PB89-160006
   MIGRATION VARIANCES TO THE HAZARDOUS WASTE LAND  DISPOSAL PROHIlgiTIONS
  GUIDANCE MANUAL FOR PETITIONERS
U.S.  ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, B.C.
JAN 89
                  U.S. DEPARTMENT OF COMMERCE
                National Technical Information Service
                                NTIS

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•NO MIGRATION" VARIANCES TO THE HAZARDOUS WASTE
          LAND DISPOSAL PROHIBITIONS:
       A GUIDANCE MANUAL FOR PETITIONERS

                    DRAFT
             DO NOT CITE OR QUOTE
                 Prepared for

     U.S. ENVIRONMENTAL PROTECTION AGENCY
             OFFICE OF SOLID WASTE
               WASHINGTON, D.C.
          CONTRACT NUMBER 68-01-7310
                 Prepared by

               NUS CORPORATION
               910 CLOPPER ROAD
                 P.O. BOX 6032
       GAITHERSBURG, MARYLAND 20877-0962

                     and

      THE EARTH TECHNOLOGY CORPORATION
         300 NORTH WASHINGTON STREET
          ALEXANDRIA, VIRGINIA 22314
                JANUARY 1989

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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/530-SW-89-032
4. Title arid Subtitle
"NO MIGRATE" VARIANCES TO THE HAZARDOUS WASTE LAND DISPOS
A GUIDANCE MANUAL FOR PETITIONERS (DRAFT) (DO NOT CITE OR 01
•)
«_ PROHIBITIONS:
3. Recipient s Accession No.
PM9 160006/AS
5. Report Date
JANUARY 1969
JOTEJ i 6.
  7.  Author(s;
      OFFICE OF SOLID WASTE
8.  Performing  Organization Rept. No
66-01-7310
  9.  Performing Organization Name and Address

      NUS CORPORATION
      910 CLOPPER  ROAD
      PO BOX  6032
      6AITHERSBUR6,  HP 20S77-Q962	
10.  Project/Task/Work Unit  No.
11.  Contract(C) or Brant 16;  No.
(C)
(6) 66-01-7310
   12.   Sponsoring Organization Name and Address
      U.S.  EPA
      OFFICE OF SOLID WASTE
      401  M STREET.  Sw
      WASHINGTON. DC 20460
13.  Type of Report Si Period  Covered
DRAFT 6UID. MANUAL - 1/89
   15.   Supplementary Notes
   i&.   Abstract (Limit:  200 words;
     /
   A 'no migration1* variance is a formal decision that can be rendered by the EPA to allow the land disposal of specific,
   prohiDiteo  wastes not  meeting the treatment  standards estaolisned by EPA at a particular facility.
   In 1966.  Congress passeo the RCRA authorizing EPA to establish nationwice standards for the management of hazaraous
   wastes.   Under HSwA, RCRA Sections 3004id),  (e),  and (g)  were to include provisions prohibiting the land disposal of all
   sucn "listen* and 'characteristically hazardous'  wastes unless they are first treated.  Wastes includeo in the EPA's
   land disposal prohibitions will  have to be treated by best demonstrated technology to aeet the treatment standard estab-
   lished bv EFA, unless  & ''no migration* variance is obtained.   Prohibited wastes cannot be stored on the land (unless.
   17.   Document Analysis   a.   Descriptors
       b.   Identifiers/Open-Ended  Teras
       c.   COSATI  Field/Group
18. Availability Statement
RELEASE UNLIMITED
19. Security Class (This Report)
UNCLASSIFIED
20. Security Class (This Page)
UNCLASSIFIED
(See ANSI-Z39.18) ~~ OPT
(For
21. No. of Pages
(04
22. Price
0
ONAL FORM 272 (4-77)
terly NTIS-35)

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                             Table of Contents
What is a "No Migration" Variance?                              1
What are the Land Disposal Prohibitions?                         1
Additional Requirements of the Land Disposal Restrictions
First Third Rule                                                3
     Compliance with Other Applicable Laws                     3
     Monitoring Plans for Land Disposal Units                     3
     Reporting of Changes in Operating Conditions From
     Those Described in the Variance Application                  3
     Detection of Migration  of Hazardous Constituents             3
Who Can Receive a "No Migration" Variance?                     4
What is the Definition of the  "Unit Boundary?"                    5
                              *
How are Levels of Constituents Evaluated?                        6
How Long is "As Long As the  Wastes Remain Hazardous?"           7
What is the Relationship Between Land Treatment
Units and "No Migration"?                                     8
What is the Relation Between "No Migration" Variances,
RCRA Permits, and Other Federal Laws?                           9
Can Generic Petitions be Submitted Covering Several
Similar Facilities?                                              10
When Does a Variance Become Effective and How Long
Does it Last?                                                  10
What is the Petition Procedure for "No Migration" Variances?        11
     Pre-Submittal                                             11
     Petition  Submittal                                         11
     Petition  Review                                           13
     Decision to Grant or Deny                                  14
What Information Should be  Included in a "No Migration"
Petition?                                                     14
     Waste Descriptions                                        15
         Waste Types and Sources                              15

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         Waste Characteristics                                  16
         Waste Incompatibilities                               16
         Waste Transformation Mechanisms                      16
     Facility Description                                        18
     Site Characterization                                      19
         Geology                                            19
         Ground-Water Hydrology                              20
         Surface-Water Hydrology                              21
         Climatology and Meteorology                          21
         Background Environmental Quality                      22
     Monitoring Plans                                         22
     Waste Mobility Modeling                                   24
     Assessment of Environmental Impacts                        27
     Prediction of Infrequent Events                              28
     Quality Assurance and Control                               29
Checklist of Information  Needs                                   31
Where Can I Obtain Additional Information
Concerning "No Migration" Variances?                            34
Appendix: Draft Air Pathway Assessment Methodology
for "No Migration" Demonstrations

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What is a "No Migration" Variance?

A "no migration" variance is a formal decision that can be rendered by the EPA to
allow the land disposal of specific, prohibited wastes  not meeting the treatment
standards established  by EPA  at  a  particular facility.  The  statutory  language
requires  anyone pursuing  a  "no migration"  variance  to demonstrate "to a
reasonable degree of certainty that there will  be "no migration" of hazardous
constituents from the disposal unit or injection zone for  as long as the waste
remains hazardous." The EPA codified this language on November 7, 1986 (40 CFR
268.6).  The EPA has interpreted the statutory language to mean  that it must be
demonstrated, to a reasonable degree of certainty, that hazardous constituents will
not  exceed Agency-approved  human  health-based  levels (or environmentally
protective levels, if they are appropriate) beyond the edge of the disposal unit. In
most cases, the  disposal  unit is defined as the limit of natural  barriers and/or
engineered components, but may be defined differently in some site-specific cases.
This definition of "no migration" does not allow fate and transport of hazardous
constituents above acceptable health-based  levels outside the boundary of the
unit

What are the Land Disposal Prohibitions?

In 1976, Congress  passed the  Resource Conservation and Recovery Act (RCRA)
authorizing EPA to  establish  nationwide standards for  the  management of
hazardous wastes.  Regulations promulgated under RCRA in Title 40 of the Code of
Federal Regulations, Part 261 (40 CFR 261), include lists of designated hazardous
wastes and methods for  identifying wastes exhibiting hazardous characteristics.
Under the Hazardous and Solid Waste Amendments  of 1984 (HSWA), RCRA Sections
3004 (d), (e), and (g) were to include provisions prohibiting the land disposal of all
such "listed" and "characteristically hazardous" wastes  unless they are first treated.
Wastes included  in  the EPA's land disposal prohibitions will have to be treated by
best demonstrated available technology (BOAT)  to meet the  treatment standard
established by the  EPA, unless a "no migration"  variance is obtained.  Prohibited
wastes cannot be stored on the land (unless storage is in containers or tanks and is
for the purpose of  accumulating sufficient quantities to facilitate proper recovery,
treatment, or disposal) without a "no migration" variance.  The land disposal
prohibitions become effective on the dates indicated below.

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     Novembers, 1986  -   Solvents
     JulyS, 1987        -   California List*
     Augusts, 1988     -   At Least One-Third of All Other Listed Wastes
     June 8,1989       -   At Least Two-Thirds of All Other Listed Wastes
     May 8,1990        -   All Remaining Listed Wastes and All Characteristic
                          Wastes

No  prohibitions  are  applicable  to  contaminated  soil  and debris from the
Comprehensive  Environmental  Response,  Compensation  and  Liability  Act
(Superfund) sites until November 8, 1988.  A complete schedule of the land disposal
prohibitions can be found in  40 CFR 268.10 through 268.13.  These prohibitions
apply to all hazardous wastes  identified under RCRA as of November 8, 1984. For
hazardous  wastes identified  in 40 CFR  261  after that date,  EPA  must make
prohibition determinations within  6 months of the date of listing or identification
of the new hazardous wastes.  However, the statute does not impose an automatic
prohibition on  land  disposal if EPA misses  a deadline  for any newly listed or
identified waste.

Direct land disposal of an untreated waste may be allowed nationally by EPA for up
to 2 years if treatment  capacity is inadequate.  In addition, two 1-year case-by-case
extensions of  the effective  dates  of prohibitions may be granted under certain
circumstances. The  applicant  must demonstrate that adequate capacity to treat,
recover, or dispose the waste is not available by the effective date and that he has
entered into a binding contractual commitment to provide such capacity.  (EPA is
developing a guidance document for case-by-case extensions.)  All other untreated
RCRA hazardous wastes will be banned from land disposal unless a "no migration"
variance is received from the EPA.
    Based on regulations developed by the California Department of Health Ser-
    vices for hazardous waste land disposal restrictions in the State of California.

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Additional Requirements of the Land Disposal Restrictions First Third Rule

In addition to promulgating specific treatment standards and effective dates for
"First Third" wastes, the Land Disposal Restrictions First Third  Rule [53 FR 31138,
August 17,  1988] added new procedural and informational requirements at 40 CFR
268.6 for petitioners seeking to demonstrate "no migration" for land disposal units.
Based on inquiries and comments  received on  the  subject of "no  migration"
petitions, the Land Disposal Restrictions  First Third  Rule added  the following
requirements.

Compliance with Other Applicable Laws

40 CFR 268.6(a)(5)  requires petitioners to include  information demonstrating that
units for which they seek a "no migration" variance comply with other applicable
Federal, State, and  local laws.

Monitoring Plans for Land Disposal Units

40 CFR Sections 268.6(a)(4) and 268.6(c)(1) require continued monitoring of media
of  concern to  verify compliance  with  the "no migration"  demonstration.
Monitoring of hazardous waste units is also required unless technically impractical
or infeasible.

Reporting  of  Changes in Operating  Conditions  From Those Described  in the
Variance Application

40 CFR 268.6(e)  requires reporting of changes from conditions described in the
variance  application,  including  changes in the type of waste  stream received,
operating practices, unit design and construction, or unusual and  significant
changes in the environment, such as the water table or surface water flow.

Detection of Migration of Hazardous Constituents

40 CFR 268.6(f) requires immediate suspension of receipt of prohibited waste and
notification  of EPA within 10 days if it is  determined that there is migration of
hazardous constituents from the unit to any environmental medium.

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Who Can Receive a "No Migration" Variance?

A "no migration" variance petition can be submitted by anyone who generates,
stores, or disposes hazardous wastes.  The petition for a "no migration" variance
can be submitted by any interested waste generator or facility owner or operator,
either individually or collectively.  The petition must clearly demonstrate that the
method to be employed protects human health and the environment. This requires
showing, to a reasonable degree of certainty, that hazardous constituents will not
exceed human health-based levels (or environmentally protective levels, if they are
more stringent) beyond the edge of the disposal unit.  The petition must also
provide long-term assurance  that the  "no migration" variance criteria will be met.
The variance only becomes effective after EPA reviews the petition, solicits public
comments, and publishes a final determination in the Federal  Register.  In most
cases, the variance will require monitoring to demonstrate continuing compliance
(see substantive and procedural requirements in the Land Disposal Restrictions First
Third Rule, August 17,1988, 53 FR 31138).

In the November 7, 1986 Final Rule (51  FR 40572), the Agency identified several
scenarios that may satisfy the "no migration" standard. These scenarios are not the
only situations where "no migration"  may be demonstrated successfully.  The first is
the placement of compatible non-volatile waste in a massive and stable geologic
formation such as a salt dome.  In this  case, the Agency would expect the "no
migration" demonstration to focus on the stability, extent, and homogeneity of the
host formation, rather than on the concentration of hazardous constituents in the
waste.

The  second scenario  is the  placement  of a  waste consisting of fairly immobile
constituents in a  monofill located  in  an  arid  area that has  no  ground-water
recharge. The petitioner would need to demonstrate that hazardous constituents
will not migrate out of the unit above health-based (or environmentally protective)
levels.   Such a  demonstration  may  be successful due to  the  well-defined
characteristics of the waste constituents in a monofill.

In the third  scenario, a treatment facility renders the waste nonhazardous through
active chemical, physical, or other processes. An example is the neutralization of a

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corrosive waste, which does not contain hazardous constituents above health-based
levels, in a surface impoundment. This scenario is especially applicable to wastes
that are considered hazardous due only to their ignitable, reactive, or corrosive
characteristics.

In the fourth "no migration" scenario, hazardous waste is stored temporarily for a
purpose other than to accumulate sufficient quantities of the waste to allow for
proper recovery, treatment, or disposal within the meaning of RCRA Section 3004(j).
The waste is stored in a totally enclosed indoor waste pile with a floor or bottom
liner, where engineered  containment systems and  air  pollution controls  are
effective over the period the waste remains in storage. Inspections of the building
are performed frequently to ensure that precipitation is not entering the unit.

Except for temporary storage or treatment operations, it should not be assumed
that man-made barriers or engineered systems (e.g., liner systems, steel tanks) alone
will meet the "no migration" standard. Although artificial barriers in conjunction
with partial waste treatment or barriers that are expected to last substantially
longer than the  hazardous  life of the waste may enhance a petition, artificial
barriers alone cannot be relied upon to provide the long-term assurances required.
For this reason, "no migration" variances are not envisioned for conventional land
disposal units (e.g., landfills and surface impoundments).

In addition, the EPA will generally deny variances to any disposal facility with a
history of continuing mismanagement of hazardous waste  and serious compliance
problems, as evidenced by State or EPA  monitoring and inspection reports. Minor
infractions in compliance should not affect EPA's review of a petition. However, for
a unit located in a waste management area where releases have occurred,  the
owner or operator is not encouraged to submit a "no migration" petition unless he
can  conclusively demonstrate that the release  is not from the  unit seeking a
variance.

What is the Definition of the "Unit Boundary?"

The unit boundary (and consequently, the point of compliance (POQ) is defined by
the extent of the natural or engineered barriers that contain the waste.  (In
demonstrating "no migration," a strong preference will be shown for units relying

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upon natural barriers to prevent migration.) For  land treatment units, the unit
boundary would be the lateral and vertical extent of the treatment zone. The unit
also includes within its boundary any dikes or berms that  immediately surround it.
For the air medium, the POC for demonstrating "no migration" is the downwind
boundary of the unit at a height of 1.5 meters.

How are Levels of Constituents Evaluated?

A successful "no migration" demonstration  must  show that actual or predicted
concentrations of hazardous concentrations or emission rates at the edge of the
disposal  unit  do  not  exceed   Agency-approved  health-based   levels   or
environmentally-based levels  for ground water, surface water,  soil, and  air.  If
health-based criteria do not exist for a constituent, the applicant may propose his
own health-based  levels using the toxicity testing  guidelines  contained in  40 CFR
Parts 797 and 798, and the Agency guidelines for assessing health risks (51 FR 33992,
34006, 34014, and 34028).  If  no health-based level can be determined for a
constituent, that constituent must not exceed analytical detection limits. If health-
based levels are below analytical detection limits for a constituent, the petitioner
must demonstrate, using  modeling, that the health-based  levels  will be met.
However, in any compliance monitoring required for the unit where health-based
levels are  below  detection  limits,  meeting  detection  limits would  constitute
compliance with  the  demonstration.   In calculating  these  concentrations, the
petitioner should use site-specific data to evaluate how the hazardous constituents
will  be apportioned between media.  When site-specific data are  not available,
worst-case assumptions must be used.

In reviewing the  petition, EPA  will compare the calculated concentrations of
hazardous constituents to Agency-approved levels. For example, the Agency would
compare the constituent concentrations in leachate to the Maximum Concentration
Levels (MCLs).  If an MCL is not available for a constituent, the appropriate health-
based levels would be the Reference Dose (RfD) for noncarcinogens and the Risk
Specific Dose (RSD) for carcinogenic compounds. These health-based criteria have
been calculated   by  assuming  chronic  (lifetime)  exposure by  ingestion  of
contaminated water.  More information on these health-based  numbers is available
in the Superfund  Public Health  Evaluation Manual.  U.S. EPA, 1986; and the
Integrated Risk Information System (IRIS); U.S. EPA, 1988.  IRIS  is available through

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various on-line networks such as DIALCOM Inc., the Public Health Network, and the
National Library of Medicine's TOXNET.

For a "no migration" petition, it is necessary  to evaluate the concentration of
contaminants in air, surface water, and soil as well as in ground water. The Agency
has published health-based levels for soil ingestion and inhalation for a subset of
the hazardous constituents listed in Appendix VIII of 40 CFR 261. The preliminary
draft RCRA Facility Investigation (RFI) Guidance (EPA 530/SW-87-001. July 1987); and
the preliminary draft Surface Impoundment Clean Closure Guidance. U.S. EPA, 1987
contain tables  of health-based criteria, as well  as explanatory  text  on  the
assumptions used to calculate the numbers. Because all health- based numbers are
subject to review and change, EPA recommends that the petitioner  contact EPA's
Environmental Criteria and Assessment Office in Cincinnati, Ohio at (513) 569-7531
to obtain up-to-date information on health-based levels.

In addition to comparing individual constituents to the appropriate health-based
level, the Agency will also  consider additivity in evaluating the  risk  posed by
concentrations at the unit boundary. For example, if the  petition  identifies two
constituents that appear at the unit boundary  at  levels which are below health-
based limits for each of the constituents, the Agency will also consider the potential
threat posed by adding the two constituents. In general, the Agency will consider
additivity  only for constituents in the  same medium (e.g.,  air).  For  more
information on the EPA's policy on chemical mixtures, the petitioner should refer to
the Guidelines for the Health Risk Assessment of Chemical Mixtures (51 FR 34014).

Petitioners for units in  high background situations must demonstrate  that  the
incremental  contributions of contaminants from  their  unit will not, in and of
themselves, exceed health-based levels.

How Long is "As Long As the Wastes Remain Hazardous?"

This is a waste- and site-specific determination.  For some waste types that degrade
naturally to health-based levels in a relatively short time period, the petitioner may
only have to demonstrate such degradation and show "no migration" from the unit
during the degradation period.  On  the  other hand,  where nondegradable
constituents such as metals will exist within the unit, the petitioner will potentially

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have to demonstrate "no migration" forever, unless such constituents are removed
at closure or the unit is capped. (Capping will only be acceptable where there is not
leaching potential as determined using the toxic characteristic leaching procedure
(TCLP)  with  water.)    Note, however,  that  the   UIC  program  considers  a
demonstration of "no migration" for 10,000 years to be sufficient. While this time
frame may be valid for degradation in the injection zone, is not necessarily valid for
other land disposal units.

What is the Relationship Between Land Treatment Units and "No Migration"?

Land treatment units are subject to all of the general provisions of the land disposal
restrictions program, since they are considered to be disposal units  under RCRA
3004(k).  Thus, in order to apply restricted  wastes which do not meet the BOAT
performance standards, an owner or operator of a land treatment unit  should
consider applying fora "no migration" variance.

The petitioner for a  land treatment unit must demonstrate that the "no migration"
standard is met for all media. The land treatment demonstration (LTD) need not be
complete in  order  to receive a  "no migration" variance. The "no migration"
variance will be granted based upon certain basic monitoring and modeling data.
However, the variance will be conditioned upon completion of the LTD within a
specified time  period (usually two  years  after the date of granting of the "no
migration" variance), or else the variance will be revoked.

Many wastes that are currently land-treated contain significant amounts of volatile
constituents and/or metals. The petitioner must demonstrate a sufficient  level of
degradation and/or immobilization  of waste constituents and metals within the
treatment zone to  assure that hazardous constituent concentrations will remain
 lower than  human health-based  or environmentally-based  standards  at the
treatment zone/soil  boundary. For land treatment units, the "disposal unit" consists
of the treatment zone (plus the liner, if any exists). For volatile  constituents, the
applicant must demonstrate that the health-based or environmental levels are not
exceeded at the downwind edge of the unit boundary at a height of 1.5  meters.
This demonstration  should be made by using site-verified emission and dispersion
models,  emission monitoring and/or ambient air monitoring.  In addition, an
applicant may need to pretreat a volatile waste (e.g., air stripping with appropriate
                                     8

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air pollution controls) in order to successfully demonstrate "no migration" of the
contaminant to the air. (For more information on "no migration" demonstrations
for the air medium, see the Appendix.)  The applicant should attach all relevant
parts of his land treatment demonstration permit application to the "no migration"
petition,  including biotoxicity  studies,  degradation studies, and general  site
information regarding ground water, surface water, climate, and soil.

The  LTD can  be used as a basis upon which to build a "no migration" petition.
However, the information that is typically provided  in the LTD is largely current
monitoring information.   The petition must  contain  sufficient modeling and
theoretical, long-term projections to  insure that migration will not occur to  any
medium  "for as long as the wastes remain hazardous." Because the LTD does  not
address the air medium, the air demonstration must also be added.  Finally, a TCLP
using water (at the pH of ambient rain water) to  determine metals leachability must
be performed at closure, and a closure and post-closure plan must be submitted (as
part of the petition) where metals are projected  to accumulate above health-based
levels.  If metals will exceed health-based levels for ingestion at closure, the  unit's
closure  plan  must require  either capping with post-closure monitoring (where
metals are not leachafefe above health-based levels), or clean closure (where metals
are teachable above health-based levels).

What is the Relationship  between "No Migration" Variances, RCRA Permits, and
Other Federal Laws?

"No  migration" variances may only be issued for  facilities functioning under interim
status or facilities with permits under RCRA. Because much of the information that
must be included in a RCRA Part B application must also accompany the petition for
a "no migration" variance, facility owners and operators are encouraged to submit
petitions with the  relevant  Part B data summarized, and copies  of critical Part B
materials attached as needed.

Before being  issued a "no migration"  variance,  the petitioner must assure the  EPA
that  land disposal of the prohibited waste(s) will comply with all other applicable
Federal laws.   These may  include the  Clean Air  Act, the Clean Water Act, the Safe
Drinking Water Act, the Endangered Species Act, the National Historic Preservation
Act,  the Wild and Scenic  Rivers Act, the Coastal Zone Management Act, the  Fish

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and Wildlife Coordination Act, the Atomic Energy Act, and the Marine Protection,
Research and Sanctuary Act. The operation for which a variance is sought must also
be in compliance with applicable State and local laws and ordinances.

Can Generic Petitions be Submitted Covering Several Similar Facilities?

Yes, but generic petitions should be avoided as a practical matter. The usefulness of
a generic petition is limited since petitions must include site- and waste-specific
data.  Accordingly,  petitioners would have to  demonstrate that each scenario
covered  under  a generic petition  is essentially the  same.   For  example,  a
demonstration that the  hydrogeological characterization of each site  is essentially
the same would require the detailed assessment of each site  addressed in  the
petition.  As a result, the Agency  expects few, if any, generic petitions for surface
land disposal units.

When Does a Variance Become Effective and How Long Does it Last?

Variances will be effective only after issuance;  submittal of a  petition will  not
exempt a facility from complying with applicable land disposal prohibitions.

Variances  will  be valid  for up to 10 years, but not longer than the term of  the
facility's RCRA permit. The  variance will automatically  expire  upon termination
or denial of a RCRA  permit, or when the volume of waste for which the variance was
issued is reached. In the Land Disposal Restrictions First Third Rule, the Agency  has
listed notification requirements if  migration is detected. Any significant departure
from the terms or  conditions of a variance would require written notification of
EPA, who will  determine  the  appropriate action.   Possible actions  include
termination of waste acceptance at the unit, termination of the petition, or petition
modifications.  The  conditions of the variance  may require periodic waste analysis
to assure the consistency of waste constituents.  If migration  from the unit is
discovered after a  variance has  been granted, the owner or  operator  must
immediately scop receipt of the restricted waste and notify EPA.  EPA will then
decide whether the unit can continue to receive waste, or whether the variance will
be terminated.  Substantive requirements for variances for waste disposal in deep
injection wells  may differ slightly  from those described above. The reader should
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refer to the July 26, 1988 rule  (53 FR 28118) for more detailed  information on
injection wells.

What is the Petitioning Procedure for "No Migration" Variances?

Outlined below is a step-by-step process for the submittal  and review of "no
migration" petitions, illustrated  in the figure on the following page.  As stated in
the preamble to the November 7,  1986 Final Rule, EPA believes that there will be
relatively few petitions.   Accordingly,  EPA is requiring that applicants submit
petitions to the EPA Administrator. Petitioners should note that authorized State
programs are free to impose disposal prohibitions if such actions are more stringent
or broader  in scope than Federal programs (RCRA Section 3009 and 40CFR 271.1(0).
Where States impose bans which contravene an EPA action, such as not allowing
provisions  for granting a  "no migration" petition, the  more  stringent  State
standard shall apply and the petition will be denied by EPA.

Pre-Submittal

A  very important  component to the "no migration" process  is pre-submittal
meetings between  the petitioner and the  EPA.   These  meetings are critical  in
ensuring expeditious decisions on petitions.  The purpose of the pre-submittal
meeting is to provide the petitioner with  an  opportunity to identify the hazardous
waste, hazardous constituents, and disposal  unit(s) to be included in the petition.
The EPA can provide some historical background on the review of similar petitions,
including  a tentative  timeframe  for the  review  process.   The  Agency  also
recommends that petitioners submit a  preliminary outline of their  petition for
Agency review.

Petition Submittal

As required by Sections 268.6(c) & (d) of the  regulations, each petition must be
submitted to the EPA Administrator and include the follow!ng statement signed by
the petitioner or an authorized representative:

     I certify under penalty of law that I have personally examined and am familiar
     with the information submitted  in this petition  and  all attached documents,
     and that, based on my inquiry of those individuals immediately responsible for
                                    11

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                    Pre-Submittal Meeting(s)
                             Does
                          State Allow
                         "No Migration"
                            Petition
                               7
 Grant
  the
Petition
   7
Inform Petitioner
   of Intent to
  Deny/Dismiss
  Yes
                        Draft Fact Sheet
                         and FR Notice
                       Internal Review









Ev



Iss

                       Propose FR Notice
                       Public Comment
                            Period
                     Evaluate Comment(s)
                        and Revise FR
                       Internal Review
                     Issue Final FR Notice
                      Petition Received
                         at EPA HQ's
                                               Send Acknowledgement
                                                 Letter to Petitioner
Technical Review
                     Request Additional
                        Information
               "No Migration" Petition Review Process
                                12

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     obtaining the information, I  believe that the submitted information is true,
     accurate, and complete. I am aware that there are significant penalties for
     submitting  false   information,  including  the  possibility  of  fine  and
     imprisonment.

The petition should be sent to the following:

     The Administrator
     U.S. Environmental Protection Agency
     401 M Street, S.W.
     Washington, D.C. 20460

To facilitate review, a copy of the petition should also be sent to the Assistance
Branch in the Office of Solid Waste. The copy should be sent to:

     Chief, Assistance Branch
     Off ice of Sol id Waste
     U.S. Environmental Protection Agency
     401 M Street, S.W. (OS-343)
     Washington, D.C. 20460

Once the petition has been received by the EPA, a public docket will be established
for the petition  and a  person from  the Assistance Branch (the reviewer) will be
assigned to the petition.   The   reviewer will  send a  letter to the  petitioner
acknowledging receipt of the petition.  This letter may also contain  a tentative
timeframe for the review of the petition. Copies of this letter will be distributed to
the appropriate EPA Regional Office and State Agency.

Petition Review

The reviewer will perform an  initial review of the petition. Once this initial review is
completed, the reviewer will  decide if additional information is needed to make a
decision on the petition. If additional information is needed, a letter requesting the
information will be sent to the petitioner. Information to aid in the review may also
be  requested from the Regional or State  contact.  The request letter to  the
petitioner will contain a deadline  for the submittal of the additional information.
This deadline will  be dependent on the type of information  being  requested.
However, the deadline will not exceed a period of 180 days  from the date of the
request letter. Once the reviewer has obtained all of the necessary information for
the review, a comprehensive, technical  review will be performed.  As  part of this
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review, the reviewer will work closely with the Regional and State contact and will
normally perform a site visit.

If the additional information is not received by the deadline, or a request for an
extension of the deadline is not submitted, the reviewer may  recommend that the
petition be dismissed.  The Agency plans to dismiss incomplete  petitions by letter. A
dismissal letter will be sent to the petitioner and to the appropriate State and EPA
regional contacts.  The  effect  of  a dismissal is to remove the petition from the
review process and close the petition file. The petitioner may at any time re-submit
a complete petition.

Decision to Grant or Deny

Once the technical review is complete, the reviewer will  recommend a tentative
decision to grant or deny the petition. If the reviewer recommends to grant the
petition, the Agency will publish a draft Federal Register notice describing its intent
to grant the petition.  If the reviewer recommends that the petition be denied, the
petitioner will be informed by letter of the intent to deny.  This letter will also offer
the petitioner the opportunity to withdraw the petition.  If the petitioner declines
to withdraw the petition, the  Agency will publish a draft Federal Register notice
describing its intent to deny the petition.

What Information Should be Included in a "No Migration" Petition?

 "No  migration" petitions will vary considerably.  The petition  content  will be
strongly influenced by the type of facility for which a variance is sought and the
 methods chosen to demonstrate that the facility will adequately protect human
 health and the environment. The petitioner must provide  site-specific information
 and  may,  additionally,  provide  generic and national  information for certain
 requirements. The descriptions of petition content provided on the following pages
 are intended to illustrate the nature and complexity of the information that may be
 required.

The information in this manual should be used as a starting point for assessing the
 level of detail  that will be required  for each element  of  the  petition.  Such
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assessments can  best be accomplished  in pre-petition conferences between  the
Agency and facility owners and operators.

Discussions of each of the principal petition components listed can be found in the
following pages. A detailed checklist of possible petition requirements is presented
at the end of this manual.

Waste Descriptions

"No migration" variances are available  only for the disposal of specific wastes at
specific units. Variances are not available for broad categories of wastes; they are
issued only for those wastes for which compliance with the "no migration "standard
is demonstrated in the petition. Proper  management of wastes for as long as they
remain   hazardous  requires   that  potential  incompatibilities  and  waste
transformation mechanisms be assessed.

Hazardous and nonhazardous wastes may interact causing changes in their toxicity
and/or  mobility.    Therefore,  it is  essential  that  the  applicant individually
characterize, to the extent possible, each waste to be placed  in the unit, including
wastes not subject to the land disposal ban.

All  waste descriptions  must be  properly documented and  in compliance with
prescribed quality control and quality assurance  guidelines.  The  following  is a
breakdown of the information required on each petitioned waste.

Waste Types and Sources --

Background information must  be provided on  each  waste to be covered by  the
variance.   Such  information  includes  the applicable waste codes  (EPA  and
industrial), the waste-generating processes, the hazardous constituents and their
properties, the quantities of waste to  be placed in the unit and the rates of
placement, and handling and storage practices.
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Waste Characteristics --

Complete physical and chemical characterization  is required for each petitioned
waste and all other wastes to be placed in the unit. The potential for leachate
formation, waste solubilities, hazardous-constituent vapor pressures, and  other
factors that  could  affect waste  mobility should  also be assessed.   Analytical
information  should  include  results of testing  for Appendix VIII  constituents
reasonably expected to be present in  the  waste, toxicity characteristic leaching
procedure (TCLP) results to determine the leachability of contaminants, simulation
models of leachability and transport,  and field  leachate analyses,  if available.
Acceptable procedures for waste sampling and  analysis can be found in the EPA
publication Test Methods for Evaluating Solid Waste.

Waste Incompatibilities --

The codisposal of incompatible wastes can  result in the generation of heat, the
production of flammable and toxic gases, and the solubilization and mobilization of
hazardous constituents.  A  comprehensive  assessment of waste compatibilities
would include  all potential chemical interactions, reaction products, and product
characteristics.  The applicant  must document, to the extent practicable, any waste
incompatibilities and reaction  products.

Waste Transformation Mechanisms--

To properly demonstrate that wastes can be contained in  the unit, the applicant
may be  able to show that wastes change over time, resulting  in nonhazardous
degradation products.   In addition, it may be necessary  to  characterize the
mechanisms by which the wastes change over time.  Waste transformations may
alter waste mobility and/or toxicity and  should be predicted to properly determine
the resulting concentrations of hazardous constituents at  the unit boundary.  In
either case,  thorough characterization should  be  provided for  reaction  rates,
products, and  product characteristics for each transformation  mechanism. The
petitioner may also be called upon to characterize combinations of transformation
mechanisms.   An  assessment  of  the stability  of the  waste  matrix, matrix
•characteristics,  and the effect of all transformation mechanisms on the matrix
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should be  provided.  The  mechanisms that must be accounted  for  in a  "no
migration" demonstration are as follows:

     Biodegradation. The breakdown of a compound by microbial attack, may be
     very important for organic compounds. Degradation rates are dependent on
     environmental conditions (pH, salinity, dissolved  oxygen, nutrients),  the
     concentrations of waste and microbes, and the types of microbes.

     Photodegradation.   A chemical  change  in a compound resulting from
     absorption of ultraviolet light, must be considered where appropriate. Tests
     to  determine  the  photodegradation rates must  control  for  pH, light
     wavelength, light intensity, competing reactions, temperature, and waste
     concentrations.
                              •
     Hydrolysis.  The  degradation  of a chemical  compound upon  reaction with
     water, may be a significant transformation mechanism for some wastes.

     Oxidation/reduction.   The transfer of electrons between  molecules, is a
     common degradation mechanism.

     Volatilization.  Although technically not a  transformation mechanism, is the
     conversion of a solid or liquid material into a vapor state. It may represent a
     significant waste transport mechanism (i.e., from one medium to  another).
     Determination of environmental factors affecting volatilization rates (e.g.,
     temperature, pressure,  vapor pressure, solubility) may also be required.

The  likelihood of these  and other waste transformation mechanisms should  be
described  in the  petition.   The methods by which   petitioners determine
transformation rates, whether  actual waste data or theoretical calculations, also
must be thoroughly described. The actual testing of waste transformation processes
or the use of accepted procedures for transformation rate determination may be
required.
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Facility Description

The petition should include a description of the hazardous-waste management
facility where  the waste will be disposed in sufficient detail  to  familiarize the
reviewer with its overall operation. The facility name, mailing address, and location
should  be provided,  together with  information  on a  point of contact for
correspondence concerning the petition. The nature of the facility's business should
be identified and, for onsite facilities, the processes involved in the generation of
hazardous wastes should be described. Operators of offsite facilities should identify
the types of industries serviced.

Detailed design,  layout,  and operating plans should be  provided  for the  unit
covered by the petition. The type of information and level of detail provided should
be similar  to those included in RCRA Part B permit applications. (Detailed guidance
concerning Part B applications for land disposal units can be found in the EPA's 1984
Permit Applicants' Guidance Manual for Hazardous Waste Land Treatment, Storage
and  Disposal  Facilities.)    Unit descriptions  should  focus  on waste isolation
capabilities of the unit or environmental setting.

Although  man-made barriers and engineered systems alone cannot be relied upon
to provide the long-term  "no migration" assurances required, they may play a role
in the facility operation. The exception is certain temporary storage and treatment
facilities that  may rely entirely upon engineered systems  to isolate wastes.  All
barriers should be thoroughly described.

The  unit  boundaries, which will serve as the compliance point for the variance,
should  be defined and  thoroughly described.   In  the  case where there is no
engineered boundary above the waste to control air emissions, the downwind edge
of the  unit at a height of 1.5 meters will  be the point  of compliance for air
emissions.

Other aspects of facility design and operation may be considered in evaluating the
petition, including:

     Monitoring systems
     Procedures employed to prevent hazards
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     Contingency plans
     Personnel training plans
     Closure plans
     Post-closure plans

These elements of the facility description are also common to Part B applications.
Any relevant Part B information should be summarized in the petition, or attached
as necessary.

Site Characterization

A thorough description of each facility's natural environmental setting is crucial to a
"no migration" demonstration. The site's climatology, meteorology, geology, and
hydrology must be described in sufficient detail to permit assessment of the degree
of waste isolation achievable. Environmental factors and long-term environmental
changes that may impact the waste isolation potential of the unit should be
addressed.  Moreover, background air, soil, surface water, and ground water quality
must be determined to properly assess any potential impacts of land disposal. The
information that may be required is similar to the  requirements for a Part B permit
application and a RCRA Facility Investigation (RFI). (Detailed guidance  concerning
RFIs can be found in EPA's 1987 RCRA Facility Investigation Guidance Manual.)

However, since a "no migration" demonstration does not allow for consideration of
fate and transport of hazardous constituents above acceptable levels outside the
unit boundary, the focus of site characterization should be on the potential impacts
of the site  on the waste to be isolated in the unit.  For example, the  potential
impacts of wind, rainfall, and the fluctuation in the ground-water table  on the unit
and the waste within it must be addressed. Information on particularly sensitive or
vulnerable site characteristics may be useful in determining the degree of certainty
required in a "no migration" demonstration.

Geology --

A comprehensive geologic description should include regional, local, and  site
information.   A discussion  of regional  and  local geology  should  include the
following components and contain maps and other supporting documentation:
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     Structure. Density, distribution, and orientation of faults, folds, and fractures

     Subsurface Geology.  Identification, lithologic description and thicknesses of
     all geologic formations underlying the region, available geophysical surveys,
     well logs, and boring logs

     Geomorphology. Discussion of present surface features, processes that could
     affect surface features, and subsurface features that may be implied

     Geologic Stability. Potential for earthquakes and degree of resulting ground
     motion, faulting, landslides, subsidence, creep,  and other  types  of earth
     movement

The discussion of local geology should also include soils and topography.  The soils
information should  encompass  soil types (Unified  Soil  Classification  System),
properties, thicknesses, and depths  to  bedrock.  In addition, similar site-specific
geologic information should be provided, whenever possible.

Ground-Water Hydrology -

The petition should include a comprehensive description of regional, local, and site
ground-water hydrology. Ground water is particularly vulnerable to contamination
with  hazardous  constituents  from land disposal  units and, in  many cases, can
provide an avenue for waste constituent transport to surface waters and municipal
and  private wells  as well as provide a subsurface migration pathway for gases. In
some instances ground water may migrate into a unit, mobilizing contaminants out
of the unit. The  following types of information, including maps and supporting
documentation, may be required fora "no migration" petition:

     Identity and  lateral extent of all aquifers, confining layers, and perched water
     tables

     Characteristics  of all necessary  aquifers and confining layers,  including
     thickness, porosity, permeability, hydraulic conductivity, and storage
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     Ground-water elevations and seasonal variations thereof

     Existence of aquifer interconnections

     Ground-water flow rates, directions, and recharge and discharge areas

     Locations of all local municipal and private wells and surface water discharge
     areas

Surface-Water Hydrology --

A  discussion of surface-water hydrology  should  include  identification  of  all
watersheds within the region that could potentially affect  the facility.  Maps of
regional and facility drainage and the effects of facility run-on and run-off controls
should be provided.  Floodplain maps incorporating appropriate flood frequency
data should  also be provided. It must be clearly demonstrated that waste isolation
will not be adversely affected by floods with a reasonable probability of occurrence
during the period in which the wastes are hazardous (e.g., 25-year floods, 100-year
floods, etc.).

Climatology and Meteorology --

Sufficient meteorological and climatological information will need to be provided
to allow for the assessment of impacts of these factors on the disposal unit and site.
The climate and meteorology of the site can have significant impact on the rate of
emissions to  air, for example. The following types of information may be required:

     Site wind roses

     Data on precipitation, temperature, and relative humidity data (seasonal
     maximumsand minimums)

     Maps of severe storm tracks and statistics on storm occurrence

     Data on depth of seasonal freezing
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Facilities relying in part on climatic factors to control waste migration (e.g., arid
regions with no ground-water recharge) will  be  required to submit considerably
more information  than facilities that are not significantly affected by climatic
changes.

Background Environmental Quality --

The  RCRA regulations specifically require that "no migration" petitions contain
analyses of background air, soil, and water quality. The analyses and levels of detail
should be site-specific.  Those petitioners with facilities in sensitive  environments
will  be required to submit considerably  more  background data  than  other
petitioners.

Monitoring Plans

Monitoring of all environmental media at land disposal  sites is necessary to confirm
that "no migration" of hazardous constituents beyond the unit boundary occurs.
Accordingly, the Land Disposal Restrictions First Third Rule [53 FR 31189, August 17,
1988] amended 40CFR 268.6 to require that "no migration" petitions include a plan
for monitoring at the unit boundary, to include the following information:

     Media to be monitored

     Type of monitoring to be conducted at the unit

     Location of the monitoring stations

     Frequency of monitoring at each station

     The specific hazardous constituents to be monitored

     An implementation schedule forthe monitoring program

     Equipment to be used at the monitoring station

     Sampling and analytical techniques to be employed
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     Data recording/reporting procedures

The petitioner should provide sufficient information to justify the design of the
monitoring program and to demonstrate that monitoring stations will be located to
detect migration from the unit at the earliest practicable time.

Monitoring immediately at the unit boundary may be difficult in certain locations or
under unusual  physical conditions at the  site.  Under  such circumstances, the
petitioner should propose a monitoring plan to be conducted as near as possible to
the unit boundary without compromising the integrity of the unit.  One such case
may be hazardous waste repositories in geologic formations that are so extensive
that installation of monitoring wells around the formation itself may not allow
detection of migration  at the earliest time, and installation of monitoring wells in
                              *
the formation may damage  the  integrity of the formation.  Monitoring of the
repository  itself (e.g.,  pressure monitoring of fluids between  well  casings in
solution-mined  caverns, or leachate sumps and  pumps in room-and-pillar mines)
may be suitable in this case.

In other cases, monitoring of all environmental media at a particular facility may be
unnecessary.  An  example of this  might  be monitoring of air outside  a totally
enclosed treatment facility. In such a case, petitioners should include information
that clearly demonstrates why monitoring of any medium is unnecessary.

In addition to monitoring at the unit boundary, the petition should also include a
plan  for monitoring the  wastes in the  unit  to  detect any  changes in waste
composition  which  could affect  the  potential  for migration  of  hazardous
constituents over time.  Such monitoring might include periodic testing of the waste
in the unit; leachate collection systems in  surface impoundments, landfills, and
room-and-pillar mines;  and fluid or gas pressure monitoring in well casings above
solution-mined cavities  in salt domes.

A petitioner may be able to incorporate all or part of a monitoring  plan designed to
comply with 40 CFR  264 or 265 Subpart F  requirements into the "no  migration"
monitoring plan.   For example,  a petitioner  may be  able  to use Subpart  F
monitoring wells if they will detect migration at the earliest practicable time, and
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may only have to increase the frequency of monitoring.  However, the petitioner
should be aware that "no migration" monitoring  is different from Subpart F
monitoring in that it is to be performed immediately at, or as close as possible to,
the unit boundary.  Subpart F ground-water monitoring, on the other  hand, does
not necessarily occur  at the unit boundary.  Furthermore, although Subpart F
detection monitoring for indicator parameters may be helpful to demonstrate "no
migration",  "no  migration"  monitoring should  be for a  set of constituents
determined based on a unit-specific analysis of the waste.

Waste Mobility Modeling

Accurate and  representative  modeling  of waste constituent  mobility may be
required for the environment within the unit including unit liners and engineered
barriers.  Presented below  is a brief overview  of information  requirements for
modeling as well as considerations relevant to the choice of a representative model.

Several types of models may be used to predict waste mobility within the confines
of the unit for which a variance is sought. Although  hazardous constituents must
not exceed human health-based levels beyond the natural or engineered boundary
of the unit, waste migration within the unit will be  acceptable. Models may be
developed for predicting  leachate and gas generation rates, barrier integrity over
time, and many other factors that can affect waste mobility. All such models and
the assumptions underlying them must be thoroughly explained, and descriptions
of the calculations and codes employed must be provided.

Modeling of waste and leachate migration in the unsaturated zone may be required
for some units  (e.g., the treatment zone of a land  treatment  unit).   Waste
constituent  transport within  that  zone depends on  site geology,  soils,  and
climatology, as well as the physical and chemical characteristics of the waste and
leachate. The  factors affecting  flow at or near the land surface are precipitation,
run-off/run-on, evaporation, and transpiration.

Physical properties of the site soils that affect flow in the unit and the unsaturated
zone that should be described in the petition include:
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     Water content
     Pressure potential
     Permeability
     Degree of water saturation
     Bulk density
     Particle density
     Water capacity
     Hydraulic conductivity
     Water diffusivity

The waste or leachate  in the unsaturated zone can be affected by various chemical
processes, including  ion exchange,  adsorption, precipitation,  dissolution, and
complex formation. Those processes appropriate to the waste and its leachates
must be considered. Moreover, certain properties of the soil can be affected by the
waste or leachate: its hydraulic conductivity can be changed; its permeability can
be increased by the removal of organic matter or a change in adsorptive properties;
and others of its properties can be altered by the dewatering of clays or a change in
pore size. Flow patterns within the soil can also be altered by changes in pore size
due to the dissolution and precipitation of chemical species. The impact of these
factors must be taken into account in the model.

The potential for air emission of hazardous constituents from the waste surface into
the atmosphere must be addressed. Emission rates are influenced by environmental
as well as chemical and physical factors.  The  principal environmental factors
influencing air emissions are  temperature, soil characteristics (e.g., pH, moisture,
grain size), and  precipitation.  The  waste or leachate properties that must be
modeled include vapor pressure, solubility, chemical activity, partitioning behavior
of the solute (waste) between the atmosphere and water (Henry's Law), diffusivity,
absorption, and release rate.

Limitations of any air emission release rate (AERR) and dispersion models must be
documented. The applicant should combine the use of models with ambient air and
emission monitoring to characterize conditions at the  unit to the best extent
possible. Any models  used must be verified at the site. (For more information on
the  "no migration" demonstration  methodology for the  air medium, see the
Appendix).
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Appropriate models must be chosen for each of the waste mobility cases discussed
(i.e., unsaturated zone, air, etc.). The choice depends on the objectives of the study
and on the sensitivity of the model to various chemical and physical processes. The
chosen model should be one that is sensitive to all of the significant processes and
most sensitive to those processes of greatest importance.

Other concerns in choosing a model are how well it represents the field situation,
whether it is appropriate for the available data, and whether it can be verified for
accuracy by comparison to actual measurements.  The most sophisticated models
may be inappropriate forthe available data.

The  petitioner has  the  following  quality assurance  and  quality  control
responsibilities for every model used:

     Model validation.  Comparing the results of analytical and numerical models
     or matching field data to the model results is critical to model validation. All
     models must be validated at the site.

     Justification of assumptions.   Proper justification of  all assumptions should
     be provided. In all cases the most conservative assumptions should  be chosen.

     Sensitivity tests.  An assessment of the influence of changes in the magnitude
     of model parameters should be provided.   Models  should show greatest
     sensitivity to the most influential processes.

     Model accuracy assessment.  It must be  demonstrated that:  (1) the model
     reasonably  represents  the   actual  physical system,  (2)  there are  no
     computational errors in the computer code, and (3) there is a high degree of
     correlation between the model and measured data.

The EPA is discouraging the use of proprietary models, since the models selected
will have to be closely scrutinized to determine their reasonableness and accuracy.
Only data developed under appropriate QA/QC procedures as described  in the
facility QA/QC plan will be considered in the petition review.
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Assessment of Environmental Impacts

In a "no  migration"  demonstration the petitioner must show that hazardous
constituents do not exceed human health-based levels at the edge of the disposal
unit. If more applicable levels must be met to protect the environment, then those
levels will be required. For example, stricter levels may be needed where there is
potential  impact to a sensitive environment or an endangered species even  if
human health- based levels are met. The assessment of environmental impacts does
not mean that migration of hazardous constituents will be measured outside of the
unit.  Such an assessment should be undertaken merely to  determine  if human
health-based levels measured at the  unit boundary are sufficient to protect any
sensitive environmental receptors.

Environmental assessments should identify any factor which may require the use of
stricter contaminant levels.  This will involve defining the terrestrial and aquatic
species that may be exposed to contaminants and the exposure pathways through
which the species  may be sensitive (e.g., inhalation, direct contact). Acute and
chronic toxicity and  bioaccumulation  factors  must  be  quantified  for  each
constituent  with  respect to the species involved.  Effects of  transported and
transformed air pollutants  (e.g., ambient ozone  or photochemical  oxidants) on
agricultural crops, forests, or materials should be considered by the applicant.  Field
studies and biomonitoring may be performed in the absence of data, or available
data for chemical analogs may be substituted.

Environmental considerations may include but are not limited to evaluation of:

     Species diversity and abundance potentially affected  by migration from the
     unit

     Bioaccumulation potential in plants and animals

     Fishery and habitat impacts

     Endangered species of flora and fauna potentially affected by migration from
     the unit
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     Biological community structure alteration potential

It is important to note that, for many chemicals, exposure levels deemed safe for
humans often have adverse effects upon terrestrial and aquatic life.  In  addition,
toxicants present at low levels in the environment may bioaccumulate, presenting
significant health risks to man and animals higher in the food chain.

Prediction of Infrequent Events

The  petitioner must identify  and quantify the  impacts  of  events  that  could
contribute  to or result in inadequate waste isolation.  Natural phenomena that
should be considered include:

     Earthquakes and resulting ground motion
     Floods and droughts
     Tsunamis (tidal waves)
     Hurricanes and tornadoes
     Climatic fluctuations
     Geologic activity

 In addition, human-induced events which may affect the isolation capability of the
 unit, such as disturbance of the hydrologic regime and future  land uses, must be
 considered.  The potential for such events during the period in which the wastes
 remain hazardous should be  determined.   Potential impacts of events with  a
 reasonable  probability of occurring during that period should then be estimated
 with respect to the facility's ability to isolate wastes from the environment.

 Analyses of predictable events should take into consideration both the disposal unit
 and the surrounding environment. For example, ground motion resulting from an
 earthquake may cause the breaching of a unit, the fracturing of surrounding  rocks,
 and surges  in the ground-water level.   Previously unconsidered avenues for
 contaminant migration may  be created by the  earthquake.   In  analyzing  the
 potential consequences of predictable phenomena, probable worst-case scenarios
 should be used to ensure that any errors occur on the side of safety.
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Quality Assurance and Control

A QA/QC plan that addresses all aspects of the petition demonstration must be
included in the petition submittal. Quality goals and methods to assure that these
goals are  achieved must be included for each of  the following aspects of the
petition demonstration:

     Waste and environmental monitoring, sampling, and analysis activities

     Field  measurements of the facility setting, such  as geophysical exploration,
     ground-water monitoring, weather observations, and topographic mapping

     Validation  of computations, codes, models, and methods used in  calculating
     critical facility parameters

     Control   of construction  activities  to  ensure   compliance with  design
     specifications

     Evaluation of the integrity of construction materials

At a minimum, the QA/QC plan should identify goals for each of the following
quality indicators and describe how they will be achieved:

     Data representativeness.  The degree to which data accurately and precisely
     represent a characteristic  of a population,  a parameter, variations at a
     sampling point, or environmental conditions.

     Data accuracy. The degree to which data agree with an accepted reference or
     true value. The measurement of accuracy exposes any bias in a system or
     method.

     Data precision. A  measure of the mutual agreement between comparable
     data  gathered or  developed  under similar  conditions.  Precision  is  best
     expressed in terms of a standard deviation.
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     Data completeness. A measure of the amount of valid data obtained against
     the amount that was expected.

Only data developed under appropriate  QA/QC procedures as described  in the
facility QA/QC plan will be considered in the petition review.
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                         CHECKLIST OF INFORMATION NEEDS
 The following checklist is a comprehensive, but not all-inclusive, list of information
 needs.  Individual petitions may  require  more or less  information  than that
 presented below. The level of detail required will depend on site-specif ic factors.
Facility Description

P    Name of facility
G    Address of facility
G    Name of owner/operator
D    Anticipated period of operation
n    Status of RCRA permit application
D    Location map
n    Detailed site plan
G    Aerial surveys
G    Advantages/disadvantages of location
G    Evaluation of storage/disposal unit
      n    Design objective.
      n    Design criteria
      Q    Design performance projection
      Q    Materials specifications
      G    Detailed drawings and
           specifications
      G    Documentation of unit
           construction
      G    Documentation of unit operation
n    Closure plans
n    Post-closure plans
n    Cover design
G    Design QA/QC demonstration (testing &
      inspection)
n    Facility operation QA/QC demonstration

Waste Characteristics

G    Waste type by name
G    Processes that produced the waste
G    Hazardous properties
G    Physical characteristics
G    Chemical characteristics
G    Biological properties
G    Constituents and percentages of
      constituents
G    Analytical methods and results
G    Projection of waste volume to be
      disposed
G    Quantity of banned waste being disposed
G    Frequency of disposal
G    Period of time waste has been and will be
      disposed
G    Handling procedures
G    Waste treatment before, during and after
      disposal
G    Liquid phase mobility information
G    Gas/particulate mobility
G    Solid phase mobility
G    Dust generation potential
G    Gas-liquid phase interactions
Q    Persistence/degradation potential in unit
      and environment
G    QA/QC demonstration

Waste Transformation and Immobilization

G    Estimation of quantity and quality of
      leachate formation
G    Waste/waste compatibility, interaction,
      reaction products
G    Waste/liner compatibility
G    Assessment of biodegradation potential
G    Assessment of oxidation/reduction
      potential
G    Assessment of immobilization due to
      insolubility
G    Assessment of photodegradation
      potential
G    Assessment of immobilization due to
      hydrolysis
G    Assessment of immobilization due to
      adsorptivity

Site Characterization

G    Surficial geology and soils (regional and
      local)
      G     Topography
      G     Soil types
      G     Soil properties
      G     Depth to bed rock
G    Bedrock geology (regional and local)
      G     Stratigraphy and  lithology
      G     Seismic activity of area
                                           31

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     n    Assessment of ground motion
           potential and degree
     n    G eol og i c c ross secti ons
     n    Degree of bedrock faulting and
           fracturing
     Q    Rock characterization
n   Ground-water hydrology (regional and
     local)
     L"3    Water table map
     n    Seasonal variations in the water
           table
     n     Identification of all aquifers and
            aquitards
      n     Characterization of all aquifers
      n     Vertical and horizontal hydraulic
            conductivity
      []     Aquifer interconnection
      n    Description of ground-water
            monitoring program
      n    Monitoring QA/QC documentation
 [3    Surface water hydrology
      [3    Location of all watersheds
      [3    Map of drainage patterns
      [3    Map of floodplain
      Q    Flood analysis
 n    Meteorology/climatology
      Q    Wind  rose
      n    Precipitation records
      n    Temperature records
      n    Relative humidity records
      n    Maps of storm tracks

 Monitoring Plan

 n    Media to be monitored
 Q    Type of monitoring to be conducted at
      the unit
 n    Location of monitoring stations
 Q    Frequency of monitoring at each station
 n    Specific hazardous constituents to be
      monitored
 fj    Implementation schedule for the
      monitoring program
 n    Equipment used at the monitoring
      stations
 []    Sampling and analytical techniques
      employed
 n    Data record i ng/reporti ng proced u res

 Waste Mobility

 [J    Unsaturated zone soils
      Q    Soil sampling
      n    Soil testing
D    Unsaturated zone physical properties
      n    Volumetric water content
      n    Degree of water saturation
      n    Bulk density
      n    Pressure potential
      fj    Relative permeability
      n    Unsaturated hydraulic conductivity
      fj    Water capacity
      n    Water diffusivity
[H    Leachate characteristics affecting
      mobility
      fj    Leachate characterization
      n    Leachate interactions
Q    Secondary leachate evaluation
n    Evaluation of transport mechanisms
n    Evaluation of fate of contaminants in
      unsaturated zone
n    Vapor concentration of constituents at
      the source
n    Vapor pressure of constituents
n    Solubility data for constituents
n    Activity coefficient
n    Henry's Law constant
n.   Background measurements for air
n    Assessment of volatilization potential

Modeling Evaluation

n    Model accounts for all transport
      mechanisms
Q    Model appropriate for petitioned waste
n    Data input accurate and verified
n    Model tested under field conditions
n    Model is accurate over long time periods
Q    Limitations of model
Q    Model inputs adequately documented
n    Model outputs appropriate and
      reasonable

Assessment of Environmental Risk

Q    Identification of all exposure pathways
      and routes
C]    Identification of all potential receptors
      n    Wildlife
      D    Vegetation
      n    Identification of sensitive or
            endangered species
n    Assessment of bioaccumulation through
      the foodchain

Uncertainty Analysis

[]    Natural Events
                                             32

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D    Climatic fluctuations
D    Glaciation
D    Stream erosion
D    Magmatic activity
D    Epeirogenic displacement
D    Orogenicdiastrophism
G    Oiagenesis
D    Static fracturing
D    Dissolution
D    Sedimentation
D    Flooding
D    Undetected features (i.e. faults,
      lava tubes)
n    Meteorites
D    Fires
n    Hurricanes
Q    Tornadoes
D    Earthquakes
[3    Ground motion
Waste/facility-induced events
n    Thermal effects
n    Chemical effects
n    Mechanical effects
n    Modif ication of hydrologic regime
Human-induced events
Q    Improper design or operation
n    Past intrusions
n    Future intrusions
n    Intentional intrusion
n    Perturbation of ground-water
      system
n    Biosphere alterations
                                        33

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Where can I Obtain Additional Information Concerning "No Migration" Variances?

Additional  information  on  "no  migration"  variances is available from  EPA
Headquarters in Washington, D.C. Facilities considering submitting a petition are
strongly encouraged to meet with the Agency before preparing the petition to
assess the   exact nature of the  information  required in the  "no migration"
demonstration and  the level of detail appropriate for the petition. Questions
concerning petitions and requests for petition meetings should be directed to:

                        U.S. Environmental Protection Agency
                        Permits and State Programs Division
                        401 M Street, S.W.
                        Washington, D.C. 20460
                        Telephone: 202/382-4782

Questions concerning these and other RCRA requirements can also be directed to
the  RCRA/Superfund Hotline  at 800/424-9346  or,  in the Washington,  D.C.
metropolitan area,  202/382-3000.  The  Hotline  can  also  provide  assistance in
obtaining copies of Federal regulations and other relevant guidance documents.

The following is a list of selected documents which may be of value to potential
petitioners:

Permit Applicants' Guidance Manual for the General Facility Standards. 1983.  EPA
SW-968.

Permit Applicants'  Guidance  Manual for Hazardous Waste Land Treatment,
Storage, and Disposal Facilities. 1984.  EPA 530 SW- 84-004.

Hydrologic Simulation at Waste Disposal Sites. 1982. EPASW-868.

Test Methods for Evaluating Solid Wastes, Third Edition. EPA SW-846.

A Method for Determining the Compatibility of Hazardous Wastes. EPA 600/2-80-
076.
                                    34

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A Guide for Estimating the Incompatibility of Selected Hazardous Waste Based on
Binary Chemical Mixtures. 1986. ASTMP-168.

Soil Properties, Classification, and Hydraulic Conductivity Testing. 1984.  EPA SW-
925.

Criteria  for Identifying Areas of Vulnerable Hydrogeology Under the Resource
Conservation and Recovery Act. 1986. NTIS 86-224946.

RCRA Facility Investigation Guidance Manual, Draft Final. May 1987.

Solid Waste Leaching Procedure. 1984. EPASW-924.

Waste Analysis Plan Guidance Manual. 1984. GPO 055-000-00244-4.
                              •

Construction Quality Assurance for Hazardous  Waste Land  Disposal Facilities,
Draft. 1985. EPA/530 SW-85-021.

RCRA Groundwater Monitoring Technical Enforcement Guidance Document, 1986.

Surface  Impoundment Clean Closure Guidance Manual, Draft Final.  September,
1987.

Superfund Public Health Evaluation Manual.  EPA/540-1-86-060.

Guidelines for Carcinogenic Risk Assessment. 51 FR 33992-34003.

Guidelines for the Health Risk Assessment of Chemical Mixtures. 51 FR 34014-
34025.

Integrated Risk Information System (IRIS) Chemical Files. EPA/600/8-86/032b.
                                    35

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          APPENDIX
 DRAFT AIR PATHWAY ASSESSMENT
      METHODOLOGY FOR
'NO MIGRATION" DEMONSTRATIONS
        OCTOBER 1988

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                      TABLE OF CONTENTS
Section                      Title                       Page
   1.0    Introduction                                     1-1

   2.0    Air Pathway Assessment Methodology               2-1
         2.1   Overview                                  2-1
         2.2   Modeling Methodology                     2-3
              2.2.1  Emission Rate Modeling                2-5
              2.2.2  Dispersion Modeling                   2-6
         2.3   Monitoring Methodology                   2-14

   3.0    Example Application                              3-1

   4.0    References                                      4-1

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                      LIST OF TABLES
                         Title                      Page
2-1      Example Adjustment Factors to Account for      2-11
        the Vertical Wind Speed Profile
2-2      Example Unit Boundary Dispersion Factor       2-13
        Values
                     LIST OF FIGURES
                         Title                       Pace
2-1      Air Pathway Assessment Methodology for        2-2
        No-Migration Demonstrations
2-2      Modeling Methodology Overview              2-4
2-3      Step4-CalculateConcentration Estimates        2-8
2-4      Example Subdivision of Area Source             2-10
2-5      Monitoring Methodology-Overview            2-15
3-1      Emission Rate Modeling - Land Treatment        3-2
        Units

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1.0        INTRODUCTION

Tht  Environmental Protection  Agency  promulgated  a final  rulemaking (51  FR 40572) that
established the overall framework for the land disposal restrictions as mandated by the Hazardous
and Solid Waste Amendments (HSWA) of 19W.  A major  requirement of the HSWA is that all
hazardous wastes must be treated using best demonstrated available technology before placement
into the land. Otherwise, the owner/operator is prohibited from land disposal of the waste. Section
3004(d),  (e). and (f) also provides an opportunity for generators, owners, and operators to either
individually or collectively petition for a variance from the prohibition against land disposal of
hazardous  wastes not treated according to Agency standards.  In order to receive a variance, a
petitioner must successfully demonstrate that there will be no migration of hazardous constituents
from the disposal unit or injection zone for as long as the waste remains hazardous [3004(d)(l)l.

A  no-migration demonstration methodology applicable to air releases has been developed.  This
methodology has been based on consideration of the emission and atmospheric dispersion potential
of air contaminants from land disposal units.  Typical hazardous waste disposal units such as land
treatment, surface impoundments, and landfills have the potential for  air contaminant emissions
even with the application of control technology.  Local wind conditions will result in the transport of
these air contaminants  beyond  the  unit  boundary.   Therefore,  the  air pathway  assessment
methodology presented in Section 2, which accounts for these emission/dispersion mechanisms, is
recommended for no-migration demonstrations.  An example application of this methodology is
presented in Section 3.
                                            1-1

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2.0         AIR PATHWAY ASSESSMENT METHODOLOGY

2.1         Overview

The intent of a no-migration petition is to demonstrate that there will be no transport of hazardous
constituents  from  the disposal unit.   Therefore, the  point(s)  of  compliance for air  pathway
assessments should be evaluated at the location(s) of the maximum  air concentration on the unit
boundary.  This approach involves the application of standard emission and dispersion models to
estimate air concentrations for comparison to available inhalation health criteria.

A standard exposure height of 1.5m should  be used for no-migration  air pathway assessments.  This
value corresponds with a typical inhalation height and  facilitates the application of  standard
modeling/monitoring methods.  The vertical profile of air  concentrations may be quite significant
but highly  variable within 1m of the surface due to various microscale atmospheric effects.  It is
frequently difficult to obtain reoresentative air concentration samples or to accurately characterize
dispersion conditions at exposure heights of less than 0.1m on or at the edge of area sources such as
land treatment areas, surface impoundments, and landfills.

A combination of modeling and monitoring approaches can be used to estimate the maximum air
concentration at  1.5m on  the  unit  boundary.   An overview of a recommended air  pathway
assessment methodology for no-migration demonstrations  is  illustrated  in  Figure  2-1.   This
methodology consists of the following major components:

      •     Conduct of an emission rate/dispersion modeling assessment
      • •    Conduct of a confirmatory emission rate/air monitoring assessment.

A modeling assessment should initially be conducted to characterize the air  emission potential for
the disposal  unit and to estimate maximum air concentrations  at the  unit boundary.   The
recommended methodology for the conduct of modeling assessments  is presented in Section 2.2.

A monitoring assessment should also be conducted  to  confirm  modeling estimates. Monitoring
should  be  conducted  at existing  units in  order to  provide  additional  information for EPA
decisionmaking.  Monitoring data  from similar units,  as  available, should  be submitted for no-
migration demonstrations involving new land  disposal  units.  In addition, the EPA may require
confirmatory monitoring as  part  of the permit conditions for  a  unit.   The  recommended
                                            2-1

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                 FIGURE 2-1

AIR PATHWAY ASSESSMENT METHODOLOGY FOR
      NO-MIGRATION DEMONSTRATIONS
                  Conduct
           Emission Rate/Dispersion
            Modeling Assessment

               (See Section 2.2)
           .Conduct Confirmatory
              Emission Rate/Air
           Monitoring Assessment

              (See Section 2.3)
                   Input

                     to
            No-Migration Petition
                    2-2

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methodology for the  conduct of monitoring  assessments  fot  no-migration demonstrations  is
presented in Seaion 2.3.

2-2         Modeling Methodology

The  air pathway assessment modeling  methodology for no-migration demonstrations involves
applying emission rate and dispersion models.  These modeling  results are used to estimate the
maximum air concentrations at the unit  boundary for comparison to health-based criteria.   The
methodology consists of five steps as follows (see Figure 2-2):

      •     Step 1 • Obtain Source Characterization Information:  This information (e.g., unit size,
            waste quantity, etc.) is needed to define the emission potential of a disposal unit.  The
            specific source data needed will be a function of the input requirements of the emission
            rate and dispersion models selected.

      •     Step 2  • Select Release Constituent/Surrogates:  Unit and waste-specific information
            should  be  used  to identify potential  release constituents for modeling purposes. A
            limited  set of surrogates can be selected to represent a wide range of potential release
            constituents. This approach significantly simplifies the modeling process.

      •     Step 3 • Calculate Emission Estimates: Unit-specific  emission models should be used
            based on  source conditions identified in Step 1  for constituents identified in Steo 2.
            These modeling results will provide emission rate estimates.

      •     Step 4 - Calculate Concentration Estimates: Emission  rates from Step 3 should be used
            to calculate concentration estimates at the unit boundary.  Standard  dispersion models
            should be used to obtain these concentration estimates.

      •     Step 5 • Compare Concentration Results to Health-Based Criteria: Concentration results
            from Step 4 should be compared to constituent-specific, health-based criteria presented
            in the RCRA Facility Investigation Guidance (U.S. EPA,  1988).   Chronic exposures for
            carcinogens should be evaluated by comparison of the estimated maximum annual (1-
            year) concentration directly to the annual  average  concentrations  (based on health
            criteria and assuming a 70-year exposure).  Interpretation of the ambient concentration
            estimates  should  account for the uncertainties associated with  the source/waste
                                            2-3

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             FIGURE 2-2

MODELING METHODOLOGY OVERVIEW
               Stepl

            Obtain Source
     Characterization Information
               Step 2

            Select Release
       Constituents/Surrogates
               Step 3

          Calculate Emission
              Estimates
                Step 4

        Calculate Concentration
              Estimates
                StepS

          Compare Results to
         Health-Based Criteria
                 1
               Input to
         No-Migration Petition
                2-4

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            characterization data,  and modeling inaccuracies.  It is also  necessary to consider
            background concentrations and contributions from other sources.

An expanded discussion of this five-step process is available in the Air Release Screening Assessment
Methodology. (U.S. EPA, 1988).

Recommended  emission  rate methods and dispersion modeling methods  as  they  apply  to  no-
migration demonstrations are presented in Section 2.2.1 and 2.2.2, respectively.

2.2.1        Emission Rate Modeling

Air emission models can be used to  estimate constituent-specific emission rates based on waste/unit
input data for many  types of waste management units.  (An emission rate is defined as the source
release rate for the air pathway in terms of  mass per unit time.)  The models applicable to land
disposal units are based upon theoretical considerations and have been evaluated against pilot-scale
and field test results. Often these models are empirically correlated. However, because the models
attempt to predict complex physical and chemical phenomena, they should be used carefully. These
models are generally considered accurate within an order of  magnitude (assuming representative
input data) for short-term emission rate estimates. Accuracies for long-term estimates are more
favorable and are also limited by mass balance considerations (i.e., the emission rate cannot exceed
the waste input to the disposal unit).

The  modeling  methodology for no-migration  demonstrations  is  based  on  the application of
CHEMOAT6 air emission  models (applicable to  releases of volatile organics) developed by EPA's
Office of Air Quality  Planning and Standards and available from NTIS.  (U.S. EPA, December 1987).
CHEMDAT6 includes air emission rate models for the following land disposal units:

      •     Land treatment
                 Oil film surface
                 Land treatment soil
      •     Disposal  impoundment
      •     Landfills
                 Open landfills
                 Closed landfills
                                            2-5

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Comprehensive technical information  regarding  these  CHEMDAT6  models is  presented  in  the
Hazardous Waste Treatment. Storage and Disposal Facilities (TSDP) Air Emission Models.  (U.S. EPA,
December 1987). This reference also presents air emission  rate models for many other units.

The potential variability of the waste and unit input data should be accounted for in the modeling
assessment.  Therefore,  a sensitivity analysis of this variability relevant  to emission rate estimates
should be conducted to determine the  level of confidence associated with the emission modeling
results.

For some applications,  Step 4 - Calculate  Concentration Estimates will not warrant the  use of
emission models because it can be assumed that all the volatile wastes handled will eventually be
emitted to the air. This assumption is generally appropriate for highly volatile organic compounds
placed in a disposal unit like a surface impoundment,  in these cases, the air emission rate  can be
assumed to be equivalent to the disposal rate, so that an  emission rate model may not be required.
                                                             »
This assumption is valid because of the long-term residence time of wastes in the disposal units. In
open  units like  surface  impoundments,  a substantial  portion  of the volatile constituents  will
frequently be released to the atmosphere within several days.  However, for more complex situations
(e.g., land treatment units and tandfills), air emission models can be used to obtain a more  refined
release rate.

2.2.2        Dispersion Modeling

Emission rate  values from  Step 3  should  be  used as  modeling input to calculate concentration
estimates at the unit boundary.  Two alternative types of models  (i.e., flux  models and  dispersion
models) are candidates for this application.

Flux models can  be used to evaluate concentrations at and in the vicinity of an area source. (Most
disposal units such as land treatment areas, surface impoundments, and landfills can be classified as
area sources.)  Although these models can be technically sophisticated, they generally lack extensive
validation.

Standard dispersion models used by EPA for regulatory  applications are based  on the assumption
that the downwind concentration of air  contaminants can be characterized by a statistical (Gaussian)
distribution.   Validation  efforts  have  confirmed the  performance  of  this  class of   models.
Atmospheric dispersion models are typically accurate within a factor of two to three for'flat terrain
sites (inaccuracy  can be a factor of 10 m complex terrains).  However, validation studies  have been
                                            2-6

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quit* limited in regard to receptors  near an  area source boundary.  However, dispersion model
predictions for such situations are still  considered more dependable than the use of flux models
which have little, if any, validation.  Therefore, the use of dispersion models is recommended for no-
migration demonstrations.

The use of the Industrial Source Complex (ISC) model is recommended as a prime candidate for no-
migration demonstrations.  The ISCLT  version of the  model can be used to calculate long-term
concentrations for exposure periods ranging from 24 hours to annual average estimates.  The model
can be used for both flat and rolling terrain. The ISC model software is available from NTIS and the
user's guide is presented in Industrial Source Complex (ISC) Model User's Guide. (U.S. EPA, 1987).

Additional guidance on dispersion model selection and application is available in the Guideline on
Air Quality Models (Revised). U.S. EPA, July 1986).

Meteorological data (i.e., wind and atmospheric  stability summaries)  are necessary dispersion
modeling input.  Data from a representative National Weather Service station can be  used as
available. Alternatively,  onsite meteorological data  can be used.  Guidance on the conduct of
meteorological programs is presented in Qn-Site Meteorological Program Guidance for Regulatory
Modeling Applications. (U.S. EPA. June 1987).

Two alternative dispersion modeling  approaches are available for no-migration demonstrations, as
illustrated in Figure 2-3.  The primary approach involves the direct application of the ISC dispersion
model  based on site-specific and unit-specific input data.  The alternative (screening) approach
involves the application of modeling results available for a limited set of source and meteorological
conditions. Following is a description  of each of these approaches.

Primary Approach

The  conduct of a dispersion  modeling study based on  site/unit-specific model  input data  is the
recommended approach for no-migration demonstrations. This refined modeling approach involves
the direct use of the ISC dispersion model to provide direct estimates of concentrations. This involves
the following tasks, as indicated in Figure 2-3:

      •     Determine the point of the maximum concentration 100m from the source.
      •     Subdivide the source area into multiple smaller source areas.
                                            2-7

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                               FIGURE 2-3

             STEP 4 - CALCULATE CONCENTRATION ESTIMATES
  Emission Rate Data
       (Step 3)
      Meteorological Data
Primary approach • conduct
site/unit-specific modeling
       based on ISC
  Screening approach • based on
  available modeling results for a
limited set of source/meteorological
            conditions
   Determine maximum
concentration point 100m
       from source
    Calculate concentrations
       based on available
       dispersion factors
   Subdivide source into
  multiple smaller source
          areas
     Adjust concentrations
       based on prevailing
    wind direction frequency
   Determine maximum
   concentration at unit
        boundary
      Adjust concentration
     estimates based on site-
   specific average wind speed
                                                       I
    Adjust results for
      vertical wind
         profile
       Adjust concentration
    estimates based on vertical
        wind speed profile
                           Input to Step 5-
               Compare Results to Health-Based Criteria
                                   2-8

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      •     Determine the maximum concentration at the unit boundary.
      •     Adjust modeling results, as necessary, to account for the vertical wind profile.

Dispersion  modeling estimates  should  be obtained  which are representative of unit boundary
conditions.  A specialized modeling  approach is generally needed for standard dispersion models,
such- as ISC, in order to obtain concentration estimates  near the boundary of a large area source. This
approach consists of the following tasks, assuming a ground-level area source:

      •     Determine the point of  maximum concentration at  approximately 100m from the unit
            boundary  using standard  dispersion  modeling  methods.    This  is  a  standard
            computational distance  for the ISC model. Concentration estimates should be obtained
            for  16  sectors  of  22.5 degrees  each  in order to  select  the  point of  maximum
            concentration.  These results will provide the basis to identify the 22.5 degree sector
            associated with the  maximum concentration.

      •     Estimate the concentration at the unit boundary for the 22.5 degree sector associated
            with the maximum concentration point located  100m  from  the boundary.   (For
            modeling purposes, a downwind distance of approximately 1m from the unit boundary
            can  be  used for  this estimate as necessary.) Contributions to the receptor from all  16
            sectors should be accounted for.

The concentration at 1m from the unit boundary can be obtained from ISC results by subdividing the
source area into multiple smaller areas (see Figure 2-4). Computational restraints of ISC require that
area sources must be represented as a square or multiple squares.  (The ISC user's guide should be
•onsulted  for the  approach to use  for irregularly shaped  area sources.)  For  no-migration
demonstrations, it is recommended that the land disposal area should be  represented by 25 squares
of equal area.

The square along the edge of the unit boundary nearest to the point of maximum concentration
should be further subdivided  if the side of this square  is greater than 10m. This approach will ensure
a representative concentration estimate at the unit boundary (i.e., 1m downwind).

Concentration estimates  for no-migration  demonstrations should be representative  of  a 1.5m
inhalation height.  Meteorological data available  for most modeling studies are based on a  10m
tower height.  Air concentrations are inversely  proportional to  wind speed.  Near the surface,  the
mean wind speed has been found to  increase  m  proportion to the  logarithm  of the height.
                                            2-9

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                              FIGURE 2-4

                 EXAMPLE SUBDIVISION OF AREA SOURCE

                             Wind Direction
Point of maximum
concentration at unit
boundary
Nested subdivisions, as
necessary to yield areas
of <100m*
Point of maximum
concentration 100m
from unit boundary
                                 2-10

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Therefore, wind speed values or modeling results should be adjusted, as necessary, to account for the
vertical wind profile. Example wind profile adjustment factors are presented in Table 2-1 based on
the logarithmic wind profile law. (U.S. EPA, 1974).

                                         Table 2-1
     EXAMPLE ADJUSTMENT FACTORS TO ACCOUNT FOR THE VERTICAL WIND SPEED PROFILE*
Wind Speed Measurement
Height X (m)
20.0
15.0
10.0
5.0
2.0
1.5
Wind Speed Adjustment
Factor (Ratio of Wind Speed
(1.5m) to Wind Speed
(Height X)]
0.7
0.7
0.7
0.8
0.9
1.0
Concentration Adjustment
Factor (CAP) [Ratio of
Concentration (1 .5m) to
Concentration (Height X)]
1.5
1.4
1.4
1.2
1.1
1.0
    * Assuming neutral stability and uniform surface roughness.

Screening Approach

Screening dispersion modeling is an alternative to the refined modeling approach. The screening
approach involves the manual calculation of concentration estimates based on adjusting dispersion
modeling results available for a limited set of source/meteorological conditions. Since these results
may be less  representative  than those  based on the refined modeling  approach,  conservative
assumptions should be used.  Following are the tasks involved in the conduct of screening modeling
as indicated in Figure 2-3:

      e    Calculate concentration estimates at the  unit boundary based on available dispersion
           factors

      •    Adjust concentration estimates to account for the frequency of the prevailing wind
           direction

      •    Adjust concentration estimates to account for the site-specific average wind speed
                                           2-11

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      •    Adjust concentration estimates to account for the vertical wind profile.
This process can be summarized by the following equation:
                           WDF         10
     C  = ERxDFxUCFx   	  x  	 x CAP                        Equation 2-1
                            100          WS
Where
      C     =    concentration at unit boundary (ug/m3)
      ER    =    emission rate (106g/yr = Mg/yr)
      OF    =    dispersion factor for appropriate source area (sec/m3)
      UCF   =    unit conversion factor (317)
      WDF  =    frequency of occurrence of the prevailing wind direction (percent)
      WS   =    average wind speed 1.5 (mph)
      CAP   =    concentration adjustment  factor  to  account for  the  vertical  wind  profile.
                 (dimensionless)

The product of ER times OF times UCF yields an initial concentration estimate.  The emission rate
estimates from Step 3 should be used as ER values.  Dispersion factor (DF) values can be obtained
from Table 2-2 as a function of source area. These DF values are based on ISCLT dispersion equations
for a receptor on  the downwind unit edge assuming  a square area  source configuration (with no
subdivisions of the area), neutral stability, 10 mph winds at a measurement height of 10m and an
invariant wind direction (i.e., the receptor point for calculation purposes is directly downwind of the
source 100 percent of the time).

This initial concentration estimate should be adjusted  (using the parameters WDF, WS and  CAP) to
account  for site-specific wind  conditions.   Representative National Weather Service or onsite
meteorological data should be used as the basis for these adjustments.
                                           2-12

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                                        TABLE 2-2
                   EXAMPLE UNIT BOUNDARY DISPERSION FACTOR VALUES
Unit Area
(Hectares)
0.01
0.04
0.25
1.00
4.00
25.00
100.00
400.00
Dispersion Factors*
(sec/m3)
3.9 x 10-3
2.6x10-3
8.9 x 10-*
2.8 x 10-»
7.9x 10-5
1.5x 10-5
43x10-6
1.4x 10-6
           a   Based on ISCLT results with the following assumptions:
              •  Ground-level area source (square configuration)
              •  Average wind speed of 10mph at a measurement height of 10m
                 (dispersion factors do not account for the expected lower wind
                 speeds at 1.5m exposure height)
              •  Invariant wind direction
              •  Dispersion factors are the maximum value at the unit boundary
The receptor should be assumed to be within the 22.5 degree sector associated with the prevailing
wind direction (i.e., the direction with the highest frequency of occurrence). Therefore, the WDF
parameter should be used to account for this condition.

The modeling results presented in Table 2-2 are based on a 10 mph wind speed. The average wind
speed (WS) at the site should, therefore, be used to adjust these  modeling results.   Similarly, a
concentration adjustment factor (CAP) should be used to account for the vertical wind speed profile.
Values of CAP are  presented in Table 2-1 for a range of wind measurements heights to facilitate
scaling concentration modeling results to represent a 1.5m inhalation exposure.

An example application of this approach is illustrated m Section 3.
                                           2-13

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2.3         Monitoring Methodology

A monitoring program  may also be appropriate to confirm modeling estimates.  This may involve
emission rate monitoring  and/or air  concentration  monitoring  as  illustrated in  Figure  2-5.
Recommendations for the conduct of an acceptable monitoring program are presented in the RCRA
Facility Investigation Guidance. (U.S. EPA, 1988).

Emission rate monitoring can  be used  in  conjunction  with  dispersion modeling to  estimate
concentrations at the unit boundary.  (An appropriate dispersion modeling methodology has been
discussed in Section 2.2.)  Direct emission  sampling should be used for point sources (e.g., vents at
closed landfills).   An isolation flux chamber  may be used for area source emission measurements
(e.g., land treatment areas).  Multiple sampling locations are required to adequately characterize the
spatial variability of emission conditions over an area source. Further guidance on the application of
isolation flux chambers is provided in Measurement of Gaseous Emission Rates from Land Surfaces
Using an Emission isolation Flux Chamber:  User's Guide. (U.S. EPA, 1986).

Air monitoring at  the  unit  boundary is  an  alternative approach for  characterizing area source
emissions.  This facilitates the direct measurement of air concentrations at the point of compliance.
However, the selection of appropriate monitoring locations is critical to ensure the measurement of
the maximum concentration.  Also,  the monitoring program duration must  be adequate to
determine  maximum concentrations  for  averaging  periods commensurate with health criteria.
Additional  recommendations for the  conduct of air monitoring programs are presented in  RCRA
Facility Investigation Guidance. (U.S. EPA, 1988).

Representative meteorological data should be available as dispersion modeling input to  calculate
concentration estimates based on emission rate monitoring results. Meteorological data will also be
necessary to interpret air monitoring  results.  Recommendations on the conduct of meteorological
programs are presented  in  On-Site  Meteorological  Program Guidance for Regulatory Modeling
Applications. (U.S. EPA, June 1987).

Monitoring results  should be compared to health criteria as discussed  in Step 5  of the modeling
methodology (see Section 2.1).
                                           2-14

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                           FIGURE 2-5
             MONITORING METHODOLOGY • OVERVIEW
                    Modeling Assessments
    Emission
   Monitoring
Direct Emissions
 Source Testing
for Point Sources
      t
                      Representative
                      Meteorological
                        ata Available,
                    No
\
1
/
ves
r
Conduct
Monitoring

Conduct
Meteorological
Monitoring



                           Air
                       Monitoring
                     Emission  Monitoring
 Isolation Flux
   Chamber
for Area Sources
Unit Boundary
     Air
Monitoring for
 Area Sources
                I
             Conduct
        Dispersion Modeling
                    Input to No-Migration Petition
                              2-15

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 3.0         EXAMPLE APPLICATION

 The following cast study has  been selected to demonstrate the recommended  air pathway
 assessment methodology for no-migration demonstrations. This case study also includes an example
 application of the screening dispersion modeling approach.

 The case study involves a no-migration petition for a new land treatment unit at a site which also has
 similar existing units.  Following is a synopsis of the modeling assessment for the new unit.

 Step 1 • Obtain Source Characterization Information

 The following information describes the proposed land treatment unit:

      •     Land area = 2.5 hectares
      •     Annual waste throughput =  1,800Mg
      •     Oil content of waste = 10 percent by weight
      •     Tilling depth = 20cm
      •     Soil air porosity = 0.5
      •     Soil total porosity = 0.61
      •     Average molecular weight' = 282 g/g mol

£teo 2 • Select Release Constituents/Surrogates

 An evaluation of the expected waste constituents indicated that benzene was the constituent with
 the greatest potential volatility and most restrictive health criteria.  Therefore, benzene was selected
 to represent the total volatile organic concentration (2,000 ppm  by weight) of the oil content of the
 waste.  Therefore, the  benzene concentration was  conservatively assumed to be 2,000 ppm by
 weight of the oil.

 Step 3 • Calculate Emission Estimates

 The emission  rate  modeling process for land treatment  units  is summarized in Figure 3-1.  Air
 emissions can occur during three stages (i.e., during waste application, after waste application, prior
 to tilling, and after tiling).  The appropriate emission rate models are also a function of the type of
 waste application (i.e., surface or subsurface injection) as well as the fate of the oil prior to  tilling
 (i.e.,  formation of a surface oil  film, oil seepage  through  a  layer of the soil, or the waste  is
 immediately
                                             3-1

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                                       FIGURE 3-1
                    EMISSION RATE MODELING • LAND TREATMENT UNITS

                              Sourca/Constituant Information

                    |   Calculate Emissions from Wast* Application   I
                      I
Surfaca
Application  / Wasta
              Application
                Moda
                                                     Subsurfaca
                                                     Injaction
          j Wasta Application Modal* \
                           1
                   Nagligibla Emiiiions    |
                       Calculata Emissions aftar Wasta Application
                                  and Bafora Tilling
                        Surfaca
                        Oil Film
               Saapaga
               Layar
                               Immtdiata
      Tilling
                 CHEMOATC
                Oil Film Modal
                    I
Nagligibla
Emissions
                                     CHEMOATC
                                   Land Traatmant
                                       Modal
                            Calculata Emissions aftar Tilling
                                     CHEMOATC
                                    Land Traatmant
                                        Moc'al
                              Input to Oisparsion Modal


*  Equations prasantad in Hazardous Wasta Traatmant. Storaaa. and Disposal Facilitias-Air
   EmiisionsModalsfU.S. EPA, Dacamb«r 1917)
                                       3-2

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tilled into the soil).  For this case study, it has been assumed that the unit will use subsurface injection
followed by immediate tilling. Modeling results are summarized below for benzene:

          Emission Source                  Model                   Emission Rate
     •   Subsurface injection              Not applicable                 Negligible
     •   Immediate tilling                Not applicable                 Negligible
     •   Soil after til I ing            CHEMDAT6 land treatment            0.33 Mg/yr
                                          model

Step 4 • Calculate Concentration Estimates

The screening dispersion modeling approach was selected for this case study.  Representative wind
data were available from the National Weather  Service.  The frequency of the prevailing wind
direction is 10 percent and the average wind speed  is 8 mph (at a measurement height of 10m).

A maximum concentration at the unit boundary was estimated as follows:
     C  s ERxOFxUCFx   	  x  	 xCAF                        Equation 3-1
Where
      C     =    benzene concentration at unit boundary (ug/m*)
      ER    =    benzene emission rate (0.33 Mg/yr)
      DP    »    dispersion factor for source area of 2.5 hectares based on Table 2-2 (interpolated
                 value of 1.2x10"*sec/m3)
      UCF   a    unit conversion factor (317)
      WDF  =    frequency of occurrence of the prevailing wind direction (10 percent)
      WS   =    average measured wind speed (8 mph)
            =    concentration  adjustment factor from Table 2-1 to account for the lower wind
                 speeds at the 1.5m receptor height compared to 10m wind measurement height
                 (1.4)
                                           3-3

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Therefore:
      C = (0.33) x(1.2x10-4) x (317) x  ——  x   ——  x 1.4               Equation3-2
                                     100          8                             ^

         =  0.002 ug/m3
Step 5 • Compare Concentration Results to Health-Based Criteria

A carcinogenic risk-specific  dose of 0.12 yg/m3 for benzene  is presented in the RCRA Facility
Investigation Guidance.  (U.S. EPA, 1988). The estimated unit boundary concentration from Step 4
(0.002 ug/m3) is lower than this health-based criteria. Background concentrations of benzene at this
site due to emissions from existing units should also be accounted for.

A monitoring program was conducted at the site to confirm modeling estimates.  A combination of
emission rate measurements  and  air monitoring data at the boundary of an existing land treatment
unit during worst case emission/dispersion conditions as well  as at  locations  representative  of
background air concentrations was obtained.  These monitoring data  confirmed that benzene
concentrations  at the  unit  boundary (including  background  conditions) do not exceed health
criteria.
                                            3-4

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 4.0         REFERENCES

 U.S. EPA.  1988.  RCRA Facility Investigation Guidance. EPA.53Q/SW.a7.om  Office of Solid Wast*.
 Washington, O.C 20460.

 U.S. EPA. 1988. Air Release Screening Assessment Methodology. Office of Solid Wast*  Washington,
 D.C. 20460.

 U.S. EPA.  1987.  On-Site Meteorological Program Guidance for Regulatory Modeling Applications.
 EPA-450/4-87-013. Office of Air Quality Planning and Standards. Research Triangle Park, IMC 27711.

 U.S. EPA.  December 1987.  Hazardous Waste Treatment Storage and Disposal Facilities (TSDF) Air
 Emission  Models).   EPA-450/3-87-026.  Office of Air Quality Planning and Standards.   Research
 Triangle Park, NC 27711.

 U.S. EPA. December 1987.  Industrial Source Complex (ISO Model User's Guide-Second Edition.  EPA-
 450/4-88-002a and  b.  Office of Air Quality Planning and Standards.  Research Triangle Park, NC
 27711.

 U..S. EPA.  February 1986.  Measurement of Gaseous Emission Rates from  Land Surfaces Using an
-Emission  Isolation   Flux  Chamber:    User's Guide.   EPA/600/8-86/008.    NTIS PB  86-223161.
 Environmental Monitoring Systems Laboratory. Las Vegas, NV 89114.

 U.S. EPA.  July 1986. Guideline  on Air Quality Models (Revised).  EPA-450/2-78-027R.  NTIS PB 86-
 245248.  Office of Air Quality Planning and Standards. Research Triangle Park, NC 27711.

 U.S. EPA.  1974.  Development of Emission  Factors for Fugitive Dust Sources.  Office of Air Quality
 Planning and Standards. Research Triangle Park, NC 27711.
                                             4-1

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