PB88-185269
TECHNICAL GUIDANCE FOR CORRECTIVE
MEASURES: DETERMINING APPROPRIATE
TECHNOLOGY  AND RESPONSE FOR AIR RELEASES
Alliance  Technologies Corporation
Bedford/  MA
 Mar 85
                U.S. DEPARTMENT OF COMMERCE
              National Technical Information Service

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                                                                    GCA-TR-85-43-G
                                    Prepared  for
                                                                    PB88-185269
                        U.S.  ENVIRONMENTAL  PROTECTION AGENCY
                               Office of Solid Waste
                               Land Disposal  Branch
                              Washington, D.C.  20460


                              Contract No.  68-01-6871
                              Work Assignment No. 45

EPA Project Officer                                              EPA Task Officer

   Jon R. Perry                                                      Art Day
                               TECHNICAL GUIDANCE FOR
                               CORRECTIVE MEASURES-
                              DETERMINING APPROPRIATE
                              TECHNOLOGY AND RESPONSE
                                  FOR  AIR  RELEASES

                                 Draft Final  Report
                                     March  1985
                                    Prepared by

                                    Mark Arienti
                                   Andrew Baldwin
                                  Michael Kravett
                                  CCA CORPORATION
                              GCA/TECHNOLOGY DIVISION
                            Bedford, Massachusetts  01730

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 REPORT DOCUMENTATION
        PAGE
1. REPORT NO.
  EPA/530-SW-88-021
3. Recipient's Accession No.
    - 185289ZAS
4. Title end Subtitle
 Technical Guidance for Corrective  Measures Determining
 Appropriate Technology  and  Response  for Air Releases
                                                   5. Report Oete
                                                     March 1985
7. Author(i)
   Mark Arienti,  etc.
                                                   8. Performing Organization Rept. No.
9. Performing Organisation Name and Address
   GCA  Corp.
   GCA/Technology Division
   Bedford, MA  01730
                                                   10. Project/Task/Work Unit No.
                                                      WA  45
                                                   11. Contract(C) or Grant(G) No.
                                                   
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                                    ABSTRACT


     The reauthorization of the Resource Conservation and Recovery Act (RCRA)
requires that all treatment, storage, and disposal facilities (TSDFs) which
apply for a permit which release hazardous waste or constituents from any
solid waste management unit at the facility must remedy such release as a
condition for permit issuance.  The purpose of the guidance document is to
assist EPA/State personnel in implementing the new corrective action
provisions by providing a central source of information on air emissions
control technologies and techniques for hazardous waste TSDFs.  This document
provides RCRA permit writers with descriptions of waste management unit design
and operation practices which prevent or control vapor and particulate
releases from containerized waste storage, storage tanks, surface impoundments,
landfills, land treatment and waste piles.  In addition, control technology
transfer from the industrial/commercial sector to the hazardous waste
management industry is discussed.
                                       111

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                                    CONTENTS
Figures. .«	        vi
Tables	       vii

     1.   Introduction	       1-1
               Background	       1~1
               Purpose of Document	       1-2
               Document Organization 	       1-3
               Other Guidance Documents	       1-3
     2.   Summary of Corrective Actions	       2-1
               Overview	       2-1
               Examples of Corrective Measures 	       2-1
               Factors to Consider in Selecting Corrective
                 Measures. ....... 	       2-14
               References	       2-25
     3.   Control of Emissions from Containerized Waste	       3-1
               Introduction.  ..... 	       3-1
               Storage Modifications 	       3-5
               Spillage Containment	       3-11
               Container Modification	       3-22
               Operating Practices 	       3-29
               References	       3-35
     4.   Control of Emissions from Storage Tanks	       4-1
               Introduction	       4-1
               Roofs	       4-8
               Covers	       4-26
               Insulation.	       4-36
               Vapor Control  Systems	       4-42
               References	       4-52
     5.   Control of Emissions from Surface Impoundments  	       5-1
               Introduction	       5-1
               Covers.	       5-2
               Aerodynamic Modifications  	       5-13
               Vapor Control  Systems	       5-18
               Operating Practices 	       5-21
               References	       5-26
     6.   Landfills	       6-1
                Introduction	       6-1
               Soil Covers	       6-2
               Synthetic Covers	       6-10
               Foam Covers	       6-15
               Encapsulation/Solidification	       6-17
                                        IV

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                         CONTENTS (continued)
          Gas Collection	„	       6-20
          Air-inflated Structures 	       6-24
          References	.	       6-28
7.    Control of Air Emissions from Land  Treatment Facilities        7-1
          Introduction	       7-1
          Changes in Operating Practices	       7-1
          Covers	.	       7-8
          Air-inflated Structures 	       7-10
          References	       7-12
8.    Control of Air Emissions from Waste Piles	       8-1
          Introduction	       8-1
          Stabilization 	       8-5
          Windscreens	       8-10
          Covers	       8-12
          Gas Extraction	       8-15
          Changes in Operational Practices	  .       8-17
          References	       8-21

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                                     FIGURES
Number                                                                  Page
  2-1     Flow chart for determining an appropriate corrective
            action	      2-2

 3-1      Apparatus for encapsulating 208-liter (55-gal) drums
            holding hazardous wastes	      3-25

 3-2      EPP overpack welding unit	      3-26

 3-3      Side view of the polyethylene fusion mold	      3-27

 4-1      Pan-type floating roof tank	      4-12

 4-2      Pontoon-type floating roof tank  .  .	      4-12

 4-3      Double-deck floating roof	      4-15

 4-4      Rim-mounted secondary seals on external floating roofs.  .      4-17

 4-5      Metallic Shoe Seal with shoe-mounted secondary seal .  .  .      4-19

 4-6a.    Interlocking configuration. . 	      4-29

 4-6b.    An uncovered cleaning tank emits large volumes of
            corrosive acid steam.	      4-29

 4-c.     A single layer of ALLPLAS balls  floating on the surface
            of  the same temperature, virtually eliminates acid
            emissions	      4-29

 4-7      Refrigerated vent condenser system	      4-45

 4-8      Activated-carbon adsorption system	      4-47

 4-9      Thermal oxidation unit	      4-49

 6-1      Two typical layered soil cover systems	      6-6

 6-2      Encapsulation process concept 	      6-19

 6-3      Pipe  and trench vents	      6-22

                                       vi

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                                     TABLES
Number                                                                  Pa§e


 2-1      Primary Corrective Actions for Example Sources of Air
            Emissions at TSDFs	<•  °       2-3

 2-2      Air Emission Control Technologies/TSDF—Matrix.  . .  . .  .       2-11

 2-3      Probable Corrective Actions as a Function of the Level of
            Release	       2-16

 2-4      Cost and Reduction Efficiency of Air Emission Control
            Technologies	»	       2-17

 3-1      Advantages and Disadvantages of Containerized Waste
            Emission Control Alternatives 	 ......       3-2

 3-2      Rating of Efficiency of Current Response Techniques to
            Control Evaporation 	  .       3-16

 3-3      Matrix of Foam Capabilities to Suppress or Otherwise
            Minimize the Release of Toxic or Flammable Vapors from
            Spilled Hazardous Chemicals as Listed 	       3-17

 4-1      Advantages and Disadvantages of Storage Tank Emission
            Control Alternatives	       4-2

 4-2      Cost of Building a Fixed-Roof Tank	       4-22

 4-3      Cost of Building an External Floating Roof Tank 	       4-23

 4-4      Cost of Installing a Contact Single Seal Internal Floating
            Roof	       4-24

 4-5      Cost of Installing a Noncontact Single Seal  Internal
            Floating Roof	„	       4-25

 4-6      Evaporation Reduction Achieved by Various Energy-
            Reducing Methods	       4-32

 4-7      Number of Floating Spheres Required per unit Area and
            Volume	       4-34

                                       vii

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                              TABLES (continued)
4-8      Costs of Various Types of Floating Spheres	      4-35

4-9      Relative Effectiveness of Paints in Keeping Tanks from
           Wanning in the Sun	„	      4-38

4-10     Permeability and Moisture Absorption	      4-40

4-11     Published Thermal Performance	      4-41

5-1      Advantages and Disadvantages of Surface Impoundment
           Control Alternatives	      5-3

5-2      Synthetic Cover Characteristics . 	  .      5-10

5-3      Evaporation Suppression by Shades ..... 	      5-17

6-1      Landfill Emission Technologies—Advantages and
           Disadvantages	      6-3

6-2      Unit Emissions Through 12-Inch Soil Covers for Soils of
           Different Dry Porosity.	      6-8

6-3      Chemical Resistance Chart (DuPont)	      6-12

6-4      Permeation Rates for Organic Chemical Vapors Through
           Synthetic Membranes 	      6-13

6-5      Estimated Unit Costs for Some Synthetic Membranes ....      6-14

6-6      Capital Costs for Air-inflated Structures 	      6-27

7-1      Land Treatment Emission Control Technologies—Advantages
           and Disadvantages	      7-2

7-2      Annual  Emissions from a Theoretical 1 Acre Land
           Treatment Area	      7-6

8-1      Waste Pile Emission Control Technologies—Advantages and
           Disadvantages 	      8-2

8-2      Cost and Relative Effectiveness of Some Chemical
           Stabilization Agents	      8-8

8-3      Approximate Storage Dome Costs	      8-16
                                     Vlll

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                                    SECTION  1
                                  INTRODUCTION

BACKGROUND

     The 1984 amendments to the Resource Conservation and Recovery Act (RCRA)
provide the Agency with additional authorities for corrective action at
facilities seeking permits and for facilities with interim status under
Section 3005(e).  The amendments for corrective action address:

     •    continuing releases at permitted facilities (Section 206);
     •    corrective action beyond facility boundaries (Section 207);
     •    financial responsibility for corrective action (Section 208); and
     •    interim status corrective action orders (Section 233).

The new authorization allows EPA to require corrective action in response to a
release of hazardous waste or constituents from any solid waste management
unit to the environment regardless of when the waste was managed.  This
authority includes releases to all media, including air.
     Currently, there are no regulatory requirements for monitoring ambient
air surrounding hazardous waste management facilities or emissions from such
facilities, or  to submit such data with a permit application should the data
exist.  Thus, the methods available for determining whether air releases are
occurring, or can potentially occur, from a hazardous waste management
facility are limited to the use of data submitted by the permit applicant.
     The Office ot Air Quality Planning and Standards (OAQPS) has been given
the responsibility for developing regulations for area-source emissions from
hazardous waste treatment, storage, and disposal facilities (TSDFs).   In this
                                       1-1

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effort, OAQPS is currently evaluating the use of predictive models  for
quantifying and assessing the health impact associated with TSDF  air
releases.  Due to the current state of development of these efforts and  the
lack of a substantial base of field validation data, OAQPS has  suggested that
guidance should be presented in such a way that it can be used  as a "flagging
tool" for identifying those sites which are obvious contributors  of air
releases.  Once those sites are identified, some type of corrective action or
measure will be required to reduce the magnitude of, or eliminate the cause  of
the air release.  As such, the guidance provided in this document identifier
the corrective actions and technologies that may be utilized to control  air
emissions at hazardous waste management facilities.

PURPOSE OF DOCUMENT

     The purpose of the guidance presented in this document is to identify
corrective actions or specific technologies which will minimize or eliminate
the cause of atmospheric releases from hazardous waste TSDFs.  Prior to
determining the appropriate methods that will minimize the atmospheric release
of hazardous waste constituents, the permit writer must first be  aware of the
types of compounds and facility practices that can potentially lead to ambient
air releases.  Supported by this background information (which is presented
in:  "Technical Guidance for Corrective Measures - Identifying Air Releases")
the permit application can be reviewed to identify if these compounds and
practices of interest are in use at the waste management facility.  If
identified, corrective measures can then be recommended or required to reduce
these air releases.
     This document was developed for use as an index of technologies
applicable to controlling air emissions from TSDF operations.  A  large variety
of technologies have been described and their effectiveness regarding both
cost and reduction of emissions has been evaluated.  Various technologies, or
combinations of technologies may be applicable to any specific situation.  The
determination of the most appropriate technology and response will depend on
site-specific factors.  Consequently, the information presented in this
document is general in nature, and the ultimate decision of the appropriate
corrective measure to recommend is left to the permit writer.
                                       1-2

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DOCUMENT ORGANIZATION

     Section 2 presents a summary of the corrective measures and  technologies
for controlling air releases.  Corrective measures for certain  types of  air
releases are listed, and technologies are categorized by  the specific  function
that they serve.  In addition, a summary of data on cost  effectiveness and
reduction efficiency is presented.
     Sections 3 through 8 present, by facility type, information  concerning
various methods for controlling air emissions at hazardous waste  management
facilities.  Control technologies for the three facility  types which emit
primarily vapor phase releases (containers, storage tanks and surface
impoundments) are discussed  in Sections 3, 4, and 5, while the  facility  types
which have the potential for emitting both vapor phase and particulate
emissions (landfills, land treatment, and waste piles) are discussed in
Sections 6, 7, and 8.  For each of the control technologies which is
applicable to a facility type, information is presented to describe the
control technology, its particular application to the facility, the cost of the
control technology, and its  effectiveness in reducing air emissions.  Certain
control technologies may have multiple applications.  In  these cases, the
technology will be described in detail in the discussion  of the first facility
type.  Reference to the original discussions will be made for subsequent
applications.

OTHER GUIDANCE DOCUMENTS

     Two additional technical guidance documents will be  available  for
determining the extent which corrective measures for air  releases are
necessary.  These documents  published respectively in the spring  and summer of
1985 are entitled:
          Technical Guidance for Corrective Measures—Identifying Air
          Releases; and
          Technical Guidance for Corrective Measures—Assessing Emissions
          Distribution and Impact.
                                       1-3

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                                    SECTION  2
                          SUMMARY  OF CORRECTIVE  ACTIONS

OVERVIEW

     Facilities which propose unacceptable design and/or operating practices,
and those that fail to explicitly state these practices, are candidates for
corrective measures for reducing air releases.  These measures are intended to
minimize or eliminate hazardous constituent emissions by correcting an
inadequate design or operating practice.  The need for, and extensiveness of,
corrective measures must be determined on a site-specific basis.
Implementation of these measures must take into account the severity of the
problem, as well as the location of the nearest receptor.  A flow chart
outlining the sequence to follow  to determine the appropriate corrective
measure is presented in Figure 2-1.  As is evident, it is first necessary to
answer several site specific questions before an effective response can be
selected.

EXAMPLES OF CORRECTIVE MEASURES

     As shown in Table 2-1, several different corrective measures may be
applied to each type of air release.  In addition, there may be several
specific technologies which can be  used to carry out  the corrective action.
Consequently, the recommendation  of a corrective action to limit a particular
air release must be based upon the  consideration of several alternatives.
After evaluating the advantages and disadvantages, the effectiveness, and the
cost of each  technology,  the optimal alternative can  be selected.
     Table 2-1 presents corrective  actions for  air emissions by the type of
facility at which the air release occurs.  One  of  the most frequently
mentioned corrective actions is to  cover open or exposed wastes.   This  type  of

                                       2-1

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None required
                  Determine the General
                  Characteristics of the
                  Required Corrective Action
                                      Select a Specific Control
                                      Technology and Response
Determine the need for
corrective actions from
PA/SI or Emission Assessment
Guidance
                               \t
                                Action Required
                Consider the facility type:
                (1) Container/drum storage
                (2) Tank storage
                (3) Surface impoundment
                (4) Landfill
                (5) Land treatment
                (6) Waste pile
                Consider the air emission
                phase—particulate or vapor?
                 Is  the emission  related  to:
                 (a)  a design  deficiency
                 (b)  a poor operating practice.
                 If  (a)  is  the  design  deficiency
                 related to:
                 A.   Uncovered  or  uncontained  waste
                 B.   Unstabilized  waste
                 C.   Waste  subject to  wind
                     transport  or  evaporation
                 Di   Vapors which  are  not collected
                 E.   Collected  vapors  which are not
                     treated.
                 Determine the required control
                 efficiency or maximum acceptable
                 release rate.
X
Review Applicable Control
Methods in Sections 3-8
\
t
Compare cost of alternative
control methods (Table 2-4)
>
t
Compare reduction efficiency
of alternative methods
(Table 2-4)
A
t
Select appropriate air
emission control method
>
f
Recommend or implement
the corrective measure
\
t
Conduct testing to determine
the adequacy of the
corrective action

 Figure 2-1.   Flow chart for determining an appropriate corrective action.

                                       2-2

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         TABLE 2-1.  PRIMARY CORRECTIVE ACTIONS FOR EXAMPLE SOURCES
                     OF AIR EMISSIONS AT TSDFs
      Cause of emissions
       Applicable corrective actions
DRUM STORAGE

Liquid leaking from containers
  and volatilizing
Container storage without cover
  or containment structure
Emissions due to environmental
   factors such as wind, heat,
   or sun
Splash  loading


Spills
No vapor control during filling/
  emptying  or  cleaning operations

STORAGE TANKS

Open  top storage tank
Utilize spill drainage methods:
     absorptive floor
  -  grid floor
  -  sloped floor
  -  collection trenches

Prevent serious leaks by implementing leak
detection and repair program.

Encapsulate container using:
  -  overpacks
  -  directly applied sprays

Cover container storage area with a
synthetic liner.

Contain storage area in a building or
air structure vented to a vapor control
system.

Use a lean-to-structure to shield
containers.

Use wind screens/barriers.

Utilize submerged or slow filling
instead of splash filling.

Improve drum handling methods:
  -  use drum grabbers
  -  decontaminate drums after emptying

Install collection and treatment system.
Cover  tank with:
     surfactant layer
  -  plastic spheres
  -  rafts
     synthetic membrane
     fixed roof
  -  floating roof (internal, external)
                                   (continued)
                                      2-3

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                              TABLE 2-1 (continued)
      Cause of emissions
       Applicable corrective actions
STORAGE TANKS (Cont'd)

Emissions due to insufficient
  effectiveness of cover or
  containment structure
Emissions due  to environmental
  factors such as sun or wind
Splash  loading


No vapor  control  during  filling/
   emptying  or cleaning operations

SURFACE IMPOUNDMENTS

Open top  surface  impoundment
 Emissions due to environmental
   factors such as sun and wind
Use alternate type of seal or add secondary
seal to floating roof.

Use conservation vent on fixed roof.

Use alternate synthetic liner material.

Use alternate tank design such as convert-
ing external floating roof to internal
floating roof.

Add vapor control system such as carbon
adsorption, condensation, or incineration
to fixed roof.

Add thermal insulation to tank walls or
cover.

Use reflective paint.

Employ wind barriers/screens.

Use submerged filling instead of splash
filling.

Install vapor collection and treatment
system.
Cover impoundment with:
     synthetic membrane
     floating spheres
     rafts
  -  surfactant layer
     air  inflated structure vented to
     vapor control system

Use screens/barriers around perimeter or
inside  the impoundment.

Use shades.
                                   (continued)
                                       2-4

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                              TABLE 2-1 (continued)
      Cause of emissions
       Applicable corrective actions
SURFACE IMPOUNDMENTS (Cont'd)

Splash loading


Spills, overrun
Disposal by evaporation

LANDFILLS

Emission from operating face
  of landfill
Emission through temporary
  soil cover
Emission through permanent
  cover
Employ submerged instead of surface
filling.

Increase the freeboard depth by:
  -  physically increasing height of
     containment
  -  lowering waste level

Prohibit.
Place temporary wind screens around
working area.

Apply temporary cover material:
  -  synthetic liner
  -  foam
  -  soil

Enclose work area with air supported
structure and employ vapor control system.

Use wind screens in addition to soil cover.

Stabilize soil cover by:
  -  moisture control (watering)
  -  chemical additives
  -  physical additives

Decrease permeability of cover by:
     using different cover material
     vegetating soil cover
  -  moisture control (watering)
  -  adding chemical/physical stabilizers
                                   (continued)
                                       2-5

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                              TABLE 2-1 (continued)
      Cause of emissions
       Applicable corrective actions
LANDFILLS (Cont'd)

Emission through permanent
  cover (cont'd)
Co-disposal of municipal
  and hazardous waste

Emissions due to solidification
  of liquids in situ
LAND TREATMENT

Pooling of  liquids due  to  surface
   application of wastes
Emissions  caused  by  environmental
   factors  such as sun or  wind
 Open treatment area


 Co-disposal of municipal  and
   hazardous waste

 Spray Evaporation

 WASTE PILES

 Open waste piles
Add vapor collection and treatment system:
     pipe vents with either forced or
     unforced collection
     trench vents (forced/unforced)

Prohibit.
Eliminate practice.
Enclose operating area and employ vapor
control system.
Use subsurface injections instead of
spraying or overland flow.

Decrease the application rate.

Dewater waste prior to application.

Cover waste with:
  -  soil and employ moisture control
     synthetic covers

Use wind screens/barriers.

Enclose treatment area with air structure
and employ vapor control system.

Prohibit.


Prohibit.
 Cover  with  flexible  liner  (tension
 structure).

 Enclose  in  rigid dome  structure.
                                   (continued)
                                       2-6

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                              TABLE 2-1 (continued)
      Cause of emissions
       Applicable corrective actions
WASTE PILES (Cont'd)

Emissions due to environmental
  factors such as wind or sun
Fugitive release due to
uncontrolled loading
Use wind screens.

Change pile orientation

Stabilize dust with:
  -  water application
  -  chemical additives
  -  vegetation

Reduce the slope of the pile.

Use alternate loading practices to lessen
particle generation:
  -  hinged boom conveyors
  -  telescopic shutes
  -  stone ladders
                                        2-7

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nu-asuru is etEuctive by providing a barrier  to  tlie  unrestricted  volatilization
of hazardous waste constituents.  The type and  extent  of  the  cover  needed is
dependent on the waste characteristics and the  type of facility  at  which  the
cover will be used.  Liquid wastes containing volatile organic compounds  have
a high emission potential and require a more permanent and  secure cover  (e.g.,
floating roof) than a solid waste with few volatile components.  For  instance,
a waste pile may require only a portable synthetic  cover  to minimize  both
vapor and particulate releases during its active  life.
     Changes in facility operating practices, namely those associated with  the
emptying, filling, or cleaning of containers, and the  loading or applying of
waste to landfills, wastepiles and land treatment facilities  are another  means
of providing corrective action.  A common method of reducing  emissions that
result from the filling of  tanks, surface impoundments, or drums is to employ
submerged filling, as opposed to splash loading.  Submerged filling minimizes
liquid surface turbulence,  a factor which contributes  to  air  releases.
Similarly, at land treatment facilities, use of subsurface injection  in place
of spreading or pouring waste on the soil surface reduces the time  and area of
waste contact with the atmosphere.
     Treatment processes that are designed totally  or  in  part, to provide for
the  release of airborne contaminants as a way of reducing the solid or liquid
phases contaminant level should not be allowed.  Practices such as disposal by
evaporation and co-disposal of hazardous and municipal  wastes, in which
significant quantities of hazardous constituents may volatilize or evaporate
are  two examples of such unacceptable practices.  The  purpose of these
practices is to promote evaporation and airborne release  of the contaminants
and  no change in the practice or add-on control equipment can change  this
intent.  Consequently, these practices should be prohibited.

Types of Corrective Actions

     The  two general types  of corrective actions mentioned above and  presented
in Table 2-1 are design or  operational.  Design measures  are  those  that limit
the  ambient emissions due to the intrinsic design of the  waste management
hardware or the  installation of air emission control devices. Operation
corrective actions minimize emissions by controlling the  manner  in  which  the

                                       2-8

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waste is handled.  Design practices can further be broken into groups based
upon the function that the specific design practice serves.  These groups  are:

     •    containment                   •    gas collection
     •    insulation                    •    vapor control
     •    stabilization

Containment—
     The purpose of containment is to minimize the surface area of the waste
which is exposed to ambient air.  This function is served by enclosing or
covering the facility or waste in some manner.  The containment structure  can
either be supported or be placed directly on top of the waste surface.  For
example, a temporary cover may either be placed directly on the solid surface
of an active landfill or it may be supported above the waste.  Supported and
unsupported structures are separated since supported containment generally
involves a much greater amount of construction or alteration than does
unsupported containment.  For example, unsupported containment measures, such
as floating spheres and rafts, can simply be placed on a liquid surface of a
tank or  impoundment, while a fixed roof or dome requires significant design
and construction to implement.

Insulation—
     Methods of  insulation serve to lessen the rate of air emissions by
specifically reducing the effects of wind and sun.  Covers may also have this
effect,  although they are primarily designed to enclose the waste and not
specifically to  protect it from environmental factors.  This type of
corrective action can generally be added on to the existing structure or
facility without changing the existing structure to a great degree.

Stabilization—
     Stabilization  is used to reduce particulate or volatile emissions  from
the waste  itself or to improve the performance of a cover material by making
the cover  less permeable and/or more stable.  Stabilization usually involves
the addition of  a chemical, or other material, to the facility or its contents.
                                        2-9

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Gas Collection—
     The installation of gas collection systems at a TSDF may  require  that
extensive alterations be made if the system is added to an existing  facility.
The effort required to retrofit an existing facility is dependent  on the
facility type.  For instance, the addition of a collection trench  vent system
to a system will involve excavation, while the addition of a conservation vent
to a fixed roof will not require as extensive an effort.  In any case,  these
types of controls are more easily applied if incorporated into  the original
design of the facility.

Vapor Control—
     Vapor control or treatment is generally used in conjunction with  some
type of containment structure and gas collection system.  The cover  serves to
channel the air pollutants to the collection device which then  vents the
pollutant to a vapor control unit.  The vapor control unit then serves  either
to destroy the pollutant, as in fume incineration, or to merely remove  it from
the gas phase as in adsorption or condensation.  Vapor control  systems  act not
to prevent volatilization from occurring, but to treat the emissions once they
have occurred.
     In Table 2-2, each of the types of air emission control methods discussed
above  is  listed, with  the type of facility to which the control can  be
applied.  Certain  technologies, such as the vapor control methods, apply to
all of  the facility  types, while others, such as subsurface injection,  only
apply  to  one  of  the  facility types.  Only those controls which  have  a  high
probability of application to the specific facility type are checked;  those
controls  which only  have  a very low potential of being applied  have  not been
checked.
      In  addition  to  the corrective actions listed in Table 2-2, there  exist
several general  classes of corrective actions which may be applicable  on a
site  specific basis.   These measures include pretreatment of the waste,
consideration of  alternate disposal options, and post-treatment.
     Waste pretreatment refers to actions that reduce the air  release
potential of  the  waste by removing the hazardous constituent of concern.
Examples  of pretreatment  include, but are not limited to:
                                       2-10

-------
TABLE 2-2.  AIR EMISSION CONTROL TECHNOLOGIES/TSDF—MATRIX
                                  Surface                 Land
    Drum storage  Tank storage  impoundment  Landfills   treatment  Waste piles
CONTAINMENT
Supported
Air inflated structure X
Building X
Dome
Fixed roof
Floating roof
Unsupported
Clay/soil cover
Immiscible film
Inert gas blanket
Floating spheres
Floating rafts
Synthetic membrane
Foam
Drum encapsulation X
OPERATING PRACTICES
Subsurface injection
Submerged filling
Spill/leak control X


X
X
X
X
X


X
X
X
X





X
X


X X X X
X X
X



XXX
X

X
X
XXX
XXX


X
X
x x x x
                       (continued)

-------
                                         TABLE 2-2  (continued)
I—»
NJ
                                                         Surface                 Land
                           Drum storage  Tank storage  impoundment  Landfills  treatment  Waste piles
  Increase freeboard depth
  Less frequent filling/
    emptying
  Decrease application rate
  Controlled loading
  Moisture control
STABILIZATION
  Wet dust suppression
  Vegetation
  Encapsulation
  Chemical dust stabilization
INSULATION
  Wind screens/Barriers
  Shades
  Thermal insulation
  Painting
GAS COLLECTION
  Pipe vents
  Trench vents
  Gas extraction
  Conservation vents
                                     X
                                     X
                                     X
                                     X
X
X
X
X
                                                                X
                                                                X
X
X
            X
            X

            X
            X
            X
            X
                                                                            X
                                                                            X
                                                                            X
                                                                                       X
                                                                                       X
                                                                                       X
                                                 X
                                                 X

                                                 X
                                                 X

                                                 X
                                              (continued)

-------
TABLE 2-2 (continued)

VAPOR CONTROL
Adsorption
Fume incineration
Condensation
SPILL CONTROL
Foam
Water dilution
Adsorbents
Coolants
Drum storage

X
X
X

X
X
X
X
Tank storage

X
X
X

X
X
X
X
Surface
impoundment

X
X
X

X
X
X
X
Landfills

X
X
X

X
X
X
X
Land
treatment

X
X
X

X
X
X
X
Waste piles

X
X
X

X
X
X
X

-------
     •    Distillation                  •    Wet oxidation
     •    Steam or air stripping        •    Chemical oxidation
     •    Adsorption                    •    Biological oxidation
     •    Ozonation                     •    Physical separation

These technologies are standard waste treatment technologies, which when
applied to a waste will reduce the hazardous constituents of concern.
     The use of an alternate disposal option can be an appropriate corrective
action if the air release potential of the waste cannot be minimized using the
more conventional (and less expensive) techniques previously described.  For
example, elimination of a waste containing volatile organic constituents by
incineration may be the most effective manner to reduce the emission potential
of the waste.
     Post-treatment measures refer to those actions that are taken to insure
that the constituents emitted from the waste (gaseous or particulate) are
captured and effectively disposed so as not to result in an emission from the
facility.  For instance, with regard to vapor collection systems on storage
tanks, captured organic vapors are condensed and returned to product storage
or disposed of in a manner that precludes their emission.  Similarly, fugitive
particulate, once captured, must be handled and disposed so as to minimize the
potential for reentrainment.
     Because pretreatment, alternate disposal, and post-treatment methods
involve action to the waste which would be conducted either previous or
subsequent  to their management at the TSDF in question, they will not be
further addressed in  this document.  The permit writer need only be concerned
with recommending practices which could be implemented on site.

FACTORS TO  CONSIDER IN SELECTING CORRECTIVE MEASURES

     A major factor to consider when recommending a particular corrective
action  is the severity of the emission.  Some releases may require major or
emergency steps  to be taken, while others will only require simple or minor
steps to be  taken.  Other factors to consider include the effectiveness of
                                       2-14

-------
that ;iction in controlling ;i i r omissions, and the cost that  is associated with
iinplonuMit ing the action.  Tlics*? two tractors together can be  combined  to
evaluate the overall cost etfeetiveness of the corrective action.  Each of
these factors is discussed below.

Severity of the Air Release—
     The severity of an air release is based on the potential for endangering
human health and the environment.  If it is determined that  an unacceptable
risk is posed by some activity, then an immediate and possibly major
corrective action will be required.  Conversely, if there is only a low
potential  for toxic air emissions due to some poor design or operating
practice,  the corrective action required may be less extensive in nature.  As
seen in Table 2-3, the difference in the actions required for an emission of
minor or significant levels of concern is primarily based upon the level of
the air release.  The difference between the actions required for an air
release of significant and major levels of concern, however, may necessitate
an entirely different sort of action,  generally much more severe.

Cost —
     The capital cost associated with each corrective action or  technology
will depend on  several factors.  The major costs are those  associated with
materials  and equipment themselves, and those associated with the construction
or  installation of the materials and equipment.  The cost of some technologies
will be almost  solely a function of the cost of materials,  while the  cost of
others will be  predominantly installation costs.  An example of  the former is
the placement of floating spheres or rafts on the surface of an  impoundment or
tank.  An  example of the latter is the covering of a surface impoundment or
other  facility  with an air supported structure.  For example, if a surface
                        2
impoundment of  60,000 ft  is to be covered by rafts, the cost will be
approximately $6,000.  (Refer  to Table 2-4).  Conversely, the cost of
installing an air supported structure for this size impoundment  will  be
approximately $400,000.  This  difference in cost is primarily a  result of the
difference in installation cost.
     Other factors, however, must be considered in addition to the capital
cost of the corrective action.  There are advantages and disadvantages of the

                                    2-15

-------
                      TABLE 2-3.   PROBABLE CORRECTIVE  ACTIONS AS A FUNCTION OF  THE  LEVEL OF  RELEASE
                                      Minor
                                           Level of release

                                            Significant
                                                     Major
      Cause:
      Corrective Action: -
 I
»—<
CTv
Toxic volatile or participate
wastes managed with poor
design and operating
conditions
Dust suppression
Cover drains and sumps
Install spill collection
system
Cover waste piles with  liner
(small piles)
Cover landfill (small)
Submerged filling instead of
splash filling
Monitor
Fixed roof and vapor  control
on open top tank (small
units).
Toxic volatiles and/or  particulates
present in populated  areas with no
controls
Highly toxic wastes managed
Dust suppression,  capture and
collection
Vapor collection and disposal
Cover waste piles  with liner (large
piles)
Fixed roof and vapor control on open
top tanks (large units)
Enclose drum storage area with vapor
collection and disposal
Cover landfill (large)
Unacceptable risk determined
due to activity; toxic vola-
tiles present and emitted
either by evaporation or
mobilization by CH^ or
C02

Prohibit disposal by evapor-
ation
Prohibit co-disposal of
hazardous wastes with
municipal wastes

-------
     TABLE  2-4.   COST  AND  REDUCTION EFFICIENCY  OF  AIR EMISSION  CONTROL  TECHNOLOGIES
                                    Cost
       Technology
                                                         Efficiency
                                                            (*)
                                                                                        Comments
Supported  Containment

Air-inflated itructure
Building
Dome
External  floating roof
  tank

Contact  internal floating
  roof with primary seal
                                   A00,000

                                  +100,000
                           (t6-9/ft2 of floor space)
     67,150


49,000-54,000



53,000-280,000


 7,450-55,000
                                          A. D. Little,  1984; total installed
                                          cost of system over 425 x 150 ft  lagoon.
                         High (>90Z)       Including carbon adsorption vents.
                                          A. D. Little,  1984; total installed unit
                                          costs; does  not include treatment system
                                          costs.

                            80-99         SCS, 1983; for drum storage
  (with  treatment)    with capacity of 33,120 ftj.

 5-100 (parti
85-95 (vapor)


      62-99b
                                                     95-100 (particulate)  Vogel et  al., 1983; installed  cost for
                                                                         waste pile  storage dome with diameter of
                                                                         61 ft, capacity 1150 tons.
       88-99c
EPA,  1980; cost of whole  tank 30-100 ft
diameter.

EPA,  1980; cost of roof,  15-90 ft diameter,
plus  seal.
+ secondary seal
Noncontact internal
floating roof with
primary seal

Fixed roof



Unsupported Containment
Soil covers
15.68/ft circumference
6,000-40,000



34,000-354,000

109,000


11. 20-17. 20/yd3
40d EPA, 1980.
88-99c EPA, 1980; coat of roof and seal 15-90
diameter.

60 EPA 1980* cost of WLDBT sea 1
90b EPA, 1980; cost of whole tank 20-90 ft
diameter.
Vogel et al., 1983; 25 ft diameter
50,000 gallon tank.

50-100 EPA, 1982; costs range depending on

ft









whether clay or topsoil is used; includes



3ft £ /.-J 9
— /o/ yO*

hauling, spreading, compaction.

90 EPA, 1982; installed coat of various
materials from 20 mil PVC to Teflon-coated
fiberglass.

                                                    (continued)

-------
TABLE  2-4 (continued)
Technology
Unsupported Containment (Cont
Tension structure

Foam cover


Immiscible film

Floating spheres

Floating rafts
Inert gas blanket


M
1
. Drum encapsulation


Operating Practices
Subsurface injection



Controlled loading


Leak detection and repair
Drum handling equipment
Submerged filling
Cost
(*)"
'd)
4.30-6.50/ft2 of
surface area
0.11/ft2

4,350
0.03 cents/ ft2

4.65-8.69/ft2

0.05-0.13/ft2
0.11-0.33/gallon
capacity



65-90/drum

26-40/drum

100,000-160,000

5,500-8,700

10,500

30,000
200-3, 000/unit
300-600/unit
HA
Efficiency
U)

95-100 (particulate)

N/A


25-75

80-90

80-90
50-99




99



30-90



75

80
MA
HA
HA
Comments

Vogel et si., 1983; synthetic membrane
with auger feed system.
Vogel et al., 1983; cost of 2-inch layer
of urea-methane foam.
One-man application system.
Vogel et al., 1983; cost of hexadecanol
monolayer.
A. D. Little, 1984; costs depend on
sphere site.
A. D. Little, 1984.
Vogel et al., 1983; annual cost of
nitrogen blanket system; efficiency when
used with insulation and conservation
vent.

EPA, 1981; fiberglass-lined and welded
systems.
Directly applied system.

Vogel et al., 1983; subsurface injection
vehicle.
Tool bar filled to existing surface
application vehicle.
Bonn et al., 1978; telescopic chute uaed
for steel industry waste piles.
Stone ladder.
Cost of monitors, both portable and fixed.
Cost of drum grabbers.
Depends on construction requirements.
         (continued)

-------
               TABLE  2-4 (conntinued)
Cost
Technology ($)a
Operating Practices (Cont'd)
Decreased application rate NA
Increase free board depth NA
Change waste pile 0
orientation
Efficiency
(Z)
NA
11-80
NA

Low cost,
required
Comments
but increased area will
for same waste production
Costs are low depending on whether
surface is lowered or berm height
increased.

be
liquid
is
Vogel et al., 1983.
 Improved cover practices


 Stabilization

 Wet dust suppression



 Vegetation

 Encapsulation/
  solidification

 Chemical dust
  stabilization

 Insulation

 Wind barriers





Wind screen


Shades
           MA
           NA
        90,000
     1,550/acre

100-850 i/ton of waste


    80-1,350/acre




   0.04-0.23/ft2




   14/lineal foot


   0.07-0.18/ft2
                                   90
                                                 A.  D. Little, 198A; moisture control of
                                                 landfill covers.
  50 (particulate)     Efficiency based on Rosbury, 1985.
  75 (particulate)     Bohn et al., 1978; water spray system
                      used at steel industry waste piles.
        NA

        NA
R. S. Means,  1984;  hydroseeding.

EPA, 1982;  low cost for lime,  high  for
organic polymer.
80/100 (particulate)   Drehmel et al., 1982; cost depends on
                      specific chemical used.
      11-80           A. D. Little, 1984; cost for styrofoam
                      barriers 1-4 inches high in varying grid
                      patterns; based on surface impoundment
                      area.

  0-30 (particulate)   Vogel et al., 1983; cost based on 6 ft
                      high fence.
                                26-44
                                                 A.  D.  Little,  1984; black woven poly-
                                                 ethylene  shade cloth.
                           (continued)

-------
                                                                  TABLE  2-4  (continued)
                              Technology
                                                             Cost
                                                             <*)"
                                                           Efficiency
                                                              (Z)
                                                                                            Comments
                        Insulation (Cont'd)
 I
NJ
o
Therul insulation
Reflective paint
Gas Collection
Pipe vents
Trench vents
0.05-0.76/in.-ft2
500-3, 000/tank

1,450/unit
330,000
50-99*
25

70-90
70-90
Gas extraction



Conservation vents


Vapor Control

Carbon adsorption




Fume incinerator


Condensation
                                                     17,000-40,000
0.01-0.09/per  gallon
   capacity
                                                     1,100-1,6007 tank

                                                       670-920/unit


                                                     7,500-11,000/tank


                                                    11,000-16,000/tank
                                                                                   70-90
                               50-90
                                                                                   85-97
                               85-99
                                                            85-95
                                                                                                    Vogel et al., 1983; polyurethane coating;
                                                                                                    efficiency when used with conservation
                                                                                                    vent.

                                                                                                    Petroleum storage facility estimate.
EPA, 1982; cost of 4-inch pipe vent,  30 ft
deep with forced ventilation.

EPA, 1982; total cost of 20 ft from vent,
4 ft wide, 1,500 ft long with  a hypalon
liner;  excavation is 80 percent of total
cost.

SCS, 1983; cost range for 2,000-100,000
ft^ waste pile and includes carbon
adsorption system.

Vogel et al.,  1983.
Vogel et al.,  1983;  unit  coat  for  large
system.
Calgon Corporation;  cost  for "barrel"
systjm.

Vogel et al.,  1983;  cost  for 50,000  gallon
tank.

Vogel et al.,  1983;  cost  for 50,000  gallon
tank.
                                                                              (continued)

-------
                                           TABLE  2-4  (continued)
 Costs are all updated to March  1985.
 As added to open tank (A. D.  Little,  1984).
CAe added to open tank (EPA,  1980).
 Increase in efficiency due to addition of secondary seal.
 When used in conjunction with a  conservation vent (Mitre, 1983).

References:

Arthur D. Little, Inc., EPA-450/3-8/017.  November 1984.
Bohn, R.. et •!., EPA-600/2-78-050.  March 1978.
Calgon Carbon Corporation, Sales  Literature, March 1985.
Drehmel, D., et al.   Relative  Effectiveness of Chemical Additives  and  Windscreens for Fugitive Dust Control.
     February 1982.
R. S. Means, Inc. Building Construction Cost Data.  1983.
SCS Engineers.  Interim Report on Air Emissions.  September 1983.
USEPA.  EPA-450/3-80-034a. December 1980.
USEPA.  EPA-600/2-81-138.   July 1981.
USEPA.  EPA-625/6-82-006.   June 1982.
Vogel, G. A.  and D.  F.  O'Sullivan.  Air Emission Control Practices at  Hazardous Waste Management
     Facilities.  June 1983.

-------
specific techno Logies which may negate any cost advantage?  of  ono  technology
over the other.  One of the major factors, of course,  is  the  amount  of  air
emission reduction which can be achieved.  Air emission  reduction using
floating rafts has been estimated to be  from 80 to  90  percent while  the
reduction associated with using an air inflated structure  can be  greater  than
90 percent.  In some cases, the added reduction efficiency may justify  the
added cost.
     The cost data which is presented in Table 2-4  is  based both  on  literature
and on current quotes provided by vendors.  Literature cost estimates have
been updated to March 1985 using the Engineering News  Record  construction  cost
index.  Comments are used to explain exactly what the  listed  cost  includes or
what it is based on.  In addition, to obtain more detailed costs,  one should
refer to the section in which the particular technology is discussed.  These
cost data are  intended to be approximate in nature, and actual costs will
depend on site specific factors.  The costs indicated  should  provide the
permit writer  a basis for a rough comparison of the cost of implementing
alternative corrective actions.

Effectiveness—
     The percent reduction or control efficiency percentage attributed to  a
certain technology is defined by the following relationship:

        ,...-..       uncontrolled emissions - controlled emissions    n nn
   Control efficiency =	rr~J	:	:	 x  100
                                  uncontrolled emissions

      The controlled  and uncontrolled emissions are  usually expressed as a  rate
and not as  the total mass  emissions.   Reduction efficiencies for a  variety
of control  technologies are presented in Table 2-4.  The  purpose  of  a
corrective  action  can in  some cases be to  control volatile emissions, while  in
other cases  the action is  implemented to control particulate  emissions.  It
should  be  noted that  the  technology efficiencies provided  in  Table 2-4  are for
vapor phase  releases.  However, certain  technologies may  be applicable  for
both  vapor  and particulate control.  In  these cases, technology efficiencies
have been provided  for both phases.  In  general, if a  technique can  mitigate
                                      2-22

-------
vapor releases, it should be capable of controlling partLculate releases at
least as effectively.
     The total control efficiency of corrective actions can be the result of
implementing several control schemes in series.  For example, the control
efficiency of a gas collection system at a landfill will be a function of the
combined efficiencies of a trench vent, a cover material, and possibly a vapor
treatment system.  If the collection system does not include an effective
cover material and lateral barriers, the vapors will not be collected in the
vent, and the control efficiency of the system will be correspondingly
decreased.
     Another example of this involves the addition of a secondary seal to a
contact internal floating roof with a primary seal.  In Table 2-4, the listed
efficiency of this action is 40 percent.  This increase in control is over and
above the 88 to 99 percent efficiency attributed to the internal floating roof
with just a primary seal.  In other words, if the primary control has an
emissions reduction efficiency of 88 percent, the installation of an add-on
secondary control with a 40 percent control efficiency will provide a combined
efficiency for the total system of 93 percent (0.88 + (0.12 x 0.40)).
Consequently, when evaluating the effectiveness of a corrective action, the
combined effects of several technologies may need to be considered.
     Very few of the control efficiency estimates listed in Table 2-4 are
based on measurements carried out at actual TSDFs.  Consequently, the level of
certainty of these estimates as applied to TSDFs is unknown.  However, they
can  be  used as general indicators of reduction efficiency.  Field testing of
the  corrective actions will verify the correctness of these estimates.  For
                         9
example, one recent  study  investigated the effectiveness of wind screens in
reducing particulate emissions from waste piles.  The findings indicated that,
contrary  to previous hypotheses, a reduction in wind speed does not
necessarily result in a commensurate reduction in particulate loss from the
pile.   Consequently, reduction efficiencies which had been based on wind speed
have been lowered  to the values presented in Table 2-4.
     In general, reduction efficiencies attributable to supported containment
structures and vapor control systems are very high (>90 percent), while those
attributable to various other design and operational practices are variable
                                     2-23

-------
and range from zero up to 99 percent.  As mentioned previously, however, many
corrective actions which may not reduce emissions by more than 90 percent, may
still be worth implementing due to their low cost.  These include operational
practices such as submerged filling, moisture control for landfill covers, and
unsupported containment designs such as placing floating spheres, rafts or
immiscible films on open surface impoundments and tanks.
                                      2-24

-------
                            REFERENCES FOR SECTION 2
1.    Vogel, G. A., and D. F. O'Sullivan.   Air Emission Control Practices at
     Hazardous Waste Management Facilities.  MTR-83W89.  Prepared for U.S.
     Environmental Protection Agency,  Office of Solid Waste.   Contract
     No. 68-01-6092.  The MITRE Corporation.  McLean, VA.  June 1983.

2.    Rosbury, K. D., and J. C. James.   Control of Fugitive Dust Emissions at
     Hazardous Waste Cleanup Sites.   Draft Report sent to M.  Arienti, GCA
     Corporation.  March 1985.
                                     2-25

-------
                                    SECTION  3
                 CONTROL OF EMISSIONS  FROM  CONTAINERIZED  WASTE

INTRODUCTION

     Hazardous waste material placed into containers can include both liquids
and solids.  The material is put into containers either at the generator site
or at the TSDF.  Containers used for this purpose may be either closed or
open-top, and loading may be done by either splash or submerged filling
techniques.
     For the purpose of discussion, this section will focus upon waste
material held in steel 55-gallon drums.  Releases from containerized wastes
occur primarily as a result of leakage or accidental spillage.  Control
options available to facilities which handle,  store, or dispose of
containerized wastes may be classified as follows:

     •    storage modifications;
     •    spillage containment;
     •    container modifications; and
     •    operating practices.

     Table 3-1 provides an overview of the advantages and disadvatanges of
control alternatives described in this section.  This section will develop and
describe technology options provided in Table 3-1 under each of these
classifications.  Example systems will be cited, and relative effectiveness
(emission reduction- and cost-) will be presented for each.
                                     3-1

-------
     TABLE  3-1.   ADVANTAGES AND DISADVANTAGES OF CONTAINERIZED WASTE EMISSION CONTROL ALTERNATIVES
                    Advantages
                   Disadvantages
 Storage Modifications

 •  Can achieve high emission reduction efficiency.

 •  Insulates containers  from external forces which
   exacerbate emissions.

 •  Will not affect containers or waste materials.

 •  Various designs available, thus can be
   applicable to any facility.

 •  Will not affect the operation of the facility.

 •  Better suited (than other options) for larger
   facilities.

 Spillage Containment

•  Reduces emissions, and possibility of reemission
   by isolating spilled substances from the
   environment.

•  Provides rapid mitigation of spill emissions.

•  Well-suited to random spill incidents.

•  Applicable to spills occurring both on land and
   water.
•  High implementation costs involved.

•  Implementation is constrained by requirements
   of location, layout, and manpower.

•  Does not increase response time to spill or
   leak.

•  Maintenance costs will rise.

•  May require handling of contaminated
   materials.
•  Emissions reductions achievable are not high.

•  Facilities which handle many different types
   of waste substances may need to implement
   many different procedures, thus increasing
   expense.

•  Requires additional handling of hazardous or
   volatile materials.
                                               (continued)

-------
                                               TABLE 3-1 (continued)
                          Advantages
                                                                          Disadvantages
u>
I
U!
 Spillage  Containment  (Cont'd)

 •   Technologies are readily  transportable, thus are
    applicable  to  any  size  facility.

 •   Manpower  required,  in general, are low.

 •   Materials needed,  in general, are inexpen-
    sive and  can be obtained  easily by a
    facility.

 •   Application methods are relatively simple and
    implementation of  such  procedures will be easy.

 •   Costs, overall, are expected to be low for such
    procedures.

 Container Modification

 •   Highly effective in reducing emissions from
    containers—most effective of all technologies
    described in this  section—due to mitigation of
    both spills and container breathing losses.

 •   Increases safety of container handling procedures.

•  Permanent system—prevents further incidents.

•  Applicable to prevention of both chemical and
   mechanical stresses from both within the
   container and externally.
•  Requires disposition of contaminated
   materials.

•  Possible side effects (e.g., seepage of
   chemicals into ground) may limit
   applicability.

•  A certain percentage of spills may not be
   manageable at all due to volume or
   location.

•  Costs are subject to variations in materials
   costs.
                                                             •  Requires  additional  equipment,  manpower,  and
                                                                materials.

                                                             •  Total  costs  to  implement  systems  may be high.

                                                             •  Costs  may be particularly high  for facilities
                                                                which  would  need  to  encapsulate a great many
                                                                drums.

                                                             •  May  require  handling procedures to be altered.

                                                             •  Drums  would  not be reusable.
                                                     (continued)

-------
                                         TABLE  3-1  (continued)
                    Advantages
                   Disadvantages
Container Modification  (Cont'd)

•   Insulates container  from thermal fluctuations
    as well  as mechanical shocks.

•   Technology allows  for transport to various points
    around facility.

•   Applicable to range  of container sizes.

•   Materials required are relatively easily obtainable.

Operating Practices

•   Reduces  leaks and  spills, the major contributor
    to containerized waste emissions.

•   Does not change or affect containers or waste.

•   Increases safety at  facility.

•   Applicable to any drum handling, disposal, or
    storage  facility.

•   Very easy to implement procedures at an existing
    facility.

•  Accomplish emissions control quickly—either by
    preventing emission  from occurring or by rapid
   response to spill or leak.
•  Emission reductions achievable are low.

•  May affect overall operation of facility
   (input/output considerations, for example).

•  May be less effective as number of drums
   increase at a facility.

•  May not be well suited to highly volatile
   or toxic substances.

•  Requires additional manpower and/or
   equipment.

•  Implementation may be limited by accessibility
   of containe-s.
•  Generally are low in total costs.

-------
STOKAGli MOD LFLCAT IONS

Introduction

     Drum storage areas range in sophistication from simple, outside,
uncovered areas with no leakage or spillage containment,  to  fully enclosed
buildings which are evacuated and serviced by a vapor control  system  (e.g.,
carbon adsorption).  Modifications to storage areas are classified as any
physical change in the area.  This subsection will focus  on  three modification
options, which are as follows:

     •    Troughing/spill drainage;
     •    Wind deflection; and
     •    Building containment

All three of these options are used extensively at both TSDFs  and industrial
processing plants.

Description

     Because emissions from containers occur largely as a result of volatile
waste materials spilling  or leaking from containers,  all modifications are
intended either to reduce environmental factors such as wind and solar
irradiation, or more effectively manage spilled or leaked material so that
emissions can be  limited.  Emissions which occur due to container "breathing"
are expected to be mitigated  by storage modifications, as well.  In selecting
the modification  option which is most applicable to a specific TSDF,  the
following considerations  must be made:
      •     Location  of  storage  area.  Whether  the  containers  are  stored  outside
           or  inside, or where  the  storage area  is  in  relation  to other  parts
           of  the  TSDF.
      •     Available area.   The storage  area may be  constrained in terms  of
           height,  layout,  and  other  space restrictions.
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          Storage procedures.  By virtue of which waste materials are being
          stored, or how a facility is equipped to handle their waste
          containers, the procedures by which the facility places containers
          into and removes containers from storage.
          Type of containers being stored.  Whether containers are open-top or
          enclosed.
          Number of containers being stored.  The number of containers to be
          stored, and the frequency with which they are brought in and taken
          out of storage.
The three modification options which are most applicable to TSDFs based upon
the above criteria, and which, therefore, are the most commonly employed
designs found in industry, are described below.

Troughing/Spill Drainage—
     Troughs, grid floors, and other similar modifications serve to contain
emissions by channeling spilled (or leaked) materials away from the
containers, so that spills can be cleaned up more efficiently and
effectively.  Most storage facilities should employ a drainage system of some
kind.  Implementation of  these systems is applicable to both outside and
inside storage areas.  Examples of this  type of modification include:

     •    perimeter trench or trench network;
     •    sloped floor;
     •    absorptive  floor; and
     •    grid (screen) floor.

     These  systems may not be applicable to  facilities which employ certain
storage procedures.

     Trench System—A system of trenches can range  in sophistication from a
simple moat around the perimeter, to a series of interconnected channels
within the  storage area.  The primary design features to be considered  in
selecting the most appropriate trench system are trench depth and trench
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system layout.  The trenches may, in addition, be  Lined with a  synthetic
membrane, or filled with absorptive material.

     Sloped Floor—A sloped floor can be formed either by reconstructing  an
existing floor, or installing a new floor.  The primary design  features to be
considered for this type of system are slope, permeability, and weight
handling requirement.
     A sloped floor could also be coated in some way, e.g., a polyurethane
sealing compound, or could incorporate a trench system.  The most common  types
of sloped floor are those constructed of concrete.  Concrete floors are
especially suitable for outside storage areas.

     Absorptive Floor—An absorptive floor is a simple system in which an
absorbent material covers either the entire floor  area or just under where the
containers will be placed.  By placing drums directly on top of the absorbent,
leaks can be handled immediately, and clean-up procedures may be simplified
greatly.  The primary design features to be considered in establishing such a
system are the type of absorbent material selected (must be chemically
compatible with waste materials), the depth of the absorbent layer, absorbent
layer layout  (related to traffic patterns), contaminated absorbent handling
procedures, and layer regeneration.  Such systems  may also incorporate
synthetic membranes or other leachate handling systems.

     Grid Floor—A grid, or screen floor is a simple system in which drums are
placed on a screen which is raised above the actual floor level.  This type of
system allows  spilled material to drop to the floor, thus separating the  spill
from the drums.  The primary design features to be considered in this type of
system are screen type (grid size, weight handling capacity, and screen
material), screen floor layout, distance between screen and floor, and waste
handling procedure.  Screen floor systems might be expected to  employ a layer
of absorbent material placed directly under the screen.  The screens
themselves may be coated, to prolong their usable  life.
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Wind Deflection—
     Various systems designed  to deflect  the  flow  of  wind  away  from
waste-containing drums are used.  These controls are  applicable only to
outside drum storage.  Considerations  involved  in  selecting  the appropriate
system are:

     •    Type of barrier.  Options  include  (and are  not  limited to)  cyclone
          fences, picket  fences, corrugated  steel  walls,  or  cinder  block walls.
     •    Height of barrier.   The higher  the  barrier  is,  the more wind  is
          reduced.  Higher barriers, however, must also be stronger
          structurally.
     •    Materials of construction.   Materials must  be chosen  with an
          emphasis on low costs.  The  effect  of chemical  degradation  must also
          be considered.
     •    Storage area arrangement.  By compartmentalizing,  the effectiveness
          of a barrier is increased.   Compartmentalizing,  however,
          necessitates the use of more fencing, and makes  the logistics of the
          storage area more complex.

     Examples of wind deflection systems  include:

     •    simple perimeter system,  and
     •     "compartmentalized"  system.

     Perimeter Wall—Perimeter walls are  the most  common  type of wind
                  •a
 deflector system.    The  primary design features to be considered in
 establishing a perimeter wall  system are  the height of the wall and the type
 of wall  selected.  The wall may be  designed  to  vary  in height according to
 expected wind  patterns.

     Compartmentalized System—A compartmentalized system serves to bring the
 nearest  wall closer  to each drum,  thus increasing  the effectiveness of  the
 wall.  A wide  variety of designs are available, ranging in sophistication from
 randomly spaced  sections to a  "honeycomb" complex.  The primary design
 features to be considered in  these  systems are  wall  height and  type,  system
 layout,  and area  access  and egress. Such a  system would  allow  a facility to
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segregate wastes, access tli<: area from different points, and  install covers  on
certain parts of the areas while leaving others uncovered.

Building Containment—
     An enclosed structure will serve to contain emissions by providing  a more
controlled environment for the drums and the waste material they contain.  The
effects of wind, solar irradiation, and precipitation can be  reduced
significantly if not eliminated completely.  A building containment can  be
more effective  in reducing emissions than any other modification to an outside
storage area.   A building containment can be equipped with various
appurtenances such as vapor control systems, or can be built with multiple
levels to provide more storage per area.  Examples of building containment
designs which might be selected are:

     •    lean-tos; and
     •    free  standing structures.

Building containments may be limited in applicability by various location or
area considerations.

     Lean-tos—A lean-to is a simple structure, commonly built onto the  side
of an existing  structure.  While in general a lean-to is constructed using
simple materials, these systems can range in sophistication from a simple roof
shade to a  fully enclosed and insulated structure.  The primary design
features to  consider in selecting the most appropriate lean-to are storage
space needs, storage procedures, and construction materials.

     Free-standing  structures—A facility may choose any number of designs for
a  free-standing structure.  Among the many design features to be considered
are:  available area, building layout (including decision to  make multiple
levels), appurtenances  (insulation, vapor control, etc.), and storage
procedures.
     The relative ease  or difficulty of implementing modifications to  storage
facilities  is dependent upon the unique constraints of each particular system
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and application.  In general, installation of troughs or wind deflectors  can
be accomplished with less cost and effort than construction of  buildings.
This is due to the space and materials requirements  involved, and  also  due  to
the difficulties associated with construction at hazardous waste facilities.

Emission Reduction Effectiveness

     Modification of the drum storage area is expected to yield moderately
high emission reductions.  The availability of information on the  efficiency,
however, is limited.  No studies of  such controls have been published in  the
literature.  Of the three modification categories described in  this section,
building containment is expected to  effect the highest reductions.  A study of
air emissions done by SCS Engineers  estimated that building containment can
achieve from 80 to 99 percent emission reduction.    The effectiveness of  a
wind barrier is directly proportional to its height  (the effectiveness  at any
point  is dependent on the ratio of barrier height to the distance  from  the
base of the barrier to that point).  One study estimated that windscreens at
waste  piles can reduce wind erosion  by an average of 80 percent.^

Co s t s

     Modifications  to the storage area are expected  to vary in  cost, depending
upon the design features selected.   Costs are based  upon construction labor
and materials,  and  operating materials requirements.  There is  no  energy  or
operating  labor cost involved, and maintenance costs are assumed to be
relatively insignificant.  Detailed  information on the control  systems
described  in  this section is not available.  In general, troughing/spill
drainage modifications are expected  to cost  less than wind barriers, which  in
turn are expected to cost less than  building containments.
     The costs  of a spill drainage  system was estimated  by SCS  in  1983  for  a
system involving a  concrete  floor with curbs and gutters (a 1200 square foot
area of 6  in.  thick sloped concrete  pad  with perimeter curbs  and gutters).^
This system is  estimated to  cost $5,200  in current dollars (March  1985).
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     The same study by SCS estimated that a fencing system consisting of a
6-foot  high, 6 gauge galvanized  industrial chain  link  fence  with  2-inch  line
posts and 10-foot 1-5/8 inch top soils and three strand barbed wire; two 15-ft
wide gates; and four 3-ft wide gates  would cost $16,600 (in March 1985
dollars) for an area of 9000 ft2 (capable of holding 100 drums).
     A building containment system was estimated by SCS for a structure of
33,120 cubic feet.^  In present value, the cost is estimated to be $68,000
for the building alone.

SPILLAGE CONTAINMENT

Introduction

     Because the air release of hazardous constituents from containerized
wastes  is  largely attributable to leaks and spills of volatile hazardous
materials,  those techniques established for containing, collecting, and
removing spilled material represent a significant area for emission control.
Spills  of  waste from containers generally occur during drum handling (moving)
operations, and to a lesser extent during drum loading operations.  Leakage
from containers occurs primarily during storage and disposal.  At present, the
various spill control  techniques in use are limited in their applica-
                                                            >i
                                                            6
bility.   The methods of controlling the vapor release of spills can be
generalized as  belonging  to one of the following categories:

      •     control  by mechanical means;
      •     control  by chemical means; and
      •     control  by use  of physical properties of the spilled substance,

Description

      All  spill  control procedures incorporate the following elements:

      •     isolation of spilled substance;
      •     coverage of spilled substance;
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     •    absorption of spilled substance; and
     •    removal of spilled substance and contaminated materials.

     The methods by which substances are absorbed and removed are standard
throughout the industry.  This subsection will focus on procedures to isolate
and cover substances.  In selecting a spill containment option, the following
considerations must be made in determining the applicability of the option.

     •    Type of material spilled.  Chemical compatibility, volatility, or
          physical properties of the spilled substance.
     •    Amount spilled.  Whether a great deal of material must be contained
          or only a small amount.
     •    Manpower and/or materials requirements.  A facility needs to
          consider the personnel or equipment capacity necessary.
     •    Spill  location.  Where a certain substance is spilled in relation to
          other parts of a TSDF.

     The  three categories of spill containment options each include procedures
which satisfy much of the above criteria.  The most commonly used procedures
are described below.

Control by Mechanical Means—
     By placing  a barrier between  the hazardous material and the environment
(atmosphere), the release of volatile material can be hindered or
eliminated.   Similar control  technologies have been applied for control of
emissions from surface  impoundments.  A mechanical barrier is applicable to
most spills.  Examples  of this  type of system are:

     •    tarpaulin or  synthetic membrane; and
     •    foam cover.

A mechanical barrier may be  limited in applicability due especially to
chemical  compatibility  or spill volume.
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     Synthetic Membrane/Tarpaulin—A synthetic membrane or  tarpaulin  is
generally a simple sheet (blanket) which would be spread out over  the spill.
These systems have been used extensively in industry.   The primary design
features which must be considered in selecting the most appropriate membrane
cover are the size of the cover, resistance to chemicals, transportability  to
spill location, and spreading technique.  These covers may  be treated with
special coatings.  They may be packaged in certain ways (e.g., parachute
covers) which make for more facile usage.  They may also be made from either
flexible or rigid materials.

     Foam Cover—There are a wide variety of foams which have found
application for spill control, including protein foams, surfactant foams, and
alcohol-based foams.   Foams are used extensively for application  in
             Q
fire-fighting  and in control of natural gas spills.  A foam blanket acts
both to isolate the spill from the atmosphere and sources of radiant energy,
and to either absorb the chemical or dilute the surface layer of the spill.  A
foam cover can be used to control both landborne and aqueous spills of
volatile compounds.   The primary design features to be considered in
selecting foam cover systems are the type of foam, the foam application
process required, and the handling of contaminated foara.

Control by Chemical Means—
     By addition of selected chemicals to the spill, the physical  or chemical
form of the spilled material may be altered, thus reducing  the volatility of
the material.   Chemical addition is applicable to many landborne  spills,
but in most cases may not be used for aqueous spills.  The  two most common
methods employed are water dilution and chemical neutralization.

     Water Dilution—Water may be applied to spilled materials in  a variety of
ways, including as a spray or mist, or by simply flooding.  Dilution with
water is the most common method employed for mitigation of  spills.   The
water acts as a diluent and/or a dispersant.  The primary design features to
consider in selecting the water dilution system to be  implemented  are
availability of water supply, chemical compatibility of water with spilled
materials, water application procedure, and seepage control.
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     Chemical Neutralization—Chemical neutralization agents are  available  in
                                                    H
various forms including foams, powders, and  liquids.   Neutralization  is  a
fairly common spill control procedure.   It  is applicable  to most  spills.
The primary considerations involved in selecting an appropriate neutralization
system are chemical compatibility, waste neutralizability  (hazardous waste
materials tend not to be consistent in their properties, and thus  a certain
"kind" of waste may not always be neutralized by a certain agent), application
procedure, and neutralization agent storage and handling procedures (the
agents themselves may be hazardous in nature).

Control by Use of Physical Properties—
     By altering the conditions affecting the spill, it is possible to utilize
the physical properties of the spill to control vaporization.   Among the
physical properties that might be taken advantage of are the sorptability,  and
vaporization point temperature.  The most commonly used control options of
this type are thus absorption and cooling.

     Absorption—A wide variety of materials may be used as an absorbent,
including straw, charcoal, mulch, flour, or one of the many commercially
available sorbents.   Absorption is, therefore, used extensively as a spill
containment alternative.  The sorbents can be kept readily available.  The
sorbents can be applied when needed either by hand or spray gun.   Sorbents  are
applicable to any spill situation.  The primary design considerations to be
made in selecting an appropriate absorbent are type of materials spilled,
application method, and contaminated sorbent handling and  disposal.

     Cooling—Many different cryogenic materials are utilized to reduce the
temperature of a spill such that the volatility of the material is reduced,
including ice, dry ice, liquid CO^, and liquid nitrogen.   Cooling has not
found wide application in spill control, although it is used in conjunction
with other procedures (cooling increases control effectiveness).   Coolants  are
generally applied by spraying over the spill.  The primary considerations
involved in selecting a cooling system are coolant type and availability,
chemical compatibility, and coolant storage  procedure.
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     Spill control procedures are very simple to implement.  Most do not
require complex application procedures or equipment.  Relative to other
container emission control options, spillage containment are perhaps the
easiest to implement at a TSDF.

Emission Reduction Effectiveness

     Spillage containment technology is considered to be a relatively
effective means of controlling emissions from spills of containerized waste.
As summarized in Table 3-2, ratings based upon field evaluation of control
technologies have been developed.  Table 3-2 shows that certain technologies,
in particular foam covers and water dilution, are moderately to highly
effective in reduction of emissions.
     Mechanical covers (synthetic membranes and foam covers) have been
assessed in a number of EPA documents.  Synthetic membrane covers, which are
similar to the covers used for surface impoundment emission control described
in Section 5, have been estimated by MITRE to be up to 90 percent effective
                                               9
for emission control from surface impoundments.   The effectiveness of such
systems applied to spill control may be somewhat less, due to lower scale
application.  In general, the effectiveness of synthetic membrane covers
relates to the vapor permeability of cover materials (see Table 4-2 in
Section 4) and the effectiveness of enclosure.  Foam covers used for spill
control were assessed in detail by Gross and Hiltz.   A summary of their
findings  is presented in Table 3-3, and is detailed below:
      1.   High  quality foams which have low drainage, i.e., retain their water
          content, performed the best in mitigating the vapors during spill
          control  tests.
      2.   For nonpolar liquids, any high quality foam cover, regardless of its
          chemical type, will provide some degree of mitigation of vapor
          release.
      3.   Only  alcohol foam was stable against hjighly polar low molecular
          weight  liquids such as acetone.  Other types of  foam rapidly
          collapsed.
      4.   The vapors  from polar spills may be mitigated with nonalcohol type
          low expansion foams if the volume of foam is several times greater
          than  the volume of the spill.  This reduction is mainly due to water
          dilution rather than a foam cover.
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TABLE 3-2.  RATING OF EFFICIENCY OF CURRENT RESPONSE TECHNIQUES TO CONTROL
            EVAPORATION
                                      Slight       Moderate     Highly
                                     reduction    reduction    effective
Sumping and trenching

Wet Foaming

Deep soil burial

Sorbents (straw, mulch, etc.)

Water flooding

Dispersants (on thin water layers)


Source:  Brown et al.,  1981 (Ref. 6).
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              TABLE 3-3.  MATRIX OF FOAM CAPABILITIES TO SUPPRESS OR OTHERWISE MINIMIZE THE RELEASE OF

                          TOXIC OR FLAMMABLE VAPORS FROM SPILLED HAZARDOUS CHEMICALS AS LISTED
u>
 I


i-octane
n-heptane
Cyclohexane
Hexane
Benzene
Toluene
Gasoline
Kerosene
Naphtha
Methanol
i-propanol
Butanol
Butyl Cellosolve
Acetone
Methyl Ethyl Ketone
Methyl 1-butyl ketone
Lacquer Thinner
Paint Thinner

Recommen-
dation
R
R
R
R
R
R
R
R
R
R
R
R
ND
R
ND
R
ND
ND
Surfacta
Low ex-
pansion
B+
B+
B+
B+
B+
B+
B+
B+
B+
E-
E-
E-
ND
fi-
ll
B+
U
U
,nt foams
High ex-
pansion
A+
A+
A+
A+
A+
A+
A+
A+
A+
E-
E-
E-
ND
E-
U
A+
ND
ND

Protein
B+
B+
B+
B+
-
-
B+
B+
B+
E-
E-
E-
U
fi-
ll
U
ND
ND

Fluoro-
protein
B+
B+
B+
B+
-
-
B+
B+
B+
E-
E-
E-
ND
E-
ND
ND
ND
ND

Alcohol
E-
E-
E-
E-
E-
E-
E-
E-
E-
A+
A+
A+
ND
A+
ND
ND
ND
ND

AFFFa
C+
C+
C+
C+
ND
ND
C+
C+
C+
E-
E-
E-
ND
E-
ND
ND
U
U

Mech.
U
U
U
U
ND
ND
U
C+
U
-
-
-
U
ND
ND
ND
ND
ND
                                                     (continued)

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                                                 TABLE 3-3 (continued)
Ul
 I
OC


sici4
i-amyl Alcohol
Ethyl Acetate
Butyl Acetate
i-propyl Acetane
Methyl Acrylate
Methyl Methacrylate
so3
Acetic Acid
Caproic Acid
Methyl Bromide
Butyl Bromide
N,N '-dimethyl Formamide
Tetrachloroe thane
n-Octanol
Tetrahydronaph tha lene
LNG
Chlorine
Ammonia

Recommen-
dation
R
ND
ND
ND
ND
R
R
R
R
ND
ND
R
ND
R
R
R
R
R
R
Surf acts
Low ex-
pansion
C+
U
U
U
U
B+
B+
C+
A+
U
U
A+
U
B+
B+
B+
E-
B+
A+
mt foams
High ex-
pansion
C+
U
-
-
-
A+
A+
O
B+
ND
U
U
E-
A+
A+
A+
A+
A+
A+

Protein
C+
U
-
-
-
ND
ND
C+
ND
ND
ND
ND
ND
ND
B+
E-
F-
B-
B+

Fluoro-
protein
C+
ND
U
U
U
U
U
C+
ND
ND
ND
ND
ND
ND
+
ND
F-
B-
B+

Alcohol
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
-
ND
F-
ND
ND

AFFFS
F-
ND
ND
ND
ND
ND
ND
F-
ND
ND
ND
ND
ND
ND
ND
U
F-
E-
E-

Mech.
ND
ND
ND
ND
ND
ND
ND
ND
U
U
ND
ND
ND
ND
U
ND
ND
ND
ND
                                                      (continued)

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                                          TABLE 3-3 (continued)
Identification  of Symbols




aAFFF = Aqueous  film  forming foam




+  = Data available indicating vapor pollution control




-  = Data available indicating no vapor pollution control




U  = Limited data available - capability uncertain







R  = Foam use recommended over spill




ND = Insufficient data







A  = Best foam  formulation




B  = Next best  foam formulation




C  = Acceptable  in some situations




E  = Unsuitable  foam  formulation




F  = Deleterious foam formulation




Source:   Gross and Hiltz, 1982 (Reference 5).

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     5.    For  liquids which are extremely water reactive, high expansion foam
          provides  the best control.   This is due to the heats of reaction or
          solution.   The higher the expansion, the slower is the rate of water
          addition  to the reactive liquid.

     6.    Foams do  not effectively mitigate the vapors for liquefied gases
          which are heavier than air and not water reactive.  The water
          draining  into the liquefied gas exaggerates the boil off rate.  The
          released  vapors, being nonbuoyant, are not readily dispersed.  There
          are  reports of foam being effective against butane, but the data
          from the  tests of this program are not in agreement.

     7.    For  liquefied gases such as ethylene which are buoyant at ambient
          temperatures, a high expansion foam blanket acts as a heat source.
          The  vapors rising through the foam increase in temperature and
          dispersion of the released vapor is enhanced.

     8.    Laboratory tests can be conducted to predict the behavior of foams
          under field conditions.

     9o    Environmental conditions such as wind and rain are more detrimental
          to high expansion foams than to low expansion foams.

     10.  High expansion foams appear to mitigate a spill by containing the
          vapors within the foam mass so a vapor-liquid equilibrium can be
          maintained, thus reducing the driving force towards vaporization.

     11.  Low expansion foams appear to mitigate the vapor by forming a
          barrier to prevent vaporization.

     12.  Foams are an inexpensive, effective method of initial vapor control
          during an accidental spill, provided the correct foam made from a
          quality agent is used.

     13.  The foam agent which produced the best results in terms of vapor
          mitigation was the metal stearate-based alcohol type foam.  This
          foam agent was better than the newer forms of polar solvent foams.
          The alcohol type foams were more difficult to apply, more was needed
          to establish a desired thickness, and the foam cover is fairly
          stiff.  However, once the foam cover was established, it provided
          good mitigation of vapors.


No data are available which quantifies the achievable reduction efficiency.
     Control by chemical means were studied by Brown et al.   Water dilution
and chemical neutralization were considered to be relatively effective,
however often produced unwanted hazardous side effects.   Data which

quantify emission reduction effectiveness for these techniques are limited.

The effectiveness of a similar technique, application of surfactant on a
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                                                                2
surface impoundment, was estimated by MITRE at 25 to 75 percent.   It is
expected that the control efficiency of these methods would fall within the
same range.
     Control of spills by adsorption or cooling was considered by Brown et al.
to be only slightly to moderately effective.   According to Brown, however,
Battelle considers control by cryogenic media to be an area of potential
development.   Data which quantify emission reduction effectiveness by these
methods are also limited.  Based upon the available information, these control
technologies are not expected to be as effective as either control by
mechanical or by chemical means.

Costs
     The costs associated with various spillage control technologies are, in
general, expected to be relatively low.  These costs will range widely,
however, as the complexity of the various systems is quite different from case
to case.  Like emission reduction effectiveness data, cost data for these
systems are severely limited.  The various costs are expected to be highly
dependent upon materials and labor, while operating and installation costs are
expected to be relatively low.
     The costs of a synthetic membrane cover or foam cover system depend upon
the cover material chosen, and the installation method used.  The synthetic
membrane or foam materials used are not unlike those in use for other similar
systems at TSDF processes.  Costs for such materials are presented in
Section 6 on  landfill emission control.  They have been estimated to range
between $3 and $26/per square yard for synthetic membranes, and $2.25/per
                                9
square yard for temporary foams.   Brown et al. estimated that a spill
containment foam system which could deliver approximately 15,000 gal/min of
aqueous-based foam would cost approximately $1,300 to implement at a
facility.6
     The costs associated with implementing a water dilution or chemical
neutralization system are largely dependent upon the equipment costs
involved.  The actual cost of chemical agents or water is assumed to be very
low in comparison.  Brown et al. estimated that a water spray pump machine
                                    3-21

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which can be used to apply a water mist blanket over a chemical  spill would
cost less than $925 (March 1983 dollars).6  The costs associated with
storing neutralization agents or water to be used  for this purpose have not
been evaluated.
     The costs associated with using absorbents or coolants  for  spill
mitigation are similar to those for water dilution or chemical
neutralization.  For solid absorbents, the costs would be based  upon materials
costs only.

CONTAINER MODIFICATION

Introduction

     Reduction of spillage and leaks from containers and, consequently,
significant reduction of emissions, may be effected by securing  the containers
themselves.  The containers are subject to a variety of  stresses, both from
within  and  from outside, including corrosion, denting, and puncture.
Encapsulation  systems are designed to  insulate the containers from the outside
and  also  to contain corrosive materials inside should they leak  from the
containers.  There are two basic  types of encapsulation  systems, as follows:

     •    Overpack designs; and
     •    Directly-applied systems.

Encapsulation  systems have only recently  found application in industry.  This
section will present  alternatives  based on  information found chiefly through
laboratory  test  programs.

Description

     The basic function  of an  encapsulation system is to completely enclose an
individual  container.  Emission of vapors resulting  from both leakage and
breathing loss would  essentially  be  eliminated.  Drums placed in an
encapsulate would  be  insulated  from  mechanical and chemical  stresses, and
                                     3-22

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thermal fluctuations.  Most encapsulates employ polymeric resins (e.g.,
polyethylene).9  Polymeric materials offer several advantages over steel or
other materials, including chemical compatibility, corrosion resistance,
weight, mechanical resilience, flexibility, strength, and low materials and
fabrication cost.  Use of polymeric materials allows for fabrication to be
done onsite, and also allows the use of readily transportable equipment, thus
facilitating their use at a TSDF.  In selecting the container modification
system most applicable to a specific TSDF, the following considerations must
be made in determining the applicability of the system:

     •    Type of material being handled.  Chemical compatibility, density,
          and volatility are all factors which must be considered.
     •    Type of containers being handled.  Containers of a certain size or
          material of construction may not be well handled by a certain
          modification.
     •    Containerized waste fate.  Encapsulation is most suited to unit
          disposal.9  Whether the containers are to be disposed of,
          shredded, or reused.
     •    Manpower requirements.  Whether or not a facility will have the
          manpower required for a certain container modification procedure.
     •    Availability of materials.  Encapsulation requires the use of
          certain special materials.

Overpack Systems —
     An overpack is essentially a jar into which a container is placed.  The
overpack is then covered and sealed, permanently.  By sealing the container
into the impermeable overpack, emissions  from waste are eliminated.  Overpacks
are available commercially, and can be produced by any manufacturer of
                     Q
rotomolded  plastics.   They can be made in a variety of sizes, capable of
handling any size from small containers to 55-gallon drums.  Overpacks are
commonly packed with sorbent material which fills  the gap between  the drum and
the overpack wall.    The sorbent material will act to stabilize the drum
within the  capsule,  insulate the drum from both thermal fluctuations and
physical shocks, and absorb leaking waste.  The key difference between
available overpack systems is in the method by which they are sealed. ^'^
The two designs described in the literature are as follows:
                                     3-23

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     •    Single layer,  friction welded;10 and
     •    Double layer,  fiberglass-lined.9

Overpacks are the more applicable of the two  types of encapsulation  systems.
They are especially well suited to handling highly reactive  or  corrosive
wastes.

     Single Layer, Friction Welded—Single layer  type overpack  systems  are
generally formed from polyethylene, although  polypropylene and  polyvinyl
chloride types  have been tested.  The systems come in two pieces:  the  capsule
and  the cover.  To seal  the capsule, friction welding has been  proposed as  the
most effective  means of  closure.  (Other designs  use mechanical  closure or
adhesives.)  A  typical overpack welding  system  is shown  in Figures 3-1
and  3-2.  The system employs  a welding device which may  be made  transportable
for  use at a TSDF.  The  primary design considerations in implementing this
type of system  are overpack materials (availability and  compatibility),
manpower requirements, and type of containers being handled.

     Double  Layer, Fiberglass Lined—Double  layer overpack systems also use
polyethylene, or polypropylene on the outside layer, and thus function
identically  to  single  layer designs.  The difference is  that double  layer
systems employ  a fiberglass inner layer  which is  formed  directly onto the
container,  thus giving a seamless seal.  The  outer layer then adheres to the
fiberglass  layer, eliminating the need to .seal  the cover.  Double layer
systems  require two applicator systems:  a spray  gun applicator  for  the
fiberglass  inner layer,  and a fusion mold system, as shown in Figure 3-3, for
the  polyethylene  layer.  The  primary design  features to  be considered in
selecting a  double layer system are  the  availability of  materials, the
manpower requirements, the application procedure, whether or not to  use
sorbents, and the transportability of equipment.

Directly-applied Systems—
     Directly-applied  systems involve spraying  or brushing resin or  other
material onto the surface of  the container.   Such systems have  the advantage
                                     3-24

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CYLINDER
                                                        PUMP
                                                    RECEPTACLE


                                                    55 gallon DRUM
   Figure 3-1.  Apparatus for encapsulating 208-liter (55-gal)
               drums holding hazardous  wastes.

   Source:   Lubowitz & Telles, 1981 (Reference 10).
                            3-25

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                                        DRIVERTRAIN



                                           LABELS
                                                    SLOTTED PLATTEN
                                                    RIBBED COVER
                                    LOADING
                                   PLATFORM
Figure  3-2.   EPP overpack welding unit.


Source:   Lubowitz  & Telles,  1981  (Reference  10),

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  UPPER HYDRAULIC
      RAM
    1 TON CAP
CLAM SHELL
HEATING JACKET
     JACKET
 HEATING COILS
 INSULATION
  LOADING
   LEVEL
  LOWER
  HYDRAULIC
     RAM
  I  TON  CAP
YOKE 6" X 6" 1 BEAM

JACKET
SUPPORT
                                                FLEXIBLE  HYDRAULIC
                                                AND HEATING  LINES
       TRUNNION BEARING AND
       ROTATION MECHANISM
                                                     ROTATION
                                                       PIT
         Figure 3-3.   Side view of the polyethylene fusion mold,

        Source:  Lubowitz & Telles,  1981.  Reference 9.
                                3-27

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of be Lnt; applicable Co any size or shape container, however do not insulate
the container as well as an overpack system.  Such systems also have no
seams.   A variety of materials are used in this application, including
fiberglass, polyethylene, and concrete.  The primary considerations in
implementing a directly-applied encapsulation system are container materials,
chemical compatibility, manpower requirements, application procedure, and  the
storage and handling of spray-on materials.
     Encapsulation systems appear to be relatively easy to implement at a
TSDF.  The requirements for operating an encapsulation system are the
encapsulation materials, application equipment (both of which must be
purchased) and trained operators.

Emission Reduction Effectiveness

     The reduction efficiency of an overpack or directly-applied encapsulation
system has been described in several laboratory test reports.  The systems
were found to be water-tight and performed better in strength tests than steel
overpack systems.  The reduction efficiency was estimated to approach
100 percent with well  insulated systems.  Volatile organic compound (VOC)
emissions would be essentially eliminated unless extreme heat conditions were
encountered.
 Costs
      The  costs  involved  in  implementing  this system  include capital equipment,
material,  and  labor.   The equipment  includes conventional drum-handling
equipment,  spray  guns, or overpacking  apparatus.  Materials costs include
costs of  resin  and  sorbent  material.   A  total cost estimate of $65 to $90/drum
for  overpack systems,  and $26  to  $40/drum  for directly-applied systems has
been calculated based  upon  encapsulation of a 55-gallon steel drum as
described in this section.
                                     3-28

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OPERATING PRACTICES

Introduction

     Because container leakage and spillage play  such  a  significant  role  in
emissions from containerized waste, operating practices  are a  potentially
significant area in which  to effect emission reductions.   Changes  in operating
practices would be specifically  intended to reduce mishandling or  degradation
of the containers.  This subsection will focus upon  three  changes  in operating
practices, as follows:

     •    Improved drum equipment and/or procedures;
     •    Leak detection and repair programs; and
     •    Submerged loading.

Changes  in operating practices are applicable to  any TSDF.

Description

     The purpose of improving operating practices is to  insure that
mishandling of containers  is prevented, factors which  lead to  the  degradation
of containers  (such as storage in a damp area) are reduced or  eliminated,  and
conditions which exacerbate  the  volatility of a waste  are  reduced.   In
 implementing changes in operating practices at a  TSDF, the following
considerations must be taken into account:

     •    Manpower  requirements.  Whether or not  a facility has the  personnel
          required  to implement  a certain change  in  operating  practice.
     •    Storage procedures.  The way containers are  stored may determine the
          applicability of a certain change in operating practice.
     •    Input/output.  The turnover rate a facility  maintains may  determine
          the applicability of a certain change in operating procedure.

     The three changes to  be reviewed in this subsection are quite common
practices at TSDFs and, as such, adhere to the above criteria.

                                    3-29

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Improved Drum Handling—
     By making improvements in the procedures used in the handling of
containers, either by purchase of better equipment or use of new procedurest
mishandling of drums can be reduced.  Mishandling of drums is the primary
cause of spills and damage to containers (leading to leaks) at TSDFs.   The
most common procedure now employed is to move drums, either two or four at a
time, by forklift.  Spills or damage commonly occur when drums fall off of the
pallets when they are in transit, or when the forklift collides with another
object.  Handling spills also occur during unloading of drums, and during drum
disposal operations.  Three changes which are common are as follows:

     •     Drum "grabber" equipment;
     •     Slow pouring; and
     •     Drum decontamination.

     Drum  "Grabber" Equipment—Drum grabbers are specially made forklifts
designed for transport of 55-gallon drums.  Drum grabbers are equipped with a
device  which wraps around the drum, thus providing a secure hold.  In some
designs, the drums are further protected by bumpers or screens so that damages
                                                         ^
in  the  event of a collision can  be reduced or eliminated.   The primary
considerations involved in selecting drum grabber equipment are available
space  requirements in  the storage area, size of drums handled, and drum
turnover rate.

     Slow  pouring—Pouring of waste material from drums often is a major
source  of  spills.  Through more  careful procedures, these spills can be
reduced.   Slow pouring may be accomplished either by implementing equipment
such as spouts, or simply by improved technique.  The considerations to be
made in implementing  this procedure are present pouring method (manual or
mechanical), waste viscosity, and drum type.

     Drum  Decontamination—After waste material has been poured from the
drums,  they are either reused or disposed of.  Residual waste often spills
                                       3-30

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during handling of empty drums.  These spills can be eliminated by
decontamination procedures.  Decontamination involves scrubbing of the drum
walls, either manually, mechanically, or chemically.  A variety of cleaning
solvents may be used for this application.  Among the primary considerations
involved in this procedure are type of drums handled, cleaning solvents,
control of volatile emissions from cleaning materials and operations, and
disposal of waste materials.

Leak Detection and Repair (LDAR) Programs—
     By instituting a program for continuously checking containers and
immediately repairing them if potential for leaking exists, a facility can
reduce the number of leaks that occur, increase the speed of response to those
that do occur and thus reduce emissions.  Various monitoring techniques that
can be used in a leak detection program include individual component surveys,
unit area ("walkthrough") surveys, and fixed point monitoring systems.

     Individual Component Survey—An individual component survey involves
checking each potential container leakage source for VOC leaks.  This may be
accomplished by spraying a suspected leakage source with a soap solution and
observing bubble formation or measuring VOC concentration with a portable VOC
detector.  In selecting an individual component survey LDAR program, the
primary considerations are the number of containers, manpower requirements,
personnel access to the containers and waste products.

     Walk-through Survey—A walk-through survey involves checking each
container.for VOC leaks by measuring the VOC concentration close by.  This is
accomplished with a portable VOC measurement device.  This type of survey has
the advantage of being quicker and requiring less manpower, but is not as
thorough as an individual component survey.  The primary considerations
involved in selecting a walk-through survey for LDAR are the number of
containers, prevailing weather (especially wind) conditions, access to
containers, and manpower requirements.

     Fixed-Point Surveys—A fixed-point survey involves placing a continuous
monitor in various locations at the storage area.  LDAR programs would then

                                    3-31

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involve responding to an audio alarm system or monitoring  the measurements on
a periodic basis.  These programs can result in  leaks being detected sooner.
Like walk-through surveys, however, they are not as  thorough as  individual
component surveys and, in addition, have higher equipment  costs.  The primary
considerations involved in selecting this option are the number  of containers,
size of storage area, manpower requirements, weather conditions, and number of
units required.  Of  the three options, fixed-point surveys have  found the most
widespread application to detection of hazardous or  toxic  emissions.

Submerged Loading—
     Loading of containers is often done at a TSDF.  Emissions from loading of
containers, like storage tanks, can be reduced by employing submerged
filling.  For open containers, submerged filling would require a nozzle which
would be placed at the bottom of the drum.  For enclosed containers, this may
require a pressure attachment to the bung hole.  The primary considerations
involved in instituting submerged loading procedures are the type of drums
being filled, and the type of waste material.

Other Practices—
     In addition to  those described in detail above, there exist many other
changes that may be  made in operating practices at a TSDF which may contribute
to  reduction of emissions.  These may include prohibiting drum stacking,
segregating wastes,  and not allowing containerized wastes  to be  stored,
handled, or disposed of at all.
     Implementation  of the changes  in operating  practices  at a TSDF are
dependent upon several factors,  including new equipment, manpower, and
overall system complexity.  Most of the changes  described  above  are considered
to  be extremely easy to implement.

Emission Reduction Effectiveness

     Changes made  in operating practices at a  facility which handles
containerized hazardous wastes are  expected to result in the reduction of air
emissions due to decreased mishandling, spills,  and  leaks.  No detailed
                                     3-32

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information has been published, however, which indicates the effectiveness of
such measures relative to add-on control systems.  Based upon engineering
judgment, these measures are considered moderately effective, but not as
effective as many of the add-on control systems.
     The effectiveness for better drum handling equipment is a direct function
of the reduction in accidents and mishandling of drums at a facility.  A
survey of manufacturers of drum handling equipment revealed that such
equipment has been found to be responsible for reducing mishandling incidents
by 50 to 75 percent.12
     The effectiveness of leak detection and repair programs may be measured
in terms of the percentage of previously undetected leaks which are detected
in the surveys.  OAQPS reports that the effectiveness of various LDAR programs
              13
is as follows:

     •    Individual component survey:  99. percent
     •    Walk-through survey:         50 percent
     •    Fixed-point survey:           33 percent.

     The effectiveness of submerged loading has been studied extensively for
the  filling and emptying of storage vessels.  AP-42 reports that submerged
loading  can result in emissions reductions of 66 percent.15
Costs
     The costs  involved in  implementing operating practice changes at a TSDF
are expected  to be relatively  low, based upon limited information.  These
costs  are dependent upon  the materials and/or equipment requirements, and
labor.  Operating costs are generally expected to be low.
     Improving  drum handling equipment may involve costs associated with
purchasing drum grabber equipment or decontamination equipment and materials.
Decontamination procedures  would also involve added materials handling and
disposition costs.  Slow  pouring would not involve any additional costs,
except  those  that may  be  incurred due to decreased rate of operation or added
manpower required.  Drum  grabber equipment was found to cost  in  the $300  to
                                     3-33

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                                                     I rt
$6UO range.*, based upon conversations witli suppliers.    Costs  of
decontamination systems could not be determined based upon  the available
information.
     The costs involved in  leak detection and  repair  programs  essentially
involve just equipment and  labor costs.  Based on conversations with
suppliers,  VOC monitoring equipment costs are  estimated to  be  within  the $200
to $1,000 range for portable units, and  $500 to $3,000 for  fixed
         14
monitors.    Labor costs would vary with the size of  the  facility.
     The costs of submerged loading essentially involve just equipment  costs.
No information detailing the cost of longer fill pipes, pressure  nozzles,  etc.
was found.  It is estimated that such costs would be  quite  low.
                                     3-34

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                            REFERENCES FOR SECTION 3
1.   Engineering-Science.   National Air Emissions from Tank and Container
     Storage and Handling  Operations at Hazardous Waste Treatment, Storage,
     and Disposal Facilities.   Prepared for U.S.  Environmental Protection
     Agency, Office of Air Quality Planning and Standards,  Research Triangle
     Park, NC.  September  1984.

2.   Vogel, G. A., and D.  F.  O'Sullivan.   Air Emission Control Practices at
     Hazardous Waste Management  Facilities.  Report No. MTR-83W89.  Prepared
     for U.S. Environmental Protection Agency,  Office of Solid Waste, Contract
     No. 68-01-6092.  The  MITRE  Corporation,  McLean, VA.  June 1983.

3.   Drehmel, D., B. Danel, and  D. Corner.   Relative Effectiveness of Chemical
     Additives and Wind Screens  for Fugitive  Dust Control.   Environmental
     Progress 1(1) :16.  February 1982.

4.   SCS Engineers.  Interim Report on Air Emissions.  Prepared for U.S.
     Environmental Protection Agency, Office  of Solid Waste, Contract
     No. 68-01-6621, SCS Engineers, Covington,  KY.  September 1983.

5.   Gross, S. S., and R.  H.  Hiltz.  Evaluation of Foams for Mitigating Air
     Pollution from Hazardous Spills.  EPA-600/2-82-029.  U.S. Environmental
     Protection Agency, Office of Research and Development, Cincinnati, OH.
     Contract No. 68-03-2478.  March 1982.

6.   Brown, D., R. Craig,  M.  Edwards, N.  Henderson, and T.  J. Thomas.
     Techniques for Handling Landborne Spills of Volatile Hazardous
     Substances.  EPA-600/2-81-207.  U.S. Environmental Protection Agency,
     Office of Research and Development,  Cincinnati, OH.  Contract
     No. 68-02-1323.  September 1981.

7.   Greer, J. S., S. S. Gross.   R. H. Hiltz, and M. J. McGoff.  Modification
     of Spill Factors Affecting Air Pollution.  Vol. I - An Evaluation of
     Cooling as a Vapor Mitigation Procedure for Spilled Volatile Chemicals.
     EPA-600/2-81-214.  U.S.  Environmental Protection Agency, Office of
     Research and Development, Cincinnati, OH.  Contract No. 68-03-2648.
     September 1981.

8.   Greer, J. S., S. S. Gross,  R. H. Hiltz,  and M. J. McGoff.  Modification
     of Spill Factors Affecting Air Pollution.  Vol. II - The Control of  the
     Vapor  Hazard from Spills of Liquid Rocket Fuels.  EPA-600/2-82-215.  U.S.
     Environmental Protection Agency, Office of Research and Development,
     Cincinnati, OH.  Contract No. 68-03-2648.  September 1981.


                                    3-35

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9.    LubowLtz, H. R., an
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                                    SECTION  4
                     CONTROL  OF  EMISSIONS  FROM  STORAGE  TANKS

INTRODUCTION

     There are two basic types of tanks found at TSDFs:  open-top and
closed-top.  The tanks in use range in capacity from 5000 to 1,500,000
gallons.  Most are above ground, although some liquid wastes are stored in
submerged tanks.  Hazardous materials are generally brought to a facility by
tank truck or rail car, and the tanks are loaded, generally via pipeline, by
either splash or submerged filling techniques.
     Hazardous constituent releases from storage tanks can occur via two
mechanisms for closed-top tanks: working loss and breathing loss.  Working
loss, which accounts for a more significant percentage of emissions, occurs
when liquid being put into a tank causes the displacement of an equal volume
of vapor.  Breathing loss occurs when a volatile compound is vaporized and
released from tank due to temperature fluctuations affecting the tank.  For
open-tanks, air releases of waste constituents are a function the diffusion
and mass transfer from the bulk material.
     The control options available to a facility which stores volatile waste
material in tanks can be classified as follows:

     •    Roofs and  associated control systems;
     •    Covers;
     •    Insulation; and
     •    Vapor control systems.

     Table 4-1 provides an overview of advantages and disadvantages of control
alternatives described in this section.  This section will  describe technology

                                     4-1

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              TABLE 4-1.   ADVANTAGES AND DISADVANTAGES OF STORAGE  TANK  EMISSION  CONTROL  ALTERNATIVES
                        Advantages
                                                                        Disadvantages
i
to
ROOFS AND ASSOCIATED CONTROLS

Fixed Roofs:

•  Highly effective in reducing emissions from open
   tanks or external floating roof tanks.

•  Provide a permanent rigid cover.

•  Insulates constituents from solar irradiation,
   rain, and wind.

•  Very durable.
     •  Very low maintenance costs required.

     •  Easy to retrofit onto existing tanks  (in
        terms of design).

     Floating Roofs (External and Internal):

     •  Very highly effective in reducing emissions
        from tanks (higher than fixed roofs).

     •  Provides a permanent, rigid cover.

     •  Insulates constituents from solar irradiation
        and wind and rain.
                                                           •  Very  high  initial  costs.

                                                           •  Very  heavy—may  not  be  applicable to existing
                                                              tanks due  to  structural  considerations.

                                                           •  Requires venting due to  internal  pressure
                                                              considerations.
                                                           •  May  necessitate  changing  tank  loading
                                                              procedure.
                                                      •  Very  expensive—particularly in terms of
                                                        maintenance  (relative  to  fixed roofs).

                                                      •  Heavy—may be limited  by  structural  con-
                                                        siderations-

                                                      •  Requires  that inside design of tank  contain
                                                        no  support columns, or beams along side.
                                                   (continued)

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                                                 TABLE 4-1  (continued)
                           Advantages
                                                                        Disadvantages
-P-
i
Floating Roofs (External and Internal) (Cont'd):

•  Very durable.

•  Easy to retrofit to existing tanks.

•  Need not be vented.

•  Not as heavy as fixed roofs.

•  Less expensive initially than fixed roof.

Seals:

•  Increase effectiveness of all. floating roofs.

•  Simplistic designs, easily adaptable to existing
   systems.

•  Relatively inexpensive to install and maintain.

•  Durable.

•  Provide good thermal insulation, vapor
   permeability.

•  Relatively low costs,  overall.
                                                              •  Difficult  to maintain.

                                                              •  May warp or sink.

                                                              •  Not as good insulator from external forces
                                                                 (particularly heat)  as  fixed roofs.

                                                              •  May require alteration  of loading procedures.
                                                              •  Application limited by design of primary
                                                                 seal system,  internal  design of tank.

                                                              •  May increase  weight of roof.

                                                              •  May not  be  applicable  for use with all waste
                                                                 substances  (e.g.,  viscous materials).

                                                              •  Weather  conditions hinder effectiveness.
                                                      (continued)

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                                         TABLE 4-1  (continued)
                   Advantages
                  Disadvantages
Vents:

•  Necessary to reduce internal pressure
   buildup inside enclosed tanks.

•  Simple designs—easy to install on existing
   vessels.

•  Inexpensive to implement—only initial costs are
   involved.

•  Durable.

•  Easy to maintain.

COVERS

•  Highly effective in reducing emissions.

•  Simple designs, easily adaptable to more
   than one storage tank at a facility.

•  Easy to implement.

•  Applicable to varying size and shape
   storage tanks.

•  Provides a close-fitting cover, more flexible
   than a roof.
•  Increases working losses—not well suited  for
   highly volatile substances.

•  By itself, not a control.  Requires the use of
   vapor control system.
•  Less effective in reduction of emissions
   than roofs.

•  More permeable by vapors and gas.

•  Less durable than roofs.

•  Low strength characteristics.

•  Poor weather resistance.

•  Requires maintenance.
                                              (continued)

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                                          TABLE  4-1  (continued)
                   Advantages
                  Disadvantages
•  Light weight—will not sink.

•  Will not warp or corrode.

•  Adaptable  to changes  in constituent type.

•  Less costly than roofs, overall.

•  Generally  low operating costs.

•  Removable.

INSULATION

•  Reduces solar irradiation and wind on tanks
   and tank constituents.

•  Simplistic designs.

•  Widespread usage in industry.

•  Many available options to choose from.

•  Highly adaptable to any storage tank.

•  Can be used in conjunction with other
   control technology.

•  Requires little or no space.
   Will transmit heat directly to liquid,

   High maintenance and installed costs.
•  Poor weather resistance.

•  Applied directly to tank—effect may be
   limited by design constraints.

•  High maintenance costs.

•  Emission reductions achievable are low.
                                               (continued)

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                                          TABLE  4-1  (continued)
                   Advantages
                  Disadvantages
INSULATION (Cont'd)

•  Uses inexpensive materials.

•  Low installed costs.

•  Particularly attractive for open or external
   floating roof tanks.

VAPOR CONTROL SYSTEMS

•  Capable of achieving the highest emission
   reduction efficiencies of the control options
   described.

•  Completely remove vapor from tanks.

•  Equally effective in reducing working and
   breathing losses.

•  Best available technology for highly volatile
   and/or toxic substances.

•  Very safe to operate.

•  Basic design of systems are simple—they are
   easy to operate;  and easy to design to fit
   a tank.
•  Most costly of all control options dis-
   cussed for storage tanks.

•  Highly complex systems to maintain.

•  Manpower required.

•  Materials required.

•  Space required.

•  Accessibility required.

•  Requires enclosed tank.

•  Requires equipment for the disposition
   of vapor control process products.
                                               (continued)

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                                         TABLE 4-1  (continued)
                   Advantages                                           Disadvantages
VAPOR CONTROL SYSTEMS (Cont'd)

•  Can be applied to one or more than one tank        •  Subject to fire and explosion hazards.
   vent systems at once.
                                                      •  Can be subject  to design capacity
•  Can be a single-pass or multiple-pass system.          limitations.

•  Can selectively recover constituents.              •  Performance is  affected by prevailing
                                                         weather conditions.
•  Adaptable to a variety of wastes—can use even
   if wastes stored changes.

•  Can regenerate carbon beds for continuous use.

•  Have found widespread usage at TSDFs.

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options provided in Table 4-1 under each of  these classifications.  Example
systems will be cited, and the relative emission reduction  effectiveness  and
cost of implementing  these options to existing TSDFs will be  examined.
ROOFS
Introduction

     Storage  tank  roofs  serve  two  basic  purposes:   (1)  to  keep  tank
constituents  contained;  and  (2)  to  shelter  the constituents  from external
forces such as  solar  irradiation,  wind,  and precipitation.   Three basic  roof
designs  for storage tanks, include:

     •     Fixed roof;
     •     External floating  roof;  and
     •     Internal floating  roof.

All  three  types have  found widespread  application  at  TSDFs.

Description

     A storage  tank roof is  defined as any  rigid,  permanently affixed
mechanism  for enclosing  tank constituents from  the environment.  A roof  is
primarily  intended to keep  tank constituents  contained,  while excluding
environmental factors from  contact with these constituents.  As a control
option,  roofs are  particularly attractive as  they  serve to limit working
losses.  A variety of designs  are  available,  including  fixed roofs,  roofs  that
move as  the  liquid level of  a  tank changes,  and  roofs with and  without vapor
seals and  pressure vents.   In  addition,  roofs may  be  made  from  a variety of
materials.   In  determining  which design is  most  applicable to a particular
storage  tank  at a  TSDF,  the  following  factors should  be considered.
                                      4-8

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     •    Tank Design.  The size, shape, structural reinforcement, and
          structural strength of a storage tank.
     •    Type of material being stored.  The volatility, viscosity, and
          chemical nature of the materials being stored.
     •    Tank loading procedure.  How the tank is loaded, when, and how  often
          the tank is loaded and emptied.
     •    Weather conditions.  Sun, wind, and rain patterns of  the local  area.

     The three basic roof designs have all found widespread usage at TSDFs.  A
description of each roof design, how they may satisfy the above criteria  for a
particular storage tank, and the considerations involved in formulating a
specific design is provided below.

Fixed Roof—
     A fixed roof is defined as any rigid cover which is permanently affixed
to the top of a storage tank.  A variety of fixed roof tanks are shown in
Reference 4.  A fixed roof is the most common of the three roof designs.
There are three styles of fixed roofs:  conical, domed, and flat.  Conical
roofs are the most common of the three.
     Fixed roofs may be constructed of steel, aluminum, or plastic.  Choice of
materials is largely dependent upon the tank design.  Fixed roofs may also be
equipped with various appurtenances, such as vents, sampling ports, and
manholes.  Fixed roofs may be coated on the inside, insulated, raultilayered,
or painted a different color in an effort to reduce the effects of solar
irradiation of tank contents.  The following considerations which are involved
in formulating a design for a fixed roof.

     •    Roof size and weight.  Since storage tanks are constructed with  thin
          walls, the weight of a fixed roof may be limited by the structural
          constraints of the tank.
     •    Roof reinforcement.  The fixed roof may require columns, or bracings
          in order to be applicable to a tank.
                                      4-9

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     •    Root: venting.  Due to the volatility of tank constituents,  it may be
          necessary to incorporate vents into the roof design to reduce
          internal pressure buildup.
     •    Inflow/outflow pipe installation.  Installation of a  fixed  roof
          requires eliminating top loading procedures and installing  inflow/
          outflow pipes.

     Fixed roofs are considered to be relatively effective  in reducing
emissions from tanks, while remaining simple so that costs  are  not a  major
factor.  Analyses of reduction effectiveness and cost are presented later in
this section.

     Pressure Tanks—A pressure tank is a special type of fixed roof  tank
design.  They are specifically designed to withstand relatively large internal
pressures.  These types of  tanks are the most commonly used for storage of
highly volatile and/or toxic materials.   They are constructed  in various
sizes and shapes, depending on the operating pressure range.  Noded spheroid
and hemispheroid shapes are generally used for low pressure (117 to 207 kPa),
while horizontal cylinder and spheroid designs are generally used for
high-pressure tanks  (up to  1827 kPa).   Pressure tanks generally operate
                                                  3
with no emissions, as  they  are an enclosed system.   Because of their
complex design and use of structural materials, such tanks  tend to be much
more expensive.  The primary considerations involved in selecting a pressure
tank design include  the operating pressure range, loading and unloading
procedure, and tank  maintenance considerations.

     Flexible Diaphragm Tanks—Another specially modified type  of fixed roof
tank incorporates a  synthetic membrane, stretched over the  top  of the vapor
space.  The membrane (also  called "diaphragm" or "bladder") serves to limit
the emission of vapor  due to working losses by expanding within the fixed roof
as the tank is filled.  By  expanding, the volume of vapor which is displaced
when  the  tanks is filled with  liquid is not immediately pushed  out of the
tank.  The diaphragms  are generally made from a synthetic rubber material or
polyvinyl chloride.  The primary considerations involved in implementing a
flexible diaphragm  system are  the tank design (structural limitations),
compatibility of the diaphragm with the tank constituents,  and  diaphragm
venting.
                                     4-10

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External Floating RooE Tanks—
     A floating roof is defined as any rigid cover permanently  incorporated
into the storage tank design which moves such that the volume of the  tank
varies as the tank is filled and emptied.  A floating roof operates by  resting
directly upon the surface of the liquid.  Storage tank working  losses are
reduced because the floating roof imparts a slight pressure upon the  liquid,
thus eliminating available vapor space.  An external floating roof tank
utilizes such a roof as the sole means of enclosure.  Floating  roofs  are
                                                            2
always equipped with a flexible vapor seal at the perimeter.    In general,
they are constructed of aluminum or steel, although the use of  plastic
materials has become increasingly common.  There are several different  types
of  roof designs in use at TSDF storage tanks, the most common of which  are:

     •    Pan roofs;
     •    Pontoon roofs; and
     •    Double-deck roofs.

     Pan Roofs—Pan roofs have found widespread usage for approximately
50  years.   A pan roof is the simplest floating roof design, involving  a
simple  flat cover resting directly upon  the liquid surface as shown in
Figure  4-1.  Emissions are controlled by such a design because  the exposed
surface area of the liquid is virtually  eliminated, and the weight of the roof
imparts a slight pressure which decreases volatility.  Pan roofs almost always
are equipped with flexible perimeter seal system.  There are basically  two
types of pan roofs in use, including:  (1) aluminum sandwich panel roofs with
a honeycomb aluminum core, and (2) flat  steel pans.  Pan roofs  have found
widespread usage because of their simplicity and emission reduction
effectiveness.
     There are  several disadvantages associated with pan roofs, however,
including:  (1) they require considerable support or trussing to prevent them
from buckling;  (2) they are subject to warping or holes which can lead  to
sinkage; (3) there are no effective drainage systems to release liquid
condensing on the top of the roof; and (4) in direct sunlight,  heat is  very
                                     4-11

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                                                       A
  Figure 4-1.  Pan-Type Floating Roof Tank.
  Source:   API,  1973 (Reference 4).
Figure 4-2.  Pontoon-type Floating Roof Tank.
Source:   API,  1973 (Reference 4).
                   4-12

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readily transmitted through the metal plate to the tank contents, potentially
increasing the substances volatility.  The primary design considerations
involved in selecting an applicable pan roof are the tank design (diameter and
weight capacity), roof thickness, seal system, and support structure.
Retrofit of a floating roof to an existing tank is a very common method
employed to effect emission control.  A major limitation to retrofitting
floating roofs is the need for internal reinforcement (columns, bracings) of
an existing tank.

     Pontoon Roofs—A pontoon roof, as shown in Figure 4-2, is similar to a
pan roof, except that it does not rest directly upon the liquid surface but
instead upon pontoons.  This results in the creation of a vapor space between
the roof and the liquid surface, greatly increasing thermal insulation.  Like
a pan roof, a pontoon roof will control working losses by limiting the
available vapor space and by imparting a slight pressure on the liquid.
Pontoon roofs are always equipped with a flexible perimeter seal.
     Design variations for pontoon roofs include the following considerations.

     •    Shape of the roof.  Flat, convex, and conical roof designs are
          commonly used.
     •    Drainage system.  Hinged or flexible connections may be used to
          recycle vapor condensed on the top to the liquid space.
     •    Pontoon design and location.  Pontoons of various size and shape are
          in use (depending upon roof design), and may be located either at
          the perimeter  (most common) or the center, or both.

     Pontoon roofs are considered to be most applicable to larger diameter
storage tanks.  Design considerations involved in selecting the most
appropriate pontoon roof design are the tank design, the pontoon design
(including the compatibility of pontoon material with the tank constituents),
the roof design, the seal system, and the design of any roof support system
needed.

     Double-deck Roofs—A double-deck roof is essentially a system which
incorporates design elements of both pontoon and pan roofs, as shown in
                                     4-13

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Figure 4-3.  The lower deck, like  pan roof, rests directly upon the liquid
surface.  Between decks is  a series of compartments, set up  so  as  to provide  a
dead air insulator so that  heat  is not easily transmitted  through  the  roof  to
the liquid.  The upper deck is equipped with drainage and  seal  systems.   This
roof design will be buoyant and  nonwarping, while providing  less available
space for volatilization.   The disadvantages of such a system are  its  weight,
high cost, and  difficulty to retrofit to tanks.  The primary considerations
involved in selecting a double-deck floating roof system are the tank  design,
the roof mass,  reinforcement or  support system, seal system  requirements, and
drainage system.

Internal Floating Roof Tanks—
     A  floating roof tank which  is covered  by a fixed roof is defined  as  an
internal floating roof tank.  A  tank equipped with this roof type  incorporates
design  elements of both fixed roof and floating roof tanks described earlier.
Internal floating roof tanks are the most effective in controlling emissions,
as the  floating roof greatly reduces working losses, and the fixed roof
                              2
contains the breathing losses.    The types  of internal floating roofs  used
in such tanks are of the same designs as in external floating roof tanks:  pan
roofs,  pontoon  roofs, and double-deck roofs.  The use of pan roofs in  internal
floating roof tank, is widespread, as the provision for thermal insulation is
best of the three.
     The use of internal floating roof tanks is more widespread at TSDFs  than
external floating roof tanks, but not as widespread as fixed roof  tanks.
Internal floating roof tanks are particularly applicable to  higher volatility,
low molecular weight substances. Design considerations involved in selecting
an internal floating roof tank design are the tank diameter  and structural
strength,  tank  venting requirements, floating roof drainage  and seal system,
floating roof reinforcement, and maintenance considerations.  Retrofit of an
internal floating roof to an existing fixed roof  tank is generally impossible,
but installing  a  fixed roof on an existing  external floating roof  tank is the
most commonly performed retrofit control change.
                                      4-14

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 Figure 4-3.  Double-Deck Floating Roof.
Source:   American Petroleum Institute,  1973
         (Reference 4).
               4-15

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Seal Systems—
     Most, if not all, floating roofs employ a  vapor  seal  system.   A floating
roof seal is designed to seal the gap between the  perimeter  of  the  floating
roof and the tank wall, such that vapors will not  escape  through  the gap  to
the atmosphere.3  The seal  is attached  to  the roof, and slides  against  the
tank wall when the roof moves up and down  (as the  tanks is emptied  or
filled).  There are  two classifications of  seal systems:   primary and
secondary.  A secondary seal provides additional coverage  to the  primary
seal.  There are differences between the types  of  vapor seals used  on external
and internal floating roof  tanks, as described  below.

External Floating Roof Tank Seals—
     There are basically three types of primary seals used on external
floating roof tanks:  mechanical shoe seals, liquid filled seals, and
                            2
resilient  foam-filled seals.   These three  comprise the majority of vapor
seal designs in use  today.

                            2
     Mechanical Shoe Seals— A mechanical,  or metallic shoe  seal  is
characterized by a metallic sheet (the  "shoe")  held against  the vertical tank
wall,  as shown in Figure 4-4a.  The shoe is connected by braces to  the
floating roof and is held tightly against  the wall by springs or weighted
levers.

                          o
     Liquid-filled Seals—A  liquid-filled  seal consists of  an  envelope,
made either  from fabric or  flexible polymeric tubing, filled with liquid and
sheathed with a  resilient fabric scuff  band, as shown in Figure 4-4b.   The
liquid is  commonly a petroleum distillate  or other liquid  which will not
contaminate  the  stored  product  if the tube  ruptures.  Liquid seals  are  mounted
such that  they rest  directly  upon the liquid surface, providing no  vapor space
below  the  seal.

                                 o
     Resilient Foam-filled  Seal—^A resilient foam-filled  seal, as  shown in
Figure 4-4c  and d, is similar to a liquid-filled seal except a  foam log
replaces the liquid.  Such  a  system is  mounted  on  or  above the  liquid surface,
as  shown.
                                      4-16

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            RIM-MOUNTED
            SECONDARY SEAL.
                                                           -TANK  WALL
                                                               »RIM- MOUNTED
                                                               SECONDARY SEAL
                                                                  FLOATING  ROOF
                                                                  SCUFF BAND
                                                                  LIQUID-FILLED
                                                                     TUBE
a.  Shoe seal  with rim-mounted
    secondary  seal.
b.  Liquid-filled  seal with rim-
    mounted  secondary seal.
             -TANK WALL
               -RIM-MOUNTED
                SECONDARY SEAL
                      FLOATING  ROOF,
                     SEAL  FABRIC
                      RESILIENT  FOAM
                          LOG
c.  Resilient foam seal  (vapor-mounted)
    with  rim-mounted secondary seal.
                                                          -TANK  WALL
             -RIM-MOUNTED
              SECONDARY SEAL
                  FLOATING ROOF
                                                                  SEAL FABRIC
                   RESILIENT FOAM
                       LOG
d.  Resilient foam seal (liquid-
    mounted)  with rim-mounted
    secondary seal.
      Figure 4-4.  Rim-mounted Secondary Seals  on  External Floating Roofs.
                   Source:   Erikson, 1980 (Reference 3).
                                     4-17

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     Secondary seal systems employed on the external  floating  roof  tanks are
quite important, as they provide weather protection to the seal.  There are
two types of systems employed: . roof-mounted, or seal-mounted,  as shown in
Figures 4-4 and 4-5.
     The primary considerations involved in selecting an  appropriate  seal
system for an external floating roof tank are the  type of material  being
stored (compatibility with seal materials), size of gap between roof  and wall,
tank design (interior reinforcements, tank wall imperfections,  and  tank weight
capacity), weather conditions, and  floating roof design.

Internal Floating Roof Tank Seals—2
     Internal floating flexible roofs typically incorporate one oZ  two types
of flexible primary seals:  resilient foam-filled  seals,  or wiper seals.  The
foam-filled seals are the same as the type used for external floating roof
tanks.  Wiper seals, which are the more common type,  are  simple systems in
which a  flexible membrane is used to cover the gap between the  roof and the
tank wall.  These types of seals are usually vapor-mounted and  are either
continuous  (one piece extending around the perimeter), or shingled
(overlapping segments extended around the perimeter).  Secondary seals are
less common for internal floating roof tanks.  The considerations involved in
selecting an appropriate seal system for internal  floating roof tanks are the
same as  for external  floating roof  tanks, although weather consideration are
much less significant due to the  fixed roof cover.

Vents—
     All  fixed  roof  tanks must be equipped with some  type of venting  system.
Tank vents  serve as  a protection  against structural damage to  the tank caused
by a buildup of vapor  inside the  vapor space, by releasing them to  the
atmosphere.  Vents may be installed in the roof or the tank walls (above the
maximum  liquid  level).  Many types  of vents are used, ranging  in
sophistication  from  simple open vents to pressure-vacuum  systems equipped with
flame  and flash arrestors.  The most common venting system used on  tanks is a
conservation vent, which  is described in detail below.    In general,  vents
                                      4-18

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                  TANK WALL
                   SECONDARY SEAL
                     (WIPER TYPE)
Figure 4-5.  Metallic  Shoe Seal with Shoe-Mounted
             Secondary  Seal.
Source:  Erikson,  1980  (Reference 3).
                      4-19

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are applicable to any tank with a fixed roof.   The  choice  of  a  vent  is
dependent upon tank design and the volatility  of  tank  constituents.

Conservation Vents—
     A conservation vent  is defined  as a  system which  is designed  to release
vapors from a storage tank once the  internal pressure  reaches a predetermined
point.  The set  point is  based upon  the structural  characteristics of the
tank.  A conservation vent furthermore serves  to  prevent the  inflow  of  air  and
the formation of a vacuum inside  the tank.  There are  three basic designs of
conservation vents:  diaphragm, liquid-seal, and  metal-to-metal.
Metal-to-metal seals have found the  most  widespread usage.  The primary
considerations involved  in selecting an appropriate conservation vent are the
volatility and flammability of the material, tank design,  and vent location.

Emission Reduction Effectiveness

     The general effectiveness of storage tank roofs in controlling  emissions
is considered to be be high.  The extent  to which emissions from an  existing
tank can be reduced depends upon  the design chosen.  A fixed  roof is  capable
of reducing emissions from open tanks or  external floating roof tanks by
anywhere from 0  to 90 percent depending upon the  volatility of  the material
being  stored, and the use of conservation venting or insulation.  A  floating
roof is capable  of reducing emissions from open or  fixed roof tanks  by  up to
99 percent depending upon the use of primary or secondary  seals, venting, and
drainage.  Installing secondary seals on  a floating roof with an existing
primary  seal may result  in reductions between  60  to 90 percent  depending on
the  interior design constraints.  Conservation vents have  produced emission
reductions of up to 90 percent  in fixed roof tanks.
 Costs
      The installation of a new tank,  new roof,  or  associated  system  is
 considered  to  be  a highly expensive.   The high  costs  involved are  largely
 based on capital  costs (materials)  and construction,  and  the  associated design
 work  needed.   The costs  vary  according to the size requirements, materials
 used,  and  input and output considerations.
                                     4-20

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     Fixed roof tanks are the most widely varied design in  terms of  costs.
Simple fixed roof tanks of small dimensions are relatively  inexpensive,  while
high pressure tanks are the most expensive.  Costs are dependent upon  the
materials used, and the structural support considerations.  Retrofitting a
fixed roof onto an existing tank is considered to be essentially as  expensive
as constructing a new tank.  Estimated costs (1980) for fixed roof tanks are
shown in Table 4-2.3  In March 1985 dollars, fixed roof tank costs range
from $36,000 to $281,000 for the size range indicated.
     Floating roof tanks are somewhat more expensive to build than fixed roof
tanks, due to greater complexity involved in the roof design.  Installation of
a floating roof on an existing tank, however, is much simpler and less
expensive than is the installation of a fixed roof due to their simpler  design
and structural considerations.  The costs of a floating roof are dependent
upon the design selected, materials, installation, and maintenance
requirements (more maintenance is required for floating roofs than for fixed
roofs).  Table 4-3 presents construction costs for external floating roof
tanks.   In March 1985 dollars, these costs range between $55,700 and
$295,000.
     Estimated costs (1980) of installing an external floating roof with
primary  seal for contact and noncontact designs are shown in Tables 4-4
and 4-5.   In March  1985 dollars these costs range from $7,800 to $57,800
for contact roofs, and $6,300 to $41,800 for noncontact roofs.
     The costs involved in installing a seal system on a floating roof are
dependent upon the design selected, materials, installation, and maintenance
requirements.  MITRE estimated that the typical cost of retrofitting a
(secondary) seal system would range from $29 to $38 per linear foot of
circumference.
     Conservation vents are the least expensive of the options described in
this section, due to their relative design simplicity and ease of
installation.  MITRE estimated that a typical vent may cost between  $540 to
$4,300 (in present day value) or approximately $0.01 to $0.09 per gallon of
capacity.
                                     4-21

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TABLE 4-2.  COST OF BUILDING A FIXED-ROOF TANK2
Diameter
(ft)
20
40
45
50
60
70
80
90
Height
(ft)
24
40
40
40
40
40
40
40
Installed cost3
26,000
63,000
73,000
89,000
113,000
139,000
168,000
202,000
  aCosts in first  quarter 1980  dollars.




  Source:   Erikson,  1980 (Reference  3).
                     4-22

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TABLE 4-3.  COST OF BUILDING AN EXTERNAL FLOATING
            ROOF TANK
Diameter
(ft)a
30
35
42.6
52
60
67
73.4
100
Height
(ft)
24
30
40
40
40
40
40
40
Installed costb
40,000
54,000
81,000
117,000
126,000
140,000
153,000
212,000
  aCost  of adding a  secondary  seal per foot
   of circumference  is $13.50.

  bCosts  in  first quarter  1980 dollars.

  Source:  Erikson,  1980 (Reference 3).
                      4-23

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TABLE 4-4.  COST OF INSTALLING A CONTACT SINGLE
            SEAL INTERNAL FLOATING ROOF
Diameter
(ft)«
15
20
25
30
35
40
45
50
55
60
65
70
75
80
85
90
Installed cost
U)b
5,630
6,485
7,510
8,780
10,280
11,970
14,180
16,190
19,630
21,480
25,120
27,770
31,240
34,360
37,910
41,530
aCost of adding a secondary seal, per foot
 of circumference is $11.85.

bCosts  in  first quarter  1980 dollars.

Source:  Erikson, 1980 (Reference 3).
                     4-24

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TABLE 4-5.  COST OF INSTALLING A NONCONTACT SINGLE
            SEAL INTERNAL FLOATING ROOF
Diameter
(ft)a
15
20
25
30
35
40
45
50
55
60
65
70
75
80
85
90
Installed cost
($)b
4,500
6,000
7,300
9,300
10,000
12,000
13,300
14,700
16,500
17,400
19,700
21,500
23,500
25,200
27,800
30,000
 alnstalled cost of adding a secondary wiper
  seal per foot of circumference is $22.50.

 ^Costs in first quarter 1980 dollars.

 Source:  Erikson, 1980 (Reference 3).
                    4-25

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COVERS
Introduction

     A cover  is defined as any  system which  limits  or  prevents  the
volatilization of material from a  storage  tank by acting  as  a barrier  between
the volatile  substances and  the atmosphere.  Covers, unlike  roofs,  are not
designed  to be permanently affixed  to a  storage  tank.  Such  systems,
therefore, are generally  applied only to open or fixed roof  tanks.  A  wide
variety of covers are available.   Covers which have found application  as
storage tank  emission control devices include:

     •    Floating  blankets;
     •    Floating  spheres;
     •    Rafts;
     •    Surfactant  layers; and
     •    Nitrogen  blankets.
      Use  of  covers  for  storage  tanks  is  not  as  prevalent  as  that  of  roofs  for
 controlling  emissions.    This subsection will present  examples  of systems
 which are in use or have  been proposed  for use  at  TSDFs.

 Description

      A cover serves to  limit the emission of volatile  substances  from  storage
 tanks by  acting as  a barrier to volatilization,  reducing  volatility, and/or
 insulating the substances from  external  forces  such as heat,  light,  wind,  and
 precipitation, which serve to  increase  volatilization. All  covers are applied
 such that much of the liquid surface  area is covered.   Covers can either be
 placed directly upon the  liquid surface, on  floats or  pontoons  just  above  the
 liquid surface, or  over the top of (open) tanks.   The  following considerations
 must be made in determining the applicability of a cover  system to a specific
 storage tank at a TSDF.
                                      4-26

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     •     Type  of material  to be stored.   The chemical and physical properties
          of the material to consider include, volatility, chemical
          compatibility,  and density.
     •     Design of storage tank.  The diameter, weight capacity, inflow/
          outflow pipe locations, and interior structural design (e.g., of
          columns or bracings) of the tank.
     •     Storage procedures.  The tank turnover rate (number of times emptied
          and filled per year), tank usage,  filling procedures, and tank level
          preference are among the procedural factors.
     •     Weather conditions.  Wind, sun, and precipitation patterns of the
          local area.
     •     Manpower requirements.  The availability of trained personnel for
          maintenance or operating procedures.

     All cover systems contain certain limitations which must be evaluated
against factors such as emission reduction efficiency, cost, and ease of
implementation.  The cover systems introduced above have been demonstrated to
be the  most applicable to storage tank emission control according to the above
criteria.
Floating Blankets—
     Floating blanket covers perform similarly to pan-type floating roofs.
Resting directly upon the liquid surface, the flat covers apply pressure to
the liquid, thus eliminating vapor space and reducing breathing losses.  As
the tank is filled and emptied, the cover rises and falls, thus reducing
working losses.  Floating blankets are usually made from lightweight
synthetics, such as polyvinyl chloride.  The blanket underside is constructed
of a large number of floats made from the same plastic material.^  The
blankets are commonly made so that only a very small gap will remain around
the periphery.  Most floating blanket systems also employ a vertical skirt
around the edge to serve as a vapor seal over the annular area.-'  Design
features to be considered in selecting the most appropriate floating blanket
design are the size and shape of the surface to be covered, the chemical
compatibility and vapor permeability of the synthetic material, the drainage
of liquid from the top of the cover, and the system weight.
                                     4-27

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Floating blankets present certain advantages over  a  floating  roof  design.
They are lightweight, more  flexible, will  not  sink,  warp,  or  corrode,  and  are
removable.  To date, these  systems  have  found  greater  application  in foreign
markets.

Floating Spheres—
     Another way  that lightweight plastic  materials  are  used  as  a  cover is in
the form of hollow  plastic  spheres.  Floating  spheres  also perform similarly
to pontoon roofs, although  they  are far  more fluid.  Floating spheres  will
cover approximately 90  percent of the  available  surface  area,  independent  of
the sphere diameter.  Because they  are hollow, they  will also act  as dead  air
insulators.  Floating spheres are commonly made  from either high molecular
weight  polyethylene or  polypropylene.    Size ranges  vary from microscopic  to
6 inches  in diameter.  '   Common designs employ  an antirotational  collar so
that the  spheres  will interlock  over the liquid  surface  and will not be
subject to natural  or forced convection  currents turning the  wet sides  of  the
spheres to the  air. (See Figure 4-6.)
     Normally,  only one layer of spheres is used to  cover  the liquid
surface.   In  certain cases, however (e.g., for  highly toxic  and/or volatile
substances), more than  one  layer is used.  It  has  been demonstrated, that  each
successive  layer  of spheres added  is less  effective, as  the added  weight
increasingly  submerges  the  bottom  layer.  The considerations involved  in
selecting the  appropriate  floating  sphere  cover  are  the  diameter of the tank,
the  size  of  the spheres,  the number of layers, and the spheric material.
Floating  spheres  have  several  advantages over  roofs  or other  cover systems.
They  are  more  fluid and can,  therefore,  be used  in any tank,  they  are  good
insulators,  will  not sink,  need  no  drainage system,  and  are removable.
Floating  spheres  have  found a  variety  of applications  including  crude  oil
waste  storage,  solvent  storage,  and at a European  wastewater  treatment
plant.

Rafts—
      A raft  is defined  as  any  device which floats  freely upon the  liquid
surface.   Rafts perform similarly  to pan-type  floating roofs. Rafts are
available in  two  designs,  including foam blocks  (the most  common type)  and

                                     4-28

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I
ro
                                     Figure 4-6a.   Interlocking configuration.
      Figure 4-6b.  An uncovered cleaning tank emits
                    large volumes of corrosive acid
                    steam.
Figure 4-6c.
                                          Source:  Capricorn Chemicals.
A single layer of ALLPLAS balls
floating on the surface of the
same temperature, virtually
eliminates acid steam emission.

-------
membranes attached to a  frame.  An example of  the  foam  block system is  shown
Ln Reference 9.
     A raft can be made  from  any  kind  of material.   Styrofoanii  polyethylene,
aluminum bonded to polyethyelne,  butyl rubber,  and  floating concrete have all
                  O                                                Q
been field tested.   A  raft can be made in any shape or thickness.
Several rafts  may be used  on  one  surface.  They are easily installed and
maintained.  Many rafts  are coated with reflective  material to  decrease their
transmissivity of heat  to  the liquid.
     The considerations  involved  in  selecting  an appropriate raft  design are
the size and shape of the  tank, chemical compatibility,  raft insulating
capacity (related to thickness and color), number of rafts to be used,  and the
drainage system.  Rafts  have  the  advantage of  being lightweight, easy to
install and maintain, buoyant, nonwarping, and  removable.   Rafts have found
only limited application as a storage  tank cover system, but have  been  used
extensively on surface  impoundments.

Surfactant Layer—
     A layer of  liquid  with which the  volatile  substances  in storage are
immiscible may be applied  as  a cover.   A floating  liquid cover  serves to limit
emissions  in much the same way as other floating covers.   As long  as the layer
is maintained, volatiles can  only be released  if they diffuse through the
liquid barrier.  The choice of a  particular  liquid  for  this application is
strongly dependent upon the materials  being  stored.  Among those materials
cited  in  the  literature were  water  (used in  the storage of ethylene
dichloride)    and  lubricating oil (acrylonitrile wastewater).   In such a
system, no vapor seals  or  drainage  systems are needed.
     The  considerations involved  in  selecting  a liquid  cover system are
chemical  compatibility,  weather conditions,  and layer regeneration method.
Use of a  surfactant  layer  can be  desirable due to  the adaptability to any
shape  or  size  tank,  the completeness of coverage with no required
appurtenances, and the  ease of implementation.   The use of such a  system,
however,  has  been quite limited.

Nitrogen  Blanket—6
     Nitrogen, or any other  inert gas, may be  maintained  in the vapor space  of
a  tank as  a cover system.  Nitrogen  blanketing works to control emissions by
                                     4-30

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applying a slight positive pressure in the tank, thus inhibiting
volatilization.  Like a surfactant layer, a nitrogen blanket acts as an
ultimately adaptable floating roof.  Nitrogen blankets are mainly applicable
to fixed roof tanks.  A small generating unit is required, to maintain the
blanket.  Application of nitrogen is limited by the internal pressure
constraints in the tank.
     The considerations involved in such a system are the design of the tank,
chemical compatibility, operation of nitrogen generators, and weather
conditions (particularly, temperature fluctuations).  Nitrogen blankets are
especially applicable to highly reactive, highly volatile substances.
Overall, nitrogen blankets have the advantage of adaptability, completeness of
cover, inertness, and low equipment cost and maintenance.

Emission Reduction Effectiveness

     In general, covers are expected to be a relatively effective means of
emission control.  The effectiveness of such control systems has not be
studied in detail, due to constraints encountered in making emission tests on
tanks.  The extent to which emissions from any tank may be reduced by a
specific cover system is highly dependent on the tank design (in particular,
the diameter and the structural characteristics), and the tank constituents.
     In general, those cover systems which are the most flexible, limit
available  liquid surface area the most, and are least subject to wind, and
other weather conditions will perform best.  Thus, while floating spheres
might reduce emissions up to 90 percent,  a floating surfactant layer, which
is subject to being dissipated by wind, might only reduce emissions by 25 to
75 percent.   Nitrogen blanketing is estimated to be potentially the most
effective  cover system, ranging from 50 to 99 percent  reduction
efficiency.  Rafts, similar in performance to floating spheres and blankets,
are estimated to range up to 90 percent in effectiveness.1  These estimates
are approximate.  Other data accumulated by Cooley are presented in
           Cl
Table 4-6.   The basis of these estimates is the percentage of surface area
covered, and the vapor permeability of the covers.  Covers are not expected to
                                      4-31

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     TABLE 4-6.  EVAPORATION REDUCTION ACHIEVED BY VARIOUS ENERGY-REDUCING METHODS
             Method
 Area of water
surface covered,
as a percentage
  Evaporation
   reduction,
as a percentage
4>
OJ
 1.  Changing the water color:

       Dye in water
       Shallow,  colored pans

 2.  Using wind  barriers:

       Baffles

 3.  Shading the water surface:

       Plastic mesh
       Blue polylaminated  plastic
          sheeting

 4.  Floating covers:
      100
      100
       47

      100
Evaporation from white pan compared with that  from black  pan.
Source:  Cooley, 1983 (Reference 8).
      6-9
     35-50a
      11



      44

      90
Perlite ore
Polystsyrene beads
Wax blocks
White spheres
White butyl sheets
Polystyrene sheets
Polystyrene rafts
Polystyrene wax
Foamed rubber
78
78
78
78
86
80
100
100
95
19
39
64
78
77
79
95
87
90

-------
perform as effectively as either vapor control systems or roofs, but are less
costly and easier to implement at an existing facility.
Costs
     Cover systems are generally considered to be less expensive than roof
systems to implement at a storage tank facility.  The costs of such systems
are strongly dependent upon the cost of materials and maintenance.  Labor,
operation, and installation costs are considered to be relatively low.
Detailed cost estimates are highly dependent upon various design and materials
considerations (tank sizes, cover materials, etc.).
     The cost of floating blanket covers is primarily dependent upon the
synthetic material selected.  The estimated average cost of a synthetic cover
(as applied to a surface impoundment) is $1.48 to $3.26 per square foot.
(1985 dollars).
     Floating spheres are available in a variety of sizes, and basically two
materials, polypropylene and polyethylene.  The number of balls required for
coverage of a storage tank can be determined by geometry.  Table 4-7, provides
some example requirements.  Table 4-8 shows that the estimated average cost
for a cover of floating spheres ranges from $4.65 to $13.50 per square foot of
internal surface area.
     Cost of raft system would be similar to floating sphere system, as both
only involve materials costs.  A typical foam block raft system was estimated
at $130  to $210 for a medium size facility (25 ft diameter).1
     The cost of a surfactant layer is dependent upon the surfactant chosen,
and application procedure.  Cost is regarded as a primary factor in the choice
of a surfactant chemical for this application.  MITRE estimated a cost of
0.09 cents per square foot (updated to 1985 dollars) for similar application
on a surface impoundment.
     The cost of a nitrogen blanketing system is dependent upon nitrogen
consumption (dependent on tank capacity), and costs of nitrogen storage and
delivery equipment.  The estimated annual installed cost of such a system is
$0.11 to $0.33 per gallon of tank capacity (Updated to 1985 dollars).^
                                      4-33

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 TABLE  4-7.   NUMBER OF  FLOATING  SPHERES  REQUIRED  PER  UNIT AREA AND  VOLUME
Spheric size/
Quantity
Quant ity/m2
Quantity/ ft2
Quantity/m^
Quantity/ ft-*
20 mm
(3/4 in.)
2.500-3.000
230-280
165.000-167.000
4.670-4.730
38 mm
(1-1/2 in.)
750-800
75-85
24.500-25.000
690-710
45 mm
(1-3/4 in.)
500-575
45-55
14.500-15.000
410-425
150 mm
(6 in.)
45-50
4-5
350-400
10-11
Source:   Capricorn Chemicals,  1985.   (Reference  7K
                                  4-34

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  TABLE 4-8.  COSTS OF VARIOUS TYPES OF FLOATING
              SPHERES
                                   Cost ($/ft2)
Polypropylene

  Diameter 1-3/4 inches              4.65-6.55

  Diameter 6 inches                  7.50-8.69

High Density Polyethyelne

  Diameter 1-3/4 inches              6.75-7.55


Source:  A. D. Little, 1984 (Reference 1).
                      4-35

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INSULATION

Introduction

     Any system or device which  serves  to  reduce  the  effects  of  climatological
forces such as sunlight, ambient  temperature  fluctuation,  wind,  and
precipitation on storage tanks and  tank constituents  may be defined  as  a  tank
insulation system.  These forces  serve  to  increase  tank breathing  losses  by
increasing the volatility of constituents  and/or  by providing a  transport
mechanism for emissions to enter  the  atmosphere.  Insulation  systems  are
highly simplistic  in design, and  as a result, have  found widespread
application.   Mo«5t storage tanks are insulated in  some way.   The  three
methods of tank insulation which  have found the most  widespread  application
are:

      •    Thermal  insulation;
      •    Reflective paint; and
      •    Wind barriers.

Description

      Insulation systems form a barrier  to  the external forces described
above.  Each  of the insulation systems  can be applied directly to  the storage
tank,  require little  to no additional maintenance,  and occupy very little
space.    The  following considerations must be made  in selecting  the
appropriate  insulation system.

      •    Weather  conditions.  The  affect  of  extreme  heat, wind, or
          precipitation on the insulation  system.
      •    Storage  tank design.   The height, shape,  and diameter  of the  tank
          may.
      •    System design.  The weight, height, and other complexities  of the
          insulation system.
                                      4-36

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     •    Storage area.  The area layout, and space for the insulation system.

Thermal Insulation^--
     Thermal insulation systems may be applied to the sides and tops of
storage tanks.  The insulation material serves to reduce the temperature
fluctuation of storage tank constituents, even when ambient conditions vary.
Various types of systems are employed, including both flexible and rigid
polymeric foam, and venniculite concrete.   The most common materials in use
at TSDFs are spray-applied polyurethane foams and rigid polystyrene
      12
foams.    Design considerations involved in selecting a thermal insulation
material are the available surface area to be covered, tank wall material
(ease of applying insulation), weather conditions, insulation thickness, and
the total applied weight of the system.

Fresh Painted Tanks—
     Fresh paint may also be applied to the sides and tops of storage tanks.
New paint will have the effect of reducing emissions by providing a better
more reflective outer surface.  The two colors most commonly applied to
storage tanks are white and silver.   A painted tank has been demonstrated
to emit less than an identical unpainted one (see Table 4-9).  The factors
which are to be considered in selecting a new paint for storage tanks are the
chemical compatibility of paints with emitted materials, maintenance
requirements and, most importantly, sun conditions.

Wind Barriers—
     Wind barriers are devices installed on or around storage tanks which
serve to reduce the flow of wind affecting a tank.  Wind increases storage
tank emissions by three mechanisms, including:  (1) increasing surface
turbulence inside a tank (particularly in the case of open tanks), leading  to
greater volatilization of liquid; (2) sweeping vapor out of a storage tank  as
wind flows over or through the tank vapor space; and  (3) creating a pressure
differential  leading to emissions via forced convection as wind flows over  a
tank or tank vent.   Barriers may be  installed on a tank or around a tank.
The most common design is a barrier installed at the top of a tank, around  the
                                     4-37

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 TABLE 4-9.   RELATIVE EFFECTIVENESS  OF  PAINTS  IN  KEEPING  TANKS
             FROM WARMING IN THE  SUN (NELSON,  1953).
              Color
Relative effectiveness
   as reflector or
 rejector of heat (%)
Black
No paint
Red (bright)
Red (dark)
Green (dark)
Red
Aluminum (weathered)
Green (dark chrome)
Green
Blue
Gray
Blue (dark Prussian)
Yellow
Gray (light)
Aluminum
Tan
Aluminum (new)
Red iron oxide
Cream or pale blue
Green (light)
Gray (glossy)
Blue (light)
Pink (light)
Cream (light)
White
Tin plate
Mirror or sun shaded
        0
       10.0
       17.2
       21.3
       21.3
       27.6
       35.5
       40.4
       40.8
       45.5
       47.0
       49.5
       56.6
       57.0
       59.2
      64.5
      67.0
      69.5
      72.8
      78.5
      81.0
      85.0
      86.5
      88.5
      90.0
      97.5
     100.0
Source: AP-40 (Reference 5).
                             4-38

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perimeter.14  Various types of barriers are used for this purpose, including
"cyclone" fences,; corrugated steel walls, and other, more complex designs.
     Wind barriers are particularly applicable to open or external floating
roof tanks.  They have not found widespread use at TSDFs for control of air
emissions from storage tanks, however.  The considerations involved in
selecting a wind barrier system for storage tank control are the tank
structural requirements, prevailing wind conditions (direction, magnitude),
availability of space, and the height and design of the barrier.

Emission Reduction Effectiveness

     Insulation systems are simple, and easy to install.    However, the
effectiveness of such systems in reducing emissions, however, is relatively
low  (compared to other add-on controls).  This is primarily due to the fact
that they are chiefly designed to reduce breathing losses, which are generally
not  as significant as working losses.  Information on the effectiveness of
such controls is also limited.
     Thermal insulation systems are generally quite effective in reducing, if
not  eliminating, thermal fluctuations.  The effectiveness of such systems is
dependent upon the thickness of the insulation layer, and amount of tank area
covered.  Insulation effectiveness is also limited by the "gradual absorption
and  permeation of moisture through the insulation.  (See Table 4-10).  The
thermal performance of several insulation materials is shown in Table 4-11.
MITRE estimated that the effectiveness of insulation in emission reduction
ranges from 50 to 99 percent."
     The application of reflective paint is limited in its effectiveness as an
emission reduction technique.  As shown previously in Table 4-9, effectiveness
varies widely with paint color.  However, since the paint itself is a
relatively thin layer, heat energy will be transmitted to the  tank.  AP-40
reported that the emission reduction  achieved, for example, by use of aluminum
paint (over black paint) was 25 percent based on data gathered by  the American
Petroleum  Institute.
     Wind barriers have been used in  many different ways  (see  Sections 5  and  8
in the document) at TSDFs.  The effectiveness of such devices  depends strongly
                                      4-39

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TABLE 4-10.  PERMEABILITY AND MOISTURE ABSORPTION
Insulation
material
FOAMGLAS®
Urethane
Polystyrene
Phenolic
Fiberglass
Mineral fiber
Calcium silicate
Expanded perlite
aPerm . Inch is the
permeability.
1 Po Tin . T«^.U — _
Permeability
Perm . Incha
0
1-3
0.5-4
6-7
75
150
NA
NA
accepted unit
1 Grain .
Absorption
% by Vol.
0.2b
1.6
0.7
10.0
65.0
70.0
75.0
16.0
of water vapor
Inch
                    Ft  .  Hr  .  Inch  of  Mercury

      only  moisture retained  is that adhering  to
  surface cells after immersion.

 Source:   Pittsburgh Corning  Corporation,  1985
          (Reference 15).
                        4-40

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  TABLE 4-11.  PUBLISHED THERMAL PERFORMANCE
Thermal
Insulation
material
FOAMGLAS
Urethane
Polystyrene
Phenolic
Fiberglass
Mineral fiber
Calcium silicate
Expanded perlite
Maximum
use
temp.
(°F)
9003
200-225
175
250
450
1800
1200
1500
conductivity
Btu'In./
Hr . F . Ft2
-100
0.27
0.14
0.18
0.19
0.16
NA
NA
NA
+200
0.42
0.25
NA
0.26
0.30
0.35
0.42
0.47
limitation when used alone.

Source:   Pittsburgh Corning Corporation,  1985,
         (Reference 15).
                     4-41

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on prevalent wind patterns.  While no direct measurements  have been published
relative to the emission reduction effectiveness of wind barriers  for  storage
tanks, Runeha1 estimated that the reduction effectiveness  would  range  from  22
to 50 percent. ^
     The costs of  insulation systems are generally regarded as being  low,
relative to other  add-on control systems.  The costs generally involve only
materials and  installation.
     Thermal insulation costs vary widely depending on  the materials  used.
Costs are also dependent upon the thickness and percentage of surface area
covered.  Based  on estimates made by MITRE,   the cost of  thermal  insulation
ranges  from $0.65  to  $0.76 per  inch thickness per square  foot of  tank area,
plus an additional $1,00 to $1.25 per  square  foot for protective  coating.
     Painting  costs are also widely variable.  The costs  depend on  the type of
paint selected,  application method, and  labor costs.  In  general, painting is
regarded as a  low-cost measure  to effect control.  A representative of Chevron
USA Inc. estimated that the average storage tank paint  job costs  between $500
and $3,000 per tank.14
     Wind barrier  costs are also regarded as  being relatively low.  These
costs depend upon  the type of fence selected, height of fence, and
installation labor.  An estimate of the  cost  of wind screens (as  applied to
waste piles) is  $2.00 to $2.50  per square foot of fence area (1982  dollars).^

VAPOR CONTROL  SYSTEMS

Introduction

     Vapor control systems control  the emission of volatile substances from
storage tanks  by evacuating vapors which form, and processing them  physically
or chemically.   Vapor control systems  are the most complex and costly of
storage tank controls, but are  the most  effective at reducing emissions.  Use
of vapor control on storage tanks  is widespread, particularly in  chemical
                                      4-42

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processing.   The three vapor control systems which are most commonly used
for storage tank emission control are:

     •    Vapor condensation;
     •    Carbon adsorption; and
     •    Fume incineration.

Description

     The primary function of a vapor control system is to remove vapors which
form in a storage tank, by some physical or chemical process such that they
will not enter the environment.  Such systems are equally effective at
controlling working or breathing losses, as any vapor which forms is evacuate
from the tank.  All vapor control processes contain at least three steps:

     (1)  evacuation;
     (2)  vapor processing; and
     (3)  recycle or venting of products.

     Use of vapor control requires that the storage tank be enclosed in some
manner.  Thus, vapor control is applicable only to tanks equipped with fixed
roofs.  Vapor control systems require the installation of ductwork, the
location of unit processing equipment in readily serviceable areas, and
equipment  for disposing of products and materials.  Vapor control has found
widespread application, particularly  in the control of highly  volatile and/or
toxic  substances, due primarily to the high emission reduction efficiencies
that can be achieved.  While the system designs may be relatively complex,  the
unit processes are simple, utilizing  physical or chemical properties such  as
the vaporization point, adsorbability, or combustibility.  The following
factors should be considered when determining the applicability of a
particular vapor control system to a  certain storage tank or tanks.
                                      4-43

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     •    Properties of the tank constituents including the volatility,
          adsorbability on carbon or other substrates, and combustibility.
     •    Number of tanks to be serviced and the total capacity to be served
          by the vapor control system.
     •    Manpower and materials requirements including maintenance, operating
          labor, and materials required by the vapor control system.
     •    Availability of space which would affect the location of the vapor
          processing unit, and attendant ductwork and systems.

     The three most common vapor control systems, described in detail below,
have found widespread application.

Vapor Condensers—
     Vapor condensation systems prevent emissions of volatile substances by
recondensing vapor which form in a storage tank.  Condenser systems are the
most widely used form of vapor control for storage tanks.    Condensers work
by extracting heat from the vapors either by contacting them with a coolant
(contact-type) or with a cooled surface (surface-type).  Contact-type
condenser are not generally used for control of TSDF emissions, due to
chemical compatibility and waste handling considerations.   The most common
type of condenser is the "shell and tube" type, as shown in Figure 4-7.  In
this system, vapors are passed through a chamber which contains thin tubes.
Coolant is passed through the tubes, and cools the metal surfaces, which in
turn cool the vapors as they flow around the tubes.  A variety of coolants are
used, depending upon the volatilization point of the vapors, including chilled
                     3
water, air, or  freon.
     Shell and  tube condensers are commonly oriented horizontally, but some
designs orient  them vertically.  Coolant flow can either be countercurrent or
concurrent with vapor flow direction.  It is common to install baffles in  the
shell side of a condenser; or to design the condenser with more than one
chamber (pass), in order to increase the contact time between vapors and
tubes.
     The considerations involved in selecting an appropriate condenser system
for control of  storage tanks are the operating temperature range, coolant
type, number of condenser tubes, baffles or passes, refrigerant storage and
handling, and condensate and vapor recycle or handling.  Condensers have
                                     4-44

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               COOLANT
                 INLET
                       VAPOR
                      OUTLET
VAPOR
INLET
               COOLANT
                OUTLET
INCOMING
VAPOR
                               , VENT
                             S_m
  COOLANT
  RETURN
                                                COOLANT
                                                SUPPLY
                                                         REFRIGERATION
                                                             UNIT
                                    n
                                      VENT
                                                         RECOVERED
                                                         TO STORAGE
                  RECOVERY
                    TANK
                                                    PUMP

           Figure  4-7.   Refrigerated Vent Condenser System.
           Source:   Erikson,  1986 (Reference 3).
                               4-45

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several advantages over other vapor control  systems.  They  require  less
maintenance, less materials and operating costs,  they are considered  to  be
safer and less subject to process upset, and are  more adaptable  to  different
types of vapors.  A condenser can be used to selectively recover materials, if
desired.  Condensers are generally  less effective in reducing  emissions,
however, and require additional facilities for coolant  storage and  handling
that other vapor control systems do not.

Carbon Adsorption—
     Carbon  adsorption systems prevent emissions  of volatile substances  by
removing vapors which form  in a storage tank via  adsorption onto carbon.
Carbon  adsorption  is not as widely  used as vapor  condensation  for storage  tank
control, but have  found use at TSDFs both for controlling tank emissions and
emissions  from other unit processes such as  surface impoundments.   Adsorption
devices utilize carbon's affinity  for nonpolar organic  compounds.
     As shown  in Figure 4-8, vapors are passed over beds of activated  carbon.
The  vapors  adsorb  onto the  carbon,  and exit  the beds to either be recycled to
the  adsorber or vented as clean air.  Gradually,  the adsorption  capacity of
the  carbon  beds is  reduced, until  the beds become saturated with organic.  At
that point,  the beds are regenerated by passing steam through  them.  Multiple
carbon  beds  are often used, such  that some beds may be  used while others are
regenerated.
     Adsorption system generally  employ activated carbon, but  recent
advancements in resin adsorption  have begun  to result in their increasing
usage  for  emission control.  Adsorption systems range in complexity from
simple  designs in  which vapors are  passed through drums filled with carbon, to
full scale  systems  employing multiple carbon beds as illustrated in
Figure  4-8.  Adsorption can be carried out as a single-pass or multiple-pass
operations  and carbon beds  may be  baffled to increase vapor residence  time.
     The most  common system in use  for storage tanks is the simple
"barrel"-type  adsorbers^.   These  are used because it is considered  safer to
control tanks  individually  than collectively (interconnected tank systems  are
subject to  increased risks  of  fire  and explosion).
     The considerations involved  in selecting an  appropriate carbon adsorption
system  for  control  of storage  tanks are the  operating temperature range,

                                      4-46

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LOW- PRESSURE
     STEAM
PROCESS
BLOWER
VAPOR-LADEN
AIR STREAM
AMBIENT
  AIR
                                                              CLEAN AIR
                                                              EXHAUST
                                               ADSORBER I


i
















J'





-1^

y






J.











ACTIVATED CARBON



JT
$ ADSORBER 2
ACTIVATED CARBON



\

^





-t
p




_f

                                                               -txl-
            COOLING and
            DRYING  BLOWER
                                  COOLING •
                                   WATER
                                                                  RECOVERED
                                                                   SOLVENT
                                                  WASTE
                                                  WATER
               Figure 4-8.  Activated-Carbon Adsorption System.
               Source:  Erikson, 1980 (Reference  3).
                                   4-47

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chemical compatibility and adsorbability of materials, number  and  sizing  of
beds, regeneration and adsorbate handling systems,  and carbon  life span.
Carbon adsorbers have several advantages over other vapor  control  systems.
They can achieve higher emission reduction efficiencies, are relatively safe
and easy to operate, and are adaptable  to different volatile organics.    The
materials, energy, and maintenance costs are high  for such systems,  however,
and they also require additional facilities for steam regeneration.

Fume Incineration—
     Fume  incineration (thermal oxidation) systems  prevent emission  of
volatile substances by changing materials chemically via oxidation.
Incineration  systems are not used as extensively as either vapor condensation
or carbon  adsorption for control of storage tanks.  They are most  commonly
used in combination with a more significant process vent emission  control
system.    Incinerators work by utilizing a vapor's  combustibility.   As shown
in Figure  4-9,  vapors are mixed with air, injected  to a burner where a pilot
source  ignites  the air-vapor mixture, and a supplementary  fuel burner
maintains  flame temperature, and products are vented to the atmosphere.
     Incineration systems may be either small units servicing  one  tank, or
large units  serving an entire TSDF.  There is little variation in  the basic
design  for incinerators.  The considerations involved in implementing an
incinerator  system for storage tank emission control are the vapor composition
and  flow  rate,  combustion  temperature,  incinerator  fuel, incinerator venting
control,  and  the number  of  tanks to be  serviced.
     The  advantages of using  fume  incineration are  the high efficiencies
achieved,  the lack of attendant systems required,  and the  elimination of
volatile  compounds  (thus,  no  emissions  will be caused by compounds which  are
recovered).   However, incineration  requires high operating costs (due to
energy  consumption and greater  safety  risks.
                                      4-48

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                  OUTLET VAPOR
PILOT
BURNER
VAPOR
BURNER
                       I
                                     STACK
                                    MAIN  BURNER


                                     FUEL
                                                   S VAPOR  SOURCE
          AIR DAMPER
                         WATER  SEAL
              Figure 4-9.   Thermal oxidation unit.

              Source:  Erikson,  1980 (Reference 3).
                              4-49

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Emission Reduction Effectiveness

     Vapor control systems have found widespread application  for  control  of
storage tank emissions, primarily because of the high reduction efficiencies
they can achieve.  Vapor control systems are generally  regarded as  the most
effective means of controlling highly volatile substances.  The percent
reductions achieved by an  individual system is dependent  upon design and
operating parameters, e.g., cooling temperature or  tank exhaust flow rate.
     Condensers are suitable  for any volatile substance.  Most condensers
utilize chilled water, at  a temperature within the  -5°C to  10°C range.  The
effectiveness  of  a condenser  is directly proportional to  the  surface area of
cooled tubes which contact the vapors to condense them.   A  typical  condenser
system is estimated to reduce emissions by 85 to 95 percent.
     Carbon adsorbers can  be  used for the control of volatile organic
compounds.  When  large-scale  adsorber systems are utilized  (controlling a
group of storage  tanks), the  system involves several units  both in  series and
in  parallel.   The effectiveness of carbon adsorption systems  is directly
proportional to  the length of time organic vapors are in  contact  with
activated carbon.  The individual-type "barrel" systems,  which are  more
commonly used  for the control of single storage tanks,  are  designed up with
two or more units in  series.  The effectiveness of  carbon adsorption has  been
estimated at a reduction efficiency range of 85 to  97 percent.
     Fume incinerators can be used to control any combustible (oxidizable)
volatile  substance.   Generally  the small  systems winch  are  employed for the
control of an  individual storage tank operate continuously.   The  effectiveness
of  vent  incinerators  is dependent upon the combustibility of  the  exhaust  gas.
Fume incinerators are estimated  to be 85  to 99 percent  efficient  in reducing
          6
emissions.

Costs

      Vapor control  systems are  the most complete  systems  in use for control of
storage  tank emissions and,  as  a result,  are  the most expensive.   The costs
elements  of  such systems  include design,  construction,  installation,
                                      4-50

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material, storage, maintenance, energy, and labor.  These costs depend
primarily upon the design of tanks, number of tanks to be serviced, type of
substances to be controlled, and materials handling considerations.
     Condensers are more expensive than the small, individual storare tank
carbon adsorption or fume incineration units, and are much less expensive than
the larger carbon adsorption or vapor incineration systems.  The cost of a
condenser is dependent on the vapor flow rate, and the heat transfer surface
area.  Hall et al. estimated the costs of a variety of tank vent condensers to
be between $2,000 and $19,000 (in March 1985 dollars).17  The operating
costs, including power consumption, maintenance, and service were estimated at
approximately $10,000 annually.
     Carbon adsorption systems used to control storage tank emissions vary
widely in cost between the large systems and the individual "barrel" type
units.   In general, large systems, which can cost up to $300,000 (in March
                                     9
1985 dollars) to install and operate,  are not used to control TSDF storage
vessels.  Individual units are totally self-contained systems which can be
easily installed as purchased.  These systems have an expected lifetime of
6 months, depending upon the vapor exhaust flow rate.  Many facilities use two
or more  in series and/or parallel to handle the exhaust capacity.  Such a
design scheme allows for continuous control if a particular unit needs to be
replaced.  The cost of such units was reported by a supplier at $670 and $920
per unit, depending on model type selected (the more expensive unit is capable
of controlling hydrogen sulfide and acid gases).    Activated carbon
suitable for adsorption of gas phase volatile compounds, may be purchased in
bulk for approximately $1.00 to $1.50 per pound.

     Fume incinerators, similar to carbon adsorption systems, vary widely
between  the large-scale systems and the individual tank units.  The
large-scale systems may cost as much as $300,000 or more to install and
                             r\
operate  (March 1985 dollars),  but are not commonly used at TSDFs  for
storage  tank emission control.  The cost of a small fume incinerator was
estimated by MITRE at $7,500 to $11,000 per tank  (March 1985 dollars).6
Costs of such systems are highly dependent on vapor exhaust flow rate,
ignition fuel usage, and combustion temperature.
                                     4-51

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                            REFERENCES FOR SECTION 4
1.   Arthur D. Little, Inc.  Evaluation of Emission Controls for Hazardous
     Waste Treatment, Storage, and Disposal Facilities.  EPA-450/3-84-017.
     U.S. Environmental Protection Agency, Office of Air Quality Planning and
     Standards, Research Triangle Park, NC.  November 1984.

2.   USEPA, Office of Air Quality Planning and Standards.  Benzene Emissions
     from Benzene Storage Tanks-Background Information for Proposed
     Standards.  EPA-450/3-80-034a.  U.S. Environmental Protection Agency,
     Office of Air Quality Planning and Standards, Research Triangle Park,
     NC.  December 1980.

3.   Erikson, D.G.  Storage and Handling, Report I in Organic Chemical
     Manufacturing, Volume 3:  Storage, Fugitive, and Secondary Sources.
     EPA-450/3-80-025.  U.S. Environmental Protection Agency, Office of Air
     Quality Planning and Standards, December 1980.

4.   API.  Evaporation Loss in the Petroleum Industry - Cause and Control.
     API Bulletin 2513.  American Petroleum Institute, Washington, D.C.  1973.

5.   USEPA, Office of Air Quality Planning and Standards.  Air Pollution
     Engineering Manual, Second Edition.  AP-40.  U.S. Environmental
     Protection Agency, Office of Air Quality Planning and Standards, Research
     Triangle Park, NC.  1973.

6.   Vogel, G. A., and D. F. O'Sullivan.  Air Emission Control Practices at
     Hazardous Waste Management Facilities.  MTR-83W89.  Prepared for U.S.
     Environmental Protection Agency, Office of Solid Waste, Contract
     No. 68-01-6092, The MITRE Corporation, McLean, VA.  June 1983.

7.   Capricorn Chemicals Corporation, Secaucus, NJ.  Sales Literature, 1985.

8.   Cooley, K. R.  Evaporation Reduction:  Summary of Long-Term Tank
     Studies.  J. Irrigation and Drainage Engineering 1(109).  March 1983.

9.   Sandberg, H. W.  PTFE-coated Foamed Glass Blocks Form a Floating Cover
     that Prevents Acid Emissions.  Chemical Processing.  February 1982.

10.  Key, J. A., and F. D. Hobbs.  Ethylene Dichloride.  Report I of Organic
     Chemical Manufacturing, Volume 8:  Selected Processes.
     EPA-450/3-80-028c.  U.S. Environmental Protection Agency, Office of Air
     Quality Planning and Standards.  October 1980.
                                     4-52

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11.  Cudahy, J. J., and R. L. Standifer.  Secondary Emissions Report.
     Report 3 of Organic Chemical Manufacturing, Volume 3:  Storage, Fugitive,
     and Secondary Sources.  EPA-450/3-80-025.  U.S. Environmental Protection
     Agency, Office of Air Quality Planning and Standards.  June 1980.

12.  Bragg, R. W., W. R. Grace and Company, Construction Products Division,
     Cambridge, MA.  Communication with M. Kravett, GCA Corporation, March
     1985.

13.  Runchal, A. K.  Hydrocarbon Vapor Emissions from Floating Roof Tanks and
     the Role of Aerodynamic Modifications.  J. Air Pollution Control
     Association, 28(5) :498-501.  May 1978.

14.  Beck, D. C.  Chevron USA Inc.,  Perth Amboy, NJ, Communication with M.
     Kravett, GCA Corporation, March 1985.

15.  Pittsburgh Corning Corporation, Pittsburgh, PA.  Sales Literature, 1985.

16.  Neulight, J.  Calgon Carbon Corporation,  Bridgewater, NJ.  Communication
     with M. Kravett, GCA Corporation, March 1985.

17.  Hall, R. S., J. Mathey, and K.  J. McNaughton.   Estimating Costs of
     Process Equipment.  Chemical Engineering, April 5, 1982.  pp.  83-116.
                                     4-53

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                                    SECTION  5
                 CONTROL OF EMISSIONS FROM SURFACE IMPOUNDMENTS

INTRODUCTION

     A surface impoundment is defined as "a facility or part of a facility
which is a natural topographic depression, man-made excavation, or diked area
fortned primarily of earthen materials (although it may be lined with man-made
materials), which is designed to hold an accumulation of liquid wastes or
wastes containing free liquids, and which is not an injection well."   There
are three basic types of surface impoundments:   (1) totally excavated;
(2) filled; and (3) combination.  Excavated surface impoundments are
constructed below grade-level; filled surface impoundments are built above
grade; and combination surface impoundments are partially below grade.  Most
surface impoundments are combinations.  Examples of surface impoundments are
holding ponds, settling ponds, aeration pits, and lagoons.  In general,
surface impoundments are used for holding, storing, or treating large
quantities of waste.
     Surface impoundments have been estimated to be the largest source of
                         o
emissions  found at TSDFs.   Emissions occur predominently as a result of
volatilization of substances  from the surface.  Particulate emissions may  be
produced as a result of wind  erosion of dry substances which have  formed
around the impoundment perimeter.  Gases may  also be generated within a
surface impoundment as a result of a chemical reaction, e.g., methane
formation  from decomposition  of organics.
     Emission control  technologies applicable to  surface  impoundments may  be
classified as systems  which either minimize the exposed surface area  or  reduce
the affect of climatological  forces  such as wind, solar irradiation,  or
precipitation.  The control options which are in  use at surface impoundments
may be categorized as  follows:
                                     5-1

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     •    Covers;
     •    Aerodynamic modifications;
     •    Vapor control systems; and
     •    Operating practices.

     Table 5-1 provides an overview of the advantages and disadvantages of the
control options described in this section.  Example systems will be cited, and
the relative emission reduction effectiveness and cost of implementing these
systems to existing TSDFs will be examined.
COVERS
Introduction

     Covers placed over surface impoundments serve to limit emissions both by
minimizing the available surface area and by insulating the impoundment
constituents from wind and solar irradiation.  Cover systems have been
reported as the most widely applied technique of controlling emissions from
surface impoundments.   There are a variety of cover designs in use at
TSDFs, including:

     •    synthetic membrane covers;
     •    floating plastic spheres;
     •    rafts; and
     •    surfactant layers.

     In general, cover systems are  considered to be easy to install and
relatively effective in emission reduction.  System costs are dependent upon
design and maintenance considerations.  This section will present a detailed
deescription of each of the above technology options.
                                     5-2

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              TABLE  5-1.  ADVANTAGES AND DISADVANTAGES OF SURFACE IMPOUNDMENT CONTROL ALTERNATIVES
                       Advantages
                                                                    Disadvantages
    COVERS:
Ul
I
Highly effective in reduction of surface
impoundment emissions.

Controls both working and breathing loss
emissions.

Increase facility safety via liquid
surface area minimization.

May be applicable to amy size or shape
impoundment.

May be made from chemically inert
materials and will not be reactive with
waste.

Nonrigid will not cause pressure buildup
      Removable.
   •  Relatively  low  in  installation and
      operating costs.

   AERODYNAMIC MODIFICATIONS:

   •  Reduces emissions  by reducing the effect
      of the wind creating turbulence on the
      liquid surface  and sweeping vapors away
      from the impoundment to the atmosphere.
•  Difficult to maintain.

•  May have poor weather resistance.

•  May not be chemically compatible if waste
   constituents vary.

•  High materials costs.

•  Gas and vapor permeability characteristics may
   be high.

•  Direct-surface application may reduce thermal
   insulation.
•  Entrapped vapors may cause pressure buildup
   and damage the cover system.

•  Would require the addition of a vapor
   collection system to control  releases.
                                               •  Low emission reductions achievable.

                                               •  Low strength and durability characteristics.

                                               •  Has no effect on volatility impoundment
                                                  constituents.
                                                  (continued)

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                                                 TABLE 5-1  (continued)
                           Advantages
                                                                       Disadvantages
Ul
.p-
AERODYNAMIC MODIFICATIONS:  (Cont'd)

•  Facilitates recondensation of vapors at a
   surface impoundment.

•  Simple designs, which can be adapted to
   most impoundment sizes and shapes.

•  Easy to implement at an existing facility.

•  Little or no operating and maintenance
   requirments.

•  Low cost option.

•  Increases overall safety of facility.

VAPOR CONTROL SYSTEMS:

•  Capable of achieving the highest emission
   reduction efficiencies of the control options
   described herein.

•  Completely remove vapor from cover system.

•  Equally effective in reducing working and
   breathing losses.
                                                          •  May require alteration of facility operating
                                                             practices.
                                                          •  Most costly of all  control options.

                                                          •  Highly complex systems to maintain.

                                                          •  Manpower required.

                                                          •  Materials required.
                                                      (continued)

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                                          TABLE 5-1 (continued)
                   Advantages                                          Disadvantages
 VAPOR CONTROL SYSTEMS:   (Cont'd)

 •  Best  available  technology  for highly           •  Space required.
    volatile and/or toxic substances.
                                                  •  Accessibility required.

                                                  •  Requires enclosed impoundment.
 •  Basic  design  of systems  are  simple—they
    are easy to operate;  and easy to design        •  Requires equipment for the disposition of
    to fit a tank.                                    vapor control process products.

 •  Can be applied  to  one or more than one         •  Subject to fire and explosion hazards.
    impoundment.
                                                  •  Can be subject to design capacity limitations.
 •  Can be a single-pass  or multiple-pass
    system.                                        •  Performance is affected by prevailing weather
                                                     weather conditions.
 •  Can selectively recover  constituents.

 •  Adaptable  to  a  variety of  wastes—can be used
    even  if  wastes  stored changes.

 •   Can regenerate  carbon beds for continuous use.

 •   Have found  widespread usage  at TSDFs.

OPERATING PRACTICES:

Increased Freeboard Depth

•  Applicable  to any surface  impoundment          •  Emission reductions achievable are low.
   design.


                                               (continued)

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                                                  TABLE 5-1  (continued)
                            Advantages
                                                                       Disadvantages
Ul
 I
OPERATING PRACTICES:  (Cont'd)

Increased Freeboard Depth

•  Simple to implement at an existing facility,

•  Only costs involved are in construction of
   higher berms.  No cost to lower level of
   liquid.  Very low costs overall.

Submerged Filling

•  Reduces emissions due to decreased
   turbulence of surface layer.

•  Applicable to most impoundments.

•  Particularly advantageous to impoundments
   which form a dry layer on top.

•  Low overall costs.

Less Frequent Drainage, Dredging, and Cleaning

•  Very simple to implement.

•  No costs involved (in fact, results in
   cost savings).
                                                           •  May affect  overall  operation of facility due to
                                                              lower impoundment capacity.
                                                              May be more applicable to smaller impoundment
                                                              due to expected  emissions reduction effectiveness.
                                                           •  Expense—may require  construction and new
                                                              equipment (piping,  pumps).

                                                           •  Emission reduction  efficiency is limited.

                                                           •  Waste characteristics may  limit  applicability.

                                                           •  Implementation may  be difficult.
                                                           •  May negatively affect  the operation of the
                                                              impoundment.

                                                           •  Emission reductions  achievable are low.
                                                       (continued)

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                                         TABLE  5-1  (continued)
                   Advantages
Disadvantages
Less Frequent Drainage, Dredging,
and Cleaning (Cont'd)
                                                  •  May not be suited to all waste types,  due to
                                                     residence time requirements.

                                                  •  Many facilities already conduct these  procedures
                                                     as infrequently as possible.

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Description

     Covers serve to limit emissions from surface  impoundments  by  acting as  an
impermeable barrier.  Waste constituents are thus  held within an enclosed
system.  Covers are applied in such a way as to cover all  or as much  as
possible of the available surface area.  Cover systems may be placed  directly
upon the liquid surface (contact), on floats at the  surface, or over  the
entire impoundment (noncontact).  Covers may be made from  a wide variety of
synthetic materials, including elastomeric sheet,  rigid  foam, flexible foam,
or liquid.  In selecting an appropriate cover system, the  following
considerations determine the applicability of the  system to a specific
impoundment.:

     •    Type of waste impounded.  The volatility,  chemical reactiveness,
          density, and chemical compatibility with liner and cover materials.
     •    Design of the impoundment.  The diameter,  shape,  depth,  berm design,
          leachate collection mechanisms, and liner design.
     •    Inlet/outlet procedure.  Whether the impoundment  is filled  and
          emptied from the top or from submerged pipeline.
     •    Impoundment status.  Whether the impoundment is  currently active or
          not, and the impoundment's primary function.
     •    Weather conditions.  Wind, sun, and rain conditions which are
          prevalent.
     •    Manpower and materials.  Maintenance and materials required.

     The  four cover systems which have found the most widespread use  are
described in detail below.  Each system satisfies  the above criteria  to
varying degrees.  In general, however, they are applicable to most surface
impoundments.

Synttietic Membrane Covers—
     Covers made from flat sheets of synthetic material  may be  used to reduce
volatilization from surface impoundments.  These systems are analogous to
floating blanket covers used  to control storage tank emissions, which are
                                     5-8

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described in Section 4.  Synthetic membranes may be installed on surface
impoundments so that they rest directly upon the liquid surface, or above  the
                                      fy
liquid, supported by floats or frames.   The cover may be constructed as one
continuous sheet, or as interlockable sections.  A wide variety of synthetic
materials have been utilized as covers.  Table 5-2 lists some of the more
common cover materials.
     The covers may or may not be anchored around the perimeter of the
impoundment, they may be coated in some way, they may be exhausted to a vapor
control system (see detailed description of vapor control, presented later  in
this subsection), and they may be colored to reflect sunlight.  The primary
considerations involved in selecting an appropriate membrane cover design  for
a surface impoundment are;  chemical compatibility with waste constituents;
resistance to weather conditions; gas and vapor permeability; tensile and  tear
strength; type of seams; anchoring technique;, and coloration.
     One example of a cover system has been installed over an
(425 ft x 150 ft x 8 ft deep) aerated lagoon owned by Upjohn, Inc. in New
Haven, Connecticut.  The air structure at Upjohn is a vinyl-coated, polyester
membrane coated with Teflon on the inside.  It is harnessed to the foundation
around the impoundment by cables.  Since installation, odor complaints have
been decreased significantly.   This system is completely enclosed.  Vapor
which  forms underneath the cover is exhausted to carbon adsorbers by two 75-hp
aerators and 25 715-hp floating aerators.  The carbon is regenerated by
steam.
     A similar structure without a vapor recovery system was installed over
glauber salt storage ponds used by American Natural Gas in Beulah, N. Dakota,
to  keep precipitation out.  The air structure, which  is movable from one pond
to  another, covers approximately 2 acres and is made of vinyl-reinforced
material over a concrete foundation.  Two air blowers are used to keep  the
structure inflated.  Another ground-mounted, air-supported structure was
installed in Livingston, LA in September 1984.

Floating Spheres—
     A blanket of hollow plastic spheres may be used  as a cover.  These
systems perform very much like synthetic membranes.   However, plastic  spheres
are more fluid and are better thermal insulators.  Gas and vapor  permeability,
                                     5-9

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                                    TABLE  5-2.   SYNTHETIC  COVER CHARACTERISTICS
Ul

i—•
o
Synthetic material
Chlorosulfonated polyethylene
(Hypalon)
Polyethylene
Chlorinated polyethylene (CPE)
Polyvinyl chloride (PVC)
Polychloroprene (Neoprene)

Chlorinated polyethylene
CSPE
Epichlorohydrin rubber
(CO, ECO)
Ethylene propylene rubber
(EPDM)
Polyolef in
Chemical resistance
Inorganics — good
Organic s — poor
Good for organics
and inorganics
Inorganics and
alipha tics-good
Aromatic organics — poor
Inorganics — good
Organics — poor
Good for organics and
inorganics
Inorganics — good
Organics — poor
Good for organics
and inorganics
Inorganics — good
Organics — poor
Inorganics — good
Organics — poor
Gas
Weather permeability
resistance resistance Tear resistance
Excellent Good Poor
Poor Excellent Poor but better
with thick (125
mil) sheets
Excellent Good Cracks in cold
weather
Poor Good Good
Excellent Good Excellent

Good Good Poor
Excellent Good Good
Excellent Good Good
Excellent Good Good-but poor
in cold weather
     Source:   MITRE, 1983 (Reference 2).

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and weather resistance characteristics are not as attractive, however.
Similar systems are used to control storage tank emissions.  The reader should
refer to Section 4 for further discussion.

Rafts—
     A raft is defined as any device which floats freely upon the liquid
surface.  Rafts perform similarly to floating plastic spheres.  Rafts have
desirable gas and vapor permeability characteristics, may be designed to fit
any size and shape impoundment, and are easy to install.  Rafts have been used
extensively to cover surface impoundments.  Similar systems are used to
control storage tank emissions.  The reader should refer to Section 4 for
further discussion.

Surfactant Layers—
     A layer of liquid may also be used to cover a surface impoundment.  In
general, the surfactant layer is applied as thin as possible.  Surfactant
liquids generally employ long chain alcohols such as hexadecanol and
octadecanol.  The primary factor affecting the effectiveness of a surfactant
layer cover is the maintenance of a continuous film on the liquid surface.
Similar systems have also been used to control emissions from storage tanks.
Refer to Section 4 for further details.
     Surfactant layers have been used to cover settling basins at three
acrylonitrile manufacturing plants in Texas.   The settling basins are
employed for suspended solids removal prior to deep-well injection of process
wastewater.  A layer of high-molecular weight lubricating oil, maintained at a
thickness of approximately 0.1  m, is used to reduce the secondary VOC
emissions.  The lubrication oil is periodically replaced to make up  for losses
due to solubilization and evaporation.

Emission Reduction Effectiveness

     Surface impoundment cover systems are attractive  for control of air
emissions primarily due to the high emission control efficiencies which can be
attained.  The emission control effectiveness is dependent upon  the  type  of
compounds being held, the design (e.g., diameter, shape, depth)  of  the
                                     5-11

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impoundment, and weather conditions.
     The effectiveness of the four cover systems described  in  this  subsection
is directly proportional to the amount of surface area covered.  A  synthetic
membrane is capable of covering the entire  liquid surface area.  Effectiveness
of synthetic membrane covers is generally limited by  the vapor permeability of
the synthetic material and the perimeter seal.  The efficiency of synthetic
                                                    2
membrane covers was estimated by MITRE at 90 pecent.
     Rafts are capable of covering up to approximately 90 to 99  percent of
liquid surface area depending on the raft shape relative to the  impoundment
shape.  Effectiveness of rafts is also related to their thickness.  Emission
reduction efficiency of rafts was estimated in one recent study  at
90 percent.
     Floating surfactant layers are capable of fully  covering  the liquid
surface area.  The effectiveness of such cover systems is primarily related to
wind disruptions in the layers caused by wind.  MITRE estimated  that reduction
                                                                 2
efficiencies of 25 to 75 percent were achievable by such systems.

Costs

     The costs associated with a cover system on a surface  impoundment are
highly dependent upon cover design, the purpose of the impoundment, and
operational considerations.  The costs of covers include materials costs,
installation costs, operating costs, and maintenance  costs.  Due to the large
size of many surface impoundments, and the  nature of  the wastes  they contain,
some cover materials and installation costs are considered  to  be particularly
high relative to other cover control options.
     The costs associated with synthetic membrane covers are similar to those
involved in similar systems implemented at  landfills, which are  discussed in
detail in Section 6.  Depending upon the synthetic material selected, the
installed costs of the liner may range between $3 and $26 per  square yard of
impoundment area.   The cost of an air supported synthetic membrane system
such as that at Upjohn was reported to cost over $500,000, while the
installation cost of the American Natural Gas system  was a  reported
$400,000.1
                                    5-12

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     The cost of a layer of plastic spheres is similar for surface
impoundments as that of the same technology applied to a storage tank.  Refer
to Section 4 for further detail.
     The cost of floating raft covers are largely dependent on design
considerations (e.g., raft thickness or coloration).  Cost estimates for rafts
applied fo surface impoundments must consider the usable life span.  Rafts
tend to become contaminated and must be occasionally replaced.  The costs for
a typical raft system was reported by Arthur D. Little to range between $0.05
and $0.13 per square foot.
     The costs of surfactant layers are potentially the lowest of any cover
system.  Materials costs are dependent upon the market price of the liquid
used and, when these costs increase, other, cheaper liquids may be used.
Installation and operating costs should be very low, and maintenance costs can
be minimized by using the appropriate application procedure.  The cost for
applying a layer of hexadecanol, for example, is approximately 0.09 cents per
            A
square foot.

AERODYNAMIC MODIFICATIONS

Introduction

     The role of aerodynamic modifications is to alter, deflect, or eliminate
the flow of wind across surface impoundments.  Wind serves to cause or
increase emissions from surface impoundments by sweeping VOCs or particles
away from the surface impoundment to the environment.  Aerodynamic
modifications are used extensively for control of surface impoundments.  The
variety of designs currently in use may be classifed as either:  barriers or
shades.
     Wind barriers and shades are considered to be, in general, easy to
implement, and moderately effective at reducing emissions.  Aerodynamic
modifications are an attractive control option due  to low costs.  This section
will present a detailed description of the above technology options.
                                     5-13

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Description

     Aerodynamic modifications  reduce  emissions  from  surface  impoundments  by
acting as a barrier or deflector  to  prevailing winds.  Aerodynamic
modifications are constructed  to  maximize  reduction of wind across  the  surface
impoundment.  In general,  the  closer a barrier is  to  the  impoundment,  the  more
effective it will be  in  reducing  winds.  The  higher the wind  barrier,  the
larger its area of effectiveness.  A wide  variety  of  designs  and  materials of
construction are employed  in aerodynamic modification systems.  In  selecting
the most effective aerodynamic  modification system, the following
considerations influence the applicability of the  modification.

     •    Impoundment constituents.  The volatility,  reactiveness,  and
          chemical compatibility  (with barrier shades) of constituents.
     •    Design of  the  impoundment.   The  size,  diameter,  shape,  depth,  and
          berm design.
     •    Weather conditions.   The sun, precipitation, and particularly  the
          wind conditions.
     •    Maintenance and  operating  characteristics.  The various maintenance
          and operating  procedures employed at the facility (including  need to
          access  the  impoundment).

     Aerodynamic modifications have  found  widespread  application  for surface
impoundment  emission  control,  both alone and  in  conjunction with  other  control
technologies.  Barrier  and shade  systems,  which  are described in  detail  below,
vary  in  their applicability under the  above criteria  depending  upon design and
operational  constraints.

Wind  Barriers—
      A wind  barrier  is  defined as any  system  which results in reduced  wind
flow  across  a surface impoundment.   Various designs have  been used  at  surface
impoundments.  These  designs  are  similar  to  those  which  are used  to control
emissions  in drum storage  areas.
      There  are  two  basic types of wind barrier designs,  perimeter and
"compartmentalized."   The  barriers may be  straight, or  "zig-zag."  Barriers
                                    5-14

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may be oriented to face in one particular direction or may simply enclose  the
entire facility.  Among compartmentalized designs, the internal cells may  be
uniform in size (e.g., the "honeycomb" design), or may be varied according  to
the use of the surface impoundment, maintenance, and constituents.  Three
examples of barrier designs, which have been tested in the field, and
described by Crow and Monges,  are as follows:

     •    Open-picket baffles which consist of a picket-type snow fence
          supported by floats.  The floats can be adjusted for different
          barrier heights, varying the ratio of the barrier spacing to the
          barrier height (L/H).
     •    Closed wind barriers which consist of a picket fence with flexible
          membrane linings fastened to the pickets.
     •    Styrofoam barriers consisting of Styrofoam strips joined to form  a
          grid over the impoundment surface.  No floats are necessary.

     The primary considerations involved in selecting the most appropriate
wind barrier design are the height of the barrier, compartmentalization,
barrier materials (strength needed for prevailing winds, and compatibility
with constituents), and impoundment access points.

Shades—
     Shades are defined as systems which serve as wind-breakers and also
reduce solar irradiation over the surface of an impoundment.   Unlike wind
barriers, therefore,  shades serve to limit both the effects of wind and sun,
the two primary forces contributing to impoundment emissions.  Various designs
of shades have been developed for impoundments.  Most involve a polypropylene
mesh stretched over the surface of the impoundment.   In general, field
testing has found that emission reduction effectiveness is proportional to
mesh size.  Shades may be made of a variety of colors, to either reflect  or
absorb radiant heat.  They may also be coated with a chemical film to reduce
vapor permeability.   The primary considerations involved in selecting the  most
appropriate shade design are  the mesh size, color, shade material (chemical
compatibility), resistance  to weather conditions  (e.g., ability  to handle  a
heavy snowfall), and  shade anchoring.  There  are no application  examples
currently available.
                                     5-15

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Emission Reduction Effectiveness

     The degree to which aerodynamic modifications are  effective  in  reducing
emissions from surface impoundments has been studied  through  field testing.
The efficiencies that can be achieved are  relatively  moderate  and, in  some
cases, low.  When used in conjunction with other  systems,  however, the
emission reductions that can be achieved are potentially attractive,
considering  their ease of implementation and low  cost.
     The reduction of wind speed by a wind barrier is dependent upon its
height.  The closer a wind barrier is to a certain point,  the  more effective
it  is  in reducing wind.  Barriers which are close together, however, tend to
exacerbate emissions due to creation of a  forced  convection mechanism.  That
is, wind flow over the barrier walls creates a pressure differential within
the enclosed cell, causing an upward flow  of air  which  would  increase
emissions.   Testing on windbarriers has shown that efficiencies range  from as
high as 80 percent to as low as 11 percent.
     The effectiveness of a shade is dependent on the shade value (see
Table  5-3).   Chemical films tend to increase the effectiveness of shades
due to decreasing vapor permeability.  The efficiency of shade systems  has
been estimated by ADL to be 44 percent for nonaerated and  floating immiscible
layer  impoundments.

Costs

     Aerodynamic modifications are considered to  be among  the  lower  cost
control alternatives available for surface impoundments.   The  cost of  such
systems primarily consists of construction costs.  Operation  and  maintenance
costs  are expected to be low under normal  conditions.   The costs of
installation are low relative to other control technologies,  however,  may vary
as  the aerodynamic modification system complexity increases.   Weather
conditions play a role in costs, as well.  Damage due to extreme  weather, such
as  a blizzard or hurricane, may result in  high replacement and repair  costs.
The stronger the system is, the lower these costs may be.  However,  stronger
systems also tend to be more expensive.  In general,  the costs have  been
estimated as follows:
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            TABLE 5-3.  EVAPORATION SUPPRESSION BY SHADES
                                               Evaporation reduction
      Material tested                               (percent)
Polypropylene Mesh                                      26

  6 percent shade (natural)


Polypropylene Mesh                                      44

  47 percent shade (black)


Source:  ADL, 1984 (Reference 1).
                                5-17

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          Barriers:   $665/yr for styrofoam barriers formed in an 8 ft x 8 ft
          grid over a surface impoundment of median size (0.46 acres).

          Shades:  $1663/yr for black woven polyethylene shades around a
          surface impoundment of median size.
VAPOR CONTROL SYSTEMS

Introduction

     Vapor control systems control the release of volatile substances from
surface impoundments by evacuating vapors which form and processing them
physically or chemically.  Vapor control systems are the most complex and
costly of surface impoundment controls, but are the most effective at reducing
emissions.  Use of vapor control at surface impoundments is widespread.
The three vapor control systems which are most commonly used for surface
impoundment emission control are:

     •    vapor condensation;
     •    Carbon adsorption; and
     •    Vapor incineration.

     Of the three, carbon adsorption systems are probably the most frequently
used.  The three systems will be described in detail below.

Description

     The  primary function of a  vapor control system is  to remove vapors which
form in a surface impoundment,  and render them by physical or chemical process
such that they will not  enter the environment.  Such systems are equally
effective at controlling working or breathing losses, as any vapor which  forms
is evacuated from the  impoundment.  All vapor control systems involve at  least
three steps, as follows:
                                     5-18

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     (1)   evacuation;
     (2)   vapor processing;  and
     (3)   recycle or venting of products.

     The  use of vapor control technology requires that the surface impoundment
be enclosed.  Therefore, only impoundments equipped with covers (see detailed
description presented earlier in this section) will be able to utilize vapor
control processes.  Vapor control systems  require the installation of
ductwork, the location of unit processing  equipment in readily serviceable
areas, and equipment for the disposition of recovered products and materials.
Vapor control systems have found widespread application at TSDFs,  particularly
in the control of highly volatile and/or toxic substances, due primarily to
the high emission reduction efficiencies these systems can achieve.  A vapor
control system helps to alleviate a major  drawback of surface impoundment
covers.  Covers tend to entrap vapors to the point where internal  pressure
builds up, and eventually causes damage to the system.  Evacuation to vapor
control eliminates this, while preventing  these substances from entering the
environment.  The unit processes are themselves simple, utilizing the physical
or chemical properties of surface impoundment constituents, such as
vaporization point, adsorbability, or combustibility.  In determining the
applicability of a particular vapor control system to certain surface
impoundment, the following factors should  be considered.

     •    Properties of the surface impoundment constituents.  The volatility,
          adsorbility on carbon or other substrates, and combustibility of
          waste constituents.
     •    Number of impoundments to be serviced.  The total capacity to be
          served by a vapor control system.
     •    Manpower and materials requirements.  The maintenance, operating
          labor, and materials required.
     •    Availability of space.  The location of the vapor processing unit
          and attendant ductwork.
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     The three vapor control systems described below have  found widespread
application both in the control of surface impoundments and storage  tanks, due
not only to the high emission reduction efficiencies they  can achieve, but
also their applicability under the above criteria.

Vapor Condensers—•
     Vapor condensation systems prevent release of volatile substances by
recondensing  the vapors which form in an impoundment.  These systems are
identical to  those used for control of storage tank emissions.  Refer to
Section 4 for further discussion.

Carbon Adsorbers—
     Carbon adsorption systems prevent the release of volatile substances by
adsorption of the volatile organic material onto activated carbon particles.
The  systems used to control surface impoundment emissions  are identical to
those used to control storage tank emissions.  Refer to Section 4 for further
discussion.

Vapor Incinerators—
     Vapor incineration systems,  also called  afterburners, control surface
impoundment emissions by oxidation (combustion) of volatile substances.  The
systems  in use for  surface  impoundment emission control are identical to those
used for  storage tank emission control.  Refer to Section  4 for further
discussion.

Emission  Reduction  Effectiveness

     Vapor control  systems  are highly effective at reducing emissions from
surface  impoundments.  Efficiencies of these  system were described in detail
in Section 4.  Refer back  for  further discussion.

Costs

     Vapor control  systems  are highly complex,  including much engineering
design, materials,  labor,  operating costs, and maintenance.  The control

                                    5-20

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systems are, therefore, the most expensive of available control alternatives.
Costs for such systems were described in Section 4.  Surface impoundments may
require additional installation and operating costs, d.ue to. their larger_size
requirement.

OPERATING PRACTICES

Introduction

     The implementation of more effective operating practices at a surface
impoundment serves to reduce emissions by limiting the affect of
climatological forces (i.e., sunshine and wind) which contribute to
emissions.  Operations during the active life involving temperature of
influent, dredging frequency, draining frequency, cleaning frequency, handling
of sediments and sludge from dredging and types of wastes accepted at a
facility could be designed to minimize emissions.   Many different operating
practices have been instituted at TSDFs on the basis of reduced emission
generation.  To exemplify the type of measures which might be instituted at a
surface impoundment,  this subsection will focus upon three changes in
operating practice, as follows:

     •    Increased freeboard depth;
     •    Inflow/outflow drainage pipe relocation to effect submerged filling;
          and
     •    Infrequent  dredging, draining and cleaning.

     While  changes in operating practices are not considered to be more  than
moderately  effective  in reducing emissions (relative to add-on controls),  they
are  often implemented at a TSDF on the basis of cost, ease  of implementation,
and  simplicity.

Description

     Changes in opeating practice at a surface  impoundment  could  involve those
which directly affect the waste material, the design of the surface

                                     5-21

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impoundment, or external forces (such as sunshine, rain,  and wind).  These
changes may involve new equipment, manpower training, or  management.   The
following considerations should be made in determining the applicability of
operating practice changes for a surface impoundment.

     •    Type of materials.  The physical or chemical characteristics of
          impoundment constituents.
     •    Manpower requirements.  Personnel and training  requirements.
     •    Impoundment turnover.  The rate at which a surface impoundment is
          filled and emptied and the retention time of waste material.

The three examples presented in this section, which are described  in detail
below, are  commonly implemented at TSDFs due to their applicability under the
above criteria.

Increased Freeboard Depth—
     The freeboard depth is the distance from the top of  the berra  to the
liquid surface.  Increasing freeboard depth at a surface  impoundment would
serve to reduce air emissions by reducing the effect of wind and surface
waveso  This modification will decrease:

     •    volatilization;
     •    turbulence on the impoundment surface;
     •    spray formation; and
     •    erosion of dust and the dried surface of the impoundment.

     There  are two ways in which a facility can increase  the freeboard depth
of an impoundment:  (1) decreasing liquid level, and/or (2) increasing berm
height.  Decreasing the liquid level of an impoundment would limit the
capacity of the facility.  For surface impoundments which operate  at steady
state (input rate = output rate, volume stays constant),  a decrease in liquid
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level would also require changing (decreasing) the flow rate.  Increasing  the
height of the berm would require additional material and construction.  The
draft RCRA Guideline Document (July 1982) suggest at least 60 cm  (2 feet)  of
freeboard to prevent overtopping.  A way to increase freeboard is to minimize
runon into the impoundment by incorporating a runon control system.
     The primary considerations involved in selecting an appropriate freeboard
depth for a surface impoundment are the capacity needed at the facility, the
surface impoundment size, the requirements involved in construction of higher
berms, and costs of berm material, labor, and more frequent draining of the
impoundment.  Increasing freeboard depth is applicable to any surface
impoundment.  Due to emission reduction effectiveness considerations,
increasing freeboard depth as the sole means of control may be more applicable
to small surface impoundments than to larger ones.

Inflow/Outflow Pipe Relocation—
     By relocating the inflow and outflow pipes such that a surface
impoundment can be filled and emptied from submerged points, emissions will be
reduced due to reduced surface turbulence.  Discharge of liquid on or above
the  surface on the impoundment not only causes the surface to become more
turbulent but may also cause spray formation or degradation of any dry crust
which may have formed over the impoundment.  In designing a submerged filling
system, it is advantageous to locate inflow pipes such that discharge occurs
into the liquid bulk and below the surface.  Relocation of pipes may require
excavation for pipeline, new pipe, and new liner materials.  The  leachate
collection systems may also require modification.  Among the considerations
involved in selecting a new inflow/outflow pipeline system are the size of
pipe required, flow rate, pressure effects on filling and emptying, waste
viscosity profile, excavation depth, and new materials requirements.  New
designs of surface impoundments primarily employ submerged filling and
emptying.  The frequency with which such systems are retrofit to  existing
surface impoundments is not known.
                                     5-23

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Less Frequent Dredging, Draining, and Cleaning—
     By decreasing the frequency with which a surface  impoundment  is
disturbed, emissions would be reduced due  to decreased  turbulence.  Three  ways
in which  this could be accomplished  are  through more infrequent  dredging,
draining, or cleaning of  the  impoundment.  Such measures  would  require  less
labor and equipment, but  might affect the  impoundment  process efficiency.  The
primary considerations involved  in implementing such measures are  the effect
on  the impoundment process (e.g., lowering the efficiency of settling),  the
waste materials,  and the  size of the impoundment  (the  smaller the  impoundment,
the  less  effective these  measures would  be).  Such measures are  quite
attractive on  the basis of decreased operating costs and,  therefore, have  been
extensively used  at TSDFs.

Emission  Reduction Effectiveness

     There  is  no  in-depth analysis present in the available literature  which
assesses  the effectiveness of changes in operating practices in  reducing
emissions from surface impoundments.  On the basis of  engineering  judgment, it
is  expected that  such measures would be  at most only moderately  effective  (in
terms  of  emission reduction  percentage).  Increasing freeboard  depth, for
example,  is analogous  to  construction of a perimeter wall of equal  height.  As
described previously,  wind  screens have  been  found to  achieve efficiencies of
between  11  and 80 percent.

Costs

      The  costs involved  in  implementing  changes  in operating practice are
generally low,  in relation  to other  control  alternatives.  Costs are the
primary  factor in selecting  such measures  for TSDF surface impoundments.
      The  costs for increasing freeboard  depth involve  cost of berm materials,
 labor,  and/or  costs  of more  frequent drainage or  lower capacity.  Such  costs
are expected  to be  quite  low,  but are difficult  to quantify.  The  more  costly
of  the two  methods  described earlier would be increasing  berm height due to
materials costs.
                                    5-24

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     The costs for changing to submerged filling and emptying are potentially
the highest of the three operating changes described.  Added costs would be
incurred during implementation of the system, including new equipment,
materials, construction labor, and maintenance labor.  No information was
available which quantified the total costs involved in such a change in
operating practice.
                                    5-25

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                                   REFERENCES
1.    Arthur D. Little,  Inc.  Evaluation of Emission Controls for Hazardous
     Waste Treatment, Storage, and Disposal Facilities.  EPA-450/3-84-017.
     U.S. Environmental Protection Agency, Office of Air Quality Planning and
     Standards, Research Triangle Park, N.C.  November 1984.

2.    Vogel, G. A., and D. F. O'Sullivan.  Air Emission Control Practices at
     Hazardous Waste Management Facilities.  MTR-83W89.  Prepared for U.S.
     Environmental Protection Agency, Office of Solid Waste.  Contract
     No. 68-01-6092.  The MITRE Corporation, McLean, VA.  June 1983.

3o    Breton, M., T. Nunno, P. Spawn, W. Farino, and R. Mclnnes.  Assessment of
     Air Emissions from Hazardous Waste Treatment Storage and Disposal
     Facilities (TSDFs).  Preliminary National Emissions Estimates.   Prepared
     for U.S. Environmental Protection Agency, Office of Solid Waste.
     Contract No. 68-02-3168.  GCA Corporation, Bedford, MA.  August 1983.

4.    Cudahy, J. J., and R. L. Standsifer.  Secondary Emissions Report.
     Report 3 of Organic Chemical Manufacturing.  Volume 3:  Storage,
     Fugitive, and Secondary Sources.  EPA-450/3-80-025.  U.S. Environmental
     Protection Agency, Office of Air Quality Planning and Standards, Research
     Triangle Park, NC.  June 1980.

5.    USEPA, Office of Research and Development.  Handbook for Remedial Action
     at Waste Disposal Sites.  EPA-626/6-82-006.  U.S. Environmental
     Protection Agency, Office of Research and Development, Cincinnati, OH.
     June 1982.

6.    SCS Engineers.  Interim Report on Air Emissions.  Prepared for U.S.
     Environmental Protection Agency, Office of Solid Waste.  Contract
     No. 68-01-6621.  SCS Engineers, Covington, KY.  September 1983.
                                      5-26

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                                    SECTION  6
                                    LANDFILLS

INTRODUCTION

     A landfill is defined as a waste disposal facility where wastes are
placed in or on the land for custodial safekeeping.    Solid or semisolid
wastes arrive in bulk or in containers,  are placed in a landfill "cell" and
are covered over with a soil layer of from 6 to 12 inches.  A landfill is
generally large in area, some extending several acres in size.  Wastes in a
landfill are isolated from the environment in the soil, and are left to
degrade by chemical or biological process.
     Atmospheric emissions from landfills can consist of both particulate
matter and volatile organic compounds (VOCs).   Air emissions can occur as a
result of activities such as soil and waste handling, landfill maintenance,
vapor diffusion, and/or wind entrainraent.  Diffusion may occur both vertically
and laterally from the landfill cell.  Emissions may also result from the
leachate generated within a landfill and removed by a collection system.
     There are two ways to control organic vapor emissions from landfills.
One method is to place a barrier on the landfill surface to minimize diffusion
into the atmosphere, thus, limiting the rate of volatilization.  This type of
control includes the use of a soil, foam, synthetic membrane cover, or
encapsulation or solidification techniques.  The other method is to collect
the vapors and vent them to a treatment system such as a carbon adsorber  or
afterburner.  This is the "ultimate" disposal method, because there is no
chance for future volatilization of the compounds.  This  type of control
includes gas collection.
                                     6-1

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     An overview of the advantages and disadvantages of  the control options
described in this section is shown in Table 6-1.  Also examined  are the  costs
and efficiencies obtainable relative to vapor emission reduction.

SOIL COVERS

Introduction

     Soil covers serve to limit emissions by acting as a barrier to diffusion
and wind entrainment.  Soil covers have experienced widespread use at
municipal landfills, primarily for minimizing odors, reducing particulate
emissions, and preventing rodent  infestation.  They have also been ussd  to
prevent  leaching of hazardous chemicals to ground water due to infiltrating
precipitation.  A variety of soil covers have found usage as both a temporary
and permanent cover, utilizing a  wide range of soil types.  Soil covers  are
considered to be relatively effective in preventing emissions and are very
cost-effective.

Description

     Temporary soil covers are placed over landfilled wastes as  soon as  is
practical, usually at the end of  each day.  Soils suitable for use as
temporary covers can sometimes be found nearby the  landfill site; otherwise,
they may have to be imported from offsite at added expense.  Permanent soil
covers  usually consist of higher  density soils,  such as  clay, which are  less
permeable to water percolation than  are the soils usually used as temporary
covers.
     Layered covers may  also be constructed using different materials (see
Figure  6-1).  These covers are placed over a landfill after all  cells have
been filled and  the  landfill is being closed.  They may  also be  used in
conjunction with a gas collection system.  Often a  layer of top-soil and
vegetation is placed over a permanent soil cover to protect it against drying
and physical damage.
     The primary factor  which controls  the release  of volatile organic
chemical (VOC) emissions  through  soil covers is  the air-filled porosity  of  the

                                      6-2

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TABLE  6-1.    LANDFILL  EMISSION TECHNOLOGIES—ADVANTAGES  AND  DISADVANTAGES
                    Advantages
                                                                       Disadvantages
 SOIL COVERS:

 •  High  volatile emissions reductions possibly       • Emissions may be significant depending on  design,
    depending on design operating  practices             operating practices,  and soil types used.
    and soil types used.
                                                    • Ultimate release of  all volatile constituents
 •  Appropriate soils may be at  or nearby landfill      from landfill (unless gas collection used).
    site.
                                                    • May crack or degrade  due to natural processes
 •  Widely  used technology.                            over time.

 •  Can be  used as a temporary or  permanent           • Requires periodic maintenance (watering,
    control measure.                                   inspection, etc0)

 •  Properly designed permanent  soil covers
    serve dual purpose of minimizing infiltration
    and reducing volatile emissions.

 •  Compatible with all waste types.

 •  Can be  used in conjunction with other tech-
    nologies (e.g., synthetic membrane covers,
    gas collection).

 •  Standard construction equipment used in
    implementation.

 •  Moderate costs.
 SYNTHETIC MEMBRANE COVERS:

 •  Very  effective when used in  conjunction
    with  soil covers and/or  gas  collection.

 •  Virtually impermeable to infiltrating
    precipitation.

 •  Available in many materials  and  thicknesses.
 •  Widely used technoloyg.
•  Emissions may be significant  over a large area if
   not  used in conjunction with  other technologies.

•  Certain cover materials not compatible with some
   wastes.

•  May  be punctured or torn easily,  limiting use
   as a temporary cover.

•  May  crack or degrade due to natural processes
   over time.
                                                (continued)

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                                     TABLE  6-1  (continued)
                    Advantages
                                                                        Disadvantages
SYNTHETIC MEMBRANE COVERS:  (Cont'd)
•  Host materials are moderate in cost.
FOAM COVERS:

•  May be used as a temporary cover.

•  May be useful for fugitive dust control.

•  Have been used at sanitary landfills  in Europe.

•  Have been shown to be somewhat effective  in
   mitigation of vapor release from spilled
   organic chemicals.
                                                     •  High performance materials may be very expen-
                                                       sive (e.g., Teflon).

                                                     •  Requires periodic maintenance (inspection,
                                                       watering, etc.)
•  Effectiveness questionable with  respect  to
   reducing emissions from hazardous  waste
   landfills.

•  Some foams are incompatible with certain wastes.

•  Only effective as short-term control.

•  Long time necessary to apply an  effective cover.

•  Application equipment and reagents costly.
ENCAPSULATION/SOLIDIFICATION:

•  Classification and encapsulation may be  very
   effective.

•  Solidification has been used effectively for
   containment of radioactive  wastes.
•  High costs.

•  Some solidification agents are not  compatible
   with organic wastes (e.g., thermoplastic
   solidification).

•  Encapsulation has not yet been developed  on a
   commercial scale.

•  Solidification is not a proven technology for
   vapor emission control.

•  Not widely used technologies.
GAS COLLECTION:

•  Expected to be very effective  when  used  in
   conjunction with • landfill  cover system.

•  Has been used for methane  gas  migration
   control.
•  Requires treatment system.

•  Some methods high in cost (e.g.,  trench  vents).

•  Some gas barriers are not compatible  with
   certain vapors<.
                                                (continued)

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                                                                      TABLE  6-1  (continued)
                                                 Advantages                                           Disadvantages
                             GAS COLLECTION:  (Cont'd)

                             •  A simple, inexpensive  system may be effective     •  Some gas barriers may be be ineffective in the
                                over a large area (e.g.,  single pipe vent            control of vapors.
                                with treatment).

                             •  Can be constructed incrementally for use
                                uhile landfill is still active.

                             •  Easy, proven construction techniques.

                             •  Moderate cost for most methods.


                             AIR-INFLATED STRUCTURES:

                             •  Expected to achieve high  collection/removal       •  High costs.
                                efficiencies.
                                                                                 •  Requires treatment  system.
                             •  Prevents infiltration  as  well  as providing
                                emission control.                                •  Structure may  be somewhat permeable to vapors,
                                                                                    depending on materials used.
                             •  Synthetic membrane of  soil covers would not be

-------
                     Loam (for Vegetation)
 Y//S7///////.   Clay (Barr.cn
 OOOOOOwOOOOOOOOOOO*
 OOOOVt/OOOOOOOOOOOO     (* ,,,-1 !<•:•». fKsnAalt
 OOOOOG-'.OOOOOOOOCOO     VAijvGi iuas \«nannei)
 OOOOObUOOCOOOOOOOOwwvwvv wowwwvwwwwwwwj
 ooooo oooooooooooooooocooooooooooooi^££aAA£ooooooo666bbii
 eoo«ouoooooooooooooo^M9pVMMafiOM^?^:-\v79«Mioooooooi;
 ooooocooooooooooooi  •" '    *MUI«^rri.v-'-.V.-.'-.-^*S??9?ooi
                            Loam
                             (Barr.er)
                          Silt (Filter)
                         Sand (Buffer)
Figure  6-1.   Two  typical  layered  soil  cover  systems

                (U.S.  EPA, 1982)  (Ref.  1)
                             6-6

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     2 3
soil. •    Decreasing the air-filled porosity decreases the effective
diffusivity of volatile materials through the soil.  This can be achieved by
using a denser cover material or .by compacting existing materials.  However,
the most effective method of reducing air-filled porosity is to increase the
moisture content of the soil.  Maintaining the highest moisture content
possible consistent with good workability and structural integrity of the soil
will result in a significant decrease in emissions.  This can be achieved by
spraying temporary covers from a spray truck or other device, or installing a
permanent sprinkler system after landfill closure.  This will also prevent
drying and subsequent cracking of the cover.
     Emission release rates are inversely proportional to cover thickness.
Hence, doubling the thickness of the soil layer will halve the release rate of
VOC's through the cover.  In selecting an appropriate landfill soil cover, the
following considerations are important:

     •    type of soil used;
     •    thickness of soil layer;
     •    design of landfill cells; and
     •    landfill facility operating and maintenance practices.

Emission Reduction Efficiency

     Soil covers are often used to control landfill emissions, due to the high
emission reductions they are capable of effecting.  Measured emission rates of
hexachlorobenzene from an experimental landfill were reduced by 92 percent
with the addition of a 1-inch soil cover.   A 40-inch soil layer was found
to  reduce emissions by 99.8 percent.
     In the study mentioned above it was also found that decreasing soil water
content by 2.3 percent increased hexachlorobenzene flux by 21.2 percent,
                                    2              9
clearly an exponential relationship.   A. D. Little  calculated
theoretical emissions through 12-inch soil covers of different dry porosities
and different moisture contents as shown in Table 6-2.  It can be seen  that
increasing soil porosity increases the unit emission rate; increasing moisture
content reduces emissions to virtually zero in the case of low porosity

                                      6-7

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  TABLE 6-2.  UNIT EMISSIONS THROUGH  12-INCH  SOIL COVERS
              FOR SOILS OF DIFFERENT  DRY POROSITY3>b
Unit emission (ft/hr)
Dry porosity (bulk density)*^
% Waterc 0.3(118) 0.4(101)
0 0.056 0.083
5 0.016 0.039
10 0.0020 0.015
15 0.0000032 0.0036
20 - 0.00033
25 -
% Moisture at zero 15.8 24.7
porosity
3,, • Ib , Ib ^^
ft -hr ft
0.5(84)
0.111
0.069
0.039
0.020
0.0084
0.0027
37.1

0,6(67)
0.142
0.10
&.073
0.050
0.032
0.020
55.8

bDiffusivity in air = 0.28 ft2/hr; t = 1 ft.

cPercent of dry weight.
      density (lb/ft^) in the parentheses,  based on
 particle density = 2.7.

Source:  Arthur D. Little, Inc., 1984.  (Reference 2).
                              6-8

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soils.  It must be noted that these high levels of water content may not be
achievable in practice.  It is evident, however, that significant emission
reductions are possible solely by increasing moisture content, probably on the
order of 75 to 99 percent, depending on the soil type.
                           n
     Other laboratory tests  indicate that changes in soil density on the
order of 10 to 15 percent may be achievable in the field using heavy
compacting machinery, depending on the type of soil.  If the water content of
                          o
the soil is about 15 Ib/ft , this level of compacting can reduce effective
diffusivity from 50 to 100 percent, resulting in similar reductions in
emission rates.
     Overall, it can be seen that both temporary and permanent soil covers are
effective at reducing VOC emissions from landfills, particularly if they are
maintained at a high moisture level.

Costs

     The costs of soil cover systems used to control landfill emissions are
low relative to other control alternatives, making such systems highly
attractive.  The costs of implementing such systems are largely dependent upon
installation and maintenance requirements.
     The costs for hauling, spreading, and compaction of a clay cover are
about $11 per cubic yard of material.   The costs for hauling, spreading,
and grading of top soil (sandy loam) are about $17 per cubic yard.
However, soils suitable for use as a temporary cover or for acting as a base
for vegetation are usually found near the landfill site.  Clays are usually
not available nearby and hence must be trucked in from offsite.
     The cost of hydroseeding grass over a landfill is about $1550 per acre of
     4
land.   Costs for irrigation systems or spray trucks have not been
estimated, but their use is expected to be very cost-effective with respect to
reducing air emissions.  Other costs may be incurred for heavier earthmoving
equipment for added compaction ability, or additional labor required to
accommodate changes in operating procedures that reduce air emissions.
                                      6-9

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SYNTHETIC COVERS

Introduction

     Synthetic covers perform similarly  to soil covers  in  controlling  landfill
emissions.  Placed on top of wastes,  they serve to  limit emissions  by  reducing
vapor diffusion and acting as a  barrier  to the wind,  sun,  and  any
precipitation or runoff  liquid.  Synthetic covers have  experienced  widespread
use at both municipal and hazardous waste landfills,  where their main  function
has been  the prevention  of leachate generation.  They are  also effective  in
reducing  atmospheric emissions of volatiles  from landfills, especially if used
in conjunction with a gas collection  system  and/or  a  soil  cover.  A wide
variety of  synthetic materials have found usage in  this application.   Their
use with  respect to emissions reduction  will be discussed  in this section.

Description

     Synthetic membranes, commonly made  of polymeric  materials such as
Hypalon,  Neoprene, and elasticized polyoLefin, can  be used as  temporary covers
over landfill cells until the daily soil cover has  been put into place.   This
practice  will reduce atmospheric emissions to some  degree.  However, synthetic
membranes are prone to puncture  or tearing by landfilling  equipment or other
sharp objects, such as metal drums, and  hence may have  limited use  as
temporary covers.
     As was mentioned earlier, synthetic membranes  may  be  very useful  as  a
permanent cover, especially  if used in combination  with a  soil cover.   A  soil
cover will  not only further  reduce emissions, but will  protect the  synthetic
cover against drying and physical damage.  Even when  covered by soil,  however,
the  synthetic cover may  be  subject to cracking or rupture.
                                     6-10

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     It must be noted that certain organic vapors are incompatible with some
liners.  Compatibility of some organic vapors with Hypalon and Neoprene
membranes is shown in Table 6-3.  The primary considerations involved in
selecting an appropriate synthetic cover for landfill emission control are:

     •    synthetic material and its compatibility with waste constituents; and
     •    membrane thickness and durability with respect to landfill
          operational and maintenance procedures.

Emission Reduction Effectiveness

     Very little data exist on synthetic membrane permeability to volatile
organic chemical vapors.  However, available data suggest that, although
synthetic membranes appear virtually impervious to water, they are somewhat
permeable to organic vapors.  The permeability of a given polymeric membrane
to a given chemical depends on the solubility of chemical in the polymeric
membrane because, unlike soils, synthetic membranes are nonporous.
     As can be seen from Table 6-4, which shows experimentally measured
permeation rates through polymeric membranes for various organic solvent
vapors, substantial variation occurs between compounds with different
properties as well as between liner materials.  Even a high-performance
material such as Teflon does not appear to be effective against permeation of
volatile chlorinated organics such as chloroform.
Costs
     The costs associated with implementing a synthetic cover  system are
considered to be relatively low to moderate, depending upon the design of  the
system selected.  The costs are primarily a function of material costs.  In
general, more favorable performance characteristics (e.g., low vapor
permeability, high tensile and tear strength), result in higher material costs.
     Unit costs of some installed synthetic membranes are presented in
Table 6-5.  These costs are only for the liner itself and do not include
maintenance and inspection costs, or costs for soil covers.
                                     6-11

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 TABLE  6-3.   CHEMICAL  RESISTANCE  CHART  (DUPONT)
Vapor type
Acetic acid (glacial)
Benzene
Butane
Butyraldehyde
Carbon tetrachloride
Cyclohexane
Dioctyl phthalate
Ethyl acetate
Ethyl alcohol
Formic acid
Gasoline
Hydrocyanic acid
Hydrogen sulfide
Kerosene
Methyl alcohol
Methylene chloride
Methyl ethyl ketone
Naphtha
Perch lor oethylene
Toluene
Trichloroethylene
Xylene
Hypalon3
X
C
A
X
C
C
C
C
A (158°F)
A
B
B
B
X
A (158°F)
C
C
B
X
C
C
C
Neoprene3
C
C
A
C
C
C
C
C
A (158°F)
A
B
A
A
B
A (158°F)
C (100°F)
C
C
C
C
C
C
aCured sheet.

A - Chemical has little or no effect.
B - Chemical has minor to moderate effect.
C - Chemical has severe effect.
X - No data - not likely to be compatible.

Unless otherwise noted, concentrations of aqueous
  solutions are saturated.
All ratings are at room temperature, unless
  specified.

Source:  U.S. EPA, 1982.  (Reference 1).


                       6-12

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               TABLE 6-4.  PERMEATION RATES FOR ORGANIC CHEMICAL VAPORS THROUGH  SYNTHETIC MEMBRANES
o-
I

Membrane
Elasticized polyolefin
High-density polyethylene
Low-density polyethylene
Polybutylene
Teflon

Thickness
(mills)
22
30
30
27
4

Methanol
2.10
0.16
0.74
0.35
0.34
Vapor
Acetone
8.62
0.56
2.83
1.23
1.27
transmission 1
Cyclohexane
760
11.7
161
616
0.026
;§/m2/day]
Xylene
359
21.6
116
178
0.16
)
Chloroform
3230
54.8
570
2120
20.6
         Source:   Haxo et al.,  1984.   (Reference 5).

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 TABLE 6-5.  ESTIMATED UNIT COSTS FOR SOME SYNTHETIC MEMBRANES







        Membrane                              Unit cost ($)






Hypalon (30-mil)                                8.60/yd2




Neoprene                                        6.60/yd2




Ethylene propylene rubber                    3.60 - 4.60/yd2




Butyl rubber                                 9.60 - 5.00/yd2




Teflon-coated fiberglass                        26.50/yd2




Elasticized polyolefin                       3.60 - 4.80/yd2




Chlorinated polyethylene                     3.20 - 4.20/yd2




PVC membrane (20-30-rail)                     3.20 - 4.20/yd2






Source:  U.S. EPA, 1982 (Reference 1).
                             6-14

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     Total cost estimate data are limited.  In general, they are considered to
be somewhat greater than those for soil covers, but lower for most other
control measures.

FOAM COVERS

Introduction

     Foam covers are a relatively new technology which can be used in much the
same manner as temporary soil covers.  In terms of emission reduction, foam
covers perform identically to soil and synthetic cover systems described
previously.  Foam covers have not been extensively utilized at hazardous waste
landfills, but they have been used in Europe for several years in sanitary
landfills as a substitute for a 6-inch soil cover.  Use of foam covers in the
past, has served to minimize particulate and gaseous emissions, rodent
infestation, and disease-spreading organisms.

Description

     Foam covers serve to limit emissions by acting as a barrier to vapor
diffusion and wind entrainment of wastes, and reducing the affect of solar
irradiation.  In general, foams are used as a temporary cover system, applied
over waste materials at the end of each day.
     Foams used as landfill covers are liquid-based materials.  A wide variety
of foams may be applicable, depending on the waste characteristics and
landfill design.  Foam systems used are either mixed on-site or are "ready
made" for immedite usage.  Foams used to cover landfilled wastes are similar
to those used to control spills from containerized waste.  For detailed
information on the materials, refer to Section 3.
     Foam application is accomplished by either spraying or spreading material
over the waste.  Foam systems may be applied by manual or mechanical devices.
Application equipment exists that can be operated by one worker.  Larger
systems which can be attached to a tractor can cover an acre  in 1-1/2 hours.
                                     6-15

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     Foam systems are a relatively new cover technology.  The advantages to
such systems are their ease and speed of application, their ability to control
both particulate and VOC emissions, and their overall emission reduction
effectiveness.  Foam systems are only applicable as a temporary system,
however, and thus necessitate daily costs.  Foams may also be found to be
incompatible with certain types of waste.
     The primary considerations involved in selecting and determining whether
a foam system is applicable for landfill coverage include:

     •    Type of foam.  The chemical compatibilllty with waste materials,
          mechanical (strength, durability) properties, and resistance to
          prevailing weather conditions.
     •    Application procedure.  The equipment, design, and personnel
          required by a certain application procedure.
     •    Landfill status.  Whether or not the landfill is active on a daily
          basis, preparing for closure, or in the process of commencing
          operations.
Emission Reduction Effectiveness

     Foam covers are not a proven control technology for reducing VOC air
releases.  As mentioned earlier, their primary use has been at sanitary
landfills.  However, they may be effective at hazardous landfills as well.  A
study on the effectiveness of various foams in the mitigation of air releases
from volatile chemical spills indicates  that for nonpolar liquids, any high
quality foam cover, regardless  of its chemical type, will provide some degree
                                Q
of mitigation of vapor release.   Only alcohol foam was found to be stable
against highly  polar low molecular weight liquids such as acetone.  The best
foam agent  in terms of vapor mitigation  was the metal stearate-based alcohol
type foam.  Actual efficiencies for  vapor emission control were not available,
but it appears  that most foams  control vapors effectively for only 1 day or
less.  Longer-term control may  be achieved with respect to fugitive dust
releases.
                                     6-16

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Costs

     Costs of foam cover systems are, in general, moderate to high relative to
other comparable emission control alternatives.  The costs are largely based
on materials, equipment, and operating expenses.  The cost of chemical
reagents needed to generate a 2-inch layer of urea-methane complex foam is
approximately 11 cents per square foot.   A one-man foam application system
costs about $4,350.  The high capital cost for equipment and reagents, the
length of time required to apply the foam, and the temporary nature of foam
covers indicate that foam covers may not be the most cost-effective of
emission control options for vapor phase air release.

ENCAPSULATION/SOLIDIFICATION

Introduction

     Encapsulation or solidification of wastes in a landfill serves to limit
emissions by changing the physical properties of the waste itself.  This
process  is considered to be effective for both vapor and particulate releases,
particularly in limiting the affect of external forces, such as wind, on waste
materials.
     Solidification of wastes has been widely used, particularly  in the
transport and disposal of radioactive wastes.  Solidification has not,
however, been widely utilized at hazardous waste disposal sites,  primarily
because  of cost .  Encapsulation techniques have only recently emerged from
development and testing stages, and no large commercial-scale encapsulation
facilities have yet been designed and operated.   The application of  these
technologies as vapor emission controls will be discussed in this section.

Description—
     Waste solidification involves a number of  techniques to seal wastes  into
a hard,  stable mass.  The basic process involves combining waste  material with
solidification agents.  In  theory, this would not only  reduce  the potential
for  organics to be leached  into ground water by  infiltration,  but would  also
                                      6-17

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limit Che evaporation of organics to the atmosphere.  Six commonly used
methods of solidification are cement-based, lime-based thermoplastics, organic
polymers, self-cementation, and glassification.   Absorbent materials can
also be used which reduce emissions by reducing the amount of exposed free
       2
liquid.   Mixing of solidification agents with waste should be carried out
in closed vessels or enclosures which are vented to a carbon adsorber or other
treatment system to minimize air releases to the atmosphere.  Open mixing
                              2
should be avoided if possible.
     Encapsulation is a process in which wastes are physically enclosed in a
synthetic encasement.  TRW Systems Group has developed bench-scale processes
which are capable of encapsulating toxic and corrosive sludges and salts, as
well as containerized wastes.  This system requires the use of polybutadiene
resin as an agglomeration agent and high-density polyethylene for an
encapsulation  jacket.  (See Figure 6-2).  As was mentioned earlier, commercial
encapsulation  facilities are not yet in operation at landfills.  For a more
detailed discussion of encapsulation processes used to control emissions from
containerized  waste, see Section 3.
     The considerations which are involved in selecting an encapsulation or
waste solidification (e/ws) technology appropriate to a particular landfill
facility include:

     •    Waste characteristics.  The volatility, density, corrosivity, and
          diffusivity of waste materials to be encapsulated or solidified.
     •    Operational and equipment requirements.  The need for specially
          trained personnel, procedures, and equipment required by a certain
          e/ws technology.
     •    Availability of materials.  Whether or not the required materials
          will be available, transportable, and interchangeable.
     •    Landfill status.  Whether or not a landfill is active or inactive.

Emission Reduction Efficiency

     No data are available in the literature on the fate of volatile organics
in  solidified  or encapsulated wastes.  Some solidification agents are not
                                     6-18

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                                       -HIGH DENSITY
                                        POLYETHYLENE
                                        JACKET
                                      WASTE/RESIN
                                      AGGLOMERATE
                                       PLATFORM
Figure 6-2.  Encapsulation process concept.
(Source:  U.S. EPA,  1982) (Ref.  1).
                6-19

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compatible with organic wastes, and hence may not be applicable.  These
include lime-based thermoplastics and self-cementing methods.   The maximum
organic content of chemical wastes that can be solidified using cement is  2  to
3 percent because of process chemistry limitations.   Organic  polymers may
be biodegraded over time, losing their structural integrity and releasing
vapors to the atmosphere.  Classification may be an effective  solidification
method relative to emission reduction, but it has not yet been adequately
tested for this purpose.
     Encapsulation is considered to have great potential in isolating many
types of waste from the environment, but also has not been adequately tested
on a large scale.

Costs

     Cement  costs range from $77 to $106 per ton at the mill.
Solidification costs will vary widely depending on the site and waste types.
Organic polymer solidification has been reported at $3.60 per  gallon for
radioactive  wastes.   No specific cost information is available for
glassification, but it  is expected to be very high because of  its intensive
energy use,  requirements for highly trained personnel, and sophisticated
machinery.   Projected costs for encapsulation at a plant are $120 per ton  of
waste.  This estimate will vary depending on the nature of the waste and the
encapsulation materials used.

GAS COLLECTION

Introduction

     Systems designed  to collect gases which form at a landfill serve to limit
emissions by reducing  the amount of volatile materials entering the
atmosphere.   Gas  collection systems are  intended to divert vapors to control
systems such as a carbon adsorbers or afterburners.  These technologies were
discussed previously  for surface impoundments and storage tanks, and are
detailed  in  Section 4.
                                     6-20

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     Gas collection has been used primarily for controlling methane gas
generated in sanitary landfills, but lias also experienced some use for control
of volatile toxics as well.
     In general, such technologies are considered to be highly effective.  The
costs to implement such systems, however, may be high.

Description

     In their simplest form, a gas collection system may consist of a single
pipe vent connected to a small fan, discharging to a treatment device.  Since
the radius of influence of a single forced ventilation pipe has been found to
be as high as 200 to 300 feet, it is conceivable that a simple fan and vent
system could be used for landfills as large as 5 to 6 acres.   Several
technologies are available for use in gas collection, including pipe vents,
trench vents, and gas barriers.  These technologies are discussed below.

Pipe Vents—
     Pipe vents consist of vertical or lateral perforated pipe installed  in a
landfill either incrementally, as the landfill is still in operation, or  as
part of landfill closure.  They may be installed within or around the
landfill, and in combination with trench vents for lateral migration control.
The pipe vents are usually surrounded by a layer of coarse gravel or sand to
prevent clogging, as shown in Figure 6-3.  Several pipe vents will connect to
an exhaust header which may, in turn, be one of several header branches
leading to a larger manifold blower.  Each branch may have butterfly valves
for balancing and flowraeters for checking flow rate.  Such complicated  systems
are usually applicable only to  landfills larger than 5 or 6 acres.

Trench Vents—
     Trench vents are constructed by excavating a deep, narrow trench
surrounding a disposal site or spanning a section of the area perimeter.  The
trench is backfilled with gravel, forming a path of  least resistance  through
which gases can pass.  Trench vents are often used in conjunction with  liners
to form an effective barrier against gas migration.  To prevent  organic  vapor
emissions, the trenches are capped with clay or a synthetic membrane  and
                                     6-21

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NJ
                                                                    To atmosphere
                                                                      or treatment
                                                                                                             To treatment
           (a) Atmospheric
                vent
           Mushroom Top
                                                          Low permeability
                                                               soil
                                                           4-6" slotted
                                                            PVC pipe
                                                          Gravel
(b) Atmospheric
     vent
   "U" Top
(c) Forced
Ventilation
(d) Vertical pipe vents connected to forced
       ventilation manifold system
                               Figure  6-3.   Pipe and trench vents (U.S.  EPA,  1982)  (Ref. 1).

-------
fitted with collection pipes.  These are connected to a negative pressure  fan
which removes vapor from the landfill and directs them to a gas treatment
system such as an afterburner.   Air can also be injected on one side of a
disposal area through a pipe or trench vent, and collected through a pipe or
trench vent on the other side.  In some cases this may be the most effective
collection method.  However, it is not desirable to exert net positive
pressure within a landfill, as seals may be ruptured, and vapors released.

Gas Barriers—
     Barriers to gas or vapor migration can be employed in a number of ways at
waste disposal sites.  Low permeability materials suitable for constructing
gas barriers include compacted clay, concrete slurry walls, gunite, and
synthetic liners.   These barriers can be used to direct vapors or gases to
trench vents or prevent lateral migration outside of the landfill area.

Emission Reduction Effectiveness

     The efficiency of gas collection and treatment systems depends primarily
on the collection system, because the treatment portion can usually achieve
                                          2           Q
levels of efficiency exceeding 95 percent.   One study  has estimated that
landfill gas control efficiency is between 70 and 90 percent.  Trench vents
attached to a negative pressure fan or blower by collection pipes offers the
most effective lateral control method if the trenches extend to ground water
or bedrock.  Pipe vent systems may be somewhat less effective but may be less
                                        o
expensive and useful at a greater depth.   The use of gas barriers to
control lateral gas movement has not been tested.  The discussion on synthetic
and clay liners, however, indicates that they will not be extremely effective
as they are somewhat permeable to some organic vapors.  The integrity of
concrete slurry walls and gunite barriers may be difficult to achieve and
maintain.
                                     6-23

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Costs
     Costs associated with gas collection  systems  are  considered  to  be  high
relative to other control alternatives, due  to  the complexity  of  the systems
involved.  The costs are based primarily on  equipment  costs  and  installation
costs.  The cost of installed vent pipe range from $2.60  to  $3.30 per inch
(diameter) per foot (depth)  for  small diameter  pipes.  This excludes  casing
costs.  Casing costs are $6.00 and $8.60 per foot  for  4-inch and  6-inch
casings, respectively.  In addition, the cost for  a  fan capable of producing
3 inches of static head and  a flow rate of up to 3 cfm would be approximately
$800.  Therefore, the total  installed cost of a single forced  ventilation pipe
vent, 4 inches in diameter and 30 ft deep would be approximately  $1450.  This
does not include treatment of the collected  vapors.
     The cost associated with trench vent  installation includes the  excavation
cost in addition to costs for the gravel fill,  the lateral and rise  pipe, and
liner material.  Excavation  accounts for 80  percent  of the total  cost.  The
total installed cost of a trench vent 20 ft  deep,  4  ft wide, and  500 ft long
         o
(1500 yd ) using a hypalon liner would be  approximately $330,000.1

AIR-INPLATED STRUCTURES

Introduction
 • i i ^^^^— *                                                            *

     An  air-inflated structure is a  system which completely  covers a
landfill.  Emissions are effectively reduced by such systems because they act
not  only as a  synthetic membrane cover, but  as  a gas collection  system  as well.
     Air-inflated  structures have been used  to  some  degree for reducing
emissions  from or  keeping precipitation out  of  surface impoundments. The
principle  behind air-inflated structures could  be  easily  applied  to
landfills.  No information was found describing their  use over landfills.

Description

     An  air-inflated structure consists of a large synthetic membrane,  sealed
around  the edges,  and  filled with air  for  support.   Usually  large fans  or
                                     b-24

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blowers introduce air into the structure, and the structure is vented to a
carbon adsorber, afterburner, or other gas treatment system.  Thus, emissions
from a landfill would be collected and treated before they could reach the
atmosphere.  Air locks for vehicle entrance and exit can be installed,
allowing emission-free entrance.  Air-inflated structures could be used to
cover landfills ranging in size from a fraction of an acre to 5 or 6 acres.
Section 4 of this report provides a discussion of this vapor
collection/treatment system.
     The use of air-inflated structures to cover landfills has not been
documented.  This type of air emission control technology has, however, been
utilized to control emissions from surface impoundments.  Two applications,
one at the UpJohn chemical company in New Haven, CT, and another at American
National Gas,  in Beulah, ND, have been discussed previously in Section 5 of
this document.
     The primary considerations involved in selecting and determining the
applicability  of a suitable air-inflated structure design for a particular
landfill include:
     •    Synthetic membrane materials.  The materials chemical compatibility
          with waste materials, tensile and tear strength, and resistance to
          weather conditions.
     •    Landfill design.  The size, shape, and cell design of a particular
          landfill.
     •    Landfill operational and maintenance characteristics.  The frequency
          of access and egress, usage patterns, and maintenance requirements
          of a landfill.
     •    Support system.  The costs, maintenance, location, and energy
          requirements of the air support system.
Emission Reduction Effectiveness

     The efficiency of an air-inflated structure  is dependent  primarily  on  the
vapor  permeability of the membrane and the air-tightness of  the  structure.
Relatively  impermeable, well-sealed  structures vented  to gas treatment systems
are generally 95 percent efficient,  or more.  As  mentioned previously with
regard  to synthetic covers, emissions through synthetic membranes  may be
substantial.  However, the use of a  high-performance cover,  such as  the
                                      b-25

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Teflon-lined membrane used at Che Upjohn  facility will  serve well  to  reduce
emissions.
Costs
     The cost of  the Upjohn structure was about $400,000,  including
installation.   In addition, carbon adsorbers,  fans, and other expenses
totalled about  $100,000.  The American Natural Gas  structure also cost
approximately $400,000,  installed.  Costs of this control  option will vary
depending on the materials used and the size of the landfill.  Estimated costs
for  two sizes of air-inflated structures are presented in  Table 6-6.  The two
sizes  represent the approximate range of landfill sizes over which an
air-inflated structure can be built.  Based on these estimates, costs will
range  from  $6 to  $9 per  square  foot of floor space.
     Despite their high  cost, air structures may be applicable in certain
situations.  If an air-inflated structure were installed over a large
landfill, there would be no need for soil or synthetic covers or other gas
collection  systems.  Precipitation would be kept out, and  volatiles would be
effectively collected and removed.
                                      6-26

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  TABLE 6-6.  CAPITAL COSTS FOR AIR-INFLATED STRUCTURESa
                       17,000 ft2
                      260,000 ft2
Structure

Heating

Lighting

Vehicle air lock

Installation

    Total

Annualized
(10%, 10 years)
    70,000

    24,500

    15,000

15,000 - 24,000

    25,500

   150,000

    24,000
  985,000

  175,000

Not estimated

Not estimated

  390,000

1,600,000

  250,000
Source: A. D. Little, 1984 (Reference 2).

aTreatment system costs not included.
                          6-27

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                                   REFERENCES
1.   USEPA, Office of Research and Development.  Handbook for Remedial Action
     at Waste Disposal Sites.  EPA-625/6-82-006.  U.S. Environmental
     Protection Agency, Office of Research and Development, Cincinnati, OH.
     June 1982.

2.   Arthur D. Little, Inc.  Evaluation of Emission Controls for Hazardous
     Waste Treatment, Storage, and Disposal Facilities.  EPA-450/3-84-017.
     U.S. Environmental Protection Agency, Office of Air Quality Planning and
     Standards, Research Triangle Park, NC.  November 1984.

3.   Farmer, W. J., M. S. Yang, J. Letey, and W. F. Spencer.  Land Disposal of
     Hexachlorobenzene Wastes.  Controlling Vapor Movement in Soil.
     EPA-600/2-80-119.  U.S. Environmental Protection Agency, Office of
     Research and Development, Cincinnati, OH.  August 1980.

4.   R. S. Means, Inc.  Building Construction Cost Data.  42nd Edition.  R.S.
     Means, Inc.  1983.

5.   Haxo, H., et al.  Permeability of Polymeric Membrane Lining Materials.
     Proceedings, International Conference on Geomembranes, Denver, CO.  June
     1984.

6.   Vogel, G. A., and D. F. O'Sullivan.  Air Emission Control Practices at
     Hazardous Waste Management Facilities.  MTR-83W89.  Prepared for U.S.
     Environmental Protection Agency, Office of Solid Waste.  Contract
     No. 68-01-6092.  The MITRE Corporation, McLean, VA.  June 1983.

7.   Davanzo, T., U.S. Environmental Protection Agency Region I, Boston, MA.
     Communication with A. Baldwin, GCA Corporation.  March 1985.

8.   Gross, S.S., and R. H.  Hiltz.  Evaluation of Foams for Mitigating Air
     Pollution from Hazardous Spills.  EPA-600/2-82-029.  U.S. Environmental
     Protection Agency, Office of Research and Development, Cincinnati, OH.
     Contract No. 68-03-2478.  March 1982.

9.   SCS Engineers.  Costs of Remedial Response Actions at Uncontrolled
     Wastes Sites.  Prepared for U.S. Environmental Protection Agency, Office
     of Solid Waste.  Contract No. 68-01-4885.  SCS Engineers, Covington, KY.
     April 1981.
                                     6-28

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OTHER REFERENCES

     Shrenfeld, J.,  and J. Bass.  Handbook for Evaluating Remedial Action
          Technology Plans.  EPA-600/2-83-076.  U.S. Environmental Protection
          Agency.  Office of Solid Waste, Washington, DC.  August 1983.

     Kinraan, R. N.,  and D. L. Nutini.  Production, Migration, and Hazards
          Associated with Toxic and Flammable Gases at Uncontrolled Hazardous
          Waste Sites.  Proceedings:  Tenth Annual Research Symposium,
          Ft. Mitchell, KY, April 3-5, 1984.  EPA-600/9-84-007.   U.S.
          Environmental Protection Agency, Office of Research and Development,
          Washington, DC.
                                     b-29

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                                   SECTION 7
                         CONTROL OF AIR EMISSIONS FROM
                           LAND TREATMENT FACILITIES
INTRODUCTION

     Land treatment is a method of destroying wastes by applying them to a
plot of land and allowing soil microbes to biodegrade them.   Because the waste
is often tilled to enhance biodegradation, significant volatilization of
organics may also occur.  The technologies in this section describe methods
which reduce vapor emissions by.

     •    providing a barrier against free diffusion (covers);
     •    changing operating practices including subsurface injection,
          decreasing application rate, and increasing soil moisture content;
          and
     •    collecting and treating the vapors generated (air-inflated
          structures).

     Table 7-1 presents an overview of the advantages and disadvantages of the
land treatment facility control technologies described in this section.  Costs
and efficiencies of these technologies will also be examined  in detail.

CHANGES IN OPERATING PRACTICES

Introduction

     Since volatilization of organic compounds in soil is greatly  influenced
by such practices as tilling, changing certain operating practices can
significantly reduce emissions from land  treatment areas.  Changes in
                                      7-1

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         TABLE 7-1.  LAND TREATMENT EMISSION CONTROL TECHNOLOGIES—ADVANTAGES  AND DISADVANTAGES
                  Advantages
           Disadvantages
OPERATIONAL PRACTICES

•  Subsurface injection is expected to achieve
   significant emission reductions for some
   wastes.

•  A subsurface injection tool bar can be
   fitted onto an existing waste application
   vehicle at nominal cost.

•  Maintaining a high soil moisture content
   will reduce emissions significantly.

•  Reducing waste application rates may in-
   crease biodegradation rates, resulting in
   a decrease in emissions.
Subsurface injection may not be effective for
highly volatile compounds.

High initial cost for a complete subsurface
injection vehicle.

Increasing injection depth may decrease bio-
degradation rates,  resulting in an increase
in emissions.

Reducing application rates may not be
economically justifiable, given the small
emissions reductions possible.
COVERS
   May serve as effective temporary measures
   to reduce emissions from land treatment
   areas, especially if the wastes being
   treated are highly volatile.
Soil covers increase the volume of material
present in the land treatment area, limiting
the volume of waste that may be applied.

Synthetic membranes can be easily torn or
punctured, limiting their effectiveness as
temporary covers.

Foam covers are not compatible with certain
wastes.
                                              (continued)

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                                         TABLE 7-1 (continued)
                  Advantages
              Disadvantages
COVERS  (continued):
AIR-INFLATED  STRUCTURES

•  Expected to achieve high collection/removal
   efficiencies.

•  May be necessary  for  land treatment areas
   receiving  highly  volatile wastes or
   located in densely populated areas.

•  If adopted biodegradation rates could be
   maximized  without heed to odor generation
   or volatilization.

•  Have been  constructed over surface
   impoundments.

•  Can cover  areas as large as 5 to 6 acres.

•  If a carbon adsorption system is used,
   condensate from steam regeneration of the
   carbon may be returned to the land treatment
   area to be further biodegraded.
                                                    •  Foam covers may be too expensive for
                                                       temporary use.

                                                    •  Covers may decrease biodegradation rates,
                                                       resulting in an increase in emissions.
•  High cost.

•  Requires treatment system.

•  May be somewhat permeable to vapors,  depend-
   ing on materials used.

•  Have not been used over land treatment areas.

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operating practices involve both  the purchase and  installation  of  new
equipment or facilities, and/or the alteration of  waste  treatment  and  handling
methods employed at the  facility.  One change that can be  made  is  to inject
wastes below the land surface, as opposed  to applying them on the  soil surface
and tilling them into the soil.   Other changes include decreasing  the  waste
application rate and maintaining  a high  soil moisture content.

Description

Subsurface Injection—
     Subsurface  injection is  a method of applying  wastes below,  as  opposed to
on  the  land surface.  This minimizes waste contact with  the atmosphere,
resulting  in reduced emission rates.  Basic subsurface injection equipment
consists of a  tool bar attached to the rear of a truck or  tractor with two or
more chisels,  similar to a chisel tooth  plow, attached.  Adjustable sweeps are
often mounted  on or near the  bottom of the chisels to open a wide but  shallow
cavity  underground.  A tube connected to the waste source  leads  down the back
of  the  chisel, and, as the sweeps open a cavity, the waste is injected.  With
proper  adjustment  and use, very little waste reaches the soil surface.
Using this method, waste is usually injected 4 to  8 inches below the land
surface.   In other devices, waste is simultaneously injected below  land
surface and mixed  into the top 6  to 10 inches of soil.   The initial injection
may be  followed  closely  by a  second pass with a cultivator to distribute waste
                                         7
uniformly  throughout  the treatment area.   In all  cases, waste  should  be
injected to the  maximum  depth consistent with maintaining  high  biodegradation
rates.   If biodegradation rates are decreased significantly by  deep injection,
waste will remain  in  the soil for longer periods of time.
     Subsurface  injection was originally developed by the  agricultural
industry and  is  commonly used for applying anhydrous ammonia and liquid
manures.   Subsurface  injection  is recommended  for any biodegradable wastes
with volatile  and/or  odorous  constituents, such as wastes  generated in the
petroleum and  chemical manufacturing  industries.
                                       7-4

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Decreased Application Rate—
     Emission rates are affected by the waste application rate per unit
area.   In theory, waste should be applied at the maximum rate compatible
with the degradative capabilities of the land treatment soil/microbe system.
In practice, however, land treatment areas are generally overloaded with
waste, resulting in decreased biodegradation rates, and subsequently increased
emission rates due to increased residence time of wastes in the soil.  Nominal
application rates range from about 22 to 66 metric tons per hectare.

Moisture Control—
     As discussed earlier under the section on landfill soil covers (see
Section 6 for further details), effective diffusivity of organic vapors can be
increased dramatically with only small decreases in soil moisture content.
Maintaining soil moisture at the highest levels consistent with good
biodegradation rates and soil workability will serve to greatly reduce
          2
emissions.   This can be achieved by using spray trucks or by installation
of an irrigation system.

Emission Reduction Effectiveness

     Table 7-2 shows theoretical annual losses from a 1-acre land treatment
                                                                  i-\
area based on emission equations discussed by A. D. Little (1984).
Although the equations do not include the effects of biodegradation, the data
are useful for comparing surface application versus subsurface injection.
Actual emissions would probably be lower in both cases by varying amounts due
to biodegradation.  The data indicate that for compounds of low volatility
(vapor concentrations below approximately 1000 ppm), subsurface injection
reduces emissions by more than 90 percent as compared to surface application
followed by plowing under.  For higher volatility compounds, efficiency may be
less than 60 percent.
                                      7-5

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           TABLE 7-2.   ANNUAL EMISSIONS  FROM A THEORETICAL  1 ACRE LAND TREATMENT AREAa
Surface application
followed by tilling
Depth of injection
Depth of plow slice
0
4"
0
8"
Subsurface injection
4"
4"
8"
8"
Percent
4"
4"
reduction
8"
8"
Equilibrium Vapor Pressure
(ppm by volume)




1
5
10
50
100
10
50
100
500
,000
,000
,000
,000
,000
4.8
10.7
15.2
34
48
107
152
287b
287b
3.4
7.6
10.7
24
34
76
107
246
287b
0.1
0.2
0.4
2
4
20
40
200
287b
0.05
0.1
0.2
1
2
10
20
100
200
98%
98
97
94
92
81
74
<59
« 59
99%
99
98
96
94
87
81
59
<59
allnits are in metric tons per year; 287 metric tons of waste applied per year.




bComplete (100%) loss.




Source:  A.  D. Little, Inc., 1984.  (Reference 2).

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     The emissions reductions associated with reducing the application rate of
wastes will depend on factors such as soil type and waste types applied, but
overall will be relatively small as compared to reductions from using
subsurface injection.
     Emissions reductions achievable by maintaining a high soil water content
have been described under the section on landfill soil covers (Section 6).  In
general, a small increase in water content results in a substantial decrease
in emissions from soils due to the decrease in the soil's air-filled porosity.

Costs

     The cost of a subsurface injection vehicle will range from $98,000 to
$158,000, depending on the vehicle's waste storage capacity, engine size, and
                                   3
the addition of optional equipment.   However, a subsurface injection tool
bar fitted onto an existing waste application vehicle costs between $5,400 and
$8,700.3
     Decreasing the application rate may involve substantial costs, as more
land would be required to treat a given quantity of waste.  If more land was
not available, costs would be incurred in the form of alternative offsite
treatment methods.
     Maintaining a high soil moisture content may involve initial capital
costs for spray trucks or irrigation systems, but operating costs will be very
low.
     Overall, it appears that both subsurface injection and maintaining a high
soil moisture content are very cost-effective methods for emission reduction.
Higher  efficiencies can be obtained, particularly for highly volatile wastes,
or at land treatment areas in congested locations by installing systems such
as air-inflated structures with vapor collection/treatment devices.  However,
costs can be substantially higher.  (See Section 4 for a discussion of vapor
collection/treatment systems).
                                      7-7

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COVERS
Introduction

     Covers similar  to  those  employed  at  landfill  facilities  (see Section 6)
may be used as a  land treatment  facility  emission  control  device.  A cover
acts as a physical barrier  to both  external  forces such  as wind,  soil,  and
vapor diffusion from the  soil matrix.   The various covers  which may be  used at
a  land treatment  facility are the same as those  used  at  a  landfill,  namely:

     •    soil;
     •    synthetic  membrane; and
     •    foam covers.

     There  is  little evidence that  covers have been used at land  treatment.
However, covers are  considered to be a potentially effective,  relatively  low
cost control option.

Description

     Any material or system which can  be  applied over land treatment  facility
which acts  as a physical  barrier to vapor diffusion,  and to external  forces
such as  solar  irradiation,  wind, and precipitation is called  a cover.   Land
treatment covers  are made from solid or semisolid  (foam) materials,  applied as
continuously as possible  over the surface area.  In general,  application
procedures  require a truck  or tractor  due to the size of the  facility.
Depending on the  system employed, land treatment covers  are sprayed,  sifted,
or spread over the soil/waste complex. Covers may be used as  a temporary
emission control  measure  on active  land treatment, but are perhaps  more
applicable  to  inactive  facilities.   In general,  the selection and
determination of  the most appropriate  cover  system to be implemented at a
land-treatment facility must  consider  the following important  factors:

     •    Design  of  land  treatment  facility.  The  size,  shape, slope, and
          vehicular  negotiability of a land  treatment facility.
                                      7-8

-------
     •    Type of waste materials.  The vapor diffusivity, chemical
          compatibility with cover materials, biodegradation characteristics,
          and application requirements of the waste materials.
     •    Design of cover systems.  The application procedure, materials.
          handling requirements, strength, weather resistance, durability,  and
          vapor permeability.
     •    Operating procedures.  The personnel requirements, waste handling
          methods, and activity of a particular facility.

Further detail on the three cover systems is provided in Section 6 of this
document on landfill emission control technologies.

Emission Reduction Effectiveness

     The efficiency of covers in reducing emissions was discussed in detail in
the  landfill section (Section 6).  Synthetic membranes may be easily torn or
punctured in the field, and may be awkward to put into place.  Foam covers may
not  be effective for certain types of waste.  Soil covers would increase the
volume of material in the land treatment area, limiting the volume of waste
that could be applied.  In all cases, covers will provide a barrier to free
diffusion, but because they are not part of a collection and treatment system,
diffusion will continue at a reduced rate.  Also, covers may affect the
biodegradation rate of wastes in the land treatment area by changing factors
such as oxygen content and/or temperature.  Such changes may ultimately result
in greater emissions.

Costs

     Costs for soil, synthetic, and foam covers have been discussed in the
landfill section of this report (Section 6).  Overall, it appears that changes
in operating practices will be more cost-effective than covers.  If, however,
the waste in question is of high volatility, and subsurface injection cannot
offer sufficient control, covers may be a viable option for temporary emission
control.
                                     7-9

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AIR-INFLATED STRUCTURES

Introduction

     The use of air-inflated  structures at  land  treatment  facilities  has  not
been documented in the literature.  Such  structures  have been  used  for
reducing air emissions from surface impoundments,  as discussed in Section 5.
It is conceivable that air-inflated structures would be equally,  if not more
applicable  to  land treatment  areas, due to  the higher  potential  for
significant air releases.

Description

     Air-inflated structures  consist  of a synthetic  membrane structure
supported by air pressure  and attached with cables or  by other means  to a
foundation.  Fans force  air into  the  structure which is then vented to a
treatment system to  remove organic vapors.  Used over  a land treatment area,
biodegradation rates could be maximized without  regard to  volatilization  from
the  soil (e.g., by using surface  application).  Organic vapors emitted from
the  soils would be captured by  the structure  and treated.   If  a  carbon
adsorption  system is used, condensate from  steam regeneration  of  the  carbon
may  be  returned to the  land treatment area  for further treatment.   Air
structures  can be constructed over land treatment  operations ranging  in size
                                            o
from a  fraction of an acre to 5 or 6  acres.

Emission Reduction Effectiveness

     As mentioned  in Section  6, the efficiency of  air-inflated structures is
dependent on  the permeability of  the  membrane and  air-tightness  of  the
structure,  as  treatment  technologies  can  effect  greater than 95  percent
removal.  Emissions  through membranes can be  significant over  a  large area.
However, since the vapor concentration within the  structure is expected to be
lower  than  that under experimental conditions, it  is expected  that  emissions
through the membrane will be  minimal, hence,  air-inflated  structures  are
                                     7-10

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expected to achieve better emission reduction rates for higher volatility
compounds than subsurface injection.  For low-volatility compounds, the
efficiency is expected.,tx> be about the same, or less.
Costs
     Costs for air-inflated structures have been presented in the landfill
section (refer to Table 6-6 in Section 6).  Air-inflated structures may be
more cost effective for land treatment areas than for landfills because of the
potential for greater emissions from land treatment.  The use of air-inflated
structures is an option to be considered for land treatment areas in densely
populated zones and/or if highly volatile or odorous constituents are being
treated.
                                     7-11

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                                   REFERENCES
1.   Brown, K. W.,  and L. Devel.  Hazardous Waste Land Treatment.  SW-874.
     Second Edition.  U.S. Environmental Protection Agency, Office of Research
     and Development, Cincinnati, OH.  February 1983.

2.   Arthur D. Little, Inc.  Evaluation of Emission Controls for Hazardous
     Waste Treatment, Storage and Disposal Facilities.  EPA-450/3-8-017.  U.S.
     Environmental Protection Agency, Office of Air Quality Planning and
     Standards, Research Triangle Park, NC.  November 1984.

3.   Vogel, G. A.,  and D. F. 0'Sullivan.  Air Emission Control Practices at
     Hazardous Waste Management Facilities.  MTR-83E89.  Prepared for U.S.
     Environmental Protection Agency, Office of Solid Waste.  Contract
     No. 68-01-6092.  The MITRE Corporation, McLean, VA.  June 1983.
                                     7-12

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                                   SECTION 8
                           CONTROL OF AIR EMISSIONS
                                FROM WASTE PILES
INTRODUCTION

     Waste piles are a common method of storing solid wastes.   Storage in a
waste pile is particularly applicable to fine-grained waste materials, such as
ash, sand, or contaminated sorbent.   Some of the waste material kept in piles
at TSDFs may contain volatile organic compounds.  Because of the physical
nature of these wastes, they may be  subject to erosion by wind, resulting in
fugitive dust emissions,  or volatilization of any organic materials present in
the wastes.  A variety of methods are described in this section which control
fugitive dust emissions and/or vapor emissions from waste piles, including:

     •    enclosure (covers);
     •    stabilization (physical, chemical, vegetative, or wet dust
          suppression);
     •    vapor collection and destruction (gas extraction);
     •    windscreens; and
     •    changes in operating practices.

Table 8-1 provides an overview of the advantages and disadvantages of waste
pile emissions control technologies  described in this section.  These methods
will also be examined in detail in terms of cost and emission reductions
effectiveness.
                                     8-1

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                 TABLE 8-1.   WASTE PILE EMISSION CONTROL TECHNOLOGIES—ADVANTAGES  AND DISADVANTAGES
                       Advantages
                                                                       Disadvantages
00
i
N>
     STABILIZATION

     •  Chemical  stabilization may be very effective
        for extended periods of  time.
•  A wide variety of chemical stabilizers are
  .available.

•  Chemical stabilization is easy to implement.

•  A vegetation/soil cover is adaptable to both
   fugitive dust and organic vapor emissions.

•  A wide variety of suitable plant species
   are available for vegetative stabilization.

•  Wet dust suppression can be used to minimize
   dust emissions during material loading to the
   waste pile as well as providing effective
   short-term control.
•  Some chemical stabilization agents are
   expensive.

•  Vegetative stabilization may require treatment
   or soil covering of the waste pile before an
   effective cover can be achieved.

•  Vegetative stabilization will require some
   period of time to establish an effective cover.
   (Chemical stabilization may be used until the
   plants develop).

•  Wet dust suppression is effective only as a
   temporary measure.

•  Wet dust suppression may not be capable of
   achieving high efficiencies.

•  Actual efficiencies of physical and vegeta-
   tive stabilization are unavailable.

•  Stabilization is generally not an effective
   control for vapor emissions.
                                                    (continued)

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                                                TABLE 8-1 (continued)
                        Advantages
                  Disadvantages
00
 I
      WINDSCREENS

      •  Commercially available in many configura-
         tions.

      •  Simple  in design and construction.

      •  Reduces wind speed over pile surfaces.

      COVERS

      •  Storage domes and synthetic  membrane  tension
         structures reduce particulate emissions  to
         virtually zero.
      •   May  be  used as  a gas collection system if
         designed  to be  air-tight  and  vented  to a
         treatment system.

      •   Both may  be used for active waste  piles.

      •   Storage domes will  retain their structural
         integrity for a long period of  time.

      •   Storage domes are a widely used technology
         for  material storage.

     •   Synthetic  membranes are widely  used  at
         landfills.
•  Probably not effective in reducing emissions
   of small, "respirable" particles.
•  Installed costs are high.

•  Tension structures may lose their structural
   integrity due to natural processes.

•  Requires treatment system if used for volatile
   wastes.
                                                     (continued)

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                                                TABLE 8-1 (continued)
                        Advantages
                                                                       Disadvantages
do
I
GAS EXTRACTION

•  May be effective in controlling organic
   vapor emissions.

•  Because the system is installed incremen-
   tally, it can be operated while the waste
   pile is still active.

•  Can be used in combination with other
   control technologies (e.g., tension
   structures, chemical stabilization).

•  Moderate cost.

OPERATIONAL PRACTICES

•  Some changes cost little or nothing to
   implement (e.g., increasing operator
   awareness).

•  Telescopic chutes may be very cost-
   effective.

•  Some controls have experienced usage in
   the steel and crushed stone industries.
                                                           •  Does  not  control  fugitive  dust  emissions,,

                                                           •  May not achieve high  removal  efficiencies  if
                                                              used  as sale  control.

                                                           •  Requires  treatment  system.

                                                           •  Not a proven  technology.
                                                           •  No  tests  have been  performed  to  determine
                                                              the efficiencies of these  controls.

                                                           •  Height-adjustable stackers and wind  guards may
                                                              be  very expensive.

                                                           •  Changing  slope, orientation,  or  surface  area of
                                                              a waste pile are not  proven control  methods.

                                                           •  These methods do not  control  organic vapor
                                                              emissions.

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STABILIZATION

Introduction

     Stabilization is a means of decreasing fugitive dust (particulate)
emissions from waste piles by minimizing the effects of wind erosion on the
pile surface.  Stabilization primarily affects particulate emissions, although
in some cases it may act to decrease the emission of volatile organic
chemicals as well.  Stabilization techniques include dust suppression,
chemical stabilization, and vegetative stabilization.  Stabilization
techniques have been used to control fugitive dust emissions from coal refuse
piles, mineral refuse piles, metallic tailings piles, and solid wastes which
are stored in piles.  Stabilization, as a dust control method, has also been
used on unpaved roads,  process materials handling, and agricultural dust sources
such as fields.  In general, stabilization is considered to be easy to
implement at an existing facility, and capable of effecting moderately high
emission reduction.  The costs involved in such systems range from being
inexpensive to very expensive, depending on the system selected and the
various constraints of the facility.

Description

Wet Dust Suppression—
     Wet dust suppression involves the application of water or aqueous-based
wetting agents on the waste pile.  This technique serves to limit fugitive
dust emissions by stabilizing dust particles in the pile via surface tension
effected by moisture, thus reducing entrainment of particles as wind blows
over the piles.  Due to evaporation, wet dust suppression is a short-term
control.  It is necessary in most cases to maintain the moisture content at a
certain level by frequent application of the wetting agent.
     Water or wetting agents are usually applied by a spray truck or hose
every few hours, although a facility may alternatively choose to install a
permanent sprinkler system to service a pile or group of piles.  A variety of
wetting agents have been used, depending largely on the type of waste
                                      8-5

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materials being stored.  The wetting agents serve to enhance  particle wetting,
moisture spreading, and pile penetration, which can be key  factors  affecting
the effectiveness of wet dust suppression as an emission control.
     Wet dust suppression has found widespread usage as an  emission control
technique, largely due to the low cost and ease of implementing such systems.
It can also be used to control dust emissions during pile loading,  and
material handling and transfer operations.  The emission reduction
effectiveness of dust suppression, however, is considered to  be low (relative
to other measures).

Chemical Stabilization—
     Chemical stabilization  is similar to wet dust suppression.  This
technique utilizes chemical  binding materials, which, upon  drying,  bind with
surface  particles to form a  protective crust.  A wide variety of such chemical
suppressants are commercially available  including such agents as Orzan GL-50
(lignosulfate). Coherex  (oil byproduct), Liquidow (calcium  chloride), and
                                          1 2
SP-301  (synthetic polymer),  to name a few. '   These agents may be  more
effective on some wastes than on others.
     Chemical stabilizers are usually applied in diluted form with  spray
equipment in a manner similar to using wet dust suppression.  The major
difference  is that some  chemical stabilizers may remain effective for periods
of 6 months or  longer, as opposed to only a few hours for wet dust
            3
suppression.   Additionally, the emission reduction effectiveness of
chemical  stabilization is much higher than that of wet dust suppression.  The
cost of  such agents, however,  is also much higher.

Vegetative  Stabilization—
     Vegetative stabilization  involves covering of a waste  pile with a layer
of vegetation,  such as grass.  Vegetative stabilization is  useful in the
stabilization of a variety  of  surfaces and can be used in conjunction with
other controls, such as  chemical stabilization.  A wide variety of  plant
species  have been  found  to  be  effective  at stabilizing different waste pile
materials.   The main  factor in reducing dust emissions from  waste  piles  is
achieving a uniform, high density plant  cover.  To that end,  grasses such as
rye, bluegrass, sorghum, and bromegrass  may be effective.
     Usually some modification to the waste pile surface must be made before
effective stabilization  can occur,  such  as the addition of  topsoil,
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fertilization, pH modificatioa, and/or slope reduction.  Vegetative
stabilization is restricted to inactive piles because of the time required to
achieve an effective cover.  To minimize dust emissions while the cover is
developing, chemical stabilization agents may be applied.

Emission Reduction Efficiency

     The available data on the control efficiency of wet dust suppression are
minimal.  Reported efficiencies are 30 percent for highly disturbed storage
piles and 67 percent for nondisturbed storage piles,  but these results are
very dependent on soil types, local climatic conditions, and frequency of
application.
     A study on dust control measures for active hazardous waste site cleanup
indicates that water spraying of the working area of a front end loader and
duraptruck resulted in a control efficiency of 42 percent for particles less
than 30 micrometers in diameter, and 64 percent for particles smaller than
2.5 micrometers .  Control efficiency for less than 3- micrometer particles
increased to 63 percent with the addition of Johnson-Marsh compound MR (a
surfactant).  Watering proved to be effective for only a few hours.
     As part of the same study, dust was sprayed as it was being dumped from
the front end loader into the dump truck.   This method was determined to be
50 percent efficient for particles smaller than 30 micrometers, and 56 percent
for particles smaller than 2.5 micrometers.
     Asa et al. found that some chemical stabilizers reduced asbestos
emissions from roads paved with surfacing material containing serpentinite by
80 to 90 percent.   The study also found that stabilizers which formed a
solid, water-resistant surface coating which bound road aggregates together
retained better than 80 percent emission reduction after 6 months, despite
vehicular traffic.  Drehmel et al. found that the stabilizers they tested  in
the laboratory were generally 50 to 70 percent efficient.2  The relative
effectiveness of some of the chemicals they tested as represented by
entrainraent velocity are presented in Table 8-2.  It can be seen that
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      TABLE 8-2.  COST AND  RELATIVE  EFFECTIVENESS  OF  SOME  CHEMICAL
                  STABILIZATION  AGENTS

re
Agent
Coherex
CPB-12
Lignosulfate
Oil and water
Pentron DC3
Polyco 2151
SP-301

Co s t at
icommended rateb
(^/hectare)
1160
874
1136
2360
1647
168
3020
Entrainment
At manufacturer's
recommended rate
55
35
61
61
44
48
55
velocity3
At a cost of
$750/hectareb
44
32
61
60
30
50
21
Source:  Drehmel et al., 1982 (Reference 2).

aLowest wind velocity in mph to cause 10 gm/min reentrainment.

bFebruary 1982 dollars.
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lignosulfate and oil and water are probably the best dust control agents,
based on wind tunnel data using coal dust.
     Rosbury et  al. have reported that the chemical stabilizers they tested
were approximately 100 percent effective for 1 to 4 weeks, with declining
control efficiencies thereafter.    Their results were based on actual field
measurements of particle emissions generated from exposed soil plots.
     The control efficiency of vegetative stabilization will vary considerably
depending on the amount and type of cover on the pile.  One report estimates a
control efficiency between 50 and 80 percent for tailings piles, based on
typical plant growth rates.   The same report estimates a 93 percent
reduction in windblown emissions by using a combination of chemical and
vegetative stabilization.   As mentioned earlier,  the most important factor
in reducing emissions is to achieve complete, high density plant cover.
Efficiencies of 100 percent should be approached with careful construction of
soil cover and vegetation, which would be applicable to nonsoil wastes.  Such
a cover system should also reduce organic vapor emissions substantially.
Contaminated soil may not support a dense vegetation cover depending on the
concentration and type of waste on it.  In this case, the addition of a clean
topsoil cover may be necessary.

Costs—
     Costs for various chemical stabilization agents tested by Drehmel et al.
are presented in Table 8-2.  Also shown in Table 8-2 is a measure of relative
cost-effectiveness, and the entrainment velocity at an application cost of
$750/hectare (based on February 1982 dollars).  It can be seen, for example,
that although SP-301 is effective at the manufacturer1s recommended
application rate, it is not effective when applied at a lower cost of $750 per
hectare.  Lignosulfate, however, was equally effective at the recommended
application rate and the lower application cost of $750/hectare.  Polyco 2151,
a synthetic copolymer manufactured by Borden, may be the most cost-effective
agent, being effective at a cost of only $168 per hectare (about $190/hectare
in March 1985 dollars).
     Cost for wet dust suppression, physical stabilization, and vegetative
stabilization were unavailable.  Costs for wet dust suppression and physical
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stabilization are expected to be low, labor generally being the largest cost
involved with implementation.  Costs for vegetative stabilization may increase
substantially if significant pile surface modifications or treatment are
necessary in development of an effective cover.

WINDSCREENS

Introduction

     Emissions from waste piles are  impacted most significantly by the affects
of prevailing winds.  Winds blowing  over waste piles generate fugitive dust
emissions due to particle entrainment, and volatile organic compound emissions
(when waste pile material is contaminated with VOC) by forced convection.
     Windscreens are devices used at waste piles to act as a physical barrier
to the wind.  Windscreens have found widespread application at TSDF for waste
pile control.  Many designs have been developed.  The designs used are similar
to those described for the control of storage tanks (see Section 4), surface
impoundments (Section 5), and landfills (Section 6).
     Windscreens are considered to be capable of achieving moderate emission
reductions.  The costs of such systems are regarded as being relatively low,
depending on the physical constraints of the waste pile.

Description

     Waste pile windscreens are very much like the wind barriers described in
previous sections  (see above) for control of other TSDF processes.  Typically,
a windscreen is a  simple wall or fence, extending either completely around the
waste pile or placed in the direction of prevailing winds.  The windscreens
are all  setaiporous to wind, which is necessary because use of a solid wall
would create a turbulent layer opposite the "wind side" which would decrease
the wind reduction effectiveness.
     A  typical example of a waste pile windscreen is a "snow fence," i.e., a
picket  fence to which a porous synthetic membrane is attached.  In installing
a windscreen wind  dispersal control  of a waste pile, the following
considerations are most significant:

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     •    Height of windscreen.   The barrier must be high enough to effect
          emission reductions (the higher the barrier, the greater the area of
          reduction effectiveness), but cannot be too high due to structural
          and cost considerations.
     •    Windscreen material.  The type,of material (system design) used may
          depend on weather, chemical,  and operational activities of the
          facility.
     •    Operational considerations.  The effect of a windscreen on the
          normal operation of a  waste pile facility may determine its
          applicability.
     •    Orientation of windscreen.  How the windscreen is set up relative to
          the wind pile has a bearing or emission reduction effectiveness.
          Constraints relative to orientation may therefore have an affect on
          the applicability of a certain system.

Emission Reduction Effectiveness

     Several laboratory and field tests have been conducted to determine the
effectiveness of windscreen control of waste piles.  The results of the
studies have indicated that the  efficiencies of such systems may be as high as
80 percent, and in general are expected to be moderately high.  The general
results indicated, however, that the effectiveness of such systems is highly
dependent on particle size, and, in fact, below a certain particle size may be
ineffective.  The studies also indicated that the effectiveness of waste pile
windscreens depends upon the height of the barrier, distance from the pile,
and orientation.
     Soo et al. conducted wind tunnel tests to simulate the effectiveness wind
barriers in reducing wind velocity over storage piles.   Preliminary results
indicated that a barrier simulating a snow fence one-third the pile height
with a wind porosity of 33 percent would reduce winds by 50 percent at a
distance of three pile-heights away.
     Drehmel et al. conducted tests on wind barriers with porosities of 50 and
65 percent.  Wind speeds were reduced by 65 percent and 40 to 70 percent,
respectively (depending on the location of the measurement).2  The study
also indicated that solid barriers provided no protection against wind
entrainraent at a storage pile due to increased turbulence.
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     A study conducted by Rosbury et al. has indicated that windscreens are
only moderately effective on larger particles, and are ineffective on
wastepiles consisting of small particles.   This study is considered to be
of great validity due to its reliance on actual emissions measurements rather
than modeling.
     In general, windscreens are considered to be relatively effective, based
on their widespread application.  They would not be expected to be as
effective as certain other measures, such as chemical suppression, but may be
used on the basis of other facility constraints.
Costs
     The  installed costs of windscreens are dependent on materials and
construction costs, only.  No operating expenses are expected.  A study by
                                                                        Q
MITRE indicated a cost of from $2.00 to $2.70 per square foot of screen.
Another screen system, a 6-foot high polyester fence, was estimated to cost
$14 per linear foot.  Windscreens are relatively attractive due to their
overall low cost, but the cost effectiveness of such systems is also
considered to be low.
COVERS
 Introduction

      Covers serve  to  limit emissions of both particulate matter and volatile
 organic  compounds  by  acting as a physical barrier to diffusion of vapors and
 to  climatological  forces  such as solar irradiation, wind, and precipitation.
 Covers may be  applied as  a gas collection system, with vapors vented to a
 treatment system (e.g., carbon adsorber, afterburner).  There are two primary
 cover designs  in use  at TSDFs, as  follows:

      •    Storage  domes;  and
      •    Synthetic membranes (tension structures).
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     Waste pile covers are essentially identical to similar systems used  to
control emissions from surface impoundments (see Section 5), landfills
(Section 6), and land treatment facilities (Section 7).  They have found
widespread application, due to the significant emission reductions they can
effect, their strength and versatility, and relative ease of implementation at
existing facilities.  Costs of cover systems, however, are generally high.

Description

     Waste pile covers are very similar to systems used to cover other TSDF
processes (refer to sections as indicated above, for further detail).   Since
the control of particulate emissions is of much greater significance in waste
pile covers, foam,  liquid, or gaseous systems are not applicable.  The most
significant factors to consider in selecting and determining the applicability
of a waste pile cover system are:

     •    pile size and shape;
     •    operating procedures including waste input and output rates  and
          restrictions;
     •    waste material's chemical compatibility and vapor characteristics
          (e.g., permeability of cover); and
     •    durability of cover including strength, tear resistance, weather
          resistance, and chemical resistance.

Description

Storage Domes—
     Storage domes are similar to the "beehives" used to store road salt.  A
typical wooden dome structure is supported on a reinforced concrete foundation
wall, which may be 4 to 10 feet high.  The waste rests on an asphalt pad about
4 inches thick.  The domes may be filled to 85 percent of capacity using a
                 Q
front end loader.   If the dome is designed to be air-tight, the enclosed
air may be vented to a treatment device to remove organic vapors which have
volatilized from wastes present in the dome.  A dome structure will provide
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effective emission control while the waste pile is still active,  and  is
expected to have a long service  life.

Synthetic Membrane Containment (Tension Structures)—
     A synthetic membrane cover may be secured over a waste pile  with tension
cables, having the same function as a storage dome.  If the membrane  is
constructed to form an air-tight seal around the foundation or asphalt pad,
the structure may be vented to a gas treatment system.  Square waste  piles are
more amenable to a membrane containment structure  than are round  piles,
because they are easier to secure.  An auger feed  system can be installed as
                                                           Q
part of the structure to allow waste loading and unloading.   Tension
structures may degrade over time due to natural processes such as photo-
oxidation and drying, and thus,  require regular inspection and maintenance.

Emission Reduction Effectiveness

     Both storage domes and tension structures will reduce particulate
emissions significantly.  Assuming that some material may escape  during
loading into the dome or tension structures, achievable efficiencies  should be
between 95 and  100 percent.  The effectiveness of  such systems in the control
of gaseous emissions will depend primarily on the  ability of the  dome or cover
to capture and contain the vapors, because gas treatment technologies can
exceed 95 percent removal efficiency.  Collection  efficiencies for domes are
                                 Q
estimated to be  about 92 percent.   Achievable efficiencies including
treatment are probably in the range of 85 to 95 percent.
     Emission control efficiencies for synthetic membrane containment will be
the  same as  those described for  synthetic landfill covers (see Section 6).
Emissions through synthetic membranes  from relatively undiluted organic wastes
may  be substantial over  large areas.    However, if a forced-draft
collection system is employed, vapor concentrations within the structure will
remain low, minimizing emissions through  the cover.
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Costs

     The installed costs of several different sizes of storage domes are
presented in Table 8-3.  These costs do not include expenditures for
installation of electric wiring, lighting, ventilation, equipment, or
treatment systems.
     Installed costs of synthetic membrane tension structures range from $4.30
                                              8
to $6.90 per square foot of pile surface area.   This estimate includes
incorporation of the auger feed system mentioned earlier, but does not include
treatment cost estimates.

GAS EXTRACTION

Introduction

     Gas extraction technology has not been used on waste piles to control
gaseous emissions, but it would be similar in construction to a landfill
leachate collection system.  Gas extraction as applied to landfills was
proposed by SCS Engineers as a feasible technology which could be operated
while a waste pile was still active.   It is not intended to control
fugitive dust emissions.

Description

     A gas extraction system consists of a network of screened pipes installed
incrementally as each layer of waste is placed into the waste pile.  The
network is attached to a negative pressure fan or blower which draws gases and
vapors from inside the waste pile and routes them to a treatment device such
as an afterburner or carbon adsorber.  In this manner, gases generated within
the waste pile are withdrawn and treated before they can be emitted to the
atmosphere.  Gas extraction can thus occur while waste is still being placed
into the pile, as well as after the pile is closed.  This technology can be
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 TABLE 8-3.  APPROXIMATE  STORAGE DOME  COSTS
Dome diameter
(feet)
50
61
72
82
100
116
Capacity
(tons)
664
1158
1780
2629
4652
6663
Approximate cost
$ 49-50,000
$ 50-53,000
$ 61-64,000
$ 70-74,000
$ 85-89,000
$103-108,000
Source:  Vogel et al.,  1983.   (Reference 8),
                    8-16

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used in combination with other control technologies such as storage domes or
synthetic membrane tension structures to minimize fugitive dust as well.

Emission Reduction Efficiency

     The collection efficiency of a gas extraction system has been estimated
at between 70 and 90 percent, based on landfill gas control efficiency
estimates.  As mentioned earlier, no particulate emission reductions will be
realized by installing a gas extraction system.
Costs
     SCS has estimated that a gas extraction system with a carbon adsorption
unit will cost about $17,000 for a 2,000-cubic foot waste pile, and about
$40,000 for a 100,000-cubic foot waste pile.^  These estimates do not
include costs associated with construction of the waste pile itself, such as
pad construction, buildings, and fences.
     Domes and membrane tension structures may be more cost-effective than gas
extraction systems because they offer control of fugitive dust as well as
gaseous emissions.

CHANGES IN OPERATIONAL PRACTICES

Introduction

     Changes in operational practices may result in significant reductions in
emissions at little or no cost.  This section will discuss the affect of
changing the way waste is added to the pile, and changing the slope,
orientation, and surface area of the pile.  These changes will not have impact
on gaseous emissions, but rather on fugitive dust emissions from waste piles.
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Description

Changes in Waste Loading—
     Reducing the fall distance of waste being dumped  from  front  end  loaders,
overhead conveyors, clamshell buckets, or other equipment used  for  the
formation and maintenance of waste piles will result in  a decrease  in fugitive
dust emissions due  to a lessening of  impact  forces.  In  some  cases, this  only
requires increased  awareness on the part of  machine operators.  In  other
cases, use of equipment such as height-adjustable  loading equipment may be
necessary.  Such equipment allows for raising or lowering of  the  point of
transfer of the waste to the pile, resulting in a  consistently  short  fall
distance.
     Other methods  for reducing dust  emissions due to  waste loading include
the use of rock or  stone ladders, telescoping chutes,  lowering  wells, and
windguards.    Rock or stone ladders  let material  fall short  distances in a
step-like manner.   By reversing the direction of travel  on successive steps,
momentum received from the previous fall, and thus the amount of  fugitive dust
generation, are reduced.
     Telescoping chutes are enclosed, extendable tubes which  carry  material
from the discharge  point to the waste pile.  This  minimizes exposure  of the
waste  to wind, and  in so doing, minimizes dust emissions.
     Lowering wells are perforated pipes projecting vertically  out  of the
waste  pile through  which waste  is added  to the pile.   Material  added  to the
pile through  the well flows out through  the  perforations, while dust  generated
due to the impact of  falling is largely  retained inside  the pipe.
     Wind guards are  placed around the discharge end of  a stacker arm,
conveyor,  telescoping chute, or other loading equipment  to minimize wind
action on dusts generated by falling  waste.  As was mentioned in  the  section
on stabilization, water or water  plus a  wetting agent  can be  sprayed  on the
material as it is being transferred to further reduce  dust emissions.

Changes  in Slope, Orientation,  or Surface Area—
     A mathematical analysis of waste pile shape has shown  that minimum
surface area  is exposed to  the  atmosphere when the angle of repose  of the pile
is 55°.   However,  studies have shown that the slope and orientation  of a
pile is more  important than surface area with regard to  control of  fugitive
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dust emissions.  Slope of the pile in the prevailing wind direction should be
less than 10 degrees, because measured up slope wind velocities accelerate
substantially for slopes greater than this.  Particulate entrainment is not
necessarily proportional to wind speed, as discussed in the section on
windscreens.  Fine particles may be entrained in significant quantities even
at low windspeeds.
     Positioning the waste pile so that its length is perpendicular, as
opposed to parallel, to the prevailing wind direction, may also reduce dust
emissions.

Emission Reduction Effectiveness

     Bohn et al. have estimated efficiencies for some of the controls
discussed above.    All efficiencies depend on the operating practices in
effect before the changes were made.
     Height adjustable equipment was estimated to achieve a 25 percent
reduction in fugitive dust emissions.  Telescoping chutes were estimated to
reduce emissions over previous conditions by 75 percent.  Stone ladders and
wind guards were estimated to achieve emission reductions of 80 percent and
50 percent, respectively.  Stabilizing the material as it was transferred was
estimated to result in a 75 percent control efficiency.
     Positioning the length of a pile perpendicular to the prevailing wind
direction can theoretically reduce dust emissions by 60 percent as compared to
                     Q
parallel positioning.
Costs
     Costs have been estimated for the above-mentioned control techniques as
they are applied to iron and steel plants.    Initial 1977 costs for the
controls are:

                        Control                   Initial cost
               Height-adjustable stacker            $150,000
               Telescopic chutes                    $ 10,500
               Stone ladders                        $ 30,000
               Wind guards                          $ 15,000
               Spray systems                        $ 90,000
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     Equipment designed for smaller operations such as those encountered at
TSDFs is expected to cost less.  Little or no cost should be associated with
changing the slope, orientation, or the adjusting fall distances through
increased awareness on the part of machine operators.
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                                   REFERENCES
1.   Carpenter, B.  H.,  and G.  E.  Weant,  III.   Particulate Control for Fugitive
     Dust.  EPA-600/7-78-071.   U.S.  Environmental Protection Agency,  Office of
     Research and Development, Washington,  D.C.   April 1978.

2.   Drehmel, D., B. Danel,  and D.  Corner.  Relative Effectiveness of
     Chemimcal Additives  and Wind Screens  for Fugitive Dust Control.
     Environmental  Progress 1(1): 16.   February 1982.

3o   Ase, P. K.,  R. Koch, and  G.  Yasmate.   Chemical  Stabilizers  for the
     Control of Fugitive  Asbestos Emissions from Open Sources.
     EPA-600/2-82-063.  U.S. Environmental  Protection Agency, Office of
     Research and Development, Cincinnati,  OH.  April 1982.

4.   Jutze, G., and K.  Axetell.  Investigation of Fugitive Dust,  Volume I:
     Sources, Emissions,  and Control.   EPA-450/3-74-036a.  U.S.  Environmental
     Protection Agency, Office of Air  Quality Planning and Standards, Research
     Triangle Park, NC.  May 1973.

5.   Rosbury, K.  D., and  S.  C. James.   Control of Fugitive Dust  Emissions at
     Hazardous Waste Cleanup Sites.  Draft  Report sent to M. Arienti, GCA
     Corporation.  March  1985.

6.   Soo, S. L.,  et al.  Wind  Velocity Distribution  Over Storage Piles and Use
     of. Barriers.  Proceedings:  Symposium on Iron and Steel Pollution
     Abatement Technology for  1980 (Philadelphia, PA, 11/18-11/20/80).
     EPA-600/9-81-017.  U.S. Environmental  Protection Agency. Office of
     Research and Development, Washington,  DC.  March 1981.

7.   Davanzo, T.   U.S.  Environmental Protection Agency, Region I, Boston, MA.
     Communication with A. Baldwin,  GCA Corporation, Bedford, MA.  March  1985.

8.   Vogel, G. A.,  and D. F. O'Sullivan.  Air Emission Control Practices  at
     Hazardous Waste Management Facilities.  MTR-83W89. Prepared for U.S.
     Environmental Protection  Agency,  Office  of Solid Waste.  Contract No.
     68-01-6092.   The MITRE Corporation, McLean, VA.  June  1983.

9.   SCS Engineers and Putnam, Hayes,  and Bartlett,  Inc.  Cost-Risk Analysis
     of Air Emissions.   Prepared for U.S.  Environmental Protection Agency,
     Office of Solid Waste.  Contract  No.  68-01-6621.  SCS Engineers,
     Covington, KY.  March 1984.
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LO.   tiaxo, H.,  et al.  Permeability of Polymeric Membrane Lining Materials.
     Proceedings:  International Conference on Geomembranes,  Denver, CO.  June
     1984.

11.   Bohn, R.,  et al.  Fugitive Emissions from Integrated Iron and Steel
     Plants.  EPA-600/2-78-050.  U.S. Environmental Protection Agency, Office
     of Air Quality Planning and Standards, Research Triangle Park, NC.
     March 1978.
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