co be equal to
the transition width.

     After calculating the load on the pipe, the next scan is to iacsrmine ;he
adequacy of the pipe in bearing che load.  rhe anility of rigid pipe  to safely
resist the calculated load depends on its inherent strength, the distribution
of the vertical load, the type of bedding material used, and the lateral
pressure acting against the sides of the pipe.  Compressive strength  is the
primary loading design parameter for rigid pipe.
                                     9-79

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          COEFFICIENT  Cd   (GRAPH  QKJ  , rc->
            1-52        345

  0-10    0-15  0-200-250-3   0-4  0-50-607     ].0      ,.5
               COEFFICIENT Cd  (GRAPH  ON  RIGHTD
   Curve
        A—C.-forKH' — 0.19 for jruiubr saiznaLs wiuiout coaesion
        B—C,«for AV = 0.165 max. for saad and gravel
        C—C
-------
              0-02   0-03
          0-05  OO7  0-10
          LOAD COEFFICIENT,
0-20   0-30
                   0-50 0-70   1-00
       Values of load coefficient CM (trench uniform surcharge)
Figure  9.2.19.
Projecting condition
Source:   SW-870.

                  9-81
- pipe  load  coefficient.

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      -,:_:ic  ,i;e   as  in  .r.r.arsr.c  jruo^ing icrangca measured :>y cne three ed^e
 bearing  test  (ASTM Method  C301).   Minimum crus'-.i-g Dreiser: for j:ancari ana
 d.xcra  strengtn  perforated  and  nonperforaced vitrified "lav --.02 13 ;r~'v':..:s-.
 rablp  °.2.°   To  represent actuai  riaia conditions,  a 'loaa factor" is used to
 convert  minimum crushing strength  to field support strength.   The load factor
 is  dependent  on the  pipe bedding material.  Recommended  load  factor values are
 (Reference 16 (Clay  Pipe Manual)):

     Class A-l  (plain concrete = 2.8

     Class A-l  (reinforced concrete) = 3.4

     Class A-ll (reinforced  concrete,  p = 0.4 oercs'nc'1  = ?.4

     Class A-ll (reinforced  concrete,  p = 1.0 percent)  = 4.8

     Crushed  atone encasement  = 2.2

     Class B  * 1.9

     Class C  * 1.5

     Class D  * 1.1

     The  field supporting  strength  is  calculated as:

    Field  supporting  strength = minimunr-t:rushing strength x load factor     (13)

 Because of limitations  in  the  3-edge twsaring test in  simulating actual field
 conditions, a factor of safety must  be applied to the field supporting
 strength  to calculate a safe supporting strength.  The safe supporting
 strength  is calculated as:

            c .         .          ,    Field supporting  strength           ,,,..,
            Sate  supporting  strength 3 	=	——%—^3	—           (19 >
                   rr      °      *          Factor of  safety

 ASTM Designation  C12-82 recommends using a safety factor of between 1.0
 and 1.5.

 Allowable Load for Flexible  Pipe

     The  load on  flexible  pipe is also calculated by  a version of Marston's
 equation.  The flexible pipe load differs  from the load  imposed on rigid pipes
 in  that the soil  at  the sides  of the pipe  is compacted to the extent  that it
will deform under the vertical load  imposed  on the pipe  itself.   Therefore.
 the side  fills can be expected to carry 3.  proportional snare  of the total
 load.   Under  these circumstances, the  trench load formula may be modified to:

                     W = B   (B w C  + w  H, C  )                          (20)
                           c    d    d    c   t  us
                                     9-82

-------



















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9-83

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wnere:  V, i ,  -, v, ,  n-ana J   ira previously aefined
            d      t   r     _5
        3  = Outside diamecer of pipe, f c ,  (see Figure - . ? . ! " N


As with rigid pipes, Che coefficients Cd and Cus may be calculated using
working graphs  provided in Figures 9.2.18 and 9.2.19.

     Under projecting conditions, the load on flexible aioe  can be assumed co
b« equal to the weight of a pri^m of ovanying waste fill  with a width BC
and a height, Hj, plus the weight of a similar prism of gravel above the
pipe (see Figure 9.2.17).  The following equation can be  used to determine the
load:

                             W - (wfHf * w Z)                              (21)


where:  W, w ,  H,,  w and Z are previously defined

     After calculating the load, it miot ':e determined whether excessive
deflection will occur.  Flexible pipe derives its ability co support a load
from its inherent strength plus che passive resistance pressure of the soil at
the sides as the pipe deflects and moves outward against  the side fills.  This
type of pipe fails by excessive deflection and collapse or buckling, rather
Chan by rupture as is the case with rigid pipes.

     Flexible pipes must be designed ca withstand vertical pressure at the top
of the pipe without excessive aeflectian.  The Iowa formula is a well-accepted
equation for calculating flexible pipe deflection under earth loading and is
given as:


                                                                           (22)
                                 2 El * 0.061 E'r

where:  Ay » horizontal and vertical deflection of the pipe (in.).  A maximum
             long term deflection of between 5 and 10 percent is recommended

        D  » a factor, generally taken at a conservative value of 1.5,
             compensating for the lag or time dependent behavior of. the
             soil/pipe system (dimensionless)

         W * vertical load acting on the pipe per unit of pipe length (Ib/in.)

         r " mean radius of the pipe (in.)


         E • modulus of elasticity of the pipe materials (psi)
        E' * modulus of passive soil resistance (psi) (normally estimated to be
             300 psi for soils with Proctor density of 65 percent, and  700 psi
             for soils with Proctor density of at least 90 percent)
                                      9-84

-------
          K *  bedding constant, reflecting Che suoport  the  -*i-?.  -?c3i-v»s frsa
              tha  '3 a c torn ~f :na :rancr.  ;insr.cic;:i^=s,  , d  conservative value of
              O.iO is normally assigned)


          I  -  moment of inertial of pipe wall per unit  of  length (in.Vin.);
              for  any round pipe,  I-t-^/12 where t is  the average thickness
              (in.)


The first  term  In the denominator of oquacion 22, Ł1,  reflects  the influence
of the inherent strength of the pipe on deflection.  The  second tens,
0.061 E'r-3, reflects the influence of the passive soil  pressure on the sides
of the pipe.  It  is recommended that the value of El «hould  never  be  lass *han
10 to 15  p'sr-nr.:  of n.OSl 3"r~.  uue co cne variety  of  flexible pipes
available,  manufacturers should be consulted for data on  pipe strength.
Example values  of El for 4 types  of pipe are as follows :

     4-inch Schedule 40,  El -  16.2
     4-inch Schedule 80,  SI *  47.4
     6-inch Schedule 40-,  21 =»  23.4
     6-inch. Schedule SO,  21 - 105.3

     Reference  4  presents a graphical technique which  can  be  used  to  evaluate
deflection  in flexible pipe.  Several examples are also provided.
Manufacturers often provide tabulated data to give the  design engineer a quick
indication  of the adequacy and applicability of flexible  pipe.   Table 9.2.10
illustrates the caoabilii::/ of ?VC pipe with 3. stiffness of 46 psi  under
projection  conditions.  The table illustrates that deflection will be less
than 7.5  percent  for depths up to 12 feet.  At greater  depths,  greater
defleciton  is possible depending  on soil type.

     The  capacity of flexible pipe to support vertical  stresses may in some
cases be  limited  by buckling.  In most cases, the allowable deflection will be
exceeded  before buckling becomes  the limiting factor.   In  some  cases, buckling
modulus of  passive soil resistance.  Specific information  on buckling
characteristics should be obtained fron Che pipe manufacturer.

Perforated  Pipe

     Perforations reduce the ability of rigid and flexible pipe to carry load
and resist  deflection under both  trench and positive projection conditions.
This effect can be accounted for  by assuming and using  an  increased load per
unit length of  pipe.   The following equation is recommended: ^

                                    12
                   Design load - - x Actual load                     (23)
                                  12 - L
where: Lp - Cumulative  length of  perforations in inches per foot
                                      9-85

-------
9-86

-------
*orxing or M.ovtr.g '-ye  -oaas

     Live loads due to  construction equipment are  a  key  consideration  in
leachate collection system design.  Dijcushions  wicn  j.anariii  operators and
designers suggest that  failures of many  leachate collection  systems  may result
from construction equipment loading.  EPA TRD SW-870  suggests  a  minimum
vertical separation of  4 feet between the loaded surface and che cop of the
pipe.  Concentrated live loads such as a truck wheel  load can  be calculated  as
follows:i6

                                      P  F
                             W   - C  —-                                   (24)
                              sc    s  L

vhsrs:   W   ~ 1 ^~.d -r. ~.u,e pipe lr* pounas per iinear  root
         sc
          P = concentrated load in Ibs

          F = impact factor; a minimum value of  1.5  is recommended

          L = effective length of pipe,  ft.  It  is recommended that  an
              effective' length of 3 feet be-used for  pipe  greater crtan
              j feet long, and actual length for pipe shorter  than 3 feet

         C  = load coefficient; the load coefficient  is  a  function of pipe
              width, effective pipe length, and  fill height


The load coefficient, C_, is a function  :>f  3C/2H and  L/2H.   Load
coefficient values can be obtained fro* Table 9.2.11  for  several combinations
of pipe size and depth.   However, Cs cannot be obtained  from this cable for
small pipe (6 to 8 inch diameter) at depths greater  than  3 or 4  feet.  For
depths  up to 8 feet the live load can be approximated from the data  presented
in Table 9.2.12.  The wheel load must first be determined and then the
percentage of that load applied to a unit length of pipe  is  obtained from
Table 9.2.12.  This load must then be corrected using an  impact  factor of 1.5
or greater.   Based on the information presented in these  tables  and  an impact
factor  of 1.5, the live loads calculated for 6-inch and  3-inch diameter pipe
under a IC-con truck are presented below:

                                Pipe load,   Ibs/linear foot

                              6-inch pipe        8-inch  pipe

                   1             3070               3600
                   2             1370               1680
                   3              700                860
                   4              +00                500
                   5              290                340
                   6              200                240
                   7              120                170
                   8              100                120
                                     9-87

-------

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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~?-~ZŁ~  :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

-------
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 Łn c^e soil
 solution because of the high amount of energy required to reduce the iron
 present.  Additionally, soils containing glauconite, iron oxide or magnesium
 oxide are known  to seal over drain joints or perforations due to the various
 chemical actions that may take place within these soils.28

 Biological Clogging Mechanisms—Research efforts ind operational experience
 witn microbiaj. removal or hazardous  waste compounds, porous media wastewater
 treatment, wastewater tile fields,  soil absorption beds,  and agricultural
drainage and irrigation systems are indicative of biological clogging
mechanisms that may be encountered in leachate collection systems.
                                     9-93

-------
      "r.  ;;^aies or  tow vOLume  irrigation systems by  Ford, a  filamentous  3
forming organism identified as '/itraoscil1j and a common, universally
distributed soil bacteria called Pseudoroonas  (specifically,  Lcs associated
polvsacchari.de slices) were snown to act as clogging agents  in  the absence of
iron. 1-9  Additionally, Ford has suggested that a clear jelly-like slime,
dominated by bacteria of the genus Enterobacter, may contribute to an  increase
in drain entry resistance by clogging the zone abutting  the  drain envelope.24

     Extensive investigations by '
-------
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                                                        9-95

-------
     •-"rirari^n 1.  The LJ percent size (315) of a filter -nataria1 should be
     'ac lease four or five times Che \5 percent size (L>I$) of a protected
     soil «

                       D   (of filter)

                       D15 (of soil)    > 4 C° 5                           (23)

The first criterion is for the control of piping (hvdraulic failara,1 j f joii
into the filter layer and rhe drainage system, while the second criterion is
meant to guarantee sufficient permeability to prevent the buildup of large
seepage forces and hydrostatic pressure in filters and drainage layers.

     Other criteria c.->.r. "-•' _ pir.if .^n --.; aaaition to or in lieu of those noted
aoove.  Ihe U.S. Army Corps of Engineers31 recommends the following for
protecting nonplastic soils:

                      D , size of filter material
                      -L2 - - - < 5                      '-IN
                      D , size or protected soil  —

                      D_. size of filter material
                                                  < 25                      (30)
                      D,_ size of protected soil  —

These criteria are based on experience witn and design of dams and other
earthworks that require slope stability, and design of underground drainage
systems.

     The U.S. Army Corps of Engineers31 also allows d relaxation of the
above criteria for medium to nignly plastic clays without sand or silt lenses,
which would require multiple stage filters by the above criteria.  These
criteria state that for these clay soils, the 0^5 size of the filter may be
as great as 0.4 mm and the above DJQ criterion may be disregarded.  This
relaxation in criteria for protecting medium to highly plastic clays will
allow the use of a one-stage filter system; however, the filter material must
be well graded, and to ensure nonsegregation of the filter macdriai, a
coefficient of uniformity (ratio of D^Q to DIQ) of not greater than 20 is
required.

     In contrast to the Corps criteria stated above, Sherard et al.32 note
that certain types of clay may erode by a process called "dispersion" or
"deflocculation."  Cedergren30 indicates that the chance of piping failure
of drainage systems using dispersive clays can be greatly reduced by providing
adequate filters to retain erodible soils.  In some cases two or three filter
layers may be required for such systems.  Field tests of soils should be
performed to establish safe piping ratios (^15 filter/Ds5 soil) for
systems using dispersive clays.

     The U.S. Bureau of Reclamation33 has also developed filter grading
criteria for high head-rapid pressure dissipation applications.  These
criteria address piping and permeability in a manner similar to those
                                     9-96

-------
mentioned above.  In addition, the Bureau recommends separate criteria for
uniform grain size filters and differentiates between angular and rounded
graded filter media.  Bureau criteria also suggest tnat all filter materials
pass a 3-inch screen to minimize particle segregation and bridging during
placement.

     A key consideration in using all the above criteria is that the
grain-size curves of filter and protected layers be somewhat oarallel.  This
objective is expressed by the reiationsnip given in equation 10 of the Corps
criteria.31

     The technical adequacy worksheet for evaluating the suieabiiitv of
drainage ^.nd :i1r.3' layer Jlesig:; using natural materials (.gravel, stone,  sand,
etc.) is presented in Figure 9.2.22.  The worksheet should be completed before
addressing the technical adequacy checklist in subsection 9.9.

Use of Filter Fabrics—When filter fabrics (geotextiles) are used in place of
graded filters, the protective filter may only be about 1 mm in thickness.
Caution should be exercised to ensure that no holes,  tears, or gaps are
permitted co form in the fabric.  Cedergren-30 suggests :hat if ;he Dg5 of
a soil is larger cnan the near maximum opening size of the fabric (035
fabric), little soil should move through the fabric mesh.

     Demery3^ has shown that if the permeability of the protected soil is
less than the permeability of the filter fabric, the soil controls the
hydraulic response of the system.  WiLLardson indicates that it is wise to
maintain the ratio of filter permeability to soil permeability
(k filter/k soil) greater than 1.0 to minimize the hydraulic gradient at  the
interface.35  rn general, the permeability of synthetic filter fabrics lies
in the range of 5 x 10"^ to L0~l cm/sec.  Thus,  in most cases a ratio of
k filter/k soil greater than 1.0 can be easily achieved.

     The advantages to using synthetic fabric filters in place of granular
filters are cost, durability, and consistency.  With increases  in costs of
graded aggregate and its installation, synthetic filters are competitive  with
graded filters.  Probably the most important advantage to fabric filters  is
quality control during construction.  The properties of fabric  filters will
remain practically constant independent of construction practices, whereas
graded filters can become segregated during placement.

     Although synthetic filters do have certain  advantages they are not
problem free.  Benz et al,36 indicated in studies of drainage envelopes that
some synthetic fabric envelopes did tear under test.   Broughton et al.37
indicated that Remay filters (27 g/m^) suffered  considerable abrasion damage
in transport and field handling requiring patching of the filter.   In other
cases37 drainage pipes (tiles)  were found blocked by  sand deposits which
apparently entered through  the joint between two sheets of filter material.
In addition,  bacterial plugging (iron bacteria)  of synthetic filters  has  been
noted by Demery. 4  Compatability of filter materials and leachate will also
be a subject of concern in  specific cases,  and should be accounted for during
system design.
                                    9-97

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.EACHATE  COLLECTION  SYSTEMS—SELECTION AND SIZING OF FILTER AND DRAINAGE MEDIA
  •   Has  this  part  of  the  applicants  submittal  been  read
      and  evaluated?                                               Yes      No

  •   Are  soils  and/or  scone  media  proposed  for  adjacent  filter  	   	
      and  drain  layers?                                            Yes      N*o
      (If  filter fabrics are  proposed,  see Figure  	)

  •   Are  the  size  gradations characterizing these soil  layers    	    	
      presented  by  the  applicant?                                  Yas      ."Jo

  •   What criteria or  equations has  the  applicant used  to
      demonstrate that  movement of  fines  (and media clogging)
      will not occur?
  •   riave  equations  recommended  by  EPA been  ased  to              	   	
      assure acceptability  of  adjacent  layers?                     Yes      No

  •   If  no, conduct  an  independent  check  using  those
      relationships
        Independent  Check


  a.  015  filter/Dsj soi.1  = _         <  5?
                                                                  Yes      No

  b.  D15  filter/Di5  soil  = _         >_ 5?              _   _
                                                                  Yes      No

  c.  D50  filter/D50  soil  = _         = 25?             __   _
                                                                  Yes      No

  •   Is the  applicants  proposal  acceptable  in  preventing         _   _
      drainage  media  clogging  by  fines?                            Yes      No
     Figure  9.2.22.   Worksheet  to  determine  adequacy  of  design of drainage
                     and  filter layers.
                                      9-98

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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

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     •    perforated drainage niof.s ' ? . .-.    i:.-iJ.-j  ..-:•/  -~-.tr;::.., „,.- .-VC/
          vtrr. 3a.aJ.3d ^31.-;^ o t a .ainimum diameter of  "3 in. co facilitate
          mechanical or chemical cleaning,

     •    manholes located at ~ajjr ^ipe incersections or bends to allow for
          access, inspection, and mechanical or chemical cleaning,

     •    incorporation of valving, ports, or other appurtenances necessary co
          introduce biocides and/or cleaning solutions, and

     •    automatic leachata level monitors and (possibly) alarm systems.

     Following construction, scheduled periodic maintenance is recommended.
After the initial lift of waste has been placed, che ^r'.inaee =•.-•:,-cm jr.oui- oe
insoected. rle.ar.ec!  :-.'i  :jjica, unc repaired if necessary.  Subsequently,
periodic testing and cleaning should be conducted, possibly once per year.  In
addition, leachate levels and flow rates should be continuously monitored and
correlated with rainfall so that inconsistencies indicating clogging can be
immediately investigated.

     Clogged drainpipes can ;>e restored Co a free flowing condition by
pnysicai or chemical cleaning except in cases vhere Dlockage is due Co
crashing jf the drain.   In this case, drain replacement would be required.
Also, except under unusual circumstances,  it would not be feasible co clean
large areas of drainage  layers which had become clogged.

     Of the two physical methods of drain cleaning, hydraulic jets have
generally been considered superior to "mechanical cleaning systems (.e.g.,
Rota-rooters) wnich are  often used with success in the cleaning of sanitary
sewer lines, or mechanical "pigs" which are used for cleaning water .-nains.

     Physical methods for removal of ochre and other associated iron clogging
agents within drains have been extensively used in Europe, and to some degree
in the United States.  These methods employ a high or  low pressure jet
cleaning system placed within the drains. 39  jn Europe, the high pressure
system is used for the more seriously clogged drains while low pressure units
are restricted to removing silt and iron deposits.39

     Preliminary tests by Ford, using a high pressure  (1100 to 1300 psi at the
pump) system, found that condiserable damage to the sand-gravel envelope
surrounding the drains and subsequent deposition of sand and gravel within the
drains was occurring.39  These observations prompted interest in a low
pressure system for ochre removal in Florida.  From a  group of 21 low pressure
nozzle types, two nozzles (as shown in Figure 9.2.25)  were rated highest on
the basis of propelling distance, cleaning efficiency, water requirements, and
ease of construction.39

     The overall performance of these low pressure nozzle cleaning systems was
found to be adequate in  removing deposits which primarily consisted of ochre
and FeS within 4 to 5 inch plastic drains of up to 550 ft in length.39  it
was noted that jetting should be performed at a slow entry rate and with a
                                     9-102

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             /
            ,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

-------
identified is .2 '~azaraou3 -asca me! .  ::".ersf;ra ,  ecu*.: ^e inappropriate,
\;,- quart arnary ammonium salCs; a nonoxidizing biocide which killed Che
bacteria but also had to be limited :o certain types of problems because these
sales form undesirable complexes, (3) iodine vhich vas a good bi.oci.de, but
which forms complexes with iron that may clog, and (4) hydrogen peroxide
(^2^2^'  which when combined with Fe forms a superoxide radical which was
found to be a good biocide.  Otherwise, t^C^ was a poor biocide for sulfur
slime and other slimes that did not contain Fe .

     In summary, numerous methods for reclaiming drainage systems have been
attempted,  oorae nave snown great success with certain clogging agents, while
others are not as effective or are dangerous to handle.  As indicated by
Ford, 19 prevention is the best method for controlling chemical-
microbiological slimes and associated
9.2.2.4  Draft Permit Preparation —
     Condition 8.2 of Permit Module XV (see Section 4) addresses design and
operation of leachate collection and removal systems.  The condition is
implemented through reference to a permit attachment that includes plans and
specifications for Che proposed leachate collection system.  To be suitable
for substitution in Ihe permit condition attachment, the submitted application
information should include ihe following:

     •    engineering plans which show the full extent of the leachate
          collection system in plan and profile views,

     •    all calculations and results— demonstrating the depth of leachate
          above the bottom liner,

     •    all calculations supporting selection of pipe of sufficient strength
          Co withstand overburden live and dead loads,

     •    all conclusions and associated documentation illustrating the
          resistance of leachate collection system materials to wastes,

     •    all calculations, assertions,  and drawings necessary to illustrate
          design procedures to prevent leachate system clogging and allow for
          correction of clogging if it occurs.

9.2.2.5  References —

      1.  Permit Applicants Guidance Manual for Preparing Part B Applications
          for Hazardous Waste Management Facilities (Draft).  U.S.
          Environmental Protection Agency.  April 1983.

      2.  Metcalf and Eddy, Inc.  Wastewater Engineering - Collection,
          Treatment, and Disposal.  McGraw-Hill.  1972.

      3.  American Society of Civil Engineers and the Water Pollution Control
          Federation.  Design and Construction of Sanitary and Storm Sewers.
          Manuals and Reports on Engineering Practice No. 37.  1974.
                                    9-105

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

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

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

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

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

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

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

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

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

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

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

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

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

17.   Johns-Manville.   Perma-Loc™ PVC Gravity Sewer Pipe.  TRX-39.  April
     1982.
                               9-106

-------
                       ?-. ;-3 j/s:2ms.  .-;r~as ;r ir.  ,  .-=r:na--oc  ,  ?VC,
     Transite  , Thermopipes  .  TR-32Q.  January  1982.

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

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

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

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

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

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

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

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

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

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

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

30.  Cedergren, H.  R.   Seepage,  drainage,  and  Flow Nets.   John Wiley and
     Sons, 1967, pp. 178-187.
                                9-107

-------
ji.  J.z. nrmy Jorps or Engineers.  ^r^ina^e ana cirosion
     Control-Subsurface Drainage Facilities for Airfields.  Fart XIII,
     Chapter 2, Engineering Manual, Military Construction, Washington,
     D.C., June 1955.

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

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

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

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

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

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

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

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

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

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

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

43.  Thomas, Abraham, et al.  Physical and Chemical Rehabilitation of
     Containment Recovery Wells, Army Creek Landfill, New Castle County,
     Delaware Presented at Association of Engineering Geologists, Annual
     Meeting Hershey, Pa., October 1978.
                               9-108

-------
                   -Vvsrr  '.   ~.n\", rcr.rr.ar.ca 1 nsc-acto c c Sulfur Dioxide
                    of Iron-.-ianganese in Pipe Drains.  Irrigation and
          Drainage,  pp.  120-125.

     45.   Dennis,  C.  W.  The Failure of a Pipe Drainage System in an Organic
          Soil and Subsequent Remedial Measures.  Land Drainage Service.
          Field Drainage Experimental Unit, Technical Report 78/3.  November
          1978, pp. 1-12.

9.2.3  Liner and Leachate ".? 11 action ana Removal System Exemption

9.2.3.1  The Federal  Requirement—
     Part 270 requires the following application information if an exemption
is sought:

               5270.2Kb) (1) "... If an exemption from the requirements for a
          liner and a leachate collection and removal system is sought as
          provided by §264.301(b), submit detailed plans and engineering and
          hydrogeologic reports, as appropriate, describing alternate design
          and operating -practices that will, in conjunction with location
          asoects, prevent the migration of any hazardous constituent into the
          ground water or surface water at any future time."

     The Part 264 standards incorporate the following exemption criteria:

               "(b) The owner or operator will be exempted from the
          requirements of paragraph (a-) of this section if the Regional
          Administrator finds, based o» a demonstration by the owner or
          operator, that alternative design and operating practices, together
          with location characteristic^^ will prevent the migration of any
          hazardous constituents (see §264.93) into the ground water or
          surface water at any future time.  In deciding whether to grant an
          exemption,  the Regional Administrator will consider:
               (1) The nature and quantity of the wastes;
               (2) The proposed alternate design and operation;
               (3) The hydrogeologic setting of the facility, including the
          atten-uative capacity and thickness of che liners and soils present
          between the lanafiil and ground water or surface water; and
               (4) All other factors which would influence the quality and
          mobility of the leachate produced and the potential for it to
          migrate to  ground water or surface water."

9.2.3.2  Summary of Necessary Application Information—
     The Part B Permit Applicants' Manual 1 specifies the following
information requirements for new units:

     •    location information relevant to assessing the potential for
          leachate migration, i.e., soil permeability, attenuation capacity,
          geology, and geohydrology, and
                                    9-109

-------
     •    a descrintion of ".he '.Itar-.at ire iasigr.  -.-a  :c2r-.: _r.g  iracci^as  ana
           • :2mon2crat.en cnsc <~.ne proposal will prsvenc contamination of
          surface and ground water aC any fuCure time.

9.2.3.3  Guidance on Evaluating Application Information—
     It is not expected that many applicants will apply for  this exemption.
Additionally, it is not expected that many, if any, locations exist where  such
a demonstration could be adequately made.  By definition, the site would first
have to be located well above the existing water table in the unsaturated
zone.  The intermediate soil would have to be a dense cohesive fine grained
material 'clay) with axtramely iOw permeaoilicy.  Given the  low water content
and low void ratio, it is expected that high suction pressures would exist.
Suction forces of this magnitude could provide a driving force for leachate
migration which is one to two orders of magnitude greater than anv attendant
hvdrostatic -ir*.v:-.7 :-rr-    .1 :r.c>_6r. -,;e v/oi.^me of ieacnace  chat would migrate
jnaer cnese conditions is less than the amount that would migrate in saturated
soils according to Darcy's Law,  the velocity of movement of  the wetting cront
could be several times greater.

     As detailed in References 2 through 12, a great deal of information
exists in this subject area.  For instance, Moore notes a linearized solution
to the unsaturacad flow equations in the TRD on Hydrologic Simulation
(SW-869).2  of niost relevance is a guidance manual (GCA-1983)3 which
illustrates the use of numerical modeling to simulate leachate flow through
clay liners.  Although the manual is intended for use in designing liners  for
storage surface impoundments, the technique could be applied to determine  cne
time of travel of the leachate from the unit to the nearest  ground water or
surface water resource.  Given the physics of the situation  and the available
solution techniques, it seems improbable that an applicant could illustrate
with validity that leachate would never reach any ground water or surface
water at any future time.

     The guidance manual on numerical modeling incorporates  a bibliography of
related scientific literature.  The references listed in subsection 9.2.3.5
should provide for further understanding of this topic.

     The technical adequacy worksheet for determining Che suitability of the
applicant's alternative to the liner and leachate collection syscam is
presented in Figure 9.2.26.

9.2.3.4  Draft Permit Preparation—
     Liner and leachate collection system exemptions are discussed in
Condition B.2 of Module XV.  The condition is implemented through reference to
a permit attachment that provides plans and specifications for an alternative
design.  The permit application may be used as the attachment provided it
includes an adequate description of the alternative design and operating
practices and demonstrates that the design and operating practices, in
combination with location characteristics, will prevent any hazardous
constituents from entering the ground water or surface water at any future
time.  Successfully demonstrated alternative plans should also be documented
in the administrative record.
                                     9-110

-------
                 LINER AND LEACHATE COLLECTION SYSTEM  EXEMPTION
Has Che applicant applied for a liner and leachate               	   	
collection system exemption?                                       Yes      No

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

Are any of the hazardous materials leachable?                    	   	
                                                                           No
'-'ill .ig-r-i-iw^ii- quantities of leacnatne hazardous waste         	  	
be disposed in the landfill?                                       Yes      No

Is the site located well above the existing water table?         	  	
                                                                   Yes      No

Has the applicant demonstrated (using engineering and            	
hydrologic reports) that the intermediats soil layer               Yes      No
nas an extremely low permeability?

Has an accepted numerical or analytical model been used          	  	
to simulate leachate flow?                                         Yes      No

Does the simulation conclude that laachrs-te will never            	  	
reach ground water or surface water?                               Yes      No

How do the results compare with your independent evaluation using  techniques
presented in SW-869 or a numerical model? 	
  Figure 9.2.26.  Worksheet for determining  the  adequacy  of  the applicant's
                  submittal for a liner and  leachate  collection system exemption.
                                   9-111

-------
 1.   U.S.  SPA.   Permit Applicants'  Guidance Manual for Hazardous Waste Land
     Storage,  Treatment,  and 2ispOJal Facilities.  volume I.  Office of Solid
     Waste.   Washington,  DC.  1933.

 2.   Moore,  C.  A.   Landfill and Surface Impoundment Performance Evaluation
     Manual.  Submitted to the U.S. Environmental Protection Agency, Office of
     Water and  Waste Management, by Gaotechnics,  Inc.  SW-86Q.  Seat amber I960,

 3.   Goode,  D.  J.,  e t a1.   Procedure for Modeling Flow through Clay Liners.
     Prepared for  the U.S. Environmental Protection Agency by GCA/Technology
     Division.   Draft Report.   August 1983.

 4.   Bear, J.   Hydraulics  of Groundvater.  McGraw-Hill,  New York.   1979.

 5.   Clapp,  R.  B.,  and G.  M. Hornberger.  Empirical Equations for  Some Soil
     Hydraulic  Properties, Water Resources Research 14(4), 1978, pp. 601-604.

 6.   Elzeftawy,  A.,  and K. Cartwrighc.   "Evaluating Che  Saturated  and
     Unsaturated Hydraulic Conductivity of Soils."  In Fermeaoility and
     Groundvater Contaminant Transport, ASTM STP  746, T.  F. Zimraie and C. 0.
     Riggs,  ed., American  Society for Testing and Materials, 1931, pp. 168-181.

 7.   Green,  W.  H.  and G.  A. Ampt.  Studies in Soil Physics I:  The Flow of Air
     and Water  through Soils,  Journal of Agricultural Science 4, 1911,
     pp. 1-24.

 8.   Gruber, P.  A.   Simplified Method for the Calculation of Unsaturated
     Hydraulic  Conductivity.  ?resented_at AGU Spring Meeting,
     Philadelphia,  PA.  May 31-June 4? 1982.

 9.   Hamilton,  J.  M., 0.  E. Daniel, and R. E. Olson.   "Measurement of
     Hydraulic  Conductivity of Partially Saturated Soils."  In Permeability
     and Groundvater Contaminant Transport, ASTM  STP  746.  T. F. Zimmie and C.
     0.  Riggs,  Eds., America Society for Testing  and  Materials, 1981,
     pp. 182-196.

10.   Mclntyre,  D.  S., R.  B. Cunningham, V. Vatanakul, and G. A. Stewart.
     Measuring  Hydraulic  Conductivity in Clay Soils:   Methods, Techniques, and
     Errors, Soil  Science  128(3), pp. 171-183, 1979.

11.   McWhorter,  D.  B., and J.  D. Nelson.  Unsaturated Flow Beneath Tailings
     Impoundments.   J. Geotech. Eng. Div. ASCE GT(ll), 1979, pp. 1317-1334.

12.   Miller, R.  D.,  and E. Bresler.  A Quick Method for  Estimating Soil Water
     Diffusivity Functions.  Soil Science Soc. Am. J. 41, 1977, pp. 1020-1022.
                                    9-112

-------
9.2.4.1  The Federal Requirement—
     As part of "he applicant's detailed plans and engineering report,
§ 270.21(b)(2) requires the submission to address "control of run-on."

     The Part 264 standards for run-on control specify in §264.301(c) that:

               "The owner or operator must design, construct, operate, and
          -i3ir.c,-.irt a run-on control system capable of preventing flow onto the
          active portion of the landfill during peak discharge from at least a
          25-year storm."

°.2.-,2  -•,-rcsry ~L "ecessary Application Information—
     The Part B Permit Applicants' Manual^ instructs the applicant to:

     •    Determine the peak flow from the upstream watershed area during the
          25-year storm event,

     •    Size and design run-on control facilities to accommodate the peak
          flow rate , and

     •    Devise a plan for run-on system maintenance, restoration, and repair.

9.2.4.3  Guidance on Evaluating Application Information—
     A flow chart indicating the applicability of the Part 264 requirements to
run-on control is provided in Figure 9.2.27.  The flow chart is also
applicao'.e EJ run-off control and management of run-on and run-off control
units, as discussed in subsections 9.2.5 and 9.2.6.
     The landfill owner/operator must design,  construct,  operate, and maintain
a run-on control system capable of preventing flow onto the active portion of
the landfill during peak discharge from at least a 25-year storm.  The
technical issues which must be considered in evaluating the application
information are presented in Figure 9.2.28.

     The amount of run-on (or runoff, as discussed in subsection 9.2.5)
expected as a result of precipitation will depend on:

     e    soil cover (vegetated or nonvegetated),

     «    upstream watershed surface slope,

     o    soil permeability,

     •    antecedent soil moisture content,  and

     •    seasonal temperatures (e.g.,  soil  freezing).

The relationships between run-on or run-off  production and these factors  are
covered in introductory hydrology textbooks  (see Reference 2 and Reference 3).
                                    9-113

-------
     DOES  THE LANDfILL DESiGN
     INCLUDE A RUN-ON CONTROL
              SYSTEM
                     YES
     IS  THE SYSTEM DESIGNED TO
   PREVENT FLOW ONTO THE ACTIVE
   PORTION DURING PEAK DISCHARGE
   FROM  AT LEAST A 25-YEAR STORM
                     YES
     DOES  THE LANDFILL DESIGN
     INCLUDE A RUN-OFF CONTROL
              SYSTEM
                     YES
     15 THE SYSTEM DESIGNED TO
   COLLECT AND CONTROL AT LEAST
    THE WATER VOLUME RESULTING
   FROM A 24-HOUR, 25-YEAR STORM
                     YES
   ARE RUN-ON/RUN-OFF COLLECTION
  FACILITY MANAGEMENT PROCEDURES
    SUITABLE TO MAINTAIN SYSTEM
         DESIGN CAPACITIES
NO
NO
NO
    THE
 PLANS ARE
TECHNICALLY
 NADEQUATE
NO
             THE PLANS
          ARE TECHNICALLY^
             ADEQUATE
Figure 9.2.27.  Regulations applicable to the control of run-on
                and run-off at hazardous waste landfills.
                             9-114

-------
                         RUN-ON CONTROL
SYSTEM DESIGN
AND CONSTRUCTION


SYSTEM
AND -MA

OPERATION
NTENANCE

   DETERMINATION OF
  MAGNITUDE/INTENSITY
OF 25-YEAR STORM EVENT
  ','S'ECTiGN
REQUIREMENTS
                                           MAINTENANCE OF
                                         DIVERSION STRUCTURE
    CALCULATION OF
    RUN-ON DURING
    PEAK DISCHARGE
     FROM DESIGN
     STORM EVENT
   DESIGN OF ASSOCIATED
   DIVERSION STRUCTURE
 Figure  9.2.28.   Technical  topics  addressed  for  run-on  control
                              9-115

-------
     Rainfall run-on can 'z--. ::'...^rr^c ^ .• _ons "r--c: •_.-.:: ^-rcn oerms or Diversion
ditches along cne upsiope side or the facility io direct flow toward natural
drainageways downslope from the unit.  Such diversion ditcnes or berms must b
designed to accommodate, at a minimum, the aeak flew associated wi.cn the
25-year scorn, as required by the Part 264 regulations.

9.2.4.3.1  tVLagnitude of the 25-Year Storm Event—The amount of rainfall
expected from a local or regional 25-year storm event can be obtained from the
National Oceanic and Atmospheric Administration or local Agricultural
Extension Service.  A worksheet for assessing cne adequacy of the applicant's
daterainacion or scorm magnitude is presented in Figure 9.2.29.

9.2.4.3.2  Calculation of Peak Run-on Discharge Rate—Two methods commonlv
used to calculate the volume of run-on or run-off :xriag and arter rainfall
ir« the "--tional .aecr.oa ' ana cne Soil Conservation Service (SCS) method.

The Rational Method

     The rational method calculates peak runoff production based on che
following expression:

                                    Q = Cia                                (34)

where Q = peak run-off rate in cubic feet per second (cfs)
      c = run-off coefficient which is actually the ratio of the peak run-off
          rate to the average rainfall rate for a period known as the time
          of concentration
      i » average rainfall intensity ITT inches per hour for a period equal
          to the time of concentration
      a 3 drainage area in acres

Use of the rational method for determination of design run-on quantity is
appropriate since the Part 264 regulations require control of the peak
discharge rate.  Q, as calculated using the rational method, is defined as the
peak discharge rate associated with the selected storm event.

     The rational method formula is based on the following assumptions:2

     (1)  the maximum run-off rate is a function of the average rate of
          rainfall during the time of concentration,

     (2)  the maximum rate of rainfall occurs during the time of
          concentration, and

     (3)  the variability of the storm pattern is not taken into consideration.

     The time of concentration (tc) is defined as the flow time from the
most remote point in the drainage area to the point in question.  The time of
concentration is calculated as follows:


                                       41b L1/3
                            t  =            °                              (35)
                             c   	
                                        t  -i2/3
                                        (ci)
                                    9-116

-------
RUN-ON CONTROL
  Determination of Magnitude of the
  25-year Storm Event
    —  Has this oart ^f "h? ~-r>i:.c^-' -  :uc~:. L^I  _,een  read
       ana evaluated?                                             	
                                                                   Yes""    No

    —  What storm magnitude was selected by  the applicant?        	
    —  What depth of rainfall is this storm event
       equivalent to?                                             	 laches

          based on what references?
       Tndeoendent Check  ,
          based on what reference?
       what is the rainfall depth associated with the
       25-year storm?                                             	    inches
       Is the rainfall depth established by the applicant
       at least as great as <:his determination?                  	
                                                                   Yes      No

       Then, likewise, this aspect of the applicant's
       submittal is or is not acceptable            	   	
                                                    is acceptable      is  not
                                                                     acceptable
       Figure  9.2.29.   Worksheet for determination of the magnitude of the
                       25-year storm event for evaluation of run-on control,
                                     9-117

-------
      c... = ci2e of concentration in minuces
       b = coefficient
      LO = overland flow length in feet
       C = run-orr coefficient (see Table 9.2.13)
       i = rainfall intensity in inches per hour during time of concentration

The equation is valid only for laminar flow conditions where Che product iLo
is less than 500.  The coefficient b is found as follows:

                                 0.0007i -i- C
                            b  =            r                              (36)
where So = surface slope
      Cr = a coefficient of retardance
Values of Cr, are given in Table 9.2.14.

     The run-off coefficient (C) is influenced by a number of variables, such
as infiltration capacity, interception by vegetation,  and depression
storage.2  AS used in the rational method, the coefficient C represents a
fixaa ratio or' run-off to rainfall, while in actuality it is not fixed and may
vary for a specific drainage basin with time during a particular storm, from
storm to storm, and with change in season.  Table 9.2.12 lists some values of
the run-off coefficient for various soils and surface covers.

     The rainfall intensity (i) is derrved from the average intensity lin/hr)
of a jtcm cor a given frequency (25-year in this case) for the time of
concentration.  Following determination of tc, che rainfall intensity is
usually obtained by making use of a set of rainfall intensicy-duration-
frequency curves such as shown in Figure 9.2.32.  Drawing a line from the
abscissa at the appropriate value of tc and then projecting upward to
intersect the desired frequency curve, i can be found by projecting this
intersection point horizontally to intercept the ordinate.  If an adequate
number of years of local rainfall records is available, curves similar to
Figure 9.2.30 may be developed.  Otherwise, data compiled by the National
Oceanic and Atmospheric Administration, the Department of Agriculture, or
other local government agencies can be used.

     A more in-depth discussion of surface water run-on and run-off
computations using the rational method is presented in References 2 and 3.

The SCS Method

     The SCS run-off equation is a method of estimating direct run-off from
storm rainfall of a duration of 1 day or less.

     The equation is:

                                     (P - I )2
                                           3   TT                           (37)
                                    (P - I )
                                          a
                                     9-113

-------
                                /'ALoc.5 -jf c\ u N —u e" F OJEF-_CIEMT,  C
                               Source:  Reference 4.
           Earth Surface
Cover
Min.
Max.
Sand, from uniform grain size,
no fines, to well graded, some
clay or ;ilt
Loam, from sandy or gravelly Co

- ~ — ^' ^ v

Gravel, from clean gravel and gravel
sand mixtures, no silt or clay to
high clay or silt content
Clay, from coarse sandy or
siity to pure colloidal clays

Bare
Light Vegetation
Dense Vegetation
Bare
*• TJ ^ *• '
L,ignc vegecacion
Dense Vegetation
Bare
Light Vegetation
Dense Vegecation
Bare
Light Vegetation
Dense Vegecation
0.15
0.10
0.05
•"v o r\
01 A
• iU
0.05
0.25
0.15
0.10
0.30
0.20
0.15
0.50
0.40
0.30
""* ~ i"
O/. ^
• ^J
0.35
0.65
0.50
0.40
0.75
0.60
0.50
NOTE:  Values of C for sarth surfaces are further varied by degree of satura
       tion, compaction, surface irregularity and slope, by character of sub
       soil, and by presence of frost or glazed snow or ice.
                  TABLE 9.2.14.  RETARDANCE COEFFICIENT, Cr
                                 Source:  Reference 2
                  Surface type                               Cr


              Smooth asphalt 	 0.007
              Concrete paving	0.012
              Tar and gravel paving	0.017
              Closely clipped sod	0.046
              Dense bluegrass turf	0.060
                                    9-119

-------
  10
-V

Ł
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
                 Ł
                 jj
                 i-
                 il
                            CJ
                            U
            9-122

-------
TABLE 9.2.15.
RUN-OFF CURVE NUMBERS FOR HYDROLOGIC SOIL-COVER  :OM?LŁXES
(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. Ł.  Data 3ook for Civil Engineers-Design.  John Wiley and
          Sons,  Inc.  New York, NY.  1960.

      3.   I-ient,  K. M.  A Method for Estimating Volume and Rat a of Runoff in
          Small  Watersheds.  J.o. Department of Agriculture, Soil Conservation
          Service.  SCS-TP-149.  Revised April 1973.

      6.   Mockus,  V.  National Engineering Handbook.  Section ^ - Hydrology.
          Chapter  10.  Estimation of Direct  Runoff From Storm Rainfall.  U.S.
          Department of Agriculture, Soil Conservation Service.  Reprinted
          with Minor Revisions, 1969.

      7.   U-S. EPA, Erosion and Sediment Control, Surface Mining in  the
          Eastern  U.S., Part 2, Design.-  EPA Report 625/3-76-006.  October
          1976.

      8.   L'.S. EPA, Design and Construction of Covers for Solid Waste
          Landfills.  Municipal Environmental Research laboratory, EPA Report
          600/2-79-165.  August 1979.

      9.   Brown, K. W. and Assoc., Inc.  Hazardous Waste Land Treatment.
          Prepared for the U.S. EPA, Municipal Environmental Research
          Laboratory.  Second Edition.  SW-874.  February 1983.

     10.   U.S. EPA, Process Design Manual for Land Treatment of Municipal
          Wastewater, EPA Technology Transfer Series, EPA Report '625/1-77-008,
          October  1977.

     11.   Brady, N. C., The Nature and Properties of Soils - 8th Ed. McMillan
          Publishing Company, N.Y., 1974.
                                      9-126

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9.2.5  Control of Run-off

9.2.5.1  The Federal Requirement—
     As part of the applicant's detailed plans and engineering report,
§270.2Kb) (3) requires the submission to address "control of run-off."

     The Part 264 standards for run-off control specify in §264.301(d) that:

          llThe —»-ner jr operator uius c uesign, construct, operate, and maintain
     a run-off management system to collect and control at least the water
     volume resulting from a 24-hour, 25-year storm."

9.2.^,2  Summary •>? "-^cassary Application j.nrormation—
     The Part B Manual 1 instructs the applicant to conduct the following
procedures and submit the results in the application:

     •    Determine the peak flow rate and run-off volume associated with at
          least a 24-hour, 25-year storm over the landfill,

     •    Size and design run-off collection facilities to collect at teast
          cnis water volume,

     •    Size and design run-off storage facilities to accommodate the
          calculated runoff volume

     0    Devise a plan for run-off system maintenance, restoration, and
          repair.

9.2.5.3  Guidance on Evaluating Application Information—
     To avoid migration of contaminated.run-off,  facilities  must be designed
and operated to collect and control surface run-off from the active portion of
the landfill.  The technical issues of concern are presented in Figure 9.2.33.

9.2.5.3.1  Magnitude of the 24-Hour, 25-Year Storm Event—Facilities must be
designed to handle the run-off volume associated  with at least the 24-hour,
25-year storm.  Figure 9.2.34 indicates the depth of rainfall for this event
throughout the United States.2  A worksheet for evaluating the magnitude of
the selected storm event is presented in Figure 9.2.35.

9.2.5.3.2  Calculation of Run-off Volume—The volume of runoff expected for
this storm event can be calculated using the SCS  Method or the Rational
Method, as described in subsection 9.2.4.3.

     The Part 264 regulations for run-off require that the run-off management
system "collect and control at least the water volume resulting from a 24-hour,
25-year storm."  Since the rational method calculates peak discharge,  use of
the SCS method may provide a more straightforward approach to calculating the
total run-off water volume associated with the design storm  event.   First,  Q
is estimated using the graphical method shown earlier in Figure 9.2.31.   Then,
the total run-off volume associated with the storm event is  approximated  as:


                                     V « ^                                (43)


                                    9-127

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                              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

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                                                              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

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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 QŁ ^an-oŁf 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

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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

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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

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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

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DOES OR WILL THE LANDFILL CONTAIN
ANY PARTinil ATF MATTFR ^!lfl IPTT

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

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 APPLICATION OF
     COVERS
 INTERMITTENT OR
TEMPORARY COVERS
   FINAL COVER
COVER MAINTENANCE
  AFTER CLOSURE
                         DESIGN OF WIND
                            rMSPERSAL
                         CONTROL SYSTEMS


OTHER MANAGEMENT
TECHNIQUES
                WIND  BREAKS
                   OUST
               SUPPRESSANTS

INSPECTION  REQUIREMENTS
   DURING  OPERATION
         Figure 9.2.39.  Wind dispersal control options,
                               9-140

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 MANAGEMENT OF WIND DISPERSAL


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

 Is ^rosion pocentiai addressed for:

     Waste materials?
                                                                  yes      no

     Landfill cover?
                                                                  yes      no

     Unpaved haul roads?                                        	   	
                                                                  yes      no

     Excavation activities?                                     	   	
                                                                  yes      no

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

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

Are waste disposal operations suspended during                  	   	
excessively high winds?                                           ves      ~
    Figure  9.2.40.   Worksheet  for  evaluating the  adequacy of wind dispersal
                    control  measures.
                                    9-141

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3...~.-  3rafc Permit Preparation—
     As noted in Module XV,  Condition 3.5,  :he permit snould soecifv -nechods
for concroLliag wind dispersal if the landfill contains  partLCjlace  ^ac:ar
vnich may be subject co wind dispersal.   This condition  is implemented througn
reference to a permit attachment that includes plans and specifications  for
the proposed wind dispersal  control measures.  Submitted application
information suitable for substitution in the permit condition attacnment
should include the following:

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

     •    A description of methods used  for wind dispersal control.

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

9.2.8  Subpart F Exemption

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

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

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

               "(a) Tha owner or operator of a double-lined landfill is  not
          subject to regulation under Subpart F of this  part if the  following
          conditions are met;
               (1) The landfill (including  its underlying liners)  must be
          located entirely above the seasonal high water table.
               (2) The landfill must be  underlain by two liners which  are
          designed and constructed in a  manner to prevent the migration of
          liquids into or out of the space  between the liners.   Both liners
          must meec all the  specifications  of §264 .301(a) (1) .
               (3) A leak detection system  must be designed, constructed,
          maintained, and operated between  the liners to detect any  migration
          of liquid into the space between  the liners.
               (4) The landfill must have a leachate collection and  removal
          system above Che top liner that  is designed, constructed,
          maintained, and operated in accordance with § 264.301(a)(2).
               (b) If liquid leaks into  the leak detection system, the owner
          or operator must:
                                    9-142

-------
                 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
       ,YŁS
      DOES THE DESIGN PROVIDE FOR TWO
      LINERS UNDEP. ~HŁ LANDFILL?
                     NO
          YES
         WILL THE DESIGN AND CONSTRUCTION OF
         THE LINERS PREVENT LIQUIDS FROM
         GETTING INTO OR OUT OF THE SPACE
         BETWEEN THE LINERS?
             .YES
            DO 80TH OF THE LINERS MEET
            OF THE §264.301(a)(1) SPEC
               \t
                .YES
               DOES THE DESIGN PROVIDE FOR THE
               INSTALLATION AND OPERATION OF A
               LEAK DETECTION SYSTEM BETWEEN
               THE TWO LINERS?
                              NO
                   YES
                  DOES THE DESIGN INCLUDE A LEACHATE
                  COLLECTION AND REMOVAL SYSTEM ABOVE
                  THE TOP LINER THAT MEETS ALL THE
                  §264.301(a)(2) CRITERIA?
                     \ r
                                    NO
                      YES
                     DOES THE SUBMITTAL INCLUDE A PLAN FOR
                     REMOVAL OF WASTES AND LINER REPAIR OR
                     IMPLEMENTATION OF A DETECTION
                     MONITORING PROGRAM IF LIQUIDS LEAK
                     INTO THE LEAK DETECTION SYSTEM?
                                                    THE
                                                 PLANS ARE
                                                TECHNICALLY
                                                 ADEQUATE
    Figure 9.2.41.
Applicability of Part 264 requirements co the Subpart F
exemption.
                                     9-144

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r=~2rr?-J  "o  — '- ;, u i.: a r. c a provic^a  -n suosectisn  ? . 2 . 1 . j . ~  rcr  evaluation  of
information on water caoLe elevation and to  suosection  9.2.1.3.2  for  guidance
on Liner -naterials, cnemical properti.es, and  liner strength and  thickness.   To
evaluate the adequacy of the leak  datsction  system and/or  the  leachate
collection system, the permit reviewer is referred to  subsection  9.2.2.3  which
provides guidance on system design and materials, chemical resistance,  pipe
strength and thickness, and media/pipe clogging.  Although resistivity  probes
could be used for leak detection systems, the Agency strongly  recommends  that
drainage media and piping be designed into the svstera  as  for leachate
collection «"scsn!3.  If 1 ;:.'kage occurs, cnen  a system  will be  in  place  for
leacnace collection and removal.

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

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

9,2.8.5  References —

1.   U.S. SPA.  Permit Aoolicancs'  Guidance Manual cor Hazardous  Waste Land
     Storage, Treatment and Disposal Facilities.  Volume I.  Office of Solid
     Waste.  Washington, D.C.  1983.
                                    9-145

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                               SUBPART F EXEMPTION
das this part of the applicant's subraittal been read             	  	
and evaluated?                                                    Yes      Mo

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

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

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

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

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 9.3   INSPECTION1  .-.Iv'JlAS'iSNTS

 9.3.1   The  Federal  Reg--: Iranian: 3

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

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

      The relevant standards of §264.303  specify:

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

     §264.303(b) states:

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

9.3.2  Summary of Necessary Application  Information

     The Part B Permit Applicants' Manuali instructs  the applicant to
develop and submit with  the application  a detailed written inspection
schedule.  The applicant is referenced CO the Permit  Applicants'  Guidance
Manual on th« General  Facility Standards for instruction on preparation of the
inspection plan.   The latter manual recommends that the applicant submit the
actual inspection log that he proposes to use for day to day inspection
activities.
                                     9-147

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 9.3.2   Guiaance_  ^n  -Zv a I : a c •. • 2  Arc'.. :g;-. jn  !.: ~ jnacior.

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

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

     •    before/during construction

     *    after construction

     •    during operation

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

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

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

     During evaluation of the  application, the permit application reviewer
should a*k Che following questions to determine the adequacy of proposed
inspection procedures.
                                    9-148

-------
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9-L49

-------
     Do  cha  inspection procedures indicate;

     (1)  When  (i.e., at whac scage of construccion; prior 1:0 che firsc
          addition of waste, Che specific procedures will be implemented?

     (2)  Why che procedures will be implemented?

     (3)  What  specific items will be inspecCed?

     (4)  How che icems idencified will be inspecced?

     (5)  What  conscicutes failure as a result of insoaccinn?

     (b)  What  corrective actions will be instituCed upon failure?

     (7)  What  records of Che inspections will be maintained?

     In §264.303(a),  che term "liners ... and cover systems" is used to
identify whac is incanded for inspection.  AC a landfill, these "systems" may
consist of multiple layers of soil and nonsoil materials.  It is che intenc of
'rhe -egulacion  chac all oiacenais used Co construct che various layers of
liners or covers be inspecced during and after installation.  The remainder of
this section addresses the procedures chat should be included in an inspection
plan to adequately comply with the inCencions of §264.303(a) regarding
inspeccion of liner and cover layers.

9.3.3.2  Is r.ha unit  an axiseing landfill? —
     A definicion of "existing porCion." can be found in §260.10.  A.ny portion
of a landfill which does ioc -neeC che criteria for existing is new and must be
inspecced during and after construction of liner and leachate collection
systems (see subseccions 9.3.3.3 chrough 9.3.3.5).  Existing portions are not
required to have liners but muse scill be inspecced on a regular basis during
operation (see subsection 9.3.3.6).

     The definicions  in §260.10 for "active portion," "closed portion,"
"exiscing hazardous waste management facility," "facility," "inactive
portion," "landfill," "landfill cell," and "partial closure" may aid che
perraic applicacion reviewer in confirming Che identification of new and
existing portions of  a landfill.

     A worksheet for evaluating the applicant's submittal in Cerras of general
inspeccion information requirements is provided in Figure 9.3.2.

9.3.3.3  Doea the application contain a description of procedures for
         impacting liner and cover sy^Cem materials for uniformity and
         integrity during installation? —

9.3.3.3.1  Introduction—Figure 9.3.3 is a chart of topics presented in this
part.   The topics address each of the various layers thac could typical I/ be a
pare of any liner or  cover system at a landfill.
                                    '9-150

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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« Ło ^-<»•• r.g :iai: -o.-i.ii .a^ers;

      •    Leak detection system materials

      •    Drainage/foundation layer raaterials

 These additional layers  wo..Id be installed  above the foundation materials and
 below che liner materials of a single liner landfill.

      A cover  system designed as a  final  cap for a landfill will consist of che
 following layers;

      •    Vegetative support layer materials

      •    Filter layer materials

      •    Drainage layer materials

      •    Bedding layer  materials

      •    Synthetic membrane layer materials

      •    Low conductivity clay layer

 In  some cases che filter and bedding layers may be  omitted.  In other cases a
 bedding layer must also  be included between the synthetic and underlying clay
 layers.  The  low conductivity clay layer will typically be placed directly
 over  the waste materials at  closure.

      The construction materials  and  inspection  procedures  for  liner  systems
 and cover systems  will be  very  similar (if  not  identical)  at many landfills.
 The guidance her*  on inspection  procedures  is organized  according to  the
materials of each  layer  in a  liner system.   The  inspections that  should be
 implemented before and during installation  of a  layer are  identical regardless
of whether the layer is  in a  liner or a cover system.   (Inspections after
 installation are discussed in subsections 9.3.3.4 and 9.3.3.5.)   The
correspondence between liner system layers  and cover system layers is shown in
Table 9.3.1.
                                      9-153

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         TABLE 9.3.1.  EQUIVALENCE OF LINER AND COVER SYSTEM LAYERS IN
                       CONSIDERATION OF INSPECTION REQUIREMENTS
        Liner system layers
     Cover system Layers
In-siCu soils

Foundation materials

Lower liner materials in a double
lined landfill

laak detection system materials

Upper liner materials in a double
lined landfill

Liner materials in a single
l-'.r.ed landfill

Leachate collection system materials

Drainage/protective material3

No equivalent
No equivalent

Bedding materials

Impermeable materials


No equivalent

Synthetic membrane materials


Synthetic membrane materials


No equivalent

Filter and drainage materials

Vegetative support material
alnstalled above any liner
                                    9-154

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      ->i2ra equivalency LS me icacad , the inspection procedures discussed here
are applicable Co both the liner and cov=r layers idenc.Jiea.

9.3.3.3.2  In-3itu Soils — Preparation of tne existing land surface sefore
conscruction of a landfill cell does noC typically require complex
procedures.  However, inspection during construction should be conducted.
These inspection procedures should confirm that:
     •    The in-sicu soils have been orooerly j
          irregularities and rocks have been removed.

     •    The finished surface is not closer to the water table Chan presented
          in the original olans.

     •    The horizontal dimensions of the prepared surface agree with Che
          original plans.

     •    There is no water or other liquid, noc previously anticipated, on
          the finished surface.

     •    There are no previously unidentified strata or geologic formations
          present thac would jeopardize the function of Che Liner system.

     It is important to determine the moisture content of the layer before it
is covered by an overlaying layer.  This is especially true in areas where Che
layer will be exposed to freeze/thaw cycles.  The inspection procedures should
provide for postponement of construction when precipitation occurs.  Any
standing water or dampness should be removed before construction continues. 3

     Other important concerns are the presence of organic materials, gas
pockets, or soluble soils. 3  if anv of these are present in the in-situ
materials, they can have a detrimental effect on all overlying layers.  Thus,
the inspection procedures should provide that the inspector will either
conduct or observe tests to confirm Chat organic materials, gas pockets, or
soluble gas are not present at or near the surface of the in-situ materials.
The corrective actions to be taken if these materials are identified should be
described .

9.3.3.3.3  Foundation Materials — Once Che bottom surface has been prepared,
foundation materials that will support the actual liner are put in place.
During construction of the foundation, the inspection procedures should
provide for confirmation of the following items:

     •    Materials are in conformance with plans and specifications.

     •    Procedures for placing materials are appropriate.

     •    Compaction equipment and procedures conform to plans.

     •    Work is  being conducted only during appropriate weather
          conditions. 3, 4
                                    9-155

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     •     Irregularities in materials or procedures are aadressea
          appropriately as they are encountered.

     In a cover system, bedding materials may be installed over lower
impermeable materials (see subsection 9.3.3.3.4) to provide a foundation for
the overlying synthetic membrane.  In other cases, the impermeable materials
in a cover system may be such that bedding materials are not necessary below
the synthetic membrane layer.  Regard! as.? ~:i vnich .3 tr.e case, tne five items
liatad above should be identified in inspection procedures relevant to any
layer immediately below the synthetic membrane layer.

     Depending on the design of the la-ndf: 1'. - = '1, :r.a L.aer ^yscem or cne
ccvar system .-nay oe penetrated by or placed over footings, pipes,  or other
appurtenances.3 ,4  Further, depending on how the liner or cover will be
secured at the perimeter of the landfill, ic may be necessary to prepare the
perimeter for liner or cover system attachment.  This preparatory work is most
important when the liner or cover layer is  a synthetic membrane or material.
The permit application reviewer should confirm that the inspection procedures
that will be conducted just prior to tne installation of such a cover or liner
demonstrate knowledge of the importance of cnis preparatory work to the
overall integrity of the liner or cover system.  The inspection procedures
should indicate that these areas will be inspected along with inspection of
liner or cover foundation materials.

     The final step in preparing foundation materials for covering by a
synthetic liner material is often that of applying a sterilizing agent to
prevent the growth of plants that could puncture the liner material.3  if
the application of a sterilizing agent is indicated in the liner or cover
system design, the inspection procedures should include confirmation of the
following items;

     •    The contents of sterilizing agent containers were inspected for
          conformity upon receipt.

     •    Appropriate storage conditions were maintained.

     •    Application was conducted under appropriate weather conditions.

     •    Appropriate application equipment and procedures were used.

     •    The application rate (dosage) was as specified in the plans.

     •    Appropriate time was allowed before initiation of liner layer
          installation.

9.3.3.3.4  Liner Materials—Inspection procedures during liner material
placement will vary depending on whether the liner material is synthetic or a
soil-based or admixed material.
                                     9-156

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      Svntheti- raacariais--0wners or operators of  landfills who  jae  synthetic
 liners or covers will have  indicated  che nominal  chi.ck.ness of chose
 materials.   In addition, they should  be able co obtain  che quality  control
 parameters  from the manufacturers of  the materials-   If  this information has
 been  submitted, it can be used by the permit application reviewer in  judging
 the adequacy of the preinstallation inspection procedures.  However,  reliance
 on the manufacturer's quality control specifications  alone is not an
 acceptable  substitute for inspection.  At a minimum,  the owner  or operator
 should indicate that the materials will ie c.osei/  inspected at  tne site of
 installation by personnel specifically representing their interests.   If
 rigorous inspection and test procedures will be employed at the  site,  in
 addition to visual inspection, the equipment and  procedures to  be used should
 be described and the cvsa ~ ? damage jr 1..-.per rice;, on -men they  are  intended to
 ^.aencify anouid be stated.  If only a representative  sample of  the materials
 is co be inspected, the permit application should justify that  the  portion
 inspected is truly indicative of the  condition of all Che materials.

      Synthetic sheets or membranes are shipped to the site as rolls or as
 accordian folds.  They are  typically  on pallets and wrapped or  otherwise
 coveraa.  It will often be  necessary  to score these materials at or .near che
 installation ,;ita.  These materials should be protected  from climatic extremes
 and vandalism during any storage period.  Inspection  procedures  should provide
 for the following:

     *    Inspection upon receipt prior to any storage.

     •    Observation of handling -luring placement into  storage.

     •    Periodic inspection while in storage.

     •    Observation of procedures and equipment for removal from storage and
          movement to installation site.

     •    Confirmation of appropriate weather conditions for placement.3>^

     •    Observation of equipment and proceduras Co  place liner material at
          che site.

     •    Inspection of liner material after placement at the site and prior
          to installation.

     •    Approval for installation to proceed.

 Inspection  procedures that  should be conducted after  liner material
 installation are presented  in subsection 9.3.3.i.  The inspection items
 presented here are intended for implementation prior  to and during placement
of liner materials.

     Synthetic liner material manufacturers conduct various tests and
inspections  at their manufacturing plants  as part of  their QA/QC procedures.
The handling and transportation of these materials to the site of installation
provides  opportunities  for damage.  Thus,  inspection of  the materials upon
                                    9-157

-------
 arrival at  Che site should be conducted.  '.'nits vhose wrappings indicate
 potential damage or rough handling should be more closely inspected.  Shipping
 papers should be compared co nacenal markings and purchase orders Co insure
 conforraance with plan specifications.  The inspection plans should specify
 liner acceptance criteria.

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

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

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

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

     The work crew also moves the fully extended panel into final position
manually.   This includes placement in anchor trenches and overlapping of
 adjacent panels.   At this point, che panel is anchored down with sandbags
and/or tire* to temporarily secure it in the desired position for subsequent
 seaming.  The inspection procedures should provide for a thorough inspection
of the placed liner panel at this time.  At a minimum the inspection should
 include:
                                     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

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                     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 oŁ 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

-------
                                           •3

                                           V)
                                           3
                                           O
                                          0)

                                          3
                                          V)
                                         J

                                         3
                                        -3
                                        "3
                                        •3

                                        73

                                        5
                                       30
                                       il
                                     >T
                                     :?\
                                     U
                                     3
9-190

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-------
seven steps (see Figure 9.4.2), constitute a review of -natariaij and
conditions at the site under consideration.  The six procedures identified in
Figure 9.4.3 encompass 25 steps and pertain co tne cnaracteristics of the
cover system.  Figure 9.4.4 identifies procedures used to evaluate the
adequacy of post-closure plans in a total of seven steps.  The following
discussion describes evaluation procedures and their relationship to §264.310:

9.4.3.2.1  Examine Background Data (see Figure 9.4.2) —

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

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

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

9.4.3.2.2  Characterize the Cover System (see Figure 9.4.3)

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

     •    Evaluate cover thickness (Steps 9-13)—In addition to federal and
          state cover requirements, the cover thickness may be governed by the
          quantity of borrow available, infiltration, gas migration,
          trafficability and support requirements, freeze/thaw and dry/soak
          effects,  cracking, differential settlement, membrane protection, and
          vegetative requirements.  These factors should be addressed in
          permit applications.
                                     9-194

-------
     •    Evaluate cover placement procedure (Steps 14-13 .'--Cover can be
          improved in several ways as it is constructed.  Materials mav be
          added for better grading, hauling and spreading equipment can be
          operated in a manner which increases compaction, and layering can be
          used.  Internal layering can combine favorable characteristics of
          several materials.  Synthetic membrane liners used in this
          configuration should be at least 20 mils thick and should be placed
          in a relaxed state between smooth layers of soil to orevent d-mage.
          Syr,'hati~. l-lr.arc are oi-^n necessary to maintain permeability at or
          below that of the bottom liner system.

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

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

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

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

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

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

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

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

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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

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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

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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

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             ARE IGNITABLE OR REACTIVE
       WASTES TO BE PLACED IN THE LANDFILL?
                    YES
           WILL THE WASTES SE DISPOSED
                OF  IN  CONTAINERS?
                                V'ES
    WILL THE WASTES 3E
IGNITABLE OR REACTIVE AFTER
PLACEMENT IN THE LANDFILL?
                      YES
                              APPLICABLE
                              REGULATIONS
                             HAVE NOT SEEN
                               ADDRESSED
  ARE THE PRECAUTIONS OF
    §264.I 7(b)  COMPLIED
           WITH?
               YES
    IS DOCUMENTATION OF
   =264.I7(b)  COMPLIANCE
         PROVIDED?
                        DO THE DISPOSAL CONTAINERS
                          AND DISPOSAL PROCEDURES
                         COMPLY WITH §264.312(fa)?
                                 NO
  YES
                                       APPLICABLE.
                                       REGULATIONS
                                        HAVE BEEN
                                        ADDRESSED
                        00 THE DISPOSAL CONTAINERS
                        AND PROCEDURES COMPLY WITH
                                 3264.316?
                            NO
YES
               YES
                                     APPLICABLE.
                                     REGULATIONS \>
                                      HAVE BEEN  ^X
                                      ADDRESSED
        APPLICABLE
    /REGULATIONS
    N.  HAVE BEE
      ^ADDRESSED
         Figure 9.5.1.
Applicability of regulations to handling and disposal
of ignitable and reactive wastes.
                                    9-205

-------
     The following Notices contain preamble discussions of §261.21 and
§251.23.  rheae sections of 40 CFR Part 261 identify criteria for ignitable
and reactive wastes.

  Federal Register Notice

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

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

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

     •    ASTM Standard D-93-79

     •    ASTM Standard D-93-80

     •    ASTM Standard D-3278-73

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

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

     General and Executive         (617) 328-9290

     Publicaton Sales              (617) 770-3002

     Washington, D.C. Office       (202) 484-8200
                                    9-206

-------
 Secailea  information on  identification  and  casting  of  reactive wastes  is
 provided  in  Section 2.1.3 of  SW-346.

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

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

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

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

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

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

 The owner or operator of a  landfill who is treating ignitabla or reactive
wastes must document that the treatment employed will not itself be
hazardous.  The permit application may be judged dificient if the required
documentation is not submitted or if it is judged  to be inadequate.
                                    9-207

-------
9.5.3.1.5  Will containers of ignitable wastes be disposed of, and if so,
disposed of in compliance with §264.312(b)?—Section 264.312(b) allows
landfilling of containerized ignitable waste if:

     •    the containers are not leaking,

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

     •    the containers are covered daily with noncorabustible material, and

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

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

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

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

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

Thus, for all reactive wastes that are not cyanide- or sulfide-bearing, the
waste must be treated or rendered nonreactive before it can be placed in a
landfill, regardless of whether it is in a lab pack.  However, cyanide- and
sulfide-bearing reactive wastes in lab packs can be landfilled without being
treated or rendered nonreactive, but only if the containerization complies
with paragraphs (a) through (d) of §264.316 for lab packs, as discussed in
subsection 9.3.
*Cyanide- and sulfide-bearing wastes are defined in §261.23(a)(5) of Subpart C
 of Part 261.
                                    9-208

-------
     The firsc requirement of §264.316(e) mandates that the reactive wastes
(other than cyanide- and sulfide-bearing) oe treated or rendered nonreactive
before concainerization in lab packs.  This activity will typically be
conducted by the generator and not by the owner or operator of a landfill.   In
these cases, the permit application should incorporate documented assurances
from the generator to the landfill owner or operator that the noncyanide- and
nonsulfide-bearing reactive wastes have been rendered nonreactive before lab
pack containerization.  The documentation should contain details of the
materials and procedures chat vill ba -nployeci jy cne generator.

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

9.5.3.1.7  Summary

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

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

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

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

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

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

9.5.3.2  Evaluation of the Technical Adequacy of the Applicant's Subraittal—
     Figure 9.5.2 presents the major topics that are discussed in this
subsection.  The permit reviewer should first determine which of the technical
topics are applicable to the facility and operation of concern.   For instance,
if the applicant proposes to containerize ignitable wastes in conformance with
the requirements of §264.312(b), then the discussion about treating,
rendering,  or mixing the waste so that it is no longer ignitable or reactive
does not apply.   If any applicable topics are not adequately addressed by the
applicant,  the application and the proposed disposal methods may be
technically deficient.
                                    9-209

-------
                                IGNITABLE OR
                               REACTIVE WASTE
METHODS TO TREAT, RENDER
OR MIX THE WASTE SO THAT
     IT IS NO LONGER
  IGN)TABLE OR REACTIVE
               LISTS OF
              IGNITABLE AND
            REACTIVE WASTE
CONTAINERIZED
  IGNI TABLE
   WASTES
        TEST FOR
      COMPATIBILITY
                                        NONLEAKING
                                        CONTAINERS
    TEST TO DETERMINE  •
    WASTES ARE IGNITABLE
       OR REACTIVE
                                     CAREFULLY HANDLE  •
                                   CONTAINERS TO PREVENT
                                         IGNITION
                                                           COVER DAILY
                                                         SEGREGATE FROM
                                                         HEAT GENERATING
                                                             WASTES
    Figure 9.5.2.
Flow diagram for evaluating the technical  adequacy of  the
application for disposal of ignitable or reactive waste.
                                      9-210

-------
 9.5.3.2-i.   Listj  ; f  IgnJCdoia  ana  Reactive  Wastes — In  Part  261,  Subpart  D  -
 Liscs  of Hazardous Wastes,  ignicable wastes  are  identified  by  an "(I)" and
 reactive wastes are  identified with an  "(R)".  Table 9.5.1  lists the  hazardous
 wastes, by  EPA Hazardous Waste Number,  which are identified in Subparc D as
 being  ignitable.  Table 9.5.2  lists the hazardous wastes, by EPA Hazardous
 Waste  Number, which  are identified in Subpart  D as being  reactive.  At a
 minimum, if the applicant  indicates that any of  these  wastes will  be  disposed
 in a landfill, he must document how compliance with §264.312 will  be  achieved.

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

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

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

     •    Strong Reducing Agents

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

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

     The applicant may propose to render ignitable or reactive compounds
nonignitable or nonreactive by diluting the waste with other compatible
material.   However,  dilution has the disadvantage that hazardous reactions may
result if the mixed materials are incompatible.  Dilution with liquids is
undesirable because of added liquids in the landfill and greater attendant
                                    9-211

-------
              TABLE 9.5.1.  IGNITABLE WASTES
EPA hazardous
  waste No.
             Hazardous waste
    F005
    U001

    U002
    U003
    U008
    uci:
    U012
    U019
    LT239
    U056
    J055
    U169
    U085
    U031
    U159
    U074
    U031
    U156
    U055
    U056
    U057
    U074
    U085
    U092
    U110
Spent ncnnaiogeriatea solvents
Spent nonhalogenated solvents
Acetaldehyde
Acetic acid, ethyl ester
Acetone
Acatonitrile
Acrylic acid
Aniline
Benzenamine
Benzene
Benzene, dimethyl-
Benzene, hexahydro-
Benzene, -C-l-me thylethyl),
Benzene, -nitro-
2,2-bioxlzane
c-butanoi
2-butanone
2-butene, 1,4-dichloro-
n-butyl alcohol
Carbonochloridic acid, methyl ester
Cunmene
Cyclohexane
Cyclohexanone
1,4-dichloro-2-butene
1,2:3,4-diepoxybutane
Dimethylamine
Dipropylamine
                         (continued)
                            9-212

-------
                   TABLE  9.5.1  (continued)
EPA hazardous
  waste No.
              Hazardous  waste
    U001
    U008
    U117
    U112
    U113
    U115
    UL17
    U125
    U213
    U125
    U124
    U140
    U152
    U092
    U045
    U153
    U154
    U154
    U186
    U045
    U156
    U159
    U161
    U162
    U161
    U169
    U171
 Ethanol
 Ethanenitrile
 dC.i^ns.  - ? j. ~ o x ~ T o i ^
 EChyl acetate
 Ethyl acrylate
 Ethylene oxide
 Ethyl ether
 2-furancarboxaldehyde
 Furan, tetrahydro-
 Furtura1
 Furfuran
 Isobutyl alcohol
 Methacrytonitrile
 Methanamid-e, N-methyl
 Methane,  chloro-
Methanethiol
 Mechanol
Mechyl alcohol
 1-tnethyl  butadiene
Mechyl chloride
Methyl chlorocarbonate
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
 4-methyl-2-pentanone
Nitrobenzene
 2-nitropropane
                        (continued)
                            9-213

-------
                   7A3LZ 9. j . i
EPA hazardous
  waste No.
                               nazaraous waste
    U115
    (J186
    U110
    U171
    U140
    J002
    U152
    U008
    U113
    U162
    U213
    (J153
    U239
Oxirane
1,3-pentadiene
1-propanamine
1-propanaraine
Propane, 2-nitro
1-propanoL, 2—mechyl
2-propanone
2-propenenicri le, 2
2-propenoic acid
2-propenoic acid, ethyl ester
2-propenoic acid, 2-methyl-, methyl ester
n-propylamine
Tetrahydrofuran
Thioraethanol
Xylene
                              9-214

-------
                          TABLE 9.5.2.   REACTIVE WASTES
EPA hazardous
  waste No.
                   Hazardous waste
    FOG:

    F008

    JCG9

    F010

    F011

    KG 11

    K013

    K027



    Ł044



    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

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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

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                   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

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 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

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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

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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

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              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

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                     '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.  ŁPA-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

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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

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 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

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          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!?"•-!Ł 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

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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

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          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 HŁ 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

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                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

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       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

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      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
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                                           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
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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

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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

-------
      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 3Ł  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

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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 ?Ł 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

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•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

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     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?