SVV947 * V LAND DISPOSAL OF HAZARDOUS WASTE ,f Summary of Panel Discussions This document (SW-947) is a summary of panel discussions sponsored by EPA on issues related to land disposal of hazardous waste US. Environmental Pr^t.:?' ^ Region V, Library 230 South Dearoorn Street Chicago, Illinois 60604 U.S. ENVIRONMENTAL PROTECTION AC2NCY May 18-22, 1981 ------- '.^j-.n/ironrnentaj footection A—_• y ------- This summary was prepared by Mitre Corp. under contract no. 68-01-6092; it is reproduced as received from the contractor. Opinions expressed in this document are those of the panel members and do not necessarily reflect the views of EPA; nor does the mention of commercial products constitute endorsement by the U.S. Government. . - " ------- INTRODUCTION This document is a summary of a series of panel discussions held in the Washington, B.C. area by the Environmental Protection Agency (EPA) during the week of May 18-22, 1981. The panel discussions were held to provide a cross-section of experts' views on the technical issues related to land disposal of hazardous wastes. The discussions are being used by EPA as a source of information for formulating final permitting standards for hazardous waste land disposal facilities. However, the discussions focused on generic technical issues rather than on proposed or potential regulatory provisions. Four major topics were addressed during the five days the discussions were held: May 18 and 19: Leachate generation (quantity and quality); attenuation in liners and the unsaturated zone; and management approaches to control leachate quantity and quality. May 20: Predicting leachate plume migration in ground water - modeling and monitoring. May 21: Gas generation and migration; rates of emissions; control practices; and dispersion modeling. May 22: Health effects resulting from exposure to hazardous wastes disposal on or in the land. Each discussion topic featured a different set of panelists chosen through recommendations by industry trade associations, the Association of State and Territorial Solid Waste Management Officials, environmental groups, and upon EPA's knowledge of experts in the field. Each panel was moderated by a cognizant EPA staff member. An agenda ------- for each session was provided in advance that contained a detailed list of questions and" discussion topics to be addressed by the panelists. Copies of the agenda were distributed to the audience. Since the regulated community, state regulatory agencies, environ- mental groups, and the general public were likely to be interested in the discussions, various members of these groups were invited to attend the sessions. Members of the audience were provided the opportunity in each session to ask questions of the panelists. The moderator and panelists for each session are listed immediately preceding the session's summary. To assist the reader in identifying and locating particular topics and to provide a precis for each session, a listing of specific technical issues and major points raised is contained at the beginning of each day's summary. The agenda for each session is contained in Appendix A. Appendix B contains a listing of the attendees for each of the five days. ii ------- TABLE OF CONTENTS Paste Introduction i First Day, Leachate Generation and Attenuation Introduction to the First Day 1-1 The Panel for the First Day 1-3 Technical Issues of the First Day 1-4 Summary of the First Day 1-5 1. Precipitation as a Source of Leaching Fluids 1-5 2. Use of Top Liners to Control Infiltration 1-7 3. Groundwater Infiltration 1-9 4. Liquids Produced by or Associated with Wastes 1-11 5. Predicting the Permeability of Clay Liners 1-14 6. Use of Synthetic Liners 1-17 7. Leachate Collection Systems 1-13 Second Day, Leachate Generation and Attenuation Introduction to the Second Day 2-1 The Panel for the Second Day 2-3 Technical Issues of the Second Day 2-4 Summary of the Second Day 2-5 1. Prediction of Leachate Quality from a Single Waste Stream 2-5 2. Prediction of Leachate Quality from Complex or Mixed Wastes 2-8 3. Waste Segregation and Separation 2-9 4. Use of Solidification, Stabilization, and Encapsulation Techniques 2-11 5. Degradation of Organic Constituents in the Landfill 2-14 6. Attenuation of Waste Constituents Prior to Discharge 2-16 Third Day, Predicting Leachate Plume Migration in Groundwater iii ------- Page Introduction to the Third Day 3-1 The Panel for the Third Day 3-3 Technical Issues of the Third Day 3-4 Summary of the Third Day 3-5 1. Direction and Velocity of Groundwater Flow 3-5 2. Phase Separation and Movement of Immiscible Fluids 3-8 3. Dispersion of Waste Constituents 3-10 4. Degradation of Waste Constituents 3-13 5. Sorption of Constituents 3-15 6. Supply of Trained Professionals to Make and Evaluate Predictions 3-18 Fourth Day, Gas Generation and Migration Introduction to the Fourth Day 4-1 The Panel for the Fourth Day 4-3 Technical Issues of the Fourth Day 4-4 Summary of the Fourth Day 4-5 1. Models for Prediction of Constituents and Atmospheric Emissions from Land Disposal Facilities 4-5 2. Appearance of Gas in Leachate or Subsurface Soils 4-9 3. Prediction of the Migration of Landfills 4-10 4. Management Controls for Gas Migration 4-13 5. Monitoring of Ambient Emissions from Surface Impoundments 4-19 Fifth Day, Health Effects Resulting From Hazardous Waste Exposures Introduction to the Fifth Day 5-1 The Panel for the Fifth Day ' 5-2 Technical Issues of the Fifth Day 5-3 Summary of the Fifth Day 5-5 1. Methodologies and Techniques for predicting Carcinogenic Effects 5-5 ------- Page 2. Use of Human Risk Numbers for Permitting Decisions 5-9 3. Sources of Additional Data"for the Permit Writer 5-12 4. Toxic Effects to Humans 5-14 Appendix A, Agenda Appendix B,. List of Attendees ------- First Day Monday, May 18, 1981 Leachate Generation and Attenuation ------- INTRODUCTION TO THE FIRST -S The purpose of this session was for the panel to examine the chief factors that are relevant to predicting the quantity, the time of first release, and the quality of leachate that is discharged from land disposal facilities into the ground. In discussing these general topics, the panelists were requested to identify, whenever possible, the relative degrees of confidence and uncertainty in making predictions, and to identify situations in which such pre- dictions are subject to particularly high or low degrees of confidence. The first day focused specifically on topics related to leachate quantity and duration of the containment period. The panel first focused its attention on the sources of liquids that produce the leachate. These sources included precipitation, groundwater, and liquids associated with the wastes. The emphasis was on the ability to predict leachate generation and the associated facility performance. With respect to precipitation the key questions were related to the characteristics of the rainfall distribution throughout the year and the evapotranspiration rates as they influence predictions of the amount of leachate generated. In this context, the attendant questions regarding the use of top liners to prevent infiltration were discussed from the standpoints of effectiveness, expected"life, and various penetration modes such as roots, erosion, or cracks. The discussion of groundwater infiltration attempted to answer 1-1 ------- questions regarding prevention techniques such as clay or synthetic liners. For cases where, the water table intersects the facility, the efficiency of passive systems such as trenches and active systems such as pumps were discussed. For landfills, the significance of the quantities of liquids in buried wastes or liquids produced by the wastes was assessed in relation to the total amount of liquids entering the land disposal facility. In this regard, the reliability and cost of pretreatment techniques were estimated. Following the discussion of the mechanisms for leachate generation, an examination was conducted of control techniques and the ability to predict their effectiveness. These predictions depend both upon the availability of data and the accuracy of the model applied to the data. Therefore,- there was a discussion of the type and amount of data needed, the cost of obtaining the data, and the degree of confidence in the models'. 1-2 ------- THE PANEL FOR THE FIRST DAY Moderator Jack Lehman Acting Director Land Disposal Division U.S. Environmental Protection Agency Washington, D.C. Panel Members Dirk Brunner U.S. Environmental Protection Agency Municipal Environmental Research Lab. 26 West St. Clair Cincinnati, Ohio 45268 Benjamin C. Garrett Battelle Columbus Laboratories 505 King Avenue Columbus, Ohio 43201 Robert A. Griffin Illinois State Geological Survey 615 East Peabody Street Champaign, Illinois 61820 Robert Ham Dept. of Civil and Environmental Engineering University of Wisconsin 3232 Engineering Building Madison, Wisconsin 53706 Amir Metry Roy F. Weston West Chester, Pennsvlvania 19380 Charles A. Moore Geotechnics, Inc. 912 Bryden Road Columbus, Ohio 43205 Philip A. Palmer, Jr. E.I. duPont de Nemours Engineering Department Wilmington, Delaware 19898 (L13 W28) Robert Stadelmeyer Cecos International P.O. Box 619 Niagara Falls, New York 14302 Peter Vardy Chemical Waste Management 900 Jorie Boulevard Oak Brook, Illinois 60521 Jim Williams Division of Geology and Land Survey P.O. Box 1638 Jefferson City, Missouri 65102 1-3 ------- TECHNICAL .ISSUES OF THE FIRST DAY o Precipitation as Sources of Liquids - Major source of liquids for leachate - Manageable problem during open periods - Easily controlled after closure - Intensity of rainfall more a factor than amount o Use of Top Liners to Control Infiltration - Standard practice for chemical landfills - Characteristics of effective ,top liners - Pros and cons of synthetic materials o Groundwater Infiltration - Very site-specific - No problem if above groundwater table - May need pumping - Designs for control o Liquids Produced by or Associated With Wastes - Minor contributor to•leachate generation - Introducing liquids can assist in decomposition - Controversy regarding liquids in drums o Predicting the Permeability of Clay Liners - Mass flew through the liner easier to predict than time of first discharge - Capillary action not well understood - Influences of leachate constituents on permeability o Use of Synthetic Liners - Highest risk during installation - Uncertainty regarding liner life o Leachate Collection Systems - Pros and cons of need - Problems with (broken pipes, plugging) - Cost estimates - Best serve as monitoring for breakthroughs 1-4 ------- SUMMARY OF THE FIRST DAY 1. Precipitation as .a Source of Leachating Fluids Rainfall was regarded by the panel as a problem during the open periods of landfill cells before the cover is in place. However, this problem was seen by several landfill operators on the panel as manageable by using diversion structures for water control, of if possible by planning the timing of cell openings and closings so that a cell would be closed by the time the wet period would arrive. The panel agreed that the use of top caps or liners would easily control the amount of rainfall infiltrating into the landfill after closure when such layers are well designed and maintained. There was general agreement that meterological data are very site specific, and consequently the prediction of precipitation rates depends on a region's specific rainfall patterns. Based on data obtained by one panelist for Illinois, the prediction of precipitation for a 10-year cycle would be plus or minus 40 percent, on a 30-year cycle would be plus or minus 15 to 20 percent, and on a 100-year cycle would be plus or minus 2 to 3 percent of the average annual mean. In other words, the prediction accuracy for rainfall increases with the length of the time period over which the prediction is made. The panel also felt that the variation for evapotranspiration rates would generally be greater than that for precipitation since evapotranspiration is a derived quantity based upon calculation rather than actual data. In that respect, they "believed that the 1-5 ------- accuracy of prediction would tend to be greater for precipitation rates. The intensity of rainfall rather than the amount of rainfall was agreed to be more important with respect to water infiltration into the landfill. Measurements taken in Illinois during April suggest that periods of rain characterized by a slow drizzle can produce up to 70 percent infiltration, whereas a heavy thunderstorm type of rain produces only 30 percent infiltration. One panelist pointed out that standard infiltration rates are noc applicable to chemical landfills because materials within the landfill would have lower infiltration rates than natural soils primarily due to the effects of construction. Several members of the panel suggested that from the standpoint of leachate generation, EPA should be thinking more in terms of" seasonally long wet periods or dry periods rather than short-term daily storm events, and that longer periods of rainfall measurements would provide more accurate predictions of potential leachate generation than shorter periods. 1-6 ------- 2. Use of Top Liners to Control Infiltration ,f Most of the members of the panel believed that use of some sort of top cap is fairly standard industrial practice for chemical land disposal sites to control infiltration, although the configuration of such caps may vary from location to location. One panelist, who constructs and operates chemical landfills, indicated that he routinely designs landfills with top liners to provide what he believed to be additional insurance and to drastically reduce the requirement for post-closure cash reserves for leachate management. This is done at a cost of about 1 to 1.5 million dollars for a site covering approx- imately 100 acres. Several panelists recommended the use of a multi-layer cap system rather than a single layer of clay material for infiltration control. Such multi-layer systems would also allow more reliable predicting of hydraulic head for infiltration calculations. Some panel members suggested that the design of the top liner was basically a function of the overall design goal of the landfill site and facility. Consequently, they argued that it is very difficult to make general pronouncements about top liners and their ability to prevent infil- tration. While there was not unanimous agreement in all cases, most panelists agreed that if top liners are to function effectively they should have the following characteristics: o At a minimum be below the depth of frosty penetration to prevent cracking o Be graded perhaps between 4 to 7 percent slope to insure runoff, yet minimize erosion. 1-7 ------- o Be protected from erosion and differential subsidence. There was also support among the panel for using synthetic materials over a clay top liner to prevent dehydration cracking of the underlying layer. However, several members pointed out that such synthetic materials are largely untried and there is little research experience to make definite conclusions about the longevity of these materials. Most panelists believed, however, that poor quality control during the placement of such synthetic liners was perhaps the greatest single factor leading to failures. Several members suggested that third-party inspections by reputable engineering firms could serve to help prevent such failures. 1-8 ------- 3. Groundwater Infiltration ,/ Groundwater infiltration into chemical landfills was judged by the panel to be a very site-specific phenomenon which they felt was primarily dependent on the hydrogeology of the particular landfill. Overall, there was consensus that it is much better practice to build landfills which are above the groundwater table, if at all possible, than to engineer chemical landfills which intersect the groundwater table. The potential for groundwater infiltration was generally agreed to be nil for landfills built above the groundwater table. In such cases, infiltration from rainfall is far more significant than groundwater infiltration in the generation of leachate. On the other hand, building a landfill below the level of the groundwater table was felt by the panel to increase the potential volume of liquids that could come into contact with the waste, creating leachate. Several participants argued that there might be a distinct advantage, however, to building a facility which intersects the piezometric surface or the groundwater table. They argued that if a leak occured in the liner, fluids would flow into the facility rather than out of the facility due to the inward gradient. One member of the panel argued that this leakage might require perpetual pumping, raising the issue of long-term maintenance of the pumps. Several participants indicated that it is possible to design groundwater infiltration of underdrain systems that are essentially natural in their operation. That is, they do no.£ depend on mechanical 1-9 ------- pumping systems, but rather on intercepting or diverting the ground- water flow on the upstream side of the facility and letting it drain out of the lower part of the facility by gravity. The panelists also discussed the relative merits of having an individual groundwater control system at each trench of the landfill as opposed to an overall control system that helps to intercept ground- water flow over the entire facility. Several panelists suggested different techniques to solve this problem. Some participants argued that it was physically difficult to line each trench of the landfill to prevent groundwater infiltration and that intercepting this water at the perimeter of the area might be more economic and more achievable. Others suggested that it is possible to construct grout curtains or diversion trenchs on the upgradient side of the trench to reduce ground- water flow. One participant argued that since such systems are more accessible to maintenance and observation than underdrain systems he would have more confidence in them than tile systems which could become plugged up over the long term. 1-10 ------- 4. Liquids Produced by or Associated with Wastes The panelists generally agreed that the relative importance of liquids in buried wastes or liquids produced by wastes, as opposed to other sources of liquids that, flow through the landfill, is site specific. Climate is a significant factor in this relationship. For example, in an area of high rainfall where a site is designed to allow some infiltration, the amount of liquids that might be contained in the waste or the amount of liquids being produced during the decompo- sition process would be insignificant. On the other hand, however, the amount of liquids that may be within the waste would be more significant in landfills situated in areas with lower rainfall. Another panelist suggested that although water in the waste would not be expected to generate significant quantities of leachate, wastes with high water contents (e.g., wet sludges) might saturate the landfill contents faster than would otherwise occur with drier wastes. Conse- quently, leachate might be generated during the first few years of operations rather than after four or five years, though the total quantities would not be appreciably different. In other words, it will cause the field capacity of the waste to be reached at an earlier date. However, most of the participants concurred that the liquids produced by wastes in the landfills contribute a very small amount of moisture relative to the generation of leachate, and furthermore, the water that is produced leaves primarily as a vapor. Another question that the panel addressed was whether there were 1-11 ------- situations where it was environmentally preferable not to prevent or minimize the entry of liquids into landfills. Overall, the panel agreed that the answer to this question was generally dependent on the design objectives for the landfill. One participant suggested that there may be some benefits of introducing water or nutrients into the landfill to achieve a slow controlled rate of decomposition. Other panelists indicated that while they believed such chemical reactions could provide for waste attenuation in chemical landfills, it might be better to achieve it through pretreataient processes prior to place- ment in the fill. The panel also briefly discussed the merits of burying liquids in drums in the landfill. Current EPA regulations prohibit liquids in drums primarily because it is felt by the agency that drums will • eventually corrode and open up causing leakage, and that excessive subsidence would result from such activity. There was lively discussion among panel members on this question. Several panel members repre- senting the chemical landfill industry argued against this prohibition because they believed that landfills could be designed adequately to prevent subsidence caused by collapsing or corroding drums. Furthermore, they argued that the capital costs involved and personal hazards to operators to remove liquids from those drums far outweight the two arguments against drum disposal in chemical landfills. Several participants argued for a middle position of allowing at least some liquids in drums in landfills. Generally, there was a consensus among 1-12 ------- the panel that the answer to this argument is clearly a judgement ./• call based, on the relative tradeoffs with long-term environmental protection on the one hand and the ease of handling and protection of workers on the other. 1-13 ------- 5. Predicting the Permeability of Clay Liners The members of the panel generally agreed that reasonably accurate prediction of the clay liner permeability can be made, leading to an estimate of the mass flow through the liner to within 1/2 to 1 order of magnitude. However, the panelists were less optimistic about making predictions of the first arrival or time of first discharge of Liquid, which are commonly calculated as functions of the effective porosity. One participant indicated that errors in estimating effective porosity can be between one and two orders of magnitude. Several panelists commented that the concept of effective porosity is an irrational or misleading concept in this context, since clay liners within a landfill would probably r.ever exhibit simple saturated flow subject to the Darcy flow equations. Another panel member indicated that capillary action would have a significant impact on the velocity of the first drop through the clay liners. That is, the pressure differential resulting from capillary forces in fine grained soils could overwhelm the low permeability of the material, causing much faster migration than would be expected based on the unsaturated permeability alone. However, there was strong support among the panelists against the use of capillary action in determining the velocity of liquid flow through a liner since the concept is not well understood and validated at this time. In summary then, there was a general consensus that evaluation of a landfill liner system would be based on the mass flow- rate through 1-14 ------- the liner rather than on the arrival time of the first drop of leachate. The panel next "discussed the issue of whether leachate constituents could affect the permeability of liners through various mechanisms. It was believed to be unlikely that leachate constituents would lead to plugging liner pores, or in other words, decreasing the permeability of liners in chemical landfills. Most believed soil plugging should be considered a bonus if it does occur. As was pointed out by several participants, much of the evidence for this phenomenon has been collected from municipal or sanitary landfill sites and limited laboratory testing. One participant indicated that his studies in Illinois suggested that there was a significant decrease in clay liner permeability (between a factor of 2 and 10) using sani- tary landfill leachate. His previous work on landfill sites had indicated that plugging of a calcium-saturated bentonite liner is likely with leachate high in sodium because of cation exchange. Conversely, a highly-ionic strength waste placed on a highly-dispersed, sodium-saturated, montmorillonite liner caused cracking, also due to cation exchange. Based on this evidence this panelist argued that there is probably no simple quantitative answer to the question of increases or decreases in the permeability of clay liners, primarily because the enormous range of chemicals that might appear at an industrial site. When soil plugging does occur, it 'generally causes no more (often much less) than 1 to 2 orders of magnitude decreases in saturated permeability, and it is occasionally reversible. When 1-15 ------- liner/waste interaction leads to increases in permeability the result is generally catastrophic failure. Several participants pointed out that there are methods of testing certain types of liner materials against certain types of waste leachate, but that these are rarely done at this point in time. The panel agreed that more research on these quantitative techniques needs to be done. 1-16 ------- 6. Use of Synthetic Liners Most of the discussion on synthetic liners focused on the issue of the risks involved in a synthetic liner tearing or degrading by chemical reactions. There was general agreement among the panelists that the period of highest risk for synthetic liners occurs during or immediately after installation, and that once these liners are in place, the prospects were good for "moderate" long-term survival. Most panelists agreed, however, that due to the lack of aging data on typical commercial membranes, it was currently impossible to predict with confidence the very long-term physical survival or integrity of synthetic liners. Several panelists representing the chemical land- fill industry argued that this uncertainty about the long-term survivability of synthetic liners should not stop the design and construction of chemical landfills. They felt there are usually risks for other similar installations such as industrial plants, sewage treatment plants, etc., and that these risks are normal and acceptable. It was suggested that full-time, third-party inspection of the entire installation process by a qualified observer would be a means of insuring proper placement. It was also suggested that it is highly unlikely that failure of a synthetic liner in a landfill would result in sudden releases of large volumes of liquid, although the public tends to focus on such so-called catastrophic events. On the other hand, catastrophic failures would be a more likely occurrence with surface impoundments. 1-17 ------- 7. Leachate Collectiou Systems There was a range of opinion regarding the need for or emphasis on leachate collection systems in chemical landfills. In the case of landfills designed for minimal infiltration, one participant felt that the leachate flow coming out of the bottom of a landfill would be minimal after closure. In his opinion, therefore, a leachate collection system would more or less act in that case as a leachate monitoring system, and that heavy flows would only occur when the landfill had open faces during waste emplacement. This viewpoint was seconded by several other members who indicated that at several research sites they were aware of there were generally only small amounts of leachata to collect. However, it was pointed out that experience with well-designed and operated landfills is limited to the relatively recent past, and that long term leachate generation in these facilities is still largely a matter of conjecture. One member indicated that as a matter of basic policy he no longer regularly designs a landfill without a leachate collection system since he believed that the cost of that installation is the cheapest insurance one could buy. His organization firmly believes that such systems are well worth the investment during construction since chemical landfill sites, in their experience, do not reach field capacity until 10 to 13 years after they are started.- Consequently, many operators can be lulled into a false sense of security saying they have a dry site, when in reality their sites have not-yet reached 1-18 ------- field capacity. It was his view that, in those circumstances, he _/» would much rather have a leachate collection system at that point. The discussion that followed focused on the operating experience of several panelists with leachate collection systems. One operator indicated that one of his major problems with these systems was broken riser pipes which were probably caused during the initial landfill construction period. Once this initial period was over his main problem was usually plugging of this .system due to settlement and sediment collection in the pipes. He indicated that his usual design goal was for 80 to 90 percent leachate removal over a period of about 30 years. He indicated that his costs for such a system typically ranged between 7 and 9 dollars per lineal foot, including the cost for riser sumps. Another operator revealed that his firm constructs leachate collection systems for each of the individual subcells with their chemical landfill sites. To maintain a suitable hydraulic conductivity to prevent clogging in the draining medium, they construct systems to act as graded filters. That is, fine-grained materials in the upper portion of the collection medium traps the sediment portions carried by infiltrating leachates, allowing the fluids to flow out through the coarser media in the bottom of the collection system. Based on their experience so far, the bulk of the leachate that is collected has been during the initial operational period, and by using the graded type of collection system they estimated that they could 1-19 ------- dewater a facility within about 2 to 3 years after closure. Treatment and offsite disposal of leachate from such collection systems was seen by several of the panelists as a typical practice. One industrial operator indicated that his capital costs for waste- water treatment, involving the physical, chemical, and biological treatments, have run batween 1.7 and 2 million dollars, with operating costs about 4 to 7 cants per gallon. Another panel member indicated that off.site disposal of leachate could generally cost from about 20 to 50 cents per gallon, and deep well recharge from about 1.5 to 2 million dollars per well, including the surface facility and the wells. Alternatives to leachata collection systems were not in general regarded by the panel as reliable for indicating the breakthrough of liquids out of a facility. Several participants,related their rather disappointing experiences with such early-warning systems as suction lysimeters and earth resistivity equipment. Many of the comments were directed at their limitations under common landfill conditions. This led one landfill operator to add that such equipment might currently provide results which were academically interesting, but generally a waste of money for most operators. The panel generally concluded that much more research needs to be done in perfecting these techniques. 1-20 ------- Second Day Tuesday, May 19, 1981 Leachate Generation and Attenuation ------- ------- INTRODUCTION TO THE SECOND DAI _f The second session of this panel discussion explored a number of technical issues related to leachate management which were largely left undiscussed by the panel during the previous day. The focus of this day's discussion was on predicting the quality or composition of leachate that may be produced and migrate from a facility. The discussions first focused on leachate produced in a monofill, a site where waste is from a single generating source. Next, complex fills with wastes from numerous generators and with a variety of compositions were discussed. Topics of discussion included the influence of the waste on leachate composition, the characteristics of the leaching medium, and commonly utilized techniques to control leachate quality, such as waste separation, pretreatment, in situ treatment, solidifi- cation, stabilization, encapsulation, and attenuation mechanisms. These topics were selected to obtain insight into the confidence level of predicting leachate quality, situations which increase or decrease the predictability of leachate quality, and data needed to achieve a particular level of confidence. Examining particular land disposal facilities or proposed facilities to predict their ability to achieve a stated goal (i.e., controlling leachate quantity, containment time, or leachate quality) involves some uncertainty. To narrow the uncertainty the relative degrees of confidence in predictions must be defined. This requires knowledge of data needs and availability of individual facilities 2-1 ------- as well as those that relate to the industry. The second session examined the state of the art of predicting leachata quality and migration to establish the degree of confidence used when analyzing leachate management for facilities. 2-2 ------- THE PANEL FOR THE SECOND DAY ,y Moderator Kenneth Schuster Office of Solid Waste U.S. Environmental Protection Agency Washington, D.C. Panel Members Dirk Brunner U.S. Environmetal Protection Agency Municipal Environmental Research Lab, 26 West St. Clair Cincinnati, Ohio 45268 Benjamin C. Garrett Battelle Columbus Laboratories 505 King Avenue Columbus, Ohio 43201 Robert A. Griffin Illinois State Geological Survey 615 East Peabody Street Champaign, Illinois 61820 Robert Ham Department of Civil and Environmental Engineering University of Wisconsin 3232 Engineering Building Madison, Wisconsin 53706 Charles A'" Moore Geotechnics, Inc. 912 Bryden Road Columbus, Ohio 43205 Philip A. Palmer, Jr. E.I. duPont de Nemours Engineering Department Wilmington, Delaware 19898 Amir Metry Roy F. Weston West Chester, Pennsulvania 19380 Peter Skinner New York State Law Department Justice Building The Capitol Albany, New York 12224 Robert Stadelmeyer Cecos International P.O. Box 619 Niagara Falls, New York 14302 Peter Vardy Chemical Waste Management 900 Jorie Boulevard Oak Brook, Illinois 60521 Jim Williams Division of Geology and Land Survey P.O. Box 1638 Jefferson City, Missouri 65102 2-3 ------- TECHNICAL ISSUES OF THE SECOND DAY o Prediction of Leachate Quality from a. Single Waste - pH value of leachate medium - Knowledge of waste characteristics - State of equilibrium between waste and leaching medium - Ratio of leaching medium to waste - Properties of soil or clay covers o Prediction of Leachate Quality from Complex or Mixed Wastes - Significance of prediction o Waste Segregation and Separation - Initial stage of research - Aid to management - Example criteria o Use of Solidification, Stabilization, and Encapsulation Techniques - Purpose of techniques - Need for regulation - Control specifications to increase solidification - Confidence level in tests for leachate on solidified or stabilized waste o Degradation of Organic Constituents in the Leachate - Data availability for chemical landfills - Predictability for sanitary landfills o Attenuation of Waste Constituents Prior to Discharge - Information needed for predicting attenuation methods - Simple systems - Complex systems - Landfill design 2-4 ------- SUMMARY OF THE SECOND DAY 1. Prediction of Leachate Quality from a Single Waste Stream With reference to the predictability of leachate quality, the panel first addressed the situation of a landfill receiving a single stream of waste from generators. The discussion primarily focused on the degree to which the following factors could be used to confidently predict leachate quality'based on laboratory testing: o Leaching medium o Waste characteristics o Duration of waste contact with leaching medium o Properties of soil or clay used as cover or intermittent cover o Ratio of leaching medium to the waste * The panelists felt that the leaching medium is an important factor in predicting leachate quality when simulating a monofill situation. Unbuffered distilled water is the leaching medium of choice, although other mediums can be justified on a site-specific basis. Most members felt that it is realistic co use something close to rainwater (e.g., distilled water or groundwater in the vicinity of the landfill) as the leaching medium since rain or groundwater is the major source of leachate in a landfill. They discussed the importance of the pH level of the test fluid in accurately modelling the composition of the expected leachate. Leachate mediums which are buffered or assigned a pK level could cause leaching of materials which might not occur in the natural situation. In fact, by assigning a pti level the 2-5 ------- leachate results are being predetermined to some extent since various materials will be released only at specific pH levels. One panelist was opposed to the use of an acidic leaching medium since he felt that it would not allow an investigator to do a bioassay test at the same time. One panelist indicated that his laboratory's batch tests for leachate composition using distilled water often predicted concentrations within a factor of two, and nearly always within a half order of magnitude of his actual field test for a particular leachate component. The panel generally concluded that the characteristics of the particular waste are also important factors in confidently predicting the leachate quality. That is, the more that is known about how the waste material is generated and its daily variation, the greater the confidence in the prediction of the leachate quality. Several of the panelists suggested that a simple analysis of the waste is not adequate to predict leachate concentrations. They felt that an elemental analysis is also necessary in order to provide the exact form of the individual waste component and its particular solubility products. Most members believed duration of waste contact to be a relatively unimportant factor overall in comparison to the waste characteristics themselves., The panel, as a whole, believed that in most normal hazardous disposal environments hydraulic conductivities and rates of leachate movement are very slow. Thus, leaching tests that simulate equilibrium conditions were felt to be more representative .than very s*- fast leaching tests. 2-6 ------- With reference to the volume ratio of the leachate to the waste, the panel was undecided whether this factor was critical in predicting leachate quality. One member suggested that it is very difficult, in his opinion, to predict leachate quality in the landfill on the basis of the ratio of the leaching medium to the waste in a test sample. Similarly, the panel did not reach a concensus regarding the usefulness of physical properties of the soil or clay cover materials in predicting leachate quality. One member believed, however, that the physical properties of various clay soils could affect the movement of leachate and overall leachate quality. 2-7 ------- 2. Prediction of Leachate Quality from Complex or Mixed Wastes The panel next focused its attention on the state-of-the-art in predicting leachate quality from a mixed stream of chemical wastes. In comparison to the rather simple case of a single waste stream, prediction of leachate quality from mixed waste landfills was judged to be a much more complicated situation. Many members of the panel felt that due to synergistic, antagonistic, and buffering interactions between the different types of wastes and the difficulties in obtaining representative samples, the common types of batch and short- term laboratory tests would not be effective for prediction. Several members indicated that such impacts are not well understood today, making the prediction of leachate quality highly speculative. Because of the tremendous swings in the daily waste stream, they questioned the need for quantitative leachate prediction exercises for complex, mixed waste systems. 2-3 ------- 3. Waste Segregation and Separation Segregation or separation of hazardous chemical wastes to prevent undesirable reactions within a landfill was discussed as a possible means of minimizing adverse reactions between wastes which could affect leachate quality. There were a number of participants on the panel who believed that the state of the art did not provide procedures for operators to efficiently segregate incompatable waste materials in a practical manner. Other panel members from the chemical landfill industry disagreed with this philosophy suggesting instead that there has been a significant amount of evaluation and effort already done by individual operators in this area, although this work is still in the very early stages of research. Based on results from existing landfills, these panelists believed that operators could generally segregate their wastes in various ways such as separating different types of waste materials which could generate harmful gases or release excessive amounts of energy upon contact with each other. • One panel member from New York described his firm's approach to waste segregation on several chemical landfills located in the north- eastern part of the United States, he indicated that they practice subcell segregation on the following types of wastes: o Heavy metals o "Pseudometallic" wastes such as arsenic, atimony, and selenium o Toxic organics 2-9 ------- o Low flash point materials o General organic or low toxicity organic materials These individual segregations are-chosen for purposes of applying specific covers to each different subcells. They believed that this will aid in the management of the waste materials, either by reducing the mobility of the individual components that are present through attenuation mechanisms, or by the detoxification of individual materials through acidic or basic hydrolysis reactions within the individual subcells of the facility. Another panelist indicated that his firm also segregated its wastes within chemical landfills based upon on waste compatibility, potential exposures to employees, and other health and safety consid- erations. He indicated that his firm currently segregates toxic organics, acids, and PCBs, although the mobility of these wastes are taken into account at this time in a very general, nonquantitative way. 2-10 ------- 4. Use of Solidification, Stabilization, and Encapsulation Techniques These techniques'were generally seen by the panel as standard practices used by the chemical landfill industry to reduce the leaching potential and physical mobility of wastes prior to landfilling. Most members agreed that wastes which are in a solid or chemically stabilized form can reduce significantly the potential infiltration of rain water into a landfill environment, and also reduce the potential amount of leachate constituents that could leave a landfill. One panel member went so far- as to suggest that there should be a regulatory effort on the part of the EPA to encourage the use of these pretreatment processes. Without this kind of regulatory effort, he felt that most chemical wastes would be pretreated using the least expensive, but not necessarily the most environmentally acceptable approach. Most panelists agreed that the bulk of the pretreatment processing of wastes currently occurs at the generating site, although some pretreatment using these solidification processes takes place at land disposal operations. One operator revealed that most of the waste pretreatment his firm employs is solidification of liquid waste materials and the modifi- cation of sludge materials to a more solid form. Their primary objective is to decrease the mobility of the waste material. He indicated that wastes accepted by his firm must meet specific control specifications regarding their volatility, mobility, solubility, and liquid content: o Maximum volatility and physical mobility for each waste are specified based on generic standards set by the firm 2-11 ------- o Liquid mobility is specified based upon load bearing strength o Physical mobility is specified based upon the requirement for containerization of very low density materials which could readily be transported by wind activity o Limits of solubility for inorganics are defined as follows : limits of solubility for heavy metals - absolute limits for pseudometal components - maximum limits for acid sensitive substances o Maximum allowable level of total fluids in barrels is set at 15 percent of total container space, including air space. If the wastes can be converted to a solid form meeting these specifi- cations they are accepted by his firm for disposal. Otherwise, his firm requires that the waste undergo additional pretreatment, by either the generator or by some other agency, to be placed into the form that is appropriate for disposal. The panel did not offer a clear cut opinion on the type of test that might be used for leachate on a solidified or stabilized waste. There was some disagreement over whether or no.t such techniques are sufficiently well-established to confidently predict the leachate constituents in the long run. One panel member, for example, suggested that grinding, crushing, or the use of acids to destroy the consoli- dated or stabilized waste monolith could negate or reverse the benefit of waste stabilization. Offering a solution to this potential dilemma, another panelist indicated that there are two processes used for stabilizing chemical wastes, one for organic materials, and another for inorganic materials. By stabilizing organic materials a relatively impermeable mass can be produced which minimizes ,£he amount of leaching 2-12 ------- that can occur, although the process does not tie up the individual .f chemical constituents. Consequently, it was his opinion, that as far as leaching tests are concerned grinding or crushing would not be an appropriate technique to determine if the stabilized organic waste has potential leaching properties. He suggested that the character- istics of the monolith should be considered when predicting potential leachability using specific leachate tests. On the other hand, he suggested that such destructive grinding or crushing techniques would not have much of an effect on chemically stabilized inorganic wastes which are chemically bound up in the crystalline structure of the soil or other material. In such cases, he believed that a leaching test would be as successful as that employed on nonstabilized wastes. 2-13 ------- 5. Degradation of Organic Constituents in the Landfill The panel, as a whole, questioned whether biodegradation of organic materials takes place in chemical landfills. While most members agreed that biodegradation is known to occur in sanitary or municipal landfills, they felt that there are not very much definitive data currently available with respect to the degree of the biotreatment that takes place in a chemical landfill. In general, biodegradation was regarded by the panel as fairly predictable in sanitary landfills because of the large data base already collected. One of the panelists suggested that there are firms that purposely mix organic wastes with soil in their chemical landfills to take advantage of what they believe is biodegradation. He indicated that these firms report that the con- stituents which accumulate in their leachate collection system are not the same as those contained in the wastes. By and large, they believe that degradation does take place. However, this panelist indicated that there is not a lot of data to support their claims of biodegradation. One member observed that the entire question of whether biodegra- dation can be predicted for chemical landfills is virtually impossible to answer at this time. He indicated that one of the things that makes it so difficult is that the degradation pathways can be highly variable depending on the conditions within the landfill during the different seasons of the year, i.e., different rainfall or temperature f regimes. In his opinion, he felt that these many factors could affect biodegradation differently making predictions extremely difficult at JU~ this time. 2-14 ------- Another panelist, while agreeing that biodegradation cannot be _y counted on by landfill operators at this particular time, indicated that chemical degradation can take place within the landfill because operators have the ability to control the internal chemical environ- ment of their facilities. He suggested that operators could use different management techniques to create in situ mechanisms such as alkaline hydrolysis within the landfill which can result in chemical degradation. This view was criticized by another panelist who questioned whether there was sufficient documentation or evidence to prove that chemical degradation actually occurs and offers a measurable degree of public protection. He maintained that he had not seen sufficient evidence to substantiate such claims. 2-15 ------- 6. Attenuation of Waste Constituents Prior to Discharge The panel attempted to specifically answer the question, "is it possible to predict the type of attenuation mechanisms which will take place in a landfill to assure adequate protection of public health?" Most of the panel members agreed that in order to make these predictions, operators would need to know the following infor- mation at the very minimum: o An accurate description of the chemical constituents that will be released from a given waste o The chemical composition and homogeniety of the earth materials that comprise the liner The panel felt that the more information available about a waste and the soil/material combination in the landfill, the more accurately attenuation that will occur could be predicted. Several members indicated that much is currently known about attenuation mechanisms for certain simple systems of wastes in a landfill. For example, metals and many toxic organics such as PC3s are known to be very strongly absorbed and attenuated in soils, particularly in those sails rich in organic matter. They believed that for such systems fairly quantitative decisions with respect to the overall attenuation of the waste within the landfill could be made. On the other hand, most panel members judged that, for complex situations where multiple waste streams are being landfilled at the same site, this type of quantification becomes more and more subject to uncertainty and requires more in the way of qualitative or worst- case judgments. 2-16 ------- Given this uncertainty of predictions, most members of the panel _j» did not favor the use of "leaking" landfill designs in which it is assumed that the waste components would be attenuated, either in the natural clay liner or through use of dispersion and dilution mechanisms prior to discharging into the local groundwater system. Instead most members felt that chemical landfill operators should concentrate more on designs to maximize containment of leachate rather than relying on attenuation mechanisms which are highly variable and sometimes extremely unpredictable with complex waste mixes. 2-17 ------- Third Day Wednesday, May 20, 1981 Predicting Leachate Plume Migration in Groundwater— Modeling and Monitoring ------- INTRODUCTION TO THE THIRD DAY The topic of the third session was "Predicting Leachate Plume Migration in Groundwater, Modeling and Monitoring". The panel con- sidered the predictability of the fate and transport of. leachate and its constituents in groundwater. Specifically, how precise can the concentrations of waste constituents at any one location and time be predicted? In attempting to answer such questions the panel assumed that the location, mass rate, and concentrations of contaminants entering the groundwater are known with some degree of confidence or uncertainty. These assumptions were made to avoid repeating any of the discussion from Monday and Tuesday on predicting leachate quality and quantity in a landfill. As a result, the discussion considered only the potential error in predicting plume migration which would result from varying degrees of certainty in leachate. The discussion focus on technical issues relating to plume migration and the availability of professionals working in this area. One issue discussed was the type and amount of data required to pre- dict plume migration of waste constituents to make quantitative predictions and worse case predictions. The panel examined the cost and time involved in generating such data. Also examined were the use of these different types of predictions. The panel tried to determine if precise knowledge of the leachate is needed in all cases or if a worse case prediction can be used to assure acceptability of a facility. Another issue discussed was the degree of expertise 3-1 ------- required to produce data and evaluate predictions on the fate of leachate. The discussion specifically considered the current supply of people with such expertise and the training and employment opportunities available to them. 3-2 ------- THE PANEL FOR THE THIRD DAY Moderator Barry Stoll, Chief of Disposal Branch Land Disposal Division U.S. Environmental Protection Agency Washington, D.C. Panel Members Patrick Domenico Department of Geology University of Illinois 245 Natural History Building 1301 West Green Street Urbana, Illinois 61801 Richard Eldredge Eldredge Engineering Association 2625 Butterfield Road Oak Brook, Illinois 60521 Carl Enfield U.S. Environmental Protection Agency Robert S. Kerr Environmental Research Laboratory P.O. Box 1198 Ada, Oklahoma 74820 James J. Geraghty Geraghty & Miller 844 West Street Annapolis, Maryland 21401 Leonard Konikow U.S. Geological Survey 431 National Center Reston, Virginia 22092 John Moore Illinois Environmental Protection Agency 2200 Churchill Road Springfield, Illinois 62705 Paul Roberts Civil Engineering Department Stanford University Stanford, California 94305 Paul H. Roux Stauffer Chemical Company Nyala Farms Road Westport, Connecticut 06880 Eric Wood Director, Water Resources Program Civil Engineering Department Princeton University Princeton, New Jersey 08544 3-3 ------- TECHNICAL ISSUES OF THE THIRD DAY o Direction and Velocity of Groundwater Flow - Accuracy.of physical measurement vs calculation - Flow prediction difficult in complex systems - Imposed limitations of time and money o Phase Separation and Movement of Immiscible Fluids - Extreme difficulty in modeling multi-phase flows - Petroleum Industry's experience - Predicting phase separation of organic compounds o Dispersion of Waste Constituents - Importance of diffusion and dilution - Estimating dispersion coefficients o Degradation of Waste Constituents - Accuracy of biological degradation predictions - Significance of chemical hydrolysis and precipitation o Sorption of Constituents - Relationship between chemicals in solution and the soil matrix - Reversing the sorption process - Determining the sorption capacity o Supply of Trained Professionals to Make and Evaluate Predictions - Benefits from public sector vs. private sector - Shortage of qualified educators 3-4 ------- SUMMARY OF THE THIRD DAY 1. Direction and Velocity of Groundvater Flow The panel addressed the issues associated with predicting the direction and velocity of groundwater flow prior to contamination of the groundwater by leachate. At the outset of the discussion, one of the panelists indicated that the direction of groundwater flow can be determined by actual physical measurement while groundwater velocity estimates are calculations. Observations of water levels from a minimum of three wells are necessary to determine the slope of the groundwater table or piezometric surface. The direction of the groundwater flow is that of the maximum downward slope along that surface. On the other hand, estimates of groundwatar velocity are calculations which require the measurement of other parameters, such as porosity and permeability. Notwithstanding this apparent lack of precision, he felt that there is a higher degree of confidence in the measurement of ground- water direction and calculation of groundwater velocity than in most other hydrologic calculations and measurements made in the field. Another panelist generally agreed with this viewpoint, adding that the solution of numerical groundwater flow equations has become almost routine. He felt that many models used to numerically simulate groundwater flow are very well documented and straightforward in their use. He also believed that they can now be applied by people not familiar with the internal working of these models. 3-5 ------- Some of the ocher members of the panel were not as optimistic. They argued that there are many conditions for which the direction and velocity of groundwater flow are extremely difficult to predict with confidence. One panelist, for example, felt that watershed groundwater flow models often do not accurately match the ground- water flow system actually existing in many landfills because geo- logical materials often vary significantly over as short a distance as a few meters. He argued that a few measurements of flow direction taken from wells hundreds of meters apart may not represent actual conditions existing at a smaller geologic scale, such as a landfill. Thus, models using these larger scale measurements may miss important local groundwater flows. Another panelist pointed out that data from only three wells are usually grossly inadequate to accurately * predict groundwater direction. He felt that information was necessary from different aquifer depths to develop precise 3-dimensional models for measuring groundwater direction. He felt that additional data concerning groundwater recharge and discharge were also clearly necessary for predicting both grswndwater direction and velocity, since the input and output relationships of groundwater would also probably keep changing due to future man-made events. Most panelists believed that given enough time and money for geologic drilling and testing it would be possible to model, and predict with a high degree of certainty, the groundwater direction and velocity in all geologic systems. However, in real world 3-6 ------- situations limits are placed on time and money. Most panelists, ,t therefore, conceded that there will probably never be enough data to make precise predictions of groundwater direction and flow for all geologic conditions. They also agreed that it is easier to predict groundwater flow in simple alluvial materials where the primary intergranular permeability and porosity is responsible for driving the flow, than in regions where flow occurs in solution cracks or fracture system (i.e., limestone and other karst terrain; fractured igneous and metamorphic rocks; and in highly layered materials such as shales and siltstones). 3-7 ------- 2. Phase Separation and Movement of Immiscible Fluids There was a lively discussion among the panelists over whether or not the movement and phase separation or organic constituents in groundwater can be predicted with confidence. One of the panelists indicated that this field research has shown that most organics usually remain in a single phase with water, and thus flow along with the water in a single plume. At low concentrations, even organics which generally are immiscible with water will be entrained in the plume. However, as the concentration of these immiscible organic constituents increase relative to the groundwater, he has seen a two phase or multiphase plume flow develop. Those organics which are heavier than the water were shewn to migrate to the bottom of the landfill in response to hydrodynamic forces. Subsequent movement is constrained by the surface characteristics of the liner. In some cases,the heavier phase may collect in holes or depressions in the surface of the liner, remaining there indefinitely. Therefore, he concluded that modeling such multiphase flows is extremely difficult. Another of the panelists agreed that modeling these phases of immiscible fluids is complicated, but felt that the panel should not imply that it is a totally intractable problem. He indicated that the petroleum industry has been dealing with this type of research problem on a routine basis involving the secondary recovery of crude oil for some time. They have extensive .-laboratory 3-8 ------- experience in this area, and have conducted complex modeling of these _,• processes. In contrast, he felt that the groundwater industry has not yet developed the requisite experience necessary to analyze and predict with confidence the direction and movement of these immiscible fluids. With reference to phase separation, one of the panelists suggested a method that could be used to predict the likelihood of different organic compounds to separate into phases. He felt that there is enough evidence suggesting that compounds with low solubil- ity will tend to form separate phases, if they are present in large enough amounts. Thus, if the solubilities of the particular compounds were known,as well as the relative rate of their introduction and the salt and mineral content of the groundwater, estimates within a factor of two could be made for phase separation of the compounds. 3-9 ------- 3. Dispersion of Waste Constituents Dispersion of a plume was discussed in relation to both molecular diffusion and dilution. For purposes of this discussion, dispersion was considered to be the family of mechanisms by which a plume spreads out as it moves down gradient, decreasing the con- centrations of contaminants, but increasing the area affected by the plume. Its two principle components are molecular diffusion, the scattering of individual molecules due to thermally induced random motions; and dilution, the decrease in concentration of con- taminants due to mixing with uncontaminated groundwater. The mechanism of molecular or ionic diffusion was regarded by several members of the panel to be well understood, but in general, orders of magnitude less important than other convective properties in determining plume migration. One panelist suggested that trans- verse dispersion (lateral or vertical spreading) of a contaminant plume is essentially similar in nature to that of diffusion. He believed that by making this assumption it is possible to calculate the diffusion coefficient of a contaminant plume by taking the square root of its transverse dispersion coefficient and multiplying this by the length of time for the dispersion to occur. The panelist suggested, however, that these diffusion coefficients in porous media are usually quite small, commonly in the range ^of 10~ square centimeters per second. Several other panelists suggested that there may be groundwater situations (e.g., archaic water with almost no 3-10 ------- movement) where diffusion will be more important. They believed ./• that under such conditions diffusion may still be small, but more important relative to the dilution mechanism. In contrast to the diffusion mechanism, the panel generally agreed that dilution is a much, more important factor in groundwater systems. Several panelists felt that the dilution coefficient depends primarily upon the fluid velocity and the physical charac- teristics of the porous geological medium. While the dependence of the dispersion coefficient was generally agreed to be approximately proportional to the fluid velocity, its dependence on the physical characteristics of the aquifer are currently not well understood, and thus hard to predict. One panelist stated that field measure- ments of this parameter can vary over about three orders of magnitude, and are generally many orders of magnitude higher than what is found in the laboratory. He believed that estimates of dilution in the field, based on laboratory results, would greatly underestimate the parameter. Several panelists argued that the lack of field measurement for .dispersion coefficients does not mean that reasonable dispersion coefficients could not be developed for solute transport models. One panelist suggested that although it is not possible to predict the dispersion coefficient exactly in all circumstances, an estimate of its range can be made to yield a worse or best case. Another panelist indicated that the U.S. Geological Suryey has developed a 3-11 ------- solute transport model for the Rocky Mountain Arsenal using a sensitivity analysis to achieve a reasonable estimate for the dispersion coefficient based on the observed 30-year record of contamination. He believed that field measures of dispersion coefficients for the Arsenal would not have yielded useful informa- tion since recharge was found to be a more important factor in diluting the concentration of contaminants than other dispersion mechanisms. 3-12 ------- 4. Degradation of Waste Constituents . ,• Biological and chemical degradation processes were discussed by the panel as possible mechanisms for the decay of waste constituents found in leachate plumes from chemical landfills. The panel members focused on the accuracy to which these processes can be predicted. In general, the panel concluded that while biological degrada- tion is understood as it takes place in the soil, recent studies have shown that current techniques used to predict biological degradation of plumes in soil are inadequate.since certain unexpected micro- organisms have been identified in the groundwater. Several of the panelists felt that most of the current research in this area is being primarily directed to determine if biological degradation takes place, rather than how fast. They believed that there are too many unknown variables in biological degradation to make quantitative predictions. For example, a slight change in the chemical structure of different compounds has been shown to cause an order of magnitude difference in the rate of biological degradation. Further, the composition of wastes going into a landfill can change dramatically with time, causing interruptions in the food supply for a particular organism, or even introducing toxic chemicals which would kill organisms which promote degradation. They, therefore, concluded that it is difficult to accurately predict the rate of biological degradation. It is generally believed that the chemical hydrolysis and 3-13 ------- precipitation processes are more significant in attenuating leachate concentration and easier to predict than biological degradation. Research has shown these processes to be pH dependent. If the p'H of the waste constituents is known, then estimates of the effects of these processes could be made. 3-14 ------- 5. Sorption of Constituents The attenuation "'of waste constituents by the sorption mechanism was discussed by the panelists, primarily focusing their efforts on the degree of confidence to which sorption can be predicted. Sorption is a mechanism that works to retard the apparent movement of chemical constituents by establishing-an equilibrium condition between the chemical in solution and the chemical absorbed by the soil matrix. Most panelists believed that there is a definite relationship between the chemical in solution and the soil matrix that can be related to several factors: o The type of clays that are in the soil matrix o The soil particle sizes comprising the soil matrix o The organic carbon present in the organic matter in the soil matrix For example, certain types of clays adsorb some chemicals much more readily than others; and porous mediums with finely divided clay and silts will allow fluids immediate access to adsorption sites when compared to a fractured medium where the porosity is more hetero- geneous and absorption may not take place in voids. Most members thought, however, that the organic matter was the site of most of the chemical sorption. They believed that as long as there was adequate uptake sorption capacity of this organic phase, it would remove some portion of the leachate constituents from solution, according to the equilibrium established between soil and solution. Eventually, however, this capacity is exhausted and further sorption 3-15 ------- will not occur. Several members suggested that the sorption follows an S-shaped curve oxrer time. .At the outset there is a gradual increase in adsorption which tails off as adsorption capacity of the organic phase is approached. Several panelists also believed that this sorption process which takes place in the organic phase of the soil matrix is reversible over time. One member reported on his observations made during a university ground-water recharge project. He indicated that sorption was shown to be reversible when the input concentration of the aqueous phase decreased causing it to desorb from the soil matrix. He argued that this desorption mechanism may be particularly impor- tant, sine a to clean up an aquifer after contamination would requira removal not only of what is in the water, but also a large component of the soil matrix. He felt this would be an enormous undertaking. There were several members of the panel who believed that there is enough expertise available for determining the sorption capacity of a soil matrix. One member indicated that sorption capacity is usually determined by hydrologists in terms of a distribution or partitioning coefficient (K^). That is, sorption is calculated in terms of the partitioning between the aqueous chemical phase and the sorbing organic phase. He indicated that university laboratories can * estimate distribution coefficients for about $150 per ion per sample. Once determined, he indicated that he often used £4 in the following equation to predict the velocity of movement of a contaminant relative x" .»• to the velocity of the groundwater: 3-16 ------- „ , . Velocity of groundwater Contaminant velocity • £ r£ 1 + — Kd U where Pb - dry density of the material U » porosity £b_ » 1-5 for most materials v For example, if the Kd of a particular ion is 100 and the velocity of the groundwater is 100 feet per year, solution of the equation would indicate that the velocity of the contaminant is less than a foot per year, suggesting that the contaminant is of little or no consequence in a human time frame. Several members pointed out that they also have used this transport equation with fair success. They believe, however, that its greatest drawback is the current lack of t experience in measuring distribution coefficients for most compounds. They also believed that it is difficult to obtain representative core samples of the geological media in place for calculation of K^. One member suggested that the overall cost o.f these representative core samples may also be as much as ten times the cost of running the K^ test in the laboratory. They argued that additional work is needed in this area to establish reasonable correlations between different soils and chemicals to obtain K^ coefficients without having to run laboratory tests for each chemical in each soil matrix in a landfill. 3-17 ------- 6. Supply of Trained Professionals to Make and Evaluate Predictions The shortage of trained professionals to help make and evaluate predictions of groundwater transport (e.g., hydrogeologists, soil scientists, engineering geologists, etc.) was seen by the group as a serious impediment to the development of an effective regulatory program in this area. Several panelists believed that the demand for trained experts in this particular area was beginning to outstrip the supply of these individuals being produced by the universities. They believed that this trend was detrimental to the state and Federal agencies assigned to regulate the chemical landfill industry because many of these agencies may not be able to attract enough talented people to cope with their difficult regulatory mission. It was believed that many of these individuals would be attracted instead to private industry where they would probably receive better pay and benefits than in the public sector. One of the panelists who is an educator indicated that a similar trend exists in the universities. He believed that since many students with bachelor or master degrees are receiving $25,000 to $30,000 offers from private industry, there is often very little incentive for them to stay on and obtain advanced graduate training. In addition, he believed that many faculty members are now finding it more financially attractive to leave the university and secure employment with private industry as well. The overall result of these two trends, in his opinion, is a shortage of qualified people 3-18 ------- to go back into the universities to teach other students. Some ./ panel members suggested that setting up a national training program might help deal with this particular problem, although it might take 5 to 10 years before any individuals would be adequately trained and be ready for employment. 3-19 ------- Fourth Day May 21, 1981 • Gas Generation and Migration ------- ------- INTRODUCTION TO THE FOURTH DAY ./• This session was concerned with several issues related to the movement of gases and vapors in and out of land disposal facilities. Both impoundments and landfills were discussed. The panel attempted to examine how confidently a permit writer could predict the genera- tion of gases, their movement within the landfill, and their eventual release to points of human and environmental exposure. This involved first identifying what the state of the art for predicting gas migration is. To make this determination the panel discussed the predictive tools and control options available to management. The discussion on predictive tools focused on models in use and currently being developed. Physical, chemical, or manipulative methods were examined as control options. As the panel discussed the state of the art they tried to identify the amount and cost of data needed for prediction, and the availability of the expertise required to produce and evaluate data and predictions. The panel also made suggestions on areas that need further development. 4-1 ------- THE PANEL FOR THE FOURTH DAY ,/* Moderator; Kenneth Shuster Office of Solid Waste U.S. Environmental Protection Agency Washington, D.C. Panelists: David Bauer IT Corporation 336 West Anahein Street Wilmington, CA 90744 Paul Harrison Engineering Science 125 West Huntington Drive Arcadia, California 91006 Charles Johnson National Solid Waste Management Association 1120 Connecticut Avenue, N.W. Washington, D.C. 20036 Charles A. Moore Geo t echnics, Inc. 912 Bryden Road Columbus, Ohio 43205 Mike Roulier U.S. Environmental Protection Agency Municipal Environmental Research Laboratory 26 West St. Clair Cincinnati, Ohio 45268 Jerry Schroy Monsanto Company 800 North Lindbergh Boulevard St. Louis, Missouri 63166 Tom Shen New York State Department of Environmental Conservation Room 138 50 Wolf Road Albany, New York 12233 Louis J. Thibodeaux Department of Chemical Engineering University of Arkansas Fayetteville, Arkansas 72701 4-3 ------- TECHNICAL ISSUES OF THE FOURTH DAY o Models for Prediction of Constituents and Atmospheric Emissions from Land Disposal Facilities - Model development in its infancy - Limitations on model use - Identification of data needs for improvements o Appearance of Gas in Leachate or Subcell Soils - Several simplistic models for sanitary landfills - Lack of data on chemical or co-disposal sites o Prediction of the Migration of Gases within Landfills - Capabilities, shortcomings, and potential uses of a model for gas migration in the unsaturated zone o Management Controls for Gas Migration - Wind barrier placement - Surfactants effectiveness - Venting/Collection systems application to pressure and diffusion problems - Active venting systems disadvantages - Use of subsurface injection plowing in Petroleum Industry - Overall disposal cost reduction from pretreatment and segregation o Monitoring Ambient Emissions from Surface Impoundments - Lack of universal sampling and analysis standards - Lower emission rates found at properly managed facilities - Measuring emissions at night or day - Measuring over an impoundment vs downwind - Insignificant monitoring results on gases selected based on incoming liquid wastes 4-4 ------- SUMMARY OF THE FOURTH DAY 1. Models for Prediction of Constituents and Atmospheric Emissions From Land Disposal Facilities There was a lively discussion among the panelists regarding the usefulness of state of the art models to make predictions regarding both constituents likely to be present in land disposal facilities and the release of such constituents to the atmosphere. Several of the panelists contended that existing models, for example those listed in Appendix F of the February 5th proposed regulations in the Federal Register, contained too many erroneous simplifying assumptions that did not account for necessary interactions (e.g., chemical interactions) occuring in landfills. The panelists indicated that except for certain simple cases, the present models are still in their infancy. The models identify the major factors of concern but need to be improved if they are to be used for accurately predicting constituents. A major obstacle to Improving the models is the sparce data base available. Several of the panelists indicated that models for emissions from surface impoundments are farther along than similar modeling efforts for other land treatment facilities and can provide reasonable correlations (within an order of magnitude) between predictions and monitoring for simple cases. One panelist indicated that currently developed sur- face impoundment models which are based on the general laws of thermodynamics, can help predict, for example, the atmospheric emissions of methanol and acetone wastes within'10 to 20 percent of field and laboratory measurements. However, most members agreed 4-5 ------- chat emissions from more complex waste groupings in landfills, especially those from existing landfills and co-disposal landfills, continue to be extremely difficult to predict. They felt that the modeling of such situations is handicapped both by a lack of data and lack of understanding of important factors such as biodegradation and mass transport mechanisms operating within these complex landfill environments. A number of the panelists argued that the results from existing theoretical models for these complex landfill situations can provide EPA with at least worst-case predictions until these mechanisms are more fully understood and quantified. Other panelists indicated that there is little confidence in such predictions. Further, these panelists cautioned that there is a problem in looking at any model for a single number. They indicated that there is no single numb.er, only a statistical relation which should be considered for regulation. One panelist went so far as to state that he would not endorse the •use of existing models for writing EPA regulations, nor for making any decisions on locating landfills. He also argued that these models should not be considered representative of the state of the art in modeling atmospheric emissions from landfills since such few researchers in the nation are now utilizing them. In his opinion, such models would more correctly be classified as developmental rather than being termed state-of-the-art technology. He revealed that his firm, a large chemical manufacturer uses, these 4-6 ------- atmospheric dispersion models only as "engineering tools" in making judgments, e.g., selecting which equipment to use and whether to use top caps to reduce emissions. He and several other panelists felt that these models were most useful for pointing out generic emission trends, but not for providing specific numbers for engineering and regulatory purposes. Several panelists focused their remarks on the type and amount of data that are required to improve existing theoretical models for the prediction of atmospheric emissions from impoundments. It was generally agreed that the data in current literature on atmospheric emissions from landfills and surface impoundments are relatively sparce and that additional data are necessary from detailed monitoring programs. Some of the panelists suggested that EPA begin a pilot study to monitor the emissions from, say, five representative landfill locations across the nation. These panel members indicated that it would be desirable to collect better infor- mation than exists on the following variables: o Solubilities (Henry's Law Constants) o Vapor equilbrium data (vapor pressures) o Heat capacities o Densities o Diffusion coefficients o Biological kinetics o Wind velocity and duration 4-7 ------- o Air densities ° Solar insolation They indicated that much of this kind of data is either unavailable or erroneous in the current literature. The cost of obtaining some of the data, however, may be quite high. One panelist, for example, indicated that it cost his firm over $50,000 to gather data on just the biokinetic factors for the compound acrylonitrile. He indicated that other types of data would be considerably cheaper to obtain. 4-8 ------- 2. Appearance of Gas in Leachate or Subsurface Soils The panelists discussed the question regarding the types of waste constituents that are most likely to produce gases in leachate or subsurface soils of chemical landfills. Several panelists indicated that cellulose or other organic materials in sanitary municipal landfills commonly generates biogas, primarily methane and C02. They indicated that several simplistic models have been devel- oped to help predict the generation rate of such gases. However, the panelists generally concluded that there are insufficient data available on chemical or co-disposal sites to accurately determine the types of constituents that would appear as gases. Some panelists believed that additional data are necessary from existing sites, particularly those practicing co-disposal of hazardous and municipal wastes since their gas generation is typically the hardest to accurately predict. Several other panelists believed, however, that existing data were sufficient to show that chemical landfill sites generally have less gas production than municipal landfills. Overall, most of the panel agreed that there is limited experience in predicting the generation of different gases from landfills. 4-9 ------- 3. Prediction of Migration Within Landfills This discussion focused on the degree of confidence with which state of the art models can help predict the migration of gases in the unsaturated and saturated zones. They indicated that most current models deal only with municipal landfills. There are some first order kinetic models available, but most assume a homogeneous fill which is rarely applicable to actual practice. These models are designed primarily for methane and carbon monoxide. One panelist presented a detailed overview of a model which he has recently developed to predict migration of gases in the partially unsaturated zone. He indicated that his model can handle the combined diffusional and convective pressure transport of multi-component gases under partial and total pressure gradients. While temperature is considered as a parameter in the model, transport under a thermal gradient is not considered, nor is the transport of heat itself. His model can, however, handle any number of chemical reactions, provided that the kinetics of the reactions are known. The model can also handle the combined flow of gases either in the presence or absence of control mechanisms. He defined his model as being "predictive" and he believed the model eliminated the necessity of conducting laboratory tests to predict the transport of gases. His model only requires that the properties of the gas and soil be specified and does not require calibration data or laboratory flow rates. He believed that this 4-10 ------- was a. particular advantage to this model because it has the potential capability of being "easily extended to other types of constituents. He indicated that the current cost of running the model was generally around $1,000 per computer run. A field verification study of his model is now underway in which methane transport will be empirically determined, This panelist indicated that his model has several important shortcomings or limitations. For example, his non-linear model handles a fair degree of heterogenicity, but was not specifically developed to simulate the type of cell structure that exists in a landfill. His model also deals only with gaseous transport within the soil. He indicated that the greatest weakness is that venting at the surface is taken into consideration using simplified surface evaporation based on partial and total pressure differential equations, He felt that researchers may need to couple his model with atmospheric transport equations so as to account for the interface conditions between the soil and the air instead of only the boundary . conditions. The panelist also indicated that if his model is used to predict the migration of gases other than the "light gases" (e.g., methane) for which it was designed, laboratory confirmation may be necessary to verify the basic equations of gas transport. Lastly, the model does not account for the transport of gases through frac- tures in the landfill top cap or cover. Overall, most of the group generally agreed that the "model 4-11 ------- was a good start toward helping predict the movement or migration of gases within a landfill. Several participants were concerned that this model, as presently constituted,does not model gaseous flow in the unsaturated zone, nor is it applicable to gases other than methane. Under questioning from the panel, the model developer indicated that his model does take into account the solution of gas in groundwater, particularly C02, by predicting the groundwater qualities as a function of time and position as the groundwater becomes altered by the C02 going into it. With reference to the later question, the panelist was uncertain whether his model could be used to predict the gaseous migration of organic compounds other than methane. He suggested that the diffusion constants for methane in his model might provide the upper.limit on the rate of gaseous diffusion in a landfill because no other hydrocarbon is expected to diffuse any faster than methane. 4-12 ------- 4. Management Controls for Gas Migration There are several different management techniques that have been utilized by hazardous waste facility operators to help control the migration of gases. The panel briefly discussed the following different control techniques, focusing primarily on their applicability in mitigating the effects of gas migration: o Barriers o 'Surfactants o Venting/Collection Systems o Liners o Injection Plowing o Pretreatment and Segregation (source control) Wind barriers such as trees, crops, and snow fences placed perpendicular to the direction of the wind can deflect the wind stream, potentially affecting the impacts of wind (e.g., gas volatilization) blowing across an impoundment. One panelist suggested, however, that without the proper design, a wind barrier might protect one side of a large impoundment while the middle or other side could actually receive more ventilation and turbulence than they would otherwise. This panelist also suggested that a thick non-volatile material placed on top of an impoundment could also serve as a wind barrier. He indicated that this layer would reduce the increased volatilization of gases due to wind. However, in high wind conditions such an artificial layer could be blown around the impoundment. In 4-13 ------- addition, several panelists argued that these barriers, by reducing the wind's action, can reduce the oxygen transfer available for aerobic biological activity in impoundments. Nevertheless, a few panelists believed that such barriers could be used effectively with holding ponds. One panelist indicated that agitation or aeration systems seem to have less emissions. However, one panelists noted that the effect of an aerator will depend on whether degradation is controlled by the gas phase or the liquid phase. Another panelists indicated that if the material does not biodegrade then air stripping predominates and would be increased by aeration. Surfactants were judged by most members of the panel as not being highly effective in reducing gas emissions from surface impoundments. One panelist indicated that surfactants should not be utilized in impoundments with activated sludge systems. He felt that these materials would probably be degraded by the microorganisms and thus, the surfactant would not serve a useful purpose other than as an expensive food for the microbes in the impoundment. He also indicated that some detergents could destroy the microorganisms. Several other panelists suggested that some pulp and paper wastes may act as natural surfactants, but they may otherwise increase the gaseous emissions from the landfill. Another panelist suggested that flocculants may be more effective than surfactants because they f can bind materials in an impoundment, thereby minimizing the partial pressure and total surface area. His experience indicated that the 4-14 ------- hydrocarbon emission rate in impoundments was commonly reduced by _/• the addition of flocculating agents. Venting or collection systems are also used by landfill operators to control atmospheric emissions and the build-up of gases. One panelist suggested that in order for an operator to determine if gas venting systems will operate efficiently, he should first determine whether the gas migration is primarily a pressure or diffusion problem. He indicated that if the predominant mechanism is pressure flow then the operator should probably choose a passive venting system which will remove the pressure gradient. On the other hand, if the primary gas transport process is diffusion, he suggested that a passive venting system would probably not be effective and may in- crease the problem. He stated that in cases where gas diffusion exists a landfill operator should construct a gas impervious barrier that would reach to another gas impervious layer such as the ground- water table. Failing to do this, the gas will eventually escape from the landfill. Active venting systems, which incorporate a flaring or incinerating process, have been suggested by some as a means to reduce the quantities of captured gas in a landfill. Most panelists believed, however, that such processes should not be used in a landfill situation primarily because the hazardous gases being flared off may not be totally incinerated during flaring and could pose an environmental hazard. One panelist suggested that instead of^incinerating materials 4-15 ------- such as PCBs and benzenes, refrigeration should be considered as a possible commercial means for reducing these emissions. He argued that it was probably far less expensive to lower the temperature of such gases than to heat them to temperatures as high as 2,000°!. Synthetic liners or impermeable caps have also been prominantly mentioned as tools to control the migration of gases from landfills. Most members of the panel generally concluded that during the course of normal operations such materials might exhibit differential cracking due to environmental conditions and that clay covers would require active maintenance. One panelist argued that if the gas migration within a landfill is a diffusion flow mechanism the probability that the gas within the landfill would escape from any one hole or crack in the liner is remote. One the other hand, if the gas migration is a pressure flow phenomenon, then he felt that a good deal of the gas would move to the tear or crack in the liner and exit the landfill. Some panelists suggested that landfill operators can construct a hybrid type of control system that would have both a liner and a granualar trench. One panelist hypothesized that the granular trench would insure that the gas pressure would be relieved with the liner membrane serving to slow down the diffusional flow even if it had an occasional hole or tear. Another participant cautioned the panel that most synthetic liner products are not totally impermeable to gas diffusional flow, since membranes are used industrially to separate gases. 4-16 ------- The panel also briefly discussed the effectiveness of subsurface injection plowing to deduce gas volatility in land treatment opera- tions. Several panelists indicated that this technique has been used by the petroleum industry to reduce the potential emissions of sludge from refinery tank bottoms. Typically, the materials are plowed into the top eight to ten inches of the soil, resulting in significant emissions for the first few days. One panelist indicated that the industry is currently experimenting with subsurface injection plowing which involves lowering the plow slice to below ten inches and then injecting the sludge material at the bottom of the plow slice allowing the soil to fall back on top. This technique has been shown to reduce the gas emission rate and prevent the destruction of aerobic life at the soil surface. However, it is necessary to replow two to four weeks later and this action can cause a burst of emissions. Another panelist said that now subsurface injection is being done by vacuum trucks and re-aeration is done without turning the soil. Several panel- ists noted, however, that injection plowing is a new technique and there are very little data concerning its effectiveness. Pretreatment, or segregation of wastes (source control) has also been suggested as another management technique to reduce 'gas volatilization. One panelist indicated that his disposal firm routinely pretreats its wastes to remove any volatile organics before these materials are placed within the impoundment. He indicated that 4-17 ------- they have internal rules for heating and stripping (e.g., distillation, air and stream stripping) volatile materials as well as separating wastes into categories. His fira believes that if pretreatment is not done correctly, the final treatment takes longer and increases the overall disposal costs. 4-18 ------- 5. Monitoring of Ambient Emissions From Surface Impoundments Most of the panelists in earlier discussions generally agreed that techniques for predictive modeling of emissions from surface impoundments are more advanced than similar modeling efforts for land- t fills and land treatment facilities, but that they still need improve- ments if they are to be used as a predictive tool. One of their conclusions was that the development appropriate emission factors to characterize existing or new surface impoundments is handicapped by the lack of an adequate data base. The panel discussed several methods that they felt could be used to help measure the atmospheric emissions from surface impoundments, focusing on the various problems and factors that may influence monitoring efforts. The discussion that followed generally indicated that there is no universally accepted method to collect samples, let alone to analyze samples of hazardous emissions that are found over impoundments. Furthermore, analytical procedures are not well defined for measuring concentrations that are found. There appears to be a variety of techniques currently utilized by dif- ferent researchers around the nation, each technique with its own particular advantages and disadvantages. The panelists also indicated that monitoring only gives trends not absolutes. At the outset of the discussion, several panelists pointed out that if the wastes placed into an impoundment are pretreated, the level of atmospheric emissions coming off the facility may be extremely low, 4-19 ------- probably below the level of detectability for most air sampling devices. These lower thresholds nay be detectable using more expen- sive devices. However, thresholds at this low of a level may not be a threat to human health and safety. Most of the panelists agreed, however, that if impoundments are not properly managed, their emission rates may be very high. Thus, current monitoring techniques may be successful la measuring their emissions. A number of panelists reviewed their currant experiences in monitoring emissions in impound- ments. Most indicated that meterological conditions (e.g., wind speed) greatly affected the monitoring. Emission rates are likely to be highest when wind speeds are high; however, due to the diluting effect of the wind, the concentrations cannot be measured. On the other hand, when wind speeds are low, emission rates may be lowest * but have the highest concentrations. One panelist discussed a technique that he used to monitor air emissions, primarily methanol, from impoundments for the pulp and paper industry. From samples of the wastewdter going into the impoundment it was known that methanol was readily available and would be emitted. His research team sampled at six heights over each point over several day's time at one impoundment (e.g., upwind and downwind of the basin). They found that the best time for detection (of a readable sample) was in the middle of the night when the wind was very calm, rather than sampling the air in the middle of the day when the wind speed is much higher. Although 4-20 ------- the emission rates may be higher in the afternoon than at night, the methanol being emitted from the impoundment could not be detected because of the wind's diluting effect. Another panelist indicated that he has attempted to run a material balance just in the air boundary layer above a large waste lagoon (roughly 80 to 100 acres) and has found it extremely difficult. His technique involved attempting to plot the plume coming off the impoundment by sampling air emissions at the shoreline at different lateral points, measuring the flux through an imaginary wall at dif- ferent heights along the plume, and determining average concentrations over long periods of time. The need to average over long periods of time was emphasized. He also indicated that when the contaminant concentrations are very close to the background concentration, his flux equations are very difficult to solve. In such instances, his results are usually poor. He believes that if the particular para- meter cannot be measured over the impoundment, the chances of measur- ing the parameter downwind is quite small. Another panelist indicated that his firm, a large chemical manu- facturer, has developed a scenario in which they can monitor specific parameters to help estimate air emissions at the property line for an impoundment. They monitor the solution of waste liquids coming into their impoundments and analyze their results using a gas chroma- tograph. These results tell them what constituents to monitor for in the air over the particular site. Their monitoring technique involved 4-21 ------- stringing a cable with sensors across the impoundment and at the property line. He indicated their research so far has indicated insignificant concentrations of organic emissions. However, another panelist indicated that he did not believe that there was a direct correlation between what is in the impoundment and what is in the air. In summary, most of the panel generally agreed that atmospheric monitoring of emissions from impoundments is not a very well developed field. The techniques described by the various panelists are largely experimental and require specialized training, particularly in meterology. Additional work on improved monitoring techniques was a major suggestion by most panelists. 4-22 ------- Fifth Day May 22, 1981 Health Effects Resulting From Hazardous Waste Exposures ------- INTRODUCTION TO THE FIFTH DAY ./• The final session of the conference addressed the topic of Health Effects Resulting from Hazardous Waste Exposures. Panelists in the previous days discussions had addressed the phenomenon of fluid flow from land disposal facilities and the means that exist to quantify and control that flow. For sake of discussion, the panelists in this session assumed that the concentrations of hazardous constit- uents present in individual land disposal facilities are known. They discussed the various types of risks that may be presented to human health and the available means to estimate the magnitude of those risks. The focus of the discussion was on how a permit writer proceeds to evaluate the potential health effects posed by an exist- ing or proposed land disposal facility. The panel attempted to identify existing regulatory standards and criteria which could be used as guidance. If no such standards or criteria exist they considered other feasible approaches. Where possible the panel was asked to identify degrees of confidence and suggest areas or techniques for development which would increase the accurate predic- tion of health effects to humans from the disposal of hazardous wastes. 5-1 ------- THE PANEL FOR THE FIFTH DAY Moderator Robert Taylor U.S. Environmental Protection Agency Washington, D.C. Panel Members Larry Claxton U.S. Environmental Protection Agency Research Triangle Park North Carolina 27711 Robert B. Gumming Biology Division Oak Ridge National Laboratory P.O. Box Y Oak Ridge, Tennessee 37830 Joseph Fiksel Risk Management Unit Arthur D. Little, Inc. Acorn Park Cambridge, Massachusetts 02174 Ralph Fruedenthal Stauffer Environmental Health Center 400 Farmington Avenue Faraington, Connecticut 06032 Joseph Highland Chairman, Toxic Chemicals Program Environmental Defense Fund 1525 18th Street, N.W. Washington, D.C. 20036 Robert McGaughy Cancer Assessment Group U.S. Environmental Protection Agency Washington, D.C. 20460 Riva Rubenstein National Solid Wastes Management Association 1120 Connecticut Avenue, N.W. Washington, D.C. 20036 David Smith IT Corporation 336 West Anaheim Street Wilmington, California 90744 5-2 ------- TECHNICAL ISSUES OF THE FIFTH DAY _,> o Methodologies and Techniques for Predicting Carcinogenic Effects - Results from in vitro useful in identifying carcinogenic substances of concern - Results from animal bioassay fairly predictive in evaluating carcinogenic potential - Results from bioassay test establishing health criteria in legal system - Epidemiclogical results useful when cancer risk factor is very large and unequivocal o Use of Human Risk Numbers for Permitting Decisions - Use of ranges rather than numbers causes concern - Inadequate assessment techniques create difficulties in establishing permit standards - Assumptions behind standards must be understood before used o Sources of Additional Data for the Permit Writer - EPA is the largest producer of related data - Considerations for reforming EPA's protocol on unpublished data o Toxic Effects to Humans - Dose level methodology provides "legal safety" measures not scientific measures - Safety levels should apply to the human population, not a standard man 5-3 ------- SUMMARY OF THE FIFTH DAY 1. Methodologies and'Techniques for Predicting Carcinogenic Effects The panelists discussed two types of tests that are currently available for evaluating, the carcinogenic effects of chemicals. The first is the in vitro (e.g., Ames test) which uses cell systems and cultures to predict transformations from normal cells to malignant cells. The panel believed that such short-term tests can be most useful as a screening tool in identifying carcinogenic substances of concern. Several panelists indicated that the in vitro test can give quick and inexpensive qualitative (not conclusive) predictions, but is not useful for making extrapolations to human risk. One panelist even suggested that the use of human cell cultures in a short-term in vitro test may not be a better predictor of human risk than the use of animal cells since there is evidence that results of all in vitro tests are much more similar to each other than to in vivo tests. They noted that there is a major difference in findings on human cells and predicting results on humans. Several panelists felt that these short-term tests often do not consider -~ the effects of important mechanisms such as the biological rates of absorption of carcinogens. One panelist revealed that his research has indicated that often the chemicals which are the most carcinogenic have shown the weakest response in these short-term cell tests and thus doubted- their usefulness for predicting in the qualitative sense. The second type of test that is currently available for 5-5 ------- evaluating the carcinogenic effects of chemicals is. the animal bioassay. An in vivo animal bioassay takes about two years and costs about $0.5 million. The panelists indicated that about one thousand in vitro tests could be done for each animal bioassay. Most of the panelists generally agreed that if these long-term tests show carcinogenic results with at least two species of animals, the results obtained are believed to be fairly effective, especially with the NCI (National Cancer Institute) bioassay, in predicting the carcinogenic potential of the particular compound under study. One panelist also indicated that when these bioassay tests are repeated using the same route of carcinogenic exposure, the results are usually reproduceable within a factor of 10, and often within a factor of 2 or 3. Using different routes of exposure, there is a wider range of difference. Yet, while most panelists believed that such tests are fairly predictable of cancer risks, extrapolation to the human situation was felt to be uncertain and subject to consider- able variability. The greatest uncertainty was felt to be in extrapolating from large doses used in tests to the effects of small doses. One panelist indicated that the an-final bioassay is the best test available for assessing the carcinogenic potential, but he does not agree it is necessarily a predictor of human carcinogen- ic ity. Several of the panelists indicated that animal bioassay tests have already been built into the legal system. In order to 5-6 ------- determine legal safety in terms of carcinogenic chemicals, the results of the bioassays have generally been utilized in existing formulas to calculate a legal standard of human risk. These panelists argued that such a technique does not really predict the risk to human health, but rests totally on a legal determination of safety and does not necessarily relate to the actual impact on human health measured in terms of the number of hospital admissions, morbidity, etc. Most of the panel felt that while such formulas are good for determining legal risk these formulas are based on simplifying assumptions and uncertainties. They believed that the public is often not aware of these assumptions and thus, takes the unit risk numbers of cancer in the human population predicted by such formulas at face value. While such numbers are useful, most panelists believed that this type of risk assessment is semi-quantitative at best and is only an estimate. Yet, most panelists believed this is about the best that can be done given current state-of-the-art conditions in risk assessment of carcinogens. A number of panelists suggested that the accumulation of epidemio- logical experience with carcinogens is the only reliable indicator of how well the current techniques have predicted human risk. Most panelists felt, however, that epidemiological techniques may be effective only when the cancer risk factor is very large and unequivocal (e.g., cigarette smoking). Where the risk factor is low or where there are a multiplicity of factors involved, most panelists believed that epidemiology is only marginally useful 5-7 ------- in estimating human risk. In addition, it was believed that the accumulation of epidemiological data to support predictions would be slow and difficult for chemicals of interest to EPA. 5-8 ------- 2. Use of Human Risk Numbers for Permitting Decisions _y One of EPA's current concerns is whether risk assessments can be useful in making permitting decisions in the area of land disposal of hazardous wastes. The panel specifically focused on this topic addressing the issue of whether these techniques can provide useful data on human risks with respect to either authorizing a new site, or denying continued operation of an existing activity. The panelists indicated that risk assessment is only applicable to chronic effects. They noted that no one has ever done risk assessments for acute effects and that the distribution on sensitivity of human populations to acute effects is not known. The panelists agreed that risk assessment is semi-quantitative at best. One panelist postulated that risk assessment may be going too far too fast and expressed doubt in the existing numbers. Another panelist indicated that there is considerable value in developing quantitative risk assessments even if there are large error ranges, providing the inaccuracies are understood. Major sources of error result from assumptions that data on one species are transferable to other species and from extrapolation of results from high doses to low doses. This panelist indicated that relative risk assessments are done based on the number generated. Another panelist disagreed stating that the magnitude of the large error precludes relative risk assessment. With regard to applying risk criteria to permitting of sites, 5-9 ------- most members of the panel argued that while scientists can predict impacts to ground-water quality as a result of land disposal activities, current risk assessment techniques are inadequate in determining if a particular level of contaminants is acceptable with regard to human health. They indicated that the risk pathway for land disposal of solid wastes is very poorly understood at present. The problem is in determining the transport of contaminants and in quantifying exposure, especially for new sites. Several panelists noted that predicting exposure patterns from land disposal sites is currently impossible. The panelists stated that there was also a need to develop reliable exposure data. These panelists believed that the protection of human health would probably best be achieved through source related standards (e.g., landfill standard) which are more concerned with minimizing the releases rather than with attempting to evaluate what an acceptable level would be upon human and biological health. However, several panelists were somewhat more optimistic in using risk numbers for existing sites since the exposure patterns were felt to already exist. * Several of the panelists felt there was, nevertheless, a need by the land disposal industry for EPA to set specific standards for new and existing land disposal sites. They argued that these limits could be reset if the limits were found at a later date not to be acceptable. Another panelist argued that while it is not possible to extrap- t olate precisely, EPA's water quality criteria for toxic pollutants (45 FR 79318) were directly applicable for evaluating risk-of chemical 5-10 ------- toxicity to human health. He felt that this document represents the _t most consistent framework so far for analyzing the level of human risk in landfill situations. He argued that hazardous waste permit writers could select an acceptable risk level from the numbers provided in this document for both new and existing sites. Another indicated that existing numbers should not be used without first looking at the exposure assumptions behind the criteria. 5-11 ------- 3. Sources of Additional Data for the Permit Writer The panelists discussed additional sources of data available to EPA permit writers dealing with human risk factors associated with land disposal of hazardous wastes. Most panelists indicated that the major source of data outside of EPA is other agencies of the Federal government. There are a number of Federal agencies such as NIOSH that internally produce toxicological data. The NIOSH Registry of Toxic Effects of Chemical Substances may be an important source of infor- mation on the toxic effects to humans. Several of the national laboratories also produce similar data in their biological programs. One panelist suggested that much of the government agency and national laboratory data ultimately appears in print and is usually carefully produced. The panel indicated that other sources of data are industries, hospitals and contract laboratories. Some of this data may be difficult to obtain or proprietory in nature, but could be released in support of a particular government permit. Several panelists indicated that some data produced from contract laboratories and other businesses producing data for a fee are of variable quality and reproducability. The panel next turned to the question of whether data that are currently unpublished should be accepted in permitting hazardous waste management facilities. Several panelists indicated that there is a protocol in EPA Water Quality Criteria Document stating that only published data (e.g., published journal articles7 5-12 ------- company reports to EPA) can be accepted so as to provide for public ./• rebuttal. -Overall, the panel thought that it vas not a good policy to limit data use to only published data. Several members of the panel believed that peer reviews accompanying regularly published data is commonly not adequate for discerning the quality of data. Additionally, they believed that much of the data which gets into the published literature after getting through the peer review process may not be in a form that is usable to EPA. Several other panelists disagreed arguing instead that peer review has value since it filters out the worst sets of data and research designs. However, most of the panel agreed that whenever published data are used in a permit application they must be independently evaluated regarding the overall research design and statistical validity. They also recommended that primary data sources be used rather than secondarv sources. 5-13 ------- 4. Toxic Effects Co Humans The panelists next discussed the methodologies and techniques used for predicting acute and chronic effects resulting from exposures to toxic compounds. The moderator indicated that EPA, in developing water quality criteria, used several toxic effect levels: NOEL (no- observed-effect-level) , LOEL (lowest-observed-effect-level), LOAEL (lowest-observed-adverse-effect-level), and FEL (frank-effect-level). The panel was asked whether this methodology or any other had particular merits in determining toxic effects in man. Several panelists indicated that a common practice is to reduce the LOEL available from a good number of comparable studies by a factor of 100 in order to determine an acceptable daily dose rate for that compound for a normal, 70 kilogram (150 pounds), adult male. They noted that when additional information is known about the interaction of the compound and humans (e.g., metabolism of a particular substance) the LOEL may need to be reduced by a factor of 1,000 rather than by 100. A number of panelists indicated that the daily dose level that is calculated by this technique is a very crude safety level for acute toxic effects. Although this technique was felt to have very little theory behind it, some panelists believed that the technique has provided dose measures that allow fairly good protection against acute*toxic effects in man (e.g., people do not die ingesting these concentrations). Several panelists cautioned, however, that the daily dose rates produced by this technique do not necessarily 5-14 ------- provide protection to humans against a chronic effect or from synergistic -/• effects of multiple compounds. However, panelists noted that while these measures do not offer absolute safety, they do provide a measure of "legal safety" which regulators can potentially monitor and enforce. A number of panelists noted that results from animal studies suggest that different safety factors would be appropriate for different substances and that they expect human populations would have a much larger variability and sensitivity to toxic chemicals than any animal population. They indicated that there are certain substances for which the acute levels or the incidence of acute effects in animals increases as the dosage of the toxic compound gradually in- creases . They indicated that for certain compounds a relatively flat increase can be observed whereas with other substances a very sudden threshold is observed at which detoxification mechanisms no longer work and the LDso (dose causing death in 50 percent of test animals) is reached fairly rapidly. They felt, therefore, that it would be an exercise in futility to try to create a dose rate for a standard human since there are numerous subpopulations of humans that are uniquely sensitive to a given dose of a toxic chemical. Overall, most of the panel generally agreed that while there are usually sensitive people to certain chemicals, the general approach still * should be to determine a legal margin of safety for the human pop- ulation as a whole. The panelists also indicated that determination of synergistic 5-15 ------- or antagonistic effects, morbidity, phytotoxic effects, and bioaccum- ulation need to be carried out on a compound-by-compound basis. Results from one compound cannot be extrapolated to another compound. 5-16 ------- Appendix A Agenda ------- AGENDA May 18 and 19, 1981 I. Leachate Generation (Quantity and Quality); Attenuation in Liners and the Unsaturated Zone; and Management Approaches to Control 'Leachare Quantity and Quality In this session, we will examine the chief factors which are relevant to controlling the quantity, the time of first release, and the quality of leachate which is discharged from land disposal facilities into the ground. {On Wednesday, the fate and transport in ground water of leached constituents which have been discharged will be discussed.) The questions listed below are intended to direct the panelists' attention to several major issues. First, we will attempt to establish leve'ls of confidence in predicting the performance of facilities. No matter what one's goal is (i.e., controlling leachate quantity, containment time, or leachate quality), it will be necessary to examine particular land disposal facilities or proposed facilities and predict whether they will achieve the stated goal. Any such prediction involves some uncertainty. We wish to identify the relative degrees of confidence and uncertainty in making predictions and, if possible, to identify situations in which such predictions are subject to particularly high or low degrees of confidence. Some factors affect facility performance more than ethers. In particular, given any mathematical model for predicting leachate generation, the range of variability or error in predicting particular inputs to the model (e.g., the pe'rmeability of a natural clay liner or the infiltration rate of liquids) may be either compressed or expanded in the output (e.g., the ------- -2- concentration of 'a particular constituent exiting the facility or the time when leachate first exits the facility). The questions below attempt to identify the factors that are most critical in predicting leachate generation, and of those factors, the subset of factors for which errors in prediction result in significant ' " errors in predicting the facility's performance. Furthermore, we will try to identify how confidently these important factors can be estimated or predicted. Since such estimates or predictions depend to a large part en data, we will discuss the type and amount of data needed to achieve particular levels of confidence, the cost of obtaining the data, the degree of expertise required to generate or collect the data, and the current availabiity of such expertise. Since the estimates also depend on the accuracy of the model or equation applied to the data, we will also discuss the confidence with which models which use simplified assumptions or complex models (which may or may not have been field tested) can be used. Finally, for each discussion, we will consider the capacity of regulatory agencies to evaluate these estimates and predictions. Second, we will identify and discuss the major waste management techniques that can help achieve any identified goal. Furthermore, we will examine whether any of them help narrow the range of uncertainty in making predictions. ------- -3- A. Leachate Quantity and Duration of Co.ntainment Period 1. Sources of Liquids a. Net Precipitation Rates; With what degree of confidence can one predict precipitation and evapotranspiration rates? What range of error is likely to be introduced by major / storm events or periods of unusually large cumulative precipitation? Given the longevity of land disposal facilities, what is the effect, for example of preventing run-on from a 25-year, 24-hour storm but not from a 100-year, 24-hour storm? To what extent will this introduce error into predictions of leachate quantity? (Consider both wet and arid climates.) To what extent can any design or management techniques minimize the- range of error? How can appropriate worst-case assumptions be developed to provide confidence in predicting maximum possible leachate quantities? b. Use of Top Liners to Prevent Infiltration of Precipitation. With what degree of confidence can infiltration of rainwater (or of inadvertent run-on) be prevented or minimized by the use of synthetic liners and clay liners as caps after closing the facility or by the use of intermediate liners during the facility's operating life? i. What is the maximum period of time during which a synthetic liner or cap may be expected to function effectively? Is it technically feasible to replace synthetic top liners when necessary over long periods of time? Are appropriate laboratory or field tests methods available to predict a svnthetic liner's life s~ ** with confidence? ------- -4- ii. With respect to a clay liner or cap/ how likely is it that any of the events listed below may occur? In each i case, how much uncertainty could the occurrence of such an event introduce into a prediction of the amount of liquids entering ( • the facility? In discussing the likelihood of such events, i consider the available management techniques for decreasing the likelihood, and the feasibility and cost of those techniques. Consider the ability to address these events over varying periods of time (e.g., 30, 100 or 500 years). (1) Channels in the liner or cap caused by root penetration (2) Channels in the liner or cap caused by burrowing animal3, (3) Channels in the liner or cap caused by fingering resulting from nonuniformity of material (4)" Erosion of the liner or cap • i (5) Cracks in the line*r or cap caused by the consolidation of underlying waste and earth materials and resulting differential settlement (6) Cracks in the liner or cap caused by decreases in moisture content or by reactions of infiltrating < liquid with the liner's earth materials (7) Cracks in the liner or cap caused by freeze-thaw cycles c. Groundwater Infiltration • ' To what extent can water infiltration into the facility , through the sides and bottom be prevented? i. If synthetic liners are used on the sides of ' the facility, is replacement of failed liners a technically feasible option? If clay liners are used on the sides of the facility, how confident can we be that the liners' relative ------- -3- impermeability will not be impaired? In particular, what manage- ment techniques may be used to minimize the problems listed in Questions (b)(ii)(3)-(7) above? ii. Where the natural water table is high enough to intersect at least part of the facility, what means could be used to artifically lower the water table and prevent water from infiltrating through the aides or bottom of the facility? Could these means effectively keep infiltration out in the long term after closure? Consider both passive systems (e.g., trenches) and active systems (e.g., pumps). d. Liauids in or Produced bv Wastes (Applies only to landfills) i. How significant are the quantities of liquids in buried wastes (including liquids in drums) or liquids produced by wastes (by decomposition of organic wastes) in relation to 'the total amount of liquids entering the land disposal facility? ii. In cases where such liquids could be significant, what pretreatment techniques (e.g., dewatering of sludges or biologically degrading the organic wastes prior to disposal) are available to minimize this problem? How reliable are these techniques and what are their costs? e. In what situations, if any, would it be environmentally preferable not to prevent or minimize the entry of liquids into a landfill or a closed surface impoundment? 2. Mass Rate of Discharge and Time of First Discharge of Liquids Whenever clay liners are discussed below, consider the unsaturated soil as well. ------- -6- a. Permeability of Clay Liners i. What level of confidence can we achieve in predicting the overall permeability (and thus mass rate and time of first discharge) of intermediate and bottom liners in light of variations in the materials used for liners (e.g., variation in type or amount of clay, existence of lenses in in-situ liners , and in leachate composition)? How much data must be obtained on such variations (particularly in the case of natural in-place bottom liners or unsaturated zones relied upon to control leachate i migration) to achieve a particular degree of confidence? What is the cost of developing such data? What expertise and equipment is required, and to what extent are they currently available? < • How likely is it that collecting many samples to develop data would impair containment by creating channels? ii. To what extent can leachate decrease the " ' permeability of liners? Can any leachate constituents reduce permeability by precipitating and plugging pores? In what situations can this be predicted, and with what confidence? Consider different types of liner material. iii. To what extent can leachate constituents i increase liner permeability by sorbing to clay surfaces and changing interlayer spacings; dissolving constituents of clay ' , minerals; shrinking clay liners by displacing pore water; and ( affecting the surface' tension of pore water? How confidently can such effects be predicted? To what extent does the level of confidence depend on precise knowledge of leachate quality (discussed < in section B of this session)? What impact does error in predicting ------- -7- changes in permeability have on the range of error in predicting either containment time or the rate of discharge after containment? _y Are any liners or natural soils relatively immune from attack by leachate or by certain types of leachate as the result of structural properties (e.g./ types of crystal formation) which resist expansion and contraction? b. Permeability of synthetic Liners. During its useful life (see Question A(l) (b.) (i)), what level of risk is there that a synthetic liner will tear or be degraded by chemical reactions? In such event, how likely is it that a surge of leachate will be able to exit the facility? c. Capillary Forces; How signficant is correct estimation of clay liners' capillary forces to predicting the initial contain- ment period of the liner system? How dependent is this estimation on knowledge of moisture content? How much data is needed to estimate moisture content? What is the effect of leachate with a specific gravity or surface tension differing from water? d. Leachate Collection System i. What are the practical limits on the effectiveness of leachate collection systems? Consider the use of different types of liner materials. ii. In the long term, what is the likelihood that the effectiveness of a leachate collection system will be impaired? Consider, for example, plugging of the drainage media, or increased permeability of the liner under the drain (as discussed in question (a)(ii)(2) above). ------- -8- iii. In the long term, what maintenance will be necessary to operate the leachate collection system? Consider both active (pumps) and passive (gravity) systems. iv. Given that the rate of ieachate discharge is very sensitive to errors or variability between the design and actuai * performance of leachate collection systems (e.g., if a system that is designed to remove 99% of any liquids passing through actually removes only 90%, the actual leachate quantity discharged will be 10 times the predicted quantity), how well can such error or variability be controlled? Is it reasonable to assume a very high (e.g. 99%) theoretical efficiency in predicting the discharge rate of leachate? Is it reasonable to build in a safety factor in designing the system? v. What are the costs of installing and operating and maintaining leachate collection systems over long periods? vi. What are feasible techniques for managing collected leachate, both during facility operation and after facility closure? e. What methods other than leachate collection systems are currently available as early warning systems for breakthrough of liquids out of a facility? How reliable are these methods, » particularly over long periods of time? 3. Quality of Leachate Discharged From a Facility 1. Production of Leachate from Single Wastes Assuming for purposes of simplicity that only a single type of waste is placed in the facility, how,, well can we predict ------- -9- the constituents that will be leached from the waste and the concentrations at which they will be released? a. How critical are each of the following factors in -»• confidently predicting the leachate quality? (i) Leaching medium (1) Proton and electron environment (pH, redox potential, ionic strength and buffering capacity) (2) Presence of solubilizing agents (ii) Waste characteristics (1) Metals (2) Other salts (3) Polar organics (acids/ bases or- neutrals) (4) Neutral, non-polar organics (iii) Duration of contact of waste with leaching medium (iv) Properties of soil or clay used as cover or intermittent cover (1) Particle size (2) Organic content (3) Clay content (v) Ratio of leaching medium to the waste (Does a large amount of liquids 'infiltration into the facility result in dilution of the leachate and thus a lowering of constituent concentrations?) b. For those properties identified in paragraph (a) as most significant, with what degree of confidence must they be known in order to confidently predict leachate quality? (Answer separately for inorganics, semi-volatile organics and volatile organics.) ------- -10- (i) Is it possible to predict leachate quality by separately determining or estimating each of the factors and then computing the leachate quality by the use of equations or models? If so, how much information is needed on these factors? What laboratory or field tests are appropriate for such predictions? What are the associated costs? How much time and expertise is needed to run the tests and make the predictions? Is a sufficiently large pool of expertise presently available? (ii) Is it preferable or absolutely necessary to use leaching tests which use representative combined samples of the waste and soil, rather than to rely on separate analyses of each factor as in paragraph (i) above? (2) How well can such tests simulate leaching in the field? To what extent have such tests been verified in the field so far? How well can one design a decision tree to select an appropriate test method for specific cases, to obviate the need to separately study each situation? Can one design a scheme whereby leachate quality for certain types of wastes are easily predicted generically and more specific testing is required for certain others? (3) Is the use of water as a leaching fluid to simulate leaching appropriate? (Consider organic and inorganic wastes separately.) §hould a mild acid be used instead? (4) What is the cost of developing adequate data under this approach and how much expertise is required? ------- -11- 2. Prediction of leachate from complex or mixed wastes. Does the state of the art enable the composition of leached complex or mixed wastes to be predicted? - a. How does one choose an appropriate leaching medium to simulate various water/waste interactions? To what extent does error in choosing an appropriate leaching medium result in error in predicting leachate quality? b. To confidently predict leachate, must one know in advance precisely what wastes will be accepted by the facility, how much of each will be accepted, and where they will be placed? .Must laboratory tests be run for this combination o-f wastes or on particular wastes only? To the extent that one fails to run such tests, what error results in the prediction of leachate quality? If one does run these tests, what are the associated costs,and are enough qualified people available to run and interpret these tests? c. Can a worst-case estimate of leachate generation be confidently assessed by considering the solubilities of the most prevalent constituents in the waste? 3. Separation and Pretreatment of Wastes In situations where it is difficult or impossible to confidently predict leachate quality, what options are available for separating or pretreating wastes in order to maximize leachate «#• quality or at least make it easier to predict? a. Waste separation (i) Other than separating each waste into separate cells or impoundments, are there groupings of wastes which would ------- -12- siaplify analyses of leachate quality (e.g., separate wastes into metals, polar organics, nonpolar organics)? (ii) To what extent do impurities (e.g., metal catalyst in organic wastes) reduce the utility of waste separation? k* Solidification, Stabilization, Encapsulation. To what extent can these techniques be used to reduce the leaching of constituents? (i) In what ways should leachate tests for solidified or stabilized wastes differ from those discussed above for wastes in general? Are these tests easier or more difficult to perform in any respects? Do they provide the tester greater or lesser confidence in their results? What confidence can we have in the long-term properties of current stabilization processes? (ii) For metal wastes, what types of techniques provide long-term reduction in leaching of constituents? How are these techniques limited by (1) exposure to freeze-thaw conditions; (2) presence of organic contaminants; (3) exposure to wet-dry conditions; (4) physical stresses; and (5) various factors leading to reversibility of reactions (e.g., pH changes)? (iii) For organic wastes, are any stabilization techniques sufficiently well established to allow confident prediction of low levels of leachate constituents in the long run? 4. Degradation of Organic Constituents in the Leachate How well can we predict whether, and how rapidly, particular /- constituents in the leachate will be decomposed by biodegradation, hydrolysis, chemical reactions or other means? ------- -13- a. How well must one simulate field conditions in performing laboratory tests (e.g. availability of oxygen, sunlight, water, appropriate aerobic or anaerobic microbes)? Have field .*• studies been conducted which confirm prior predictions of sorption of constituents of hazardous waste leachates? b. What is the cost of performing the appropriate tests, what is the degree of expertise needed to perform the tests, and how much time would the testing require? c. How well can one predict the resulting decomposition by-products and the relative amounts of each one? How likely is it that these by-products will be as or more mobile or toxic as the parent compounds? d. To what extent can a bottom liner serve as a biotreatment layer or filter to reduce the concentrations of organic constituents in the leachate? To what degree does it depend on permeability'of the liner? How'is a prediction affected by errors in estimating these factors? (See Question A(2)(a) and (b)). 3. Attenuation of Constituents Prior to Discharge From Facility a. (i) If clay bottom liners are used, how reliably can we predict the degree to which constituents will be attenuated by sorption? How confident can we be in predictions of sorption? What are the major factors producing uncertainty, and to what extent can they be overcome by collecting enough data? Have field studies been conducted which confirmed prior predictions of adsorotion of constituents of hazardous waste' leachates? ------- -14- (ii) How significant is the risk that sorption will be reversed over time (e.g., due to pH changes in the facility}? b. Are any chemical or physical mechanisms other than sorption significant enough and definable enough to be evaluated in predicting attentuation of constituents? In such cases, how •, « significant is the risk that the reactions will reverse over time? c. Is confidence in predictions of attenuation in the unsaturated zone less than in the case of clay liners? How much less? For example, what effect would increased oxygen and other gas content have? 6. Summary Combining your responses to Question 1-5, with what degree of confidence can we predict leachate quality? In what situations are such predictions more easily made? In what situations are they impossible to make with any confidence? Is there an adequate supply of trained professionals to make these predictions and evaluate them? ------- -15- May 20, 1981 II. Predicting Leachate Plume Migration in Groundwater Modeling and Monitoring ,s This discussion will address the issue of how well one can * predict the fate and transport of the leachate and its constituents » in the ground water. Specifically, how precisely can the concen- trations of constituents at any loction and time be predicted? Assume that the location/ mass rate and concentrations entering into the ground water are known with some degree of confidence or uncertainty, as discussed in Question I in the Monday and Tuesday sessions. Among other things, the questions below will examine the sensitivity to, or potential error in predicting plume migration which results from, varying degrees of uncertainty in .the preceding pre- diction of the leachate quantity and quality entering the ground water. In considering methods for predicting leachate plume migration, we will consider the type and amount of data required, the cost of generating such data, and the degree of expertise required to produce and evaluate the data and predictions. 1. Ground-water flow; With what degree of confidence can we predict the direction and velocity of ground-water flow prior to contamination of the ground water by leachate? a. Are there certain types of geological systems (e.g., fractured strata or strata which may easily be dissolved) for which predictions of the direction of ground-water flow are too speculative to be made with any confidence? How well can we identify such systems prior to site-operation? Where are such systems j- predominantly located? ------- -16- b. Are there certain types of geological systems for which predictions of the direction of ground-water flow can be made with a high degree of confidence? How well can we identify such systems prior to site operation? Where are such systems predominantly located? c. How good is the current stare of the art for estimating ground-water velocity? d. How is any prediction affected by the nearby presence of wells which are used for withdrawal or recharge of ground water by use of pumps or other means? How good is the state of the art for calculating how far the leachate plume must be from such wells to remain relatively unaffected by the use or cessation of use of these wells? 2. General Movement of Constituents in Ground Water. If one ignores all attenuation, how well can one predict the transport of leachate constituents? a. Separation of Phases Based on Specific Gravities (i) Heavy organics. If a leachate plume contains organic constituents which are heavier than water, will those constituents form a separate plume which does not move with the ground water? If so, how well can we predict the direction and rate of flow of this plume? Which type of organic constituents are most likely to form separate plume? With what precision must one know the leachate quality to determine the likelihood that such a separate plume will form? (ii) Light organics. Answer £or light organics j- the same cuestions as raised in Question(i) above. ------- -17- (iii) Is the answer to Questions (i) and (ii) dependent on the salt or mineral content of the ground water? To what degree? b. Molecular Diffusion. How well can we predict the • degree to which the leachate plume will expand and concentrations ;- of constituents will decrease by virtue of molecular diffusion? (i) To what extent, if any, does this effect depend on the initial concentrations in the plume? Does the rate of diffusion differ for different constituents? To what degree? (ii) To what extent does this effect depend on ground-water velocity? c. Dilution in Ground Water. How well can we predict the degree to which constituent concentrations will be decreased by virtue of dilution in the ground water? (Disregard the effect of separate plumes discussed in Question (a) above.) How dependent is the dilution effect on ground-water velocity and geological stratification? 3. Degradation of Constituents. To what extent can the following mechanisms be expected to cause the decay of constituents in the unsaturated zone? For what types of constituents, if any, is such decay likely to be signficant? If not significant, can any fate equation or model ignore the degradation effect? If signficant, how well can the effect be predicted, and how sensitive is any fate/transport prediction to error in predicting the degradation effect? a. Biological degradation - both aerobic and /- anaerobic processes b. Degradation by hydrolysis ------- -18- c. Reaction with other constituents in the leachate plume, groundwater, or geologic environment 4. Sorption of constituents. With what degree of confidence can the attenuation of constituents by sorption be predicted? a. How dependent is sorotion capacity and rate uoon i ' factors such as soil particle size, organic content, porosity * and cation exchange capacity? How much data concerning these factors is needed to characterize the geology and confidently predict sortion capacity and rate? Does sufficient expertise and equipment exist to make the required analyses? b. To what degree is sorption enhanced by a low ground-water velocity? c. How dependent is the sorption rate for a particular constituent upon the concentrations and sorption rates of the constituent or other constituents in the leachate plume? Is it likely that constituents would compete for sorption sites, or are enough sites available for all leached constituents within a short distance from the facility? d. What is the role of humic and fulvic acids in attenuating (by coraplexation) or accelerating (by decreasing soil sorptive potential) the migration of organics and inorganics? How well can this role be predicted in any particular situation? e^ What other factors, if any, are highly significant f r in predicting sorption rates? f. How likely is it that sorption will be reversed over time? What factors are significant in promoting such reversal? In cases of potential reversal, how well can one predict the ------- -19- extent to which constituent concentrations will be altered by the sorption and subsequent desorption? ./ 5. Attenuation or Retardation by Means other than Sorption. Are any mechanisms other than sorption signficant enough and predictable enough to be evaluated in predicting attenuation of constituents? How reversible are these mechansims? 6. Simplified approaches. Where knowledge of the leachate quality entering the ground water is highly uncertain, what simplified approaches can be used to characterize plume migration? (i) Can particular constituents known to be prominent constituents in the leachate be selected for analysis as representative of all constituents? (For example, select one or two metals, organic acids, organic bases, neutral polar organics and neutral non-polar organics.) What factors would one apply to determine representativeness? Chemical structure? Mobility? Toxicity? Concentration in the leachate? (ii) Rather than select representatives constituents, could "worst-case" (i.e., highly mobile) constituents be selected to determine the maximum mobility of all constituents? Going one step further, is it reasonable, in light of data and modeling difficulties, not to consider attenuation and degradation and only consider dispersion? 7. Summary Is prediction of the concentration of constituents at various locations in the ground water possible and, if so, with what degree of accuracy? Is the answer dependent on a detailed knowledge' ------- -20- of leachate quality? Can qualitative predictions suffice for some situations? Can worst-case analyses be used to assure acceptability of faculties? Is there an adequate supply of trained professionals to make these predictions and to evaluate them? If not/ how much time is needed to develop the supply through education* and training? ------- -21- May 21, 1981 III. Gas Generation and Migration; Rates of Emissions; Control Practices; and Dispersion Modeling v This session is Divided into several topics related to the movement of gases and vapors in and out of land disposal facilities. As in the previous sessions on leachate and ground-water migration, we will examine how confidently a permit writer could, given the current state of the art/ predict the generation, movement and release of constituents to points of human and environmental exposure. This examination will include monitoring techniques, predictive techniques, the type, amount and cost of data needed for predictions, and the availability of the expertise required to produce and evaluate data and predictions. The discussion is divided into several subtopics. First is a discussion of gas generation and migration within and out of landfills and of the available techniques to control these factors. Second is the volatilization of constituents from leachate into i buildings. Third is emission rates of volatile organic compounds from surface impoundments into the atmosphere. - Fourth is dispersion modeling of emitted compounds. A. Gas Generation and Migration 1. With what degree of confidence can one predict the constituents that will be generated as gases and the concentrations at which they will occur in landfills? Can conservative estimates of maximum or minimum concentrations be developed? a. Have models been developed to predict the generation ^- of gases? What type and amount of data is generally required to ------- -22- » be input into these models? What assumptions are generally made in applying these models? (i) Have any of these models been used to predict ( the generation of gases other than methane, carbon dioxide and hydrogen? Have any been used to predict specific organic compounds?, , (ii) To what extent have any of the existing models been subject to field verification? For what compounds have they been field-tested? How well do the predicted and measured values i correlate? b. Which types of constituents are most likely to appear as gases in the leachate or subsurface soils? Can a screening i mechanism (e.g./ waste analysis) be used to determine whether significant production of gases may occur? c. How does codisposal of wastes affect one's ability i to predict the constituents that will be generated in gaseous form? d. How likely is it that substantial amounts of gas would be generated in a landfill that does not accept municipal waste (e.g., food and paper wastes) or liquids? What are the zypes of wastes or compounds most likely to generate gases in such a landfill? 2. With what degree of confidence can the migration of gases j within and out of a land disposal facility be predicted? At what cos.t'' a. How well can one predict the paths in which gases *• will travel? Which of these paths are most or least significant? Consider the following: (i) Gases moving with leachate in the. subsurface soil or unsaturated zone (ii) Gases dissolved in ground water ------- -23- (iii) Gases moving with, but not dissolved in, water _/• (iv) Gases migrating independently of water movement b. How significant is diffusion in predicting gas movement? How well can this factor be determined? c. How significant is pressure gradient in the soil in predicting gas migration? (i) What are the major factors governing pressure gradient? Hew are these factors likely to vary over the life of the facility? (ii) Does pressure gradient affect soluble and non- soluble constituents to the same degree? d. Have any models been developed to predict the direction and rate of flow of gases in land disposal facilities? Which of these have been field-tested? With what results? 3. What type and amount of data is needed to accurately characterize gas migration at an existing site? What is the range of sampling error in measuring emissions at any particular point? 4. How significant a factor is degradation of gases by chemical reaction, biodegradation, photolysis (if near or at the ground surface) or other means? Can any of these means of degradation be ignored without signficantly impairing predictions of ga-s concentrations ultimately released from the ground surface? 5. How significant is sorption in attenuating concentrations s~ of gases in the soil and in the unsaturatec and saturated zones? How confidently can one predict the extent to which particular ------- -24- gaseous constituents will be sorbed or subsequently cesorbed? What are the major factors in making such a prediction? 6. With what confidence can one predict the average or maximum rate at which gases will migrate through synthetic membranes, compacted clay liners,or relatively permeable soil? What are the most significant factors in making such predictions? 7. Are closed surface impoundments in which sludges or liquids have been left in place capable of generating significant quantities of gas? 8. For how many years after closure can gas generation and migration remain a potential problem at a facility? Would it be reasonable to allow buildings to be built on or near the closed site after a certain specified number of years have passed? Can this number be determined in advance, or must it be solely determined subsequently through gas monitoring? 3. Controls for Generated Gas What means are available to control the migration of gas from landfills? What are the most probable failures of these means? 1. Liners. To what extent can relatively impermeable caps and side liners reduce the rate of migration of gas from landfills? 2. Collection/Venting Systems. To what' extent can vents be used to control emissions or build-up of gases? a. Can vents interfere with liner systems that are designed to minimize the. infiltrations of liquids into the facility and the discharge of leachate from the facility? If so," what are the .*•- available tradeoffs between designing for leachate and gas control? b. Discuss the following options for handling collected gases and their costs. ------- -25- (i) Emission to the air (ii) Burning (iii) Sorption (iv) others c. How effective are vents absent pumping? Does this depend on gas characteristics? d. For how many years after closure of a landfill would such a system need to be operated before nearly all potential gases have been removed from the landfill? Do models exist to confidently address this question at a particular site? What degree of maintenance would be required during operation of the system? (Consider both systems with pumping and those without pumping.) 3* Barriers How effective are barriers in preventing passage of gas to particular locations of concern? For how long a period of time can they be relied upon to remain effective? Consider different types of geology. 4. Reclamation. Can gases be economically recovered for use as an energy source from a landfill that contains only chemical wastes or that contains a mixture of sanitary and chemical wastes? C. Emissions from Surface Impoundments 1. Eow significant are surface impoundments as sources of emissions? What is the range of daily or annual emissions (measured by total organic carbon, for example), considering different sizes of impoundments and variations in climatic temperatures? s~ 2. What is the range of sampling error in measuring TOC at a particular site? What is the error in measuring specific organic compounds? ------- t -26- 3. In attempting to develop appropriate emission factors to characterize existing surface impoundments, what are appropriate < methods for sampling? What is the cost of each sampling method? -, Are the necessary equipment and skilled technicians currently available a. At what locations (both vertical and horizontal) _. ' should sampling be conducted? b. How does the size of the impoundment affect the answer to this question? ' c. How many samples are needed? Does the answer depend upon meterological conditions? 4. For new surface impoundments, what confidence can one have in predictions of emission rates of various constituents from the impoundment? - ( a. How critical are each of the following factors? (i) Solubility, Henry's law constant, and other physical properties of the volatile constituent < (ii) Temperature (iii) Wind (iv) Solar mixing i (v) Peed ratios and methods :>- (vi) Properties of the waste as a whole (vii) Aeration of impounded wastes b. Have models been developed for emission rate predictions? Have they been field-tested? How well do the predicted and actual measured results correlate? ,'~ ( c. Can a worst-case assumption or model be used to predict with a high degree of confidence that emission rates for ' various constituents will not exceed specified maxima? i ------- -27- 5. Can emission rates for particular compounds in existing or new impoundments be estimated by performing mass balances for ./• the compounds by analyzing the liquid and solid waste streams? For example, could one analyze the influent, effluent and sludge at an activated sludge facility, including analysis for potential daughter compounds of the compounds of interest? 6. What management techniques are currently available to control the rate of emissions? Consider both pre-treatment (e.g., stripping prior to placing in impoundment) and in-place methods. a. What are the costs of these methods? b. To what extent, if any, do these methods interfere with the purpose of impoundments? For example, are any of them incompatible with impoundments used for aerobic decomposition? 7. Are there certain types of impounded wates which clearly result in very little air emissions and do not require any emissions analysis? D. Dispersion Modeling 1. How well can one predict average annual concentrations of constituents.in the vicinity of a land disposal facility, assuming that emission rates from the facility are known? a. If one considers a land disposal facility as a point source, do adequate models exist to predict the facility's impact upon ambient concentrations ox total volatile organic compounds? What are the major difficulties with such models? In what types of situations have they been used successfully, and with what degree of accuracy? /" How much data is needed, and at what cost, to apply these models? ------- -23- b. Answer, for specific volatile organic compounds (e.g., specific solvents), the same questions as raised in the preceding question. c. Must different models be used for aerosols, gases and particles? d. Can concentrations near a facility of several or more acres be predicted by the use of a model which has been designed for point sources? Hew much more reliable does such a model become as one increases distance from the facility? 2. Can short-term concentrations (e.g., daily or weekly) of either total VOC or specific organic compounds be predicted if necessary to assess acute effects? What degree of error is introduced by such factors as wind and temperature variations? Hew much data, and at what cost, must be collected to account for these -factors? 3. Can a screening model be used to confidently predict maximum annual or short-term concentrations? 4. How significant is the problem of toxic by-products that- are created by photochemicals? Can the by-products affect local concentrations at significant levels or only broader ambient concentrations at low levels? What is the state of the art for considering photoconversion? ------- -29- May 22, 1981 IV. Health Effects Resulting from Exposures to Hazardous Wastes Disposed on or in the Land In the previous-panel discussions, we have examined techniques for controlling and predicting the migration of waste constituents, including their .reaction products and decomposition by-products, out of a land disposal facility into the ground water, surface water, subsurface soil and air. In this session, we assume that the concentrations of constituents in various media, at various times, and at various locations are known. We will examine the various types of risks that may be presented to human health and the available means to estimate the magnitude of those risks. The central question in this discussion is: How may a typical permit writer proceed to evaluate the potential health effects posed by an existing or proposed land disposal facility? We • will briefly review basic methodology for assessing effects. We will also try to identify existing regulatory standards and suggestive criteria which may be used as guidance, consider feasible approaches where no such standards or criteria exist, and identify the range of uncertainty and the means of compensating for that uncertainty. A. Toxic Effects (Acute and Chronic) to Humans- 1. What are the most reliable and readily usable methodologies and techniques for predicting acute effects that may result from human exposures to toxic compounds? With what degree of confidence can these methodologies and techniques be- used? ,*- a.(i) What are the appropriate techniques for using animal toxicity data to determine, in animals, a. NOEL (no-observed- ------- -30- ( effecu-level), NCAEL (no-observed-adverse-effect-level), LOEL (lowest- observed-effeet-level), LOAEL (lowest-observed-adverse-effect-levei ; and PEL (frank-effect-level)? How does one distinguish between < an "effect" and an "adverse effect"? (ii) What are the most reliable published sources for determining these levels (e.g., NIOSH Registry of Toxic __ ( Effects of Chemical Substances; Sax, Dangerous Properties of Industrie Materials) and how reliable is the information they contain for use in either setting regulatory standards or judging the acceptability ( of particular facilities? b.(i) What are the appropriate techniques for using animal toxicity data to determine, in animals, an LDjQ (dose causing lethality in 50% of test animals), or LC5Q (concentration causing lethality in 50% of test animals)? ( (ii) What are the most reliable published sources for determining these levels (e.g. NIOSH Registry; Sax) and how reliable is the information that they contain? < c.(i) Can NOELs, NOAELs, LOELs, LOAELs, and FELs be used to determine the risk of mortality to humans from exposure to a particular level? Is it possible to define risk in such terms as i "10-5 risk of lethal effect from inhaling concentration continuously;*? (1) If so, how is such a risk determined? What published * •" sources, if any, provide this sort of estimated risk? (2) If not, is it possible to predict risk at all or is one forced to assure safety by seeking to limit permissible levels to, e.g., below the NOAEL? ------- -31- (ii) Can LD5Q or LCjQ be used to determine the risk of mortality to humans from exposure to a particular level? Consider _s the same issues as in the previous question. (iii) Can any animal toxicity data or other means be used to predict the risk of morbidity to humans from exposure to a particular level? Do any means exist to quantify these risks? Consider the same issues as in question (i). (iv) Does human epidemiological data exist on morbidity due to various compounds? d. What are appropriate techniques to account for the bioaccumulation potential of a compound in assessing chronic toxicity effects? Can bioconcentration factors for fish be extrapolated to humans? e. What are appropriate means to account for uncertainty in extrapolating animal daca to man? Should uncertainty factors be * used? If so, how large should they be? f. How can the more sensitive segments of the population (e.g., infants, old people, people with certain types of health problems or high background exposures) be protected? g. To what extent can data developed for one exposure route (e.g., inhalation) be used to predict effects caused by exposure through a different route (e.g., ingestion)? What type and amount of comparative uptake data is required? h. How significant are synergistic or antagonistic effects? Does the present state of the art enable any reasonable estimate s~ of these effects? Where a waste or leachate from a waste is available, can an animal study be performed on the waste or ------- -32- Isachats to give an overall picture of the toxicity? 2. Can threshhold limit values (TLVs) published by the , American Conference of Governmental and Industrial Hygienists (ACGIH), National Institute for Occupational Safety and Health h (NICSH) or Occupational Safety and Health Administration (OSHA) < be used to predict human health effects or select safe levels? a. How are TLVs determined? b. Can simple equations be used to transform TLVs (based on i work-week exposure) to potential full-time exposures? c. Since TLVs are designed to protect healthy, working people, how can they be adjusted to protect sensitive populations ( exposed to waste-site emissions? d. Can TLVs be used only to protect against inhalation - induced effects? How much information would be required concerning " { absorption efficiency and metabolic pathways before one could use TLVs to predict, e.g., ingestion - induced effects? 3. Can EPA's water quality criteria for toxic pollutants (a summary of which was published on November 23, 1980, in 45 FR 79318] be used to evaluate risks of toxicity or to establish safe levels i with respect to ground water? What calculations or manipulations . . would be needed to adjust the criteria (which are set for surface water quality and assume a certain level of fish consumption by • '" i people) for use as ground-water criteria? How much information is needed to correctly make these adjustments? 4. Do any other criteria or standards^-exist that may be useable by permit writers in protecting against risks of toxicity from hazardous waste land disposal facilities? ------- -33- 5. Is it technically possible to develop EPA criteria or standards to protect .against risks of toxicity from hazardous waste land disposal facilities? What approach should be used? How long would such an effort take for each compound studied? Would any assumptions need to be made about background concentra- tions? 6. If no standards or usable quantitative criteria are available to the permit writer, what approach may be used to evaluate risk? a. If a permit applicant were required to conduct studies, what types of -studies would be appropriate? How much quality control would be required? How long would such -studies take, and what would they cost? b. Is there any way to use a qualitative approach, other than totally subjective judgment by the permit writer, to determine whether a site is acceptable or unacceptable without quantifying the effects of toxicity from all compounds or preventing all exposures? B. Carcinogenic Effects 1. What are the most reliable and readily available methodologies and techniques for predicting carcinogenic effects that may result from human exposures to, compounds? With what degree of confidence can these techniques be applied? a. To what extent can short-term (including mutagenicity) studies be relied upon to identify carcinogens? To what extent can they be used to quantify the carcinogenic risks from particular carcinocens? ------- -34- b. What is the range of uncertainty in quantitatively predicting risk of human cancer based upon animal studies? i Consider the following sources of uncertainty: (i) Estimating the carcinogenic potential at high doses (ii) Extrapolating high doses to low doses. i (a) Which models (linear one-hit; linear multistage;" threshold) are most consistent with the available data? (b) Which models are the most conservative in terms i of protecting human health? Which are the least conservative? (c) What is the potential variability among the various non-threshold models in predicting effects at low doses? (iii) Extrapolation of animal studies to humans, in light of different metabolic pathways. Can this be confidently done if several varieties of animal species are used? ( c. Can evidence of carcinogenic risk through one route of exposure b'e issued to predict the risk through a different exposure route? ( d. What are the appropriate techniques for resolving uncertainty? (Consider, e.g., statistical confidence intervals and safety factors) i 2. What regulatory standards, criteria or guidances have • been published in a form that may be used by a permit writer to assess the potential carcinogenic effects of exposure to waste < constituents from a hazardous waste land disposal facility? (Consider the effect of non-he^alth criteria used in part to help develop some j~ of these standards.) * ------- -35- a. Consider, e.g., the following: (i) Surface water quality criteria for toxic pollutants under the Clean Water Act (ii) Drinking Water Standards (NIPDWS) under the Safe Drinking Water Act (iii) National emissions standards for hazardous air pollutants under the Clean Air Act (iv) Criteria and regulations by the Occupational Safety and Health Administration (v) Criteria and regulations by the Consumer Product Safety Commission (vi) Criteria and regulations by the Food and Drug Administration b. For what routes of exposure are these standards and criteria usable? c. To what extent do the sources listed in Question (a) conflict? What assumptions or differences in techniques lead to the conflicts? d. When any of the above standards or criteria are not directly usable, can they be readily modified by changing certain assumptions (e.g., routes and times of exposure) and recalculating the values for purposes of assessing risks from hazardous waste land disposal facilities? 3. Where published standards or criteria are unavailable for a particular compound believed to be significant at a waste disposal site, how readily can appropriate risk values be selected based on ------- -36- the techniques discussed in Question 1? How much time is needed? What is a typical cost? 4. Can synergistic or antagonistic effects of different corapourv; in a waste be accounted for? Can experiments on a whole waste (or v leachate or emissions) be performed to assess its toxicity? 5. Can the risks-presented by carcinogens to identified sensitive portions of the population be separately estimated or compensated for? C. Reproductive Effects 1. With what confidence can mutagenic effects be predicted? How do -mutagenic risks from particular compounds compare to the carcinogenic risks? 2. What types of effects are most likely to occur as the result of mutagencity, based on present studies? 3. What potential is there for a particular population's long-term (e.g., several generations) exposure to mutagenic compounds to develop adverse effects? To what extent will the effects multiply over time? 4. Can teratogenic effects be predicted with any confidence? What types of effects are most likely? D. Exposures to Waste Constituents 1. How can future exposures to waste constituents placed in . .- the ground today be predicted? a. Based upon past trends, is it reasonable to assume that populations in any particular areas wi^.1 not decrease s~ substantially? ------- -37- b. Based upon past trends, is it reasonable to assume that any ground-water or surface-water resource currently used ./• for drinking or other purposes at least the same extent in the future, unless it is depleted? c. Where future land-use water-use projections are difficult to make, do techniques for predicting maximum exposures to waste constituents exist? ------- Appendix B List of Attendees ------- ------- NOTE ,f Since there was no pre-registration for this seminar, the list of attendees is based solely upon the information contained in the daily sign-up sheets that were available at the registration desk. In many cases, individuals who attended more than one session,only signed up for the first session they attended. Consequently, the list of attendees as presented here is not complete for each day. Moreover, in some cases the handwriting on the sign-up sheet was illegible, abbreviations were used for the affiliation, and the addresses were incomplete. No attempt was made to overcome these limitations and the listing that follows reflects exclusively the information on the sign-up sheets. ------- May 18, 1981 Name Kant Anderson Tom Aspitarte Jim Bachmaier Ralph Basinski Donna Berry Susan Broom Paul Cassidy Len Caarca Rob Clemens Irish Cooper Arthur Day Paul R. dePercin Gary Dietrich Hike Duo-kin Richard W. Eldredge Mark Evans Mike Flynn David Friedman Kevin Garrahan Benjamin C. Garrect Allen G«swein Mark. Greenwood Bob Griffin Ed Hall Bob Ham Rick Holberger Kay Holub Dick Janowiecki Charles Johnson John Keller Gregory Kev Todd KissBell Barry Kerb Affiliation EPA Crown Zeller Bach EPA/OSW J & L Steel U.S. EPA U.S. EPA EPA/OSW GM Legal Staff EPA, OHWE U.S. EPA U.S. EPA U.S. EPA U.S. EPA U.S. EPA Eldredge Bag. Asso. U.S. EPA EPA/OSW EPA/OSW EPA/OSW Battelle Columbus Laboratories U.S. EPA U.S. EPA II. State Geological Survey UCC University Vis. MUSE Corp. SPA/Eaforcement Monsanto HSWMA NR2C Exp. Assess Gp. EPA EPA/OSW U.S. EPA Address 401 M St., S.W. Washington, D.C. WH-564 CA MAS, Washington, D.C. 401 M St., S.W. Washington, D.C. WH-564 900 Agnev Rd., Pittsburgh, PA 15227 401 M St., S.W. Washington, D.C. KM-220 401 M St., S.W. Washington, D.C. HH-564 401 M St., S.W. Washington, D.C. WH-564 3044 W Grand Blvd., Detroit, MI 43202 401 N St., S.W. Washington, D.C. EN-340 Room 222 401 M St., S.W. Washington, D.C. lERL-Ci, Cincinnati, OH 45268 401 M St., S.W. Washington, D.C. 2625 Butterfield Rd., Oak Brook, ? 401 M St., S.W. Washington, D.C. WH-654 401 M St., S.W. Washington, D.C. WH-564 401 M St., S.W. Washington, D.C. WH-565 401 M St., S.W. Washington, D.C. WH-564 Columbus, OH 43201 401 M St., S.W. Washington, D.C. WE-564 401 M St., S.W. Washington, D.C. 615 E. Peabody, Champaign, It 61820 South Charleston, WV 3232 Engineering Bldg. Madison, WI 53705 1820 Dolley Madison Blvd., McLean, VA 1515 Nicholas, Dayton, OH 1120 Connecticut Ave., N.W. Wash., D.C. 1725 I St., H.W. Washington, D.C. RD-689, EPA Hqs. Washington, D.C. 20460 401 M St., S.W. Washington, D.C. WH-565 1120 Connecticut Ave., K.W. Room 222 ------- Name Affiliation Address Joseph Thornton U.S. Ecology 9200 Shelbyville Sd., Louisville, SET 40222 Jim Tripp EDF 444 Park Ave., S. New Tork, NT 10018 Peter Vardy Waste Mgmt. Inc. 900 Jorie Blvd., Oak Brook, IL 60515 Dov Weitsian EPA/OGC 401 M St., S.W. Washington, D.C. 20460 Jim Williams Missouri Dept. P.O. Box 250, Rolla, MO Kat'l. Resources ------- Name Affiliation Address David Lennett Michelle Love Bruce Lundy Don McClenahan Richard A. Meserve Amir Mecry Michael Miller Hugh Mullen Sam Napolicon Les Otte Philip A. Palmer Dale E. Papajcik Suellen Pirages iCen Poet Pacer Querrero Jacqueline M. Rama Chris Rhyne Cliff Rothenstein Mike Roulier Reva Rubenscein Eldon Rucker Tim Savior John Segna Edward R. Shuater Ken Shuster Barbara Simeo« J.W. Spear Sc. Anthony A. Sptoda Robert A. Stadalmarer 3.3. Taylor William E. Thacker EDF Wald, Harkrader & Ross 0.S. EPA CTM, Inc. Covington & Burling Weacoa 3FI rues a.s. EPA (J.S. EPA DuPont Republic Steel Congressional Off. Tech. Asst. ?H3 EPA/OSW ASTSWMO EPA/OSW EPA/OSW tJSEPA—Cincinnati SHWBD/MEBL HSWMA Amarican Petroleum Inst. Hammermill Paper Co. EPA/OURS CZCOS International EPA/OSW ASTSWHO SEXTON TOS Corp. CECOS lat'l Inc. EPA NCASI 1525 13th St., N.W. 1300 19th St., S.W. 401 S St., S.W. Washington, D.C. EN-340 900 Josie Blvd., Oak Brook, IL 388 16th St., N.W. Washington, D.C. Roy F. Weston, Westchester, PA 19380 P.O. Box 3151, Houston, TX Horsham, ?A 401 M St., S.W. Washington, D.C. 401 M St., S.W. Washington, D.C. '..11-364 Eng. Dept L1378 - Wilmington RI 19898 1000 Prospect Ave., Cleveland, OH Washington, D.C. 20510 2828 Pennsylvania Ave., Washington, D.C. 401 M St., S.W. Washington, D.C. WH-562 444 S. Capitol St., S.W. Washington, D.C. 401 M St., S.W. Washington, D.C. 401 M St., S.W. Washington, D.C. WH-562 26 W. St. Clair St. Cinncinatti, OH 45263 1120 Connecticut Ave., NW Washington,D.C. 2101 L St. Washington, D.C. PO 1440, Erie, PA 16533 P.O. Box 619, Niagara Falls, -TT 14302 401 M SC., S.W. Washington, D.C. WH-564 444 ti. Capitol St., Washington, D.C. 1814 S. Wolf Rd., Hillside, U. 60162 600 Grant St., Pittsburgh, PA 15230 P.O. Box 619, Niagara Falls, NT 14302 201 I St., S.W. Washington, D.C. "520"' Western Michigan University Kalamazoo, MI 49008 ------- ame Affiliation Address David Lennett Bruce Lundy Don McClenahan Richard A. Meserve Amir Metry Michael Miller Norman Mines Hugh Mullen Sam Xapoliton Las Octe Philip A. Palmer Dale E. Papajcik Jon Perry Suellen Pirages Pecer Querrero Marc Rogoff Mike Roulier Paul R.OUX Reva Rubens cein Tim Saylor E.R. Shuster Ken Shuscer Peter Skinner J.W. Spear Anthony A. Spinola Scan Spracker Richard Spri&ce R.A. SCadelman Barry Scoll Robert B. Taylor EOF U.S. EPA/OHWE CWM, Inc. Covlnton & Burling Roy ?. West on BFI MITRE I0CS U.S. EPA U.S. EPA/OSW E.I. DuPont Republic Steel U.S. EPA/OSW OTA-Congress U.S. EPA/OSW MITSE EPA/MERL Cincinnati CMA (Stauffer) NSWMA Haamermill Paper CO. CECOS U.S. EPA/OSQ NTS. Att. General SEXTON U.S. Steel Corp. Wald, Ear trader & Ross Tracor, lac. CECOS, Inc'l. U.S. EPA/OSW U.S. EPA 1525 18th St., N.W. Washington, D.C. Etf-335 Washington, D.C. 20460 Oak Brook, IL 888 16th St., N.W. Washington, D.C. West Chester, PA 19380 Houston, TX 1S20 Dolley Madison Blvd., McLean, 7A Horsham, PA 401 M St., S.W. Washington, D.C. WH-564 Washington, D.C. 20A60 Engr. Dept. L1378, Wilmington, DE 19898 25 W. Prospect Ave., Cleveland, OH 44115 Washington, D.C. 20460 Washington, D.C. 20510 WH-562 Washington, D.C. 1820 Dolley Madison Blvd. , McLean, VA Cincinnati, OH 45268 Westport, CT. 1120 Connecticut Ave., Washington, D.C. P.O. Box 1440, Erie, PA. 16533 Niagara Falls, JTT 14302 401 M St., S.W. Washington, D.C. Justice Bldg. The Capitol, Albany, ST 12196 1815 S. Wolf Rd., Hillside, IL 60162 600 Grant St., Pittsburgh, PA 15230 Washington, D.C. 1601 Research Blvd., Rockville, MD 20850 Hiagara Falls, NT. 14107 Washington, D.C. 20460 EN-335 Washington, D.C. 20460 ------- May 19, 1981 Name Tom Aspicarte Salph Basinski Donna Berry Dave Slounc Susan Bromai Paul Gassidy Leonard F. Charla Rob Clemans Steve Cordle Arthur Day Paul defercin R.W. Eldredge David M. Erickson Mark L. Evaas David Friedman Allen Geswein Mark Greenwood M.E. Hall 3ob Ham Douglas G. Hayman Rick Holberger Say Holmes Bruce Hunter Seong T. Hwang Andrew Jackson Dick Janowiecki John Keller Gregory Sew Todd Carol Affiliation Crown Zellerbach JiL Sceel EPA EPA (OWE&P) EOA/OSW EPA/OWS SSI Legal Staff U.S. EPA/OHWE EPA/ORD/OEPER EPA/OSV U.S. EPA IESL EEA, Inc. EPA/OPE U.S. EPA- Land Disposal Div. U.S. EPA/OSW U.S. EPA/OSW 0.3. EPA Union Carbide Corp. University of WI. Fuller, Henry, Hedge & Snyder MITBE EE.CO ERGO U.S. EPA a.S EPA/OHWE Monsanto SRDC EPA/OKD/Zxp. Asacaa. Gp EPA/OSW/HIWD MITRE Address Camas, VA2M. 900 Agnew Eld., Pittsburgh, PA 15227 Washington, D.C. EN-336 Washington, D.C. 20406 WH-564 401 M St., S.W. Washington, D.C. 3044 W. Grand Blvd., Detroit Ml. 43202 EN-335 Washington, D.C. 401 M St., S.W. Washington, D.C. 401 M St., S.W. Washington, O.C. Cincinnati, OH. 45263 Oak. Brook, IL 401 M St., S.W. Washington, D.C. Washington, D.C_. Washington, D.C. 20460 Washington, D.C. 20460 401 M St., S.W. Washington, D.C. P.O. Box 8361, S. Charleston, W 25177 Madison, WI P.O. Box 2038, Toledo, OH 43603 1820 Dolley Madison Blvd., McLean, VA Boston Boston Washington, D.C. 401 H St., S.W. Washington, O.C. 1515 Nicholas, Dayton, OH 45407 1725 I St., N.W. Washington, D.C. SD-639 Washington, D.C. WS-565 Washington, D.C. 20460 1820 Dolley Madison Blvd., McLean, 7A ------- May 20, 1981 flame Jim Bachmaier Frank Barber Ralph Basinski Donna Berry Mary Bishop Susan Bronm Paul Caasidy Leonard F. Charla Bob Clemens Steve Cordle Arthur Day Paul dePercis George Dixon Patrick. Domenico Richard Eldredge Carl Enfield Mark Evans Janes J. Geraghty Claire Goal man Douglas G. Haynan J.W. Hirry Rick Holberger Dick Janowiecki John Keller Gregory Kev Leonard Konikov Barry Sorb John D. Koutsanders Affiliation U.S. EPA/OSW U.S. EPA/OE/OHBE/ REU J&L Steel U.S. EPA API (lnc'1. Paper) U.S. EPA/OSW U.S. EPA/OSW GM Legal Staff U.S. EPA/OHWE U.S. EPA/ORD U.S. EPA/OSW U.S. EPA/IESL U.S. EPA Univ. of Illinois EEA U.S. EPA, RSKEBL U.S. EPA/OSW/LDD Geragfaty & Miller, Inc. EPA/OE/OWEP/DHSEB Fuller, Henry, Hodge & Snydar U.S. EPA MURE Monsanto NRDC EPA/ORD/Exp. Assess. Gp. uses EPA/OPE EPA/ORD Address 401 M St., S.W. Washington, D.C. ES-338 900 Agnev Rd., Pittsburgh, ?A 15227 401 M St., S.W. Washington, D.C. 77 West 45th St. OH-564 401 M St., S.W. Washington, D.C. 3044 W Grand Blvd., Detroit, MI 48202 EN-335 401 M St., S.W., Washington, D.C. RD-682 401 M St., S.W. Washington, D.C. Cincinnati, OH 45268 401 M St., S.W. Washington, D.C. Urbana, XL 2625 Batterdiald Rd., Oak Brook, XL P.O. Box 1198, Ada, OK 74820 401 M St., S.W. Washington, D.C. Annapolis, MD EN-338 P.O. Box 2088, Toledo, OH 43603 401 M St., S.W. Washington, D.C. 1820 Dolley Madison Blvd., McLean, VA 1515 Nicholas Rd., Dayton, OH 45407 1725 I St., N.W. Washington, D.C. Has. RD-689, Washington, D.C. 431 Nat'l. Center, Rescon, 7A 22092 Ba 222 RD-680 ------- Name William E. Thacker Joe Thornton Peter Vardy Bumell W. Vincent Dov Wei nan Linda Wilbur Jim Williams Affiliation HCASI U.S. Ecology Waste ttgmt. Inc. U.S. EPA O.S. EPA/OGC a.s. EPA/OWRS Missouri Geological 4 Land Survey Address Western Mich. Univ., Kalamazoo, MI. 49008 9200 Shelbyvllle Rd., Louisville, KY 40222 900 Joria Blvd., Oak 3rook, IL . 60521 Washington, D.C. 401 M St., S.W. Washington, D.C. Washington, D.C. P.O. Box 250, Rolla, MO 65401 ------- Name Affiliation Address Dov Weitman EPA/OGC Washington, D.C. Linda Wilbur U.S. EPA Washington, D.C. James H. Williams Missouri Div. Geol. P.O. Box 250, Rolle MO 65401 & Land Survey Eric Wood Princeton Dept. Civil Eng'g., Princeton University, Princeton, NJ 08544 3..L. Wormell U.S. EPA. 401 M St., S.W. Washington, D.C. ------- Maae Affiliation Address Carol Kuhlman David Lennett Bruce Lundry Don McClenahan 3.. A. Meserve Michael Miller Hugh Mullen Sam Mapolitan Dale E. Papajcki Suellen Pirages XaryAnn Pocock Paul S. Price Peter Querrero Paul Roberts Marc Jogoff Paul Xoux Reva Rubenstein Mark Segal Thomas T. 5hen . , Edward R. Shuster Ken Shuster P. Skinner J.W. Spear Anthony A. Spinola Scoec 0. Springer Barry Scoll Robert 3. Taylor William Thacker Joe Thornton Surnell W. Vincent MITRE EOF EPA/OHWE Chem. Waste Mamt Covinton & Bulny BFI rocs EPA/OPE Republic Steel Material Prog. Cong. Off Tech. Assess. OPE EPA/OPTS EPA/OSW Stanford b'niv. MITSE Stauffer HSWtA U.S. EPA NT State DEC CECOS OSW/EPA NTS Att. &en. SECTON U.S. Steel EPA/OSW/LDD EPA/OSW O.S. EPA NCASI U.S. Ecology OSW 1820 Dolley Madison Blvd., McLean, 7A 1525 18th St., N.W. Washington, D.C. EN-335 Washington, D.C. Oak Brook, H. 388 16th St., S.W. Washington, D.C. P.O. Box 3151, Houston, TX 77001 115 Girraltar Rd., Horsham, PA 19044 401 M St., 5.W. Washington, D.C. 25 W. Prospect Ave., Cleveland, OH 44115 Washington, D.C. 2828 Pennsylvanie Ave. , 401 M St., S.W. Washington, D.C. WH-562 Dept. of Civil Eng'g., Tarsian Sng'g. Center, Stanford Univ. Stanford, GA 94305 1820 Dolley Madison Blvd., McLean, VA Westport, CT. 06881 1120 Connecticut Ave. Washington, D.C. 401 M St., Washington, D.C. 50 Wolf Sd., Albany, Mt Niagara Falls, M7 401 M St., S.W. Washington, D.C. Justice Bldg., Albany, NT 12224 1815 S. Wolf M., Hillside, IL 600 Grant St., Pittsburgh, PA 15230 wa-564 WH-564 Washington, D.C. 201 I St., S.W. #520, Washington, D.C. Western Mich. Univ., Kalanazoo, MI 49008 9200 Shelbyvill* 5d., Louisville, KT 401 M St., S.W. Washington, D.C. ------- Name Kent Anderson Alfred Angiola Jim Bachmaier Ellen Barrett Donna Berry Mary Bishop Dave Blount Susan Broom Sue Suggum Kathleen M. Burke- ?aul Cassidy Larry Claxton Steve Cordle Arthur Day Charles Delos Paul dePercin George Dixon Michael Dworkin Aon Fisher Richard C. Fortan Ralph Freudenthal Lisa Friedman &evin Garrahan Al Geswe a Iris Goodman Peter Guerrero John Harris Stuart Haus Toue Hewitt Joe Highland Affiliation WAPORA EPA/OSW EPA/OTS EPA laternat'l. Paper EPA 0.S. EPA W*ld, Harkroderi Boss EPA EPA/OSW EPA EPA/OHD EPA EPA/OWRS EPA/IEHL EPA EPA/oec/wasw EPA Hoere SC Transp. & Commerce Stauffer Chan Co. EPA/OGC EPA/OSM OTA EPA EPA/AD-tqDB MTISE EPA EOF 211 E 43, N.T., N.Y. 10017 401 M St., S.W. Washington, D.C. WH-564 ET 329 (TS 798) 401 M St'., S.K. Washington, D.C. PM-220 72 W 45th St., N.Y., H.T. 401 M St., S.W. Washington, 3.C. EN-336 401 M St., S.W. Washington, D.C. WH-564 1300 19th St., S.W. Washington, D.C. 401 M St., S.W. Washington, D.C. WH-564 MD-68, HEEL, RIP, N.C. 27711 401 M St., S.W. Washington, D.C. KD-682 Washington, D.C. 401 M St., S.W. Washington, D.C. WH-553 Cincinnati, Ohio 45268 401 M St., S.W. Washington, D.C. 401 M St., S.W. Washington, D.C. PM-220 225-1467 400 Farmington Ave., Farmington, CT 06032 Hdqtrs. 426-4497 401 M St., S.W. Washington, D.C. WH-564 401 M St., S.W. Washington, D.C. WH-562 401 M St., S.W. Washington, D.C. TS-278, Room 926, CM #2 Westgate Research Park, McLean, VA E537C Washington, D.C. 833-1484 ------- May 21, 1981 Ngge Alfred Angiola Jim Bachmaier David 3auer Donna Serry Mary Bishop Sue 3uggum Arthur Day ?aul de Fercia Michael Dworicia Paul 3.. Harrison Stuart Bans Douglas G. Eaynes Dick Janowiacici Gregory Kew David Lennett 3.. A. Meserve Xoraan H. Mines Las Otte Java Rubease*in Jerry M. Schroy £.&. Shuster Sea Shuster David a. Smith Robert 8. Taylor William E. Thacicar T.J. Thibodeaux Don Ucicnaa Unda Wllber Affiliation Address 211 £. 43rd Street, Sew Toric, M7 WAP08A, Inc. EPA IT Corporation 336 W. Aubern Street, Wilmington, CA EPA Washington, D.C. International Paper 77 W. 45th Street, Mew Torie, Tf Vald, Saritrodar SLoss EPA U.S. EPA, ISHL Engineering Science fflTBE "Ilia, Henry, Hodge i Sayden Monsanto SPA/ ORB EDF Covlngton & Burling MIT2E a.s. EPA/OSW Monsanto Co. CSCOS EPA/PSW IT Carp. SPA XCASI University of Arkansas EPA EPA 1300 19th Street, JI.W. , Washington, 3.C. Cincinnati, OH 45253 125 ». Huntington Dr., Arcadia, CA 91006 1320 Dolley Madison Blvd., McLean, TA P.O. 3ox 2088 1215 Nicholas Soad , Daycaa, OH -3407 SPA Hqs. Rd-639, Washington, D.C. 20460 Toledo, OH 43603 388 16th Street, M.W., Washington, D.C. 1320 Dolley Madison Blvd., XcLaan, 7A WH56A, Washington, D.C. 20460 300 S. Lindbergh Blvd., St. Louis, MO 53166 Xiagara Falls, JtT 401 H Street, S.W. , Washington, D.C. 20460 336 S. Ananiem Street, Wilmington, CA 90744 201 Street, S.W. , #523, Washington, D.C. Western Michigan University , KaXaaazoo, MI 49008 Department of Chemical Engineering Washington U.S. Environmental Protection Agency Region V, Library 230 South Dearborn Street Chicago, Illinois 60604 ------- Name Affiliacion Addraas Seong Hwong Dick Janowiecki Cace Jenkins Laurel 0. Kasaoka Tom Kally Gregory Kew Kathy Kohl Mike Koaakowski Carol Kuhlaan J. Lehman David Lannett Bruce Lundy Horaian H. Mines Bruce Mintz Chuck Morgan Ronald E. Ney, Jr. Sam "lapolitano tarry 0' Bryan Donald ft. Olson Chec Opacsky Laa Otte Suallen Pirages Chris Rhyne Marc J. SogofS leva Rubensteia Hark S«gul E.H.. Shuster San Shuscer David a. Smith Dick S prince Barry Stoll Bada Talboc Robert 3. Taylor Buroall Vincent Don V«itman EPA Monsa&to 2PA/OSW E?A/OSW EPA/PED E2A/OSD EPA EPA MIT22 EDF SPA MITSE EPA OHWE/OE EPA EPA OTS EPA EPA/HStD EPA/OSQ Materials Program Cong. Off. Tech, Assessment M1TBE HSSMA EPA/OTS CZCOS EPA/OSW IT Corporation T5ACOR E5A/OSW EPA/ORE/OHR EPA / EPA 1515 Nicholas M., Dayton, OH 45407 401 M St., S.W. Washington, D.C. WH-565 401 M St., S.W. Washington, D.C. KH-56A 407 W 755-0306 SPAHqs., 3D-6fi9, Washington, D.C. Washington, D.C. Hdqtrs. EN-335 Westgata Research ?ark, McLean, 7A 1525 13th St., S.W. 401 M St., S.W. Washington, D.C. 21-335 W«stgate Research Park, McLean, 7A 401 M St., S.W. Washington, D.C. WS-547 Hdqcrs. 426-6374 Washington , D.C. Hdqtrs. E613B 755-2110 OWE? ES-338 E714 755-1500 401 M St., S.W. Washington, D.C. WH-564 Washington, D.C. 20510 Westgace Research Park, McLaan, 7A 1120 Conn. Ava. , N.W. Washington, D.C. 755-4360 Niagara Falls, H.T. 401 M St., S.W. Washington, D.C. 336 W. Anaheim St., Wilmington, CA 90744 1601 Research Blvd., Sockviile, MD Washington, D.C. 20510 401 M St., S.W. Washington, Q.C. SD-633 201 I St., S.W. Washington, D C. "520" OGC ------- |