TECHNICAL GUIDANCE FOR
       CORRECTIVE MEASURES -
           SUBSURFACE GAS
           Prepared For:
        Land"Disposal  Branch
       Office of Solid Waste
U.S. Environmental  Protection Agency
       Washington,  D.C. 2,Q460
            Prepared By:
           SCS Engineers
      11260 Roger Bacon Drive
          Reston, VA 22090
           March 28, 1985

         File No. 28286-12
               LC 89

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                              DISCLAIMER
    This report was furnished to the Environmental Protection Agency by the
SCS Corporation, Reston, VA, in fulfillment of a contract.  The opinions,
findings, and conclusions expressed are those of the authors and not
necessarily those of the Environmental Protection Agency or the cooperating
agencies.  Mention of company or product names is not to be considered as
an endorsement by the Environmental Protection Agency.

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                        TABLE OF CONTENTS
                                                       Page

SECTION 1 - INTRODUCTION	1-1'

     1.1  PURPOSE	1-1

     1.2  REGULATORY/STATUTORY REQUIREMENTS	1-2

     1.3  DEFINITION OF A RELEASE	1-4

       1.3.1  Constituents of Concern	1-4
       1.3.2  Indicator Constituents	1-9

     1.4  TYPES OF SOLID WASTE MANAGEMENT UNITS	1-16

       1.4.1  Landfills	1-22
       1.4.2  Sites Closed as Landfills	1-22
       1.4.3  Underground Tanks	1-23

SECTION 2 - GENERATION AND MIGRATION OF SUBSURFACE	2.1
            GASES

     2.1  GAS GENERATION	2-1

       2.1.1  Biological Decomposition	2-1
       2.1.2  Chemical Decomposition	2-4
       2.1.3  Physical Decomposition	2-5

     2.2  GAS MIGRATION...	2-7

       2.2.1  Natural Barriers	2-8
       2.2.2  Design Barriers	2-9

SECTION 3 - IDENTIFYING RELEASES	3-1

     3.1  APPROACH	3-1

     3.2  PRELIMINARY ASSESSMENTS	3-4

       3.2.1  Checklist Section  I	3-8
       3.2.2  Checklist Section  II	3-9
       3.2.3  Checklist Section  III	3-10
       3.2.4  Checklist Section  IV  and V	3-11
       3.2.5  Checklist Evaluation	3-12

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TABLE OF CONTENTS (Continued)

     3.3  SITE INVESTIGATIONS	3-14

        3.3.1  Monitoring or Sampling Inside	3-14
               Structures
        3.3.2  Subsurface Monitoring or Sampling	3-15
        3.3.3  Methane	3-16
        3.3.4  Other Indicator Constituents	3-19
        3.3.5  Factors Not Related to Monitoring	3-21
        3.3.6  Evaluation	3-23

SECTION 4 - REMEDIAL INVESTIGATIONS AND HEALTH	4-1
            ASSESSMENTS

     4.1  EMERGENCY SITUATIONS	4-1

        4.1.1  Criteria	4-1
        4.1.2  Identification	4-2
        4.1.3  Fast-Track Corrective Actions	4-4

     4.2  ROUTINE SITUATIONS	4-6

        4.2.1  Predictive Models	4-7
          4.2.1.1  Data Requirements	4-8
          4.2.1.2  Example Application	4-10
        4.2.2  Use of Experts	4-21

SECTION 5 - CORRECTIVE MEASURES	5-1

     5.1  MONITORING PROGRAMS	5-1

        5.1.1  Methane	5-1
          5.1.1.1  General	5-1
          5.1.1.2  Equipment	5-4
          5.1.1.3  Probe Pressure	5-4
          5.1.1.4  Methane Monitoring	5-7
          5.1.1.5  Interpretation	5-9
          5.1.1.6  Record Keeping	5-11
        5.1.2  Indicator Constituents of Concern	5-12
          5.1.2.1  General	5-12
          5.1.2.2  Equipment	5-13
          5.1.2.3  Preparation of Sample Traps	5-16
          5.1.2.4  VOC Monitoring	5-17
          5.1.2.5  Handling and Record Keeping	5-22
          5.1.2.6  Interpretation	5-22

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TABLE OF CONTENTS (Continued)

     5.2  CONTROL SYSTEMS	5-23

        5.2.1  Passive Systems	5-23
        5.2.2  Active Systems	5-26
          5.2.2.2  Perimeter Extraction Trench	5-28
          5.2.2.3  Perimeter Well Injection	5-28
          5.2.2.4  Perimeter Injection Trench	5-30
          5.2.2.5  On-Site Extraction Well	5-30
          5.2.2.6  Subslab Gravel Bed Injection	5-32
                   or Extraction


                         LIST OF FIGURES

Figure 1-1  Subsurface gas generation/migration	1-20
            in a landfill

Figure 1-2  Subsurface gas generation/migration	1-21
            from tanks and units closed as landfills

Figure 3-1  Typical  Deep Subsurface Gas Monitoring....3-18
            Wells

Figure 4-1  Example Landfill	4-11

Figure 4-2  Uncorrected Methane Migration Distance....4-13

Figure 4-3  Correction Factors for Landfill  Depth	4-15
            Below Grade

Figure 4-4  Correction Factors for Soil Surface	4-16
            Venting Condition Around Landfill

Figure 4-5  Example Landfill Methane Contours	4-19

Figure 5-1  VOC Sampling Assembly	5-14

Figure 5-2  Gas Migration Control Vents	5-25


                          LIST OF TABLES

Table 1-1  Concentration Limits To Define a Release	1-6

Table 1-2  Constituents of Concern	1-7

Table 1-3  Compound Descriptions	1-10

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TABLE OF CONTENTS (Continued)


List of Tables (Continued)

Table 1-4  Indicator Constituents of Concern	1-18

Table 3-1  Preliminary Assessment Checklist	3-5

Table 3-2  Subsurface Sampling Techniques	3-17

Table 4-1  Actions to Take in Gas Emergency	4-5
           Situations in Buildings

Table 4-2  Methane Migration Distance Tabulating	4-18
           Form

Table 5-1  Field Data Form for Subsurface Gas	5-2
           Monitoring

Table 5-2  YOC Field Data Form	5-18

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                             SECTION  1



                            INTRODUCTION
1.1  PURPOSE








This manual is intended to provide technical  guidance  for  EPA



and authorized State personnel in assessing the  needs  for



corrective action, reviewing  permit  applications,  and  writing



permits for hazardous waste facilities.   Its  primary function



is to assist in the assessment of the  potential  for  subsur-



face gas generation and migration from these  facilities.   In



addition, it provides a framework to States,  EPA,  and  facil-



ity owners or operators to identify  whether subsurface  gas is



migrating or will likely migrate beyond the facility boundary



or into on-site structures at concentrations  that  are  threats



to human health and the environment.   If  there is  known  or



probable migration of this kind, then  technically  sound  cor-



rective action will be required.







The discussion in this section addresses  current  regulatory/



statutory requirements pertaining to subsurface  gases,  the



definition of a release, and  the types of  solid  waste  manage-



ment units at which a release can occur.   Section  2  is  an



overview on factors that impact subsurface gas generation  and



migration.  Section 3 provides methods to  identify a subsur-



face gas release by the presence of  specific  hazardous  waste
                           1-1

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constituents.  This section summarizes the above  into  a



checklist for the permit writer, providing evaluation  of  the



presence or potential  for a release based on the  type  of



unit, existing site data, the potential for subsurface gas



release, existence of control  or systems, and other  factors.



The checklist assists the permit writer in identifying sites



that require actions, emergency response, Remedial



Investigation/Health Assessment, or corrective measures.



Section 4 describes criteria for emergency situations  and



related actions and describes procedures for Remedial



Investigations.  Section 5 describes approaches to corrective



measures such as monitoring, treatment, and control  systems



that could be implemented for subsurface gas releases.







1.2  REGULATORY/STATUTORY REQUIREMENTS








Releases of subsurface gases from hazardous waste  facilities



can result in threats to human health and the environment.



Potential threats include accumulations of explosive or



flammable gases, development of oxygen-deficient  atmospheres



in enclosed areas, possible acute or chronic health  effects,



and impacts on local  plant and animal  communities.   The



current regulatory/statutory requirements pertaining to these



threats are summarized below.








Concentration limits for subsurface gases released from a



solid waste management facility (applicable to all RCRA Sub-
                          1-2

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title D facilities) are established  in 40 CFR  Part



257.3-8(-a).    The levels for explosive  gas  concentrations



are not to exceed:



     1.  The lower explosive limit;  i.e., 5  percent methane,



         at the property boundary, and







     2.  25 percent of the lower  explosive limit,  i.e.,  1.25



         percent methane, in facility structures.







These limits were designed to address methane  generation  and



migration from landfills and open dumps  and  do not apply  to



hazardous waste (Subtitle C) or deep well injection



facilities subject to regulation  under 40 CFR  Part 146 under



the Safe Drinking Water Act.







Hazardous waste facilities must minimize subsurface gas



releases and are required, under  40 CFR  Part 264.31,  to:







     "be designed, constructed, maintained,  and operated  to



     minimize the possibility of  a fire, explosion, or any



    ,unplanned sudden or non-sudden  releases of hazardous



     waste or hazardous waste constituents to  air, soil,  or



     surface water which could threaten  human  health  or  the



     environment."







The 1984 Amendments to RCRA prov-ide  additional authority  for



corrective action at facilities for which'permits  are being
                          1-3

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sought and for facilities with interim  status  under  Section



3005(e).  The amendments address:  (1) continuing  releases  at



permitted facilities; (2) corrective  action  beyond  facility



boundaries; (3) financial responsibility  for corrective



action; and (4) interim  status corrective  action  orders.








EPA is to require corrective action in  response to a  release



of hazardous waste from  any solid  waste management unit



(SWMU) to the environment regardless  of when the  waste was



managed.  Its authority  encompasses releases to all  media,



e.g. air, surface water, and ground water, and specifically



includes releases to the unsaturated  soil  zone.   This applies



to all SWMU's, including former or existing  nonregulated



units, existing regulated units, and  new  units.   While the



regulatory requirements  cover all  SWMU's,  this document will



focus exclusively on those units exhibiting  a  potential for



subsurface gas releases  that are a threat  to human health  and



environment.








1.3  DEFINITION OF A RELEASE








1.3.1 Constituents _ojf_ Conc er_n








A subsurface gas release from a SWMU  is defined as having



occurred when the concentration of a  "constituent of concern"



exceeds a specified level when measured in the unsaturated



soil at the property boundary or within any  structure on  the
                          1-4

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hazardous waste facility.  In the context of this document, a



constituent of concern is (1) methane or (2) a compound,



specified in 40 CFR Part 261 or in Appendix VIII, with a



vapor pressure at 20°C that exceeds 0.1 mm Hg.








The components of a subsurface gas release will vary in



concentration depending on the relative amounts of



constituents volatilized by biological decomposition,



chemical reactions, and physical  degradation.  By far, the



predominant subsurface gas of concern from landfill  SWMU's is



methane.  Methane is included in the grouping of constituents



of concern due to its volatility, explosive properties, and



frequency of detection in subsurface gases.  The methane



concentration limits specified to identify a subsurface gas



release are those limits defined for explosive gases in 40



CFR Part 257.








The other constituents of concern (besides methane)  are



specified as toxic, corrosive, ignitable, or reactive in 40



CFR Part 261 or in Appendix VIII and are commonly termed



volatile hazardous waste compounds because of their



relatively high vapor pressures. A worker exposure level



established by OSHA for each of these hazardous compounds



will  serve as the concentration limit to define a subsurface



release.  In summary, the concentration limits for



identifying releases are shown in Table 1-1.  Table 1-2



presents a specific listing of the constituents of concern by
                            1-5

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       TABLE 1-1.  CONCENTRATION LIMITS TO DEFINE A RELEASE
     Constituent
     _0f_ _C o n c e r n

     Methane
     Methane
     Compounds for
     which an exposure
     level has been
     established,
     recommended or
     adopted.

     Other compounds.
   Concentration Limit
(equalto or greater than)
      5% i n ai r
      1.25% in air
      PEL or alternative
      concentration*
      To be established
Applicable
 Location__

Soil at facili
ty property
boundary

Within any
structure on
the facility

Soil at facili
ty property
boundary or
within any
structure on
the facility.

Same as above
     * A PEL is the Permissible Exposure Limit as established by
OSHA, in 29 CFR 1910.1 and is the 8-hour, work-shift,
time-weighted average (TWA) level.  For other constituents of
concern for which a PEL has not been established by OSHA, the
NIOSH recommended level  is to be used.  NIOSH recommended levels
may be found in NIOSH Publication No. 78-210, September 1978.   If
no NIOSH recommended level is published, the current Threshold
Limit Value - Time Weighted Average (TLV-TWA) adopted by the
American Conference of Governmental Industrial Hygienists (ACGIH)
is to be used.
                               1-6

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TABLE 1-2.  CONSTITUENTS OF CONCERN



Compound Name
Maleic anhydride
2-Methy laz lr id ine
Methyl bromide
Methy 1 ch 1 or ide
Methane
Methyl ethyl ketone
Methylene chloride
Methyl cydrazine
Methyl isocyanate
Naphtnc . t, n e
N icxe i cc.r oony 1
Nitric ox i de
Nitrogen dioxide
Phenol
Phosgene
Phosph ine
Pyr id i ne
T etrachl or o benzene
1,1,2,2-Tetrachl oroethane
1 , 1, 1,2-Tetrachloroe thane
Tetrachloroethylene
Tetraethyl lead
To 1 uene
Tr i bromome thane
Tr ichlorobenzene
1,1,1-Trichloroe thane
1, 1,2-Trichloroe thane
Tr ich loroethy lene (TCE)
1 ,2,3-Tr ichloropropane
Vinyl ch lor ' de
N/E - Not Established
N/A - Not Ava i 1 able



Synonym
2, 5-Furaned lone
Propylene amine
Bromomethane
Ch loromethane
--
2-Butanone
D ich 1 oromethane
—
--
Wh >te tar
—
Nitrogen monoxide
--
Car bo lie ac id
--
Hydrogen phosph ide
--
--
Acetylene tetrach 1 or ide
--
Perch loroethy lene
--
Methy 1 benzene
Br omof orm
--
Methyl chloroform
Vinyl trichloride
Ethylene trichloride
Al ly 1 tr ichlor ide
Ch loroethy lene


Chemical
Abstract
System
Number
108-31-6
75-55-8
74-83-9
74-87-3
74-82-8
78-93-3
75-09-2
60-34-4
624-83-9
9 1-20-3
13463-39-3
10102-43-9
10102-40-0
108-95-2
75-44-5
7803-51-2
1 10-86-1
12408-10-5
79-34-5
630-20-6
127-18-4
78-00-2
108-88-3
75-25-2
12002-48-1
71-55-6
79-00-5
79-01-6
96-18-4
75-01-4


EPA
Hazardous
Waste
Number
U147
U194
U029
U045
None
U159
U080
P068
P064
UI65
U073
P076
P078
U188
P095
P096
UI96
U207
U209
U208
U2IO
PI 10
U220
U225
N/A
U226
U227
U228
N/A
U043




PEL
(ppm)
0.25
2
5
100
N/E
200
500
0.2
0.02
10
0,001
25
5
5
0.1
0.3
5
N/E
5
N/t
100
5
200
0.5
N/E
350
10
100
50
1



Vapor Pressure
(mm HG)
f 20 degrees C
0.2
N/A
> 760
> 760
> 760
70
354
36
346
< 1
321
> 760
720
0.4
> 760
3 760
18
< 1
8
8
10
0.2
22
5
< 1
100
18.8
58
3
> 760



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    TABLE  1-2  (Continued)
 i
00
Compound Name
Aceta 1 dehy de
Acetone
Aceton i tr i 1 e
Aero 1 e 1 n
Aery 1 on i tr H e
Al ly 1 alcohol
Ally! chlor ide
Benzene
Benz 1 eh lor ide
B i s (ch loromethy 1 ) ether
Carbon d Isu 1 f Ide
Carbon tetr ach 1 or i de
Chloroacetaldehyde
Ch 1 or obenzene
2-Chloro ethyl vinyl ether
Ch loroform
1,2- 0 i br omoethane
D i bromomethane
,2-Dichloro benzene
, 3-D ich lor obenzene
, 4-D Ich loro benzene
1 Ich lorod i f 1 uoromethane
, t -0 Ich loroethane
,2-0 ich lor oe thane
, 1-D Ich loroethy 1 ene
,2-Dlchloroethylene
,2-Dichloropropane
,1- D imethy 1 hydraz ine
Dimethyl sulfate
2,4- Din itrotol uene
Epichlorohydr in
Ethy lene Im i ne
Ethylene Oxide
F 1 uorene
Forma 1 dehyde
Hydraz ine
Hydrocyanic acid
Hexach 1 or oe thane
Hydrogen su 1 f ide
1 odomethane
Isobutyl alcohol
Synonym
Acet ic a 1 dehyde
2-Propanone
Cyanomethane
Aery lie a 1 dehyde
Propenon Itr 1 le
2-Pr opano 1
3-Chloropropene
Benso 1
Alpha-chlorotoluene
Syn-dlchlorodlmethylether
Carbon b 1 su 1 f 1 de
Tetr ach 1 or ome thane
2-Chloroethanol
Pheny 1 ch 1 or Ide
--
Tr ich 1 or ome thane
Ethylene dlbromide
Methylene bromide
o-D Ich lor obenzene
m-D Ich loro benzene
p-Dich loro benzene
Freon 12
Ethylfdene dlchlorlde
Ethylene dlchlorlde
Vinyl idene chloride
Acetylene chloride
Propylene dlchlorlde
--
Methy 1 su 1 fate
--
l-Chloro-2,3-epoxypropane
Az ir id 1 ne
1,2- Epoxy ethane
--
Methylene oxide
D lami ne
Hydrogen cyanide
Perch! or oe thane
Hydroso 1 f ur Ic acid
Methyl Iodide
1 sobutanol
Chemi ca 1
Abstract »
System
Number
75-07-0
67-64-1
75-05-8
107-02-8
107-13-1
107-18-6
107-05-1
71-43-2
100-44-7
542-88-1
75-15-0
56-23-5
107-20-0
108-90-7
1 10-75-8
67-66-3
106-93-4
75-09^-2
95-50-1
25321-22-6
106-46-7
75-71-8
75-34-3
107-06-02
75-35-4
540-59-0
78-57-5
540-73-8
77-78-1
121-14-2
106-89-8
151-56-4
75-21-8
86-73-7
50-00-0
302-01-2
74-90-8
67-75-1
7783-06-4
74-88-4
78-83-1
EPA
Hazardous
Waste
Number
UOOI
U002
U003
P003
U009
P005
N/A
UOI9
P028
P016
P022
U211
P023
U037
U042
U044
U067
U068
U070
U071
U072
U075
U076
U077
U078
U079
U083
U098
UI03
UI05
U04 1
U054
U1 15
P056
UI22
U133
P063
U131
U135
U138
UNO
PEL
(ppm)
200
1000
40
O.I
2
2
50
1
1
N/E
20
10
1
75
50
10
20
N/E
50
N/E
75
1000
100
10
5
200
75
0.5
1
185
2
0.5
50
0.1
3
1
10
1
10
5
50
Vapor Pressure
(mm HG>
» 20 degrees C
750
266
73
214
83
17
295
80
0.9
N/A
300
91
100
9
N/A
160
1 1
25
1
2.5
0.4
> 760
182
62
N/A
220
4 1
103
0.5
1
13
N/A
> 760
760
1
10
620
0.2
> 760
375
9

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compound name, synonym, EPA  Hazardous  Waste  number,  Chemical



Abstract System (CAS) number, OSHA  Permissible  Exposure Limit



(PEL), and vapor pressure.   Table  1-3  provides  further



information about constituents of  concern.   It  includes



general descriptions of waste types that  likely  contain



specific constituents of concern.







1.3.2  Indicator Constituents



The presence of individual constituents of concern in



subsurface gases is often site-specific and  dependent on



factors discussed in the next section.    Although  variations



in subsurface gas composition have  been observed from



different sites and different locations on the  same  site,



some compounds .are detected more frequently  than others.



Many of the compounds in Table 1-2  have not  been reported  in



samples from subsurface gas monitoring, are  not  stored,



treated, or disposed of in significant quantities  at



subsurface SWMU's, or are not likely to migrate  and  exceed



PEL's due to physical or chemical  properties.  Thus



monitoring for each of the constituents of concern will  not



be required to determine if a release  has occurred.   Instead,



a screening procedure may be used  to monitor  for those



compounds that the facility owner/operator or permit writer



expects are migrating from the SWMU and pose a threat to



human health and the environment.
                                  1-9

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                                              TABLE  1-3.  GENERIC  COMPOUND DESCRIPTIONS
    Compound Name
   Synonym
   EPA
Hazardous
  Haste
  Number
                    DescrIptIon
 i
H-1
O
    AcetaIdehyde
    Acetone
    AcetonItrI Ie
    Aero IeIn
    Aery Ion ItrI Ie
    A My I  alcohol
    Ally)  chlor Ide
    Benzene
   Benzy I  chI orIde
   Bls(chloromethyI ) ether
   Carbon  dIsuIf Ide
Acet Ic a I deliyde
                                  2-propanone
Cyanomethane
Aery lie a Idehyde
PropenonItrIle
2-propenol
3-Chloropropene
                                   l-chlorotoluene
D IchlorodImethyI  ether
                                  Carbon bIsuIfIde
   UOOI



   U002



   U003



   P003




   U009



   P005



   N/A



   UOI9




   P028




   POI6


   P022
Distillation bottoms and by products  from  production
of acetaldhyde from ethylene; chemical  family  Is
a I dehyde.

Spent non-haIopenated solvents; spent cleaning or splnnln
solvent; spent paint, laquor, or varnish remover; chemlca
fami Iy  Is ketone.

By-products from the hydrocarbon extraction of butadiene;
by-products from the production of certain vegetable oils;
chemical family  Is nitrites.

By-products from the manufacture and waste treatment of
various pharmaceutlea Is, herbicides, and polymers, expeclal'
polyurethane and polyester resins.  Chemical family  Is
a Idehyde .

By-products from the manufacture and waste treatment of
acrylic polymers and various semI conduct I ve polymers.
Chemical famllly Is nltrlle.

By-products from the manufacture and treatment of pharma-
ceutlcals,  herbicides,  pIast Ic I zers, and glycerol.
Chemical family  Is ester.

By-products from the manufacture and treatment of
epIchlorohydrIn; certain synthetic Pharmaceuticals, and
adheslves.   Chemical family Is halogenated hydrocarbon.

Chemical by-products from manufacture and waste treatment
of the  following chemical  Intermediates:  ethyI benzene,
dodecyclobenzene, and nitrobenzene.  Chemical  family
 Is aromatic hydrocarbons.

By-products from the manufacture and waste treatment of
photographic chemicals, quarternay (ammonium)  agents, perfum
and Pharmaceuticals.  Chemical famllly  Is  halogenated aromat
hydrocarbons.
Spent  Ion-exchange resins and  laboratory  reagents.
f am My  Is ether .
                                                                                                                                 Chemleal
                                          Manufacturing by-products and/or  sludge  from  the  treatment
                                          of vlscone rayon, cellophane,  and  veterinary  medicines.
                                          Chemical family  Is sulflde.

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 Compound Name
    Synonym
   EPA
Hazardous
  Haste
  Number
                      Oescr I pt Ion
Carbon tetrachI orIde
Chloroacetaldehyde
ChIorobenzene
2-chloro ethyl  vinyl  ether
Ch1 or oform
 1-2  DIbromomethane
DIbromomethane
 I,2-dlchlorobenzene
I,3-d Ichlorobenzene
DIchlorodIfIuoromethane
 I ,I-dIchloroethane
I,2-dichloroethane
 j l-dIchloroethylene
                               TetrachIoromevhane
2-chloroethanol
                               PhenyI  chlor Ide
Tr1chIoromethane
Ethylene dlbromlde
Methylene dlbromlde
o-d IchIorobenzene
m-dIchIorobenzene
                               Freon 12
EthylIdene chloride
Ethylene dlchlorlde
Vinyl Idene chloride
  U2I I



  P023


  U037



  U042


  U044




  U067


  U068


  U070



  U07I


  U075


  U076


  U077
                                          Spent refrigerant and metal degreaslng  solvents.   By-produi
                                          from the manufacture and waste  treatment  of  various  semi-
                                          conductors.  Chemlca! family  Is  halogenated  hydrocarbon.
Various spent fungicides.
products of acetaldehyde.
                           Possible distillation  by-
                           Chemical family  Is  aldehyde.
                                          Possible distillation by-products of  phenol,  chloronltro
                                          benzene, and aniline.  Spent pesticide  Intermediates.
                                          Chemical family  Is halogenated aromatic  hydrocarbons.
                                          Spent organic laboratory reagents,
                                          I s ether.
                                    ChemlcaI fami Iy
Various spent refrigerants and propellants.  By-products
from the manufacture of  Insecticides  and fluorocarbon plastic
Spent analytical laboratory reagents.  Chemical family  Is
halogenated hydrocarbon.
                             ChemlcaI  fami Iy  Is
                             ChemlcaI  fami Iy Is
                                                             U078
Spent organic Intermediate.
halogenated hydrocarbons.

Spent organic Intermediate.
halogenated hydrocarbons.

Spent organic solvent, by-product from the manufacture
of various dyes. Insecticides, and metal polishes.
Chemical famllly Is halogenated aromatic hydrocarbons.

By-products from the manufacture of  Insecticides.  Chemical
family  Is halogenated aromatic hydrocarbons.

Spent refrigerant.  Chemical family  Is halogentaed
hydrocarbon.

Spent organic solvent.  Chemical family  Is
halogenated hydrocarbon.

Spent organic solvent.  By-product from manufacture of

vinyl chloride,  soaps, chelatlng agents, degreasers,  end
anti-knock gasoline.  Chemical family  is halogenated
hydrocar bon.

Spent organic solvents.  By-product  from the manufacture of
perfumes, lacquers, and thermoplastics.  Chemical  family
Is halogenated hydrocarbon.

-------
    Compound  Name
    Synonym
   EPA
Hazardous
  Waste
  Number
                      Descr f pf Ion
    I,2-dIchloroethylene
    I,2-d Ichloropropane
    1,1-dimethyl  hydrazlne
    Dimethyl  sulfate
    2,4-Dlnitrotoluene
    Ep ichIorohydr i n
^_,  Ethytene (mine
INJ
    Ethy lene ox ide
    FIuor ine
    Forma Idehyde
   Hexachloroethane
   Hydraz i ne
   Hydrocyan ic  ac id
 Acetylene  chloride
 Propylene  dlchlorlde
Methyl sulfate
Az (r Idene
 1,2-epoxy ethane
MethyIene oxIde



Perchloroethane


D i am Ine



Hydrogen cyanide
  U079



  U083




  U098


  UI03


  UI05
 I -chIoro-2,3-epoxy propane    U04I
  P054



  Ul 15



  P056


  UI22



  U031


  UI33



  P063
 Spent  organic  solvent.   By-product from the manufacture o
 perfumes,  lacquers,  and  thermoplastics.  Chemical  family
 Is  halogenated hydrocarbons.

 Spent  organic  solvent.   Gasoline component.  By-products
 the  manufacture  of  carbon  tetrachI or Ide,  and various gums
 waxes,  and  resins.  Chemical  family Is halogenated  hydroca


By-products from the manufacture  of  various  Jet and
rocker r els.  Chem?C3l  family  is  amine.

By-product of the manufacture for  various amine and  pheno
based compounds.  Chemical  family  is allkyl  sulfate.

By-products of  the manufacture of  varlouls dyes and
explosives.  Chemical family is aromatic hydrocarbon.

By-products of  the manufacture of  various epoxy and
phenoxy resins.  Chemical family  Is epoxlde.

By-products of  the manufacturing  In the following
 Industries:  Pharmaceuticals,  Ion exchange and protective
coatings,  end surfactants.   Chemical family  Is imfnes.

By-products from the manufacture of several  glycols,
surfactants and rocket propellent.  Chemical family  is
ox (rane.

By-product from the manufacture of rocket fuels and
various fIuorocarbons.  Chemical family Is halogen.

Spent  laboratory reagents.   By-products from manufacture of
fertilizers, dyes, embalming fluids, disinfectants,  and
germicides.  Chemical family is aldehyde.

Spent solvent and organic laboratory reagent.  Chemical
family  Is halogenated hydrocarbon.

By-products from the manufacture of agricultural chemicals,
rocket fuels, and metal  plating solutions.   Chemical
fam fIy  Is amine.

By-products from the manufacture  of acrylates, cyanide  salts
dyes, end chelating agents.  Chemical  family  Is nltrile.

-------
Compound  Name
Hydrogen sulf ide



Iodomethane



IsobutyI a IcohoI


Male !c  anhydr ide


2-methylaz ir id ine


 MethyI  bromIde


 Methy.  oh!or irfe



 Methane

 Methyl  ethyl  ketone


 Methylene chloride


 Methyl  hydrazine
    Synonym
Hydrosul f ur Ic acid
Methyl  Iodide
 I sobutanol
2,5-Furanedione
Propylene am Ine
 Bromomethane
 OH : - •GiV)F-Th;rne
  2-butanone
 Dlchloromethane
   EPA
Hazardous
  Haste
  Number
                    DescrIpt Ion
  UI35        Spent laboratory reagent. "By-product from the manufacture
              of elemental  sulfur,  sulfurlc acid, and hydrochloric acid.
              Chemical  family Is sulfide.

  UI38        Spent organic laboratory reagent.  By-products from
              manufacture of various medicines.  Chemical family  Is
              hydroqenated  hydrocarbon.

  UNO        Spent organic laboratory reagent.  Spent paint solvent.
              Chemical  family is alcohol.

  (Jl 4 7        By-products from the  manufacture of polyester and alkyd
              resins,  pesticides,  and paper.  Chemical family  is furan.

  UI94        Spent organic laboratory reagent.  Chemical family
              Is am Ine.

   U029        Spent organic laboratory reagent.  By-product from the
               manufacture of various agricultural disinfectants.

   U045        Spoilt organic solvent.  By-product from the manufacture
               of herbicides and gasoline additives.  Chemical  family
                is halogenated hydrocarbon.

   None        Natural  gas.  Chemical family  Is hydrocarbon.

   UI59        Spent solvent.  Spent organic  laboratory  reagent. Spent
               paint and wax remover.  Chemical family  is ketone.

   U080        Spent solvent.  Spent depreaser.  Spent paint remover.
               Chemical  family  Is haloqenated hydrocarbon.

   P068        Spent solvent.  Spent or contaminated rocket  fuel.
               Chemical  family  is amlne.
 Methyl  isocyanate

 Naphtha Iene



 N icke I car bony I
 Wh Ite  tar
   P064

   UI65



   P073
Spent chemical  Intermediate.  Chemical family  Is nltrile.

Spent solvent.   By-product from the manufacture of
lubricants, fungicides, and explosives.  Chemical
family Is aromatic hydrocarbon.

By-product from the manufacture of various nickel coating
Chemical  family Is carbonyl compound.

-------
Compound Name
                                  Synonym
   EPA
Hazardous
  Haste
  Number
DescrIptIon
                               Carbolie  acId
 Nitric oxide                  Nitrogen monoxide

 Nitrogen  dioxide


 Phenol




 Phosgene



 Phosph ine


 Pyr Id Ine



 Tetrachlorobenzene



 I, I,2,2-tetrachloroethane     Acetylene tetrachI orIde


I„I,I,2-tst-  ;!->.loroethan?
                                Hydrogen  Phosphide
Tetrachloroethylene
Tetraethyl  lead
To I uene
Tr I bromomethane
                              Perchloroethylene
                              Methyl benzene
                               Bromoform
   P076        Spent chemical  Intermediate.  Chemical  family  Is  oxide.

   P078        By-products from the manufacture  of  nitric  acid.
               Chemical family  Is oxide.

   UI88        Spent organic  laboratory reagent.  By-product  from  the
               manufacture of  various dyes, pharmaceut IcoIs,  and
               phenol-based compounds.  Spent  solvent.   Chemical  family
               I s phenol.

   P095        Spent organic  solvent.  By-product from  the manufacture
               of various  Isocyanates, carbonates,  chIoroformaIes,
               pesticides, and herbicides.  Chemical  family  Is  ketone.

   P096        Spent organic  Intermediate.  Spent doping agent  for  solid
               state electronic components.  Chemical family  Is  phosphide.

   UI96        Spent solvent.  By-product  from manufacture of  various
               vitamins, drugs, dyes, and  fungicides.   Chemical  family
               is am Ine.

   U207        Spent solvents.  Found in dielectric  fluids  and  electrical
               Insulation.  Chemical family Is halogenated  aromatic
               hydrocarbon.

   U209        Spent solvent.  Spent degreaser.  Spent  organic  laboratory
               reagent.  By-product In manufacture of various  Insecticides

   11208         Spent  solvent.   Spent degreaser.   Spent  organic laboratory
               reageni.  By-product  in manufacture of various  insect icioes
               and photographic tf i I ms „  Chemical  family  is halogenated
               hydrocarbon.

   U210         Spent  dry cleaning  solvent.   Spent degreaser.  By-product  of
               manufacture of  fIuorocarbons.   Chemical  family is
               halogenated  hydrocarbon.

   PI 10         Used  as  a  fuel  additive.  Chemical  family is metal
               substituted  hydrocarbon.

   U220         Spent  solvent.   Fuel  additive.   By-products from manufacture
               of  resins,  coatings,  dyes,  and  explosives.  Chemical family
               is  aromatic  hydrocarbon.

   U225         Spent  solvent.   Organic  Intermediate.  Chemical family
               Is  halogenated  hydrocarbon.

-------
 TADLE  1-3  (Continued)
Compound Name
   Synonym
   EPA
Hazardous
  Waste
  Number
                     DescrIptIon
 Tr ichIorobenzene
 I,I,I-trichI oroethane
 I,1,2-trichloroethane
 TrIchloroethylene
 1,2,3 TrIchloropropane
 Vinyl chI or ide
Methyl chloroform
Vinyl chloride
Ethylene trichloride
At lyI  trIchlor Ide
Chloroethylene
   N/A



   U226


   U227


   U228



   N/A


   U043
                                                                         Spent solvent.  By-products  from manufacture of  dyes,
                                                                         dielectric fluids, lubricants, and  Insecticides.  Chemica
                                                                         family  is halotjenated aromatic hydrocarbon.
Spent solvent.  Spent metal degreaser.
Is halogenated hydrocarbon.
      ChemicaI  family
Spent solvent.  Spent organic laboratory reagent.
Chemical family is halogenated hydrocarbon.

Spent solvent.  Spent refrigerant.  Spent decreaser.  Spent
chemical Intermediate.  Chemical family  is halogenated
hydrocarbon.
Spent solvent.  Spent degreaser.
genated hydrocarbon.
Chemical family Is halo-
By-product from the manufacture of polyvinyl chloride
end related polymers.  Chemical family  is halogenated
hydrocarbons.
 By  products are defined as those compound(s), reacted  or unreacted,
 found  present in a non-product stream exiting the manufacturing process.
 N/A  :  Not  Available

-------
A group of 16 indicator constituents of concern  has  been



selected and is shown in Table 1-4.  Monitoring  for  these  16



constituents may be used as a screening approach  to  the



identification of a subsurface gas release.  Table 1-4



includes methane, a compound without an OSHA PEL, and the



other compounds that are primarily chlorinated hydrocarbons



with PEL's in the range of 1 to 1,000 parts per million



(ppm).  These constituents were selected as indicators due to



their presence in past subsurface gas releases from  hazardous



waste landfills that had received a wide variety  of  wastes.







Other compounds could be added to the indicator list



depending on the type of SWMU, available site-specific data



on construction, operations, monitoring, and spills, and



inspections performed at the site.  For example,  if  an



underground storage tank contains acetaldehyde, it could be



added to the indicator list for this specific SWMU.  To be



added to the indicator list, the compound should  (1) be a



constituent of concern (listed on Table 1-2); (2) be expected



to migrate beyond the facility boundary or into on-site



structures at concentrations exceeding the specified levels;



and (3) pose a threat to human health and the environment.







1.4  TYPES OF SOLID WASTE MANAGEMENT UNITS







This document addresses SWMU's (1) at which only  solid waste



is or was managed, and that are located at treatment, stor-
                                 1-16

-------
                                      TABLE  1-4.   INDICATOR  CONSTITUENTS OF CONCERN

Compound (Molecular Weight)
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
Benzene (78)
Chloroform (119)
Dichlorodifluromethane (121)
1,1-Dichloroethane (99)
1,2-Dichloroethane (99)
1,1-Dichloroethylene (97)
1,2-Dichloroethylene (97)
Dichloromethane (85)
Methane (16)
1,1,2,2-Tetrachloroethane (168)
Tetrachloroethylene (166)
Toluene (92)
1,1,1-Trichloroethane (133)
1,1,2-Trichloroethane (133)
Trichloroethylene
Vinyl Chloride (62)
RCRA
Synonym Appendix VIII
—
Trichloromethane
Freon 12
Ethyl idene Chloride
Ethylene Dichloride
Vinylidene Chloride
—
Methyl ene Chloride
—
—
Perchl oroethyl ene
Methyl Benzene
Methyl Chloroform
Vinyl Trichloride
TCE
Chloroethylene
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
Vapor Pressure
(mm Hg at 20°C)
75
160
>760
182
62
490
220
350
>760
8
14
22
100
19
58
>760
PEL
(ppm)
1
50
1,000
100
10
5
200
500
*
5
100
200
350
10
100
1

* No PEL established.  Levels for methane are not to exceed 5 percent at the property boundary or 1.25 percent
  in facility structures.

-------
age, or disposal facilities seeking  a RCRA  Permit;  and  (2)



that exhibit a potential for subsurface  gas migration of



methane or hazardous constituents at concentrations  that  pose



a threat to human health or the environment.   The  applicable



types of SWMU's are principally underground and  are  discuss-



ed below.







Underground units, (those designed for storage,  treatment,  or



disposal of waste below grade and not open  to  the  atmosphere)



are the only units that have significant  potential  for  sub-



surface gas releases.   Gases generated in these  units may



migrate upwards or horizontally and  can  attain concentrations



of concern to human health and the environment.  For example,



the methane in landfill gas can be explosive and is  known  to



migrate through soils  and along confining barriers  such as



ground-water tables, clay layers, synthetic liners,  and com-



pacted covers.  Since  gases in these units  are generated well



below the surface, horizontal migration  prior  to surface



venting is possible.







Some SWMU's are essentially surface  operations that  extend



below grade into shallow soils.  Although gases  may  be  gen-



erated in these units  and migrate into the  unsaturated  soil



zone, the potential for horizontal migration is  low  and a  re-



lease is unlikely.  Shallow subsurface gases will  escape  into



the atmosphere as surface emissions  unless  prevented by barr-



iers; e.g., paving, campaction, or installation  of  covers  for
                                1-18

-------
closure.  If gases are prevented  from  venting  to  the  atmos-



phere, lateral  migration may occur.  Generally, this  lateral



migration is limited to the extent  of  the  barrier.  There-



fore, while pathways do exist  for subsurface  gas  releases



beyond a property boundary, the potential  for  releases  from



shallow SWMU's is usually  insignificant.







Although depth (underground versus  shallow) is  one  of  several



considerations for determining release  potential, the  type of



SWMU establishes potential migration pathways  and the  waste



characteristics create the driving  forces  for  subsurface



gas movement.  Figures 1-1 and 1-2  illustrate  some  potential



path- ways from a few example  SWMU's.   It  should  be noted



that for most SWMU's, it is unlikely that  a release would



ever occur because gases generated  in  the  units would  be  more



likely to vent to the atmosphere  than  to concentrate  in the



unsaturated soil.  Therefore,  the types of SWMU's of  concern



for subsurface gas releases are listed  below.







     0  Landfills







     •  Sites closed as landfills







     •  Underground tanks
                                1-1:

-------
ro
o
IB UNSATURATED

      SOIL
                           Figure 1-1.  Subsurface gas generation/migration in a landfill.

-------
                           UNDERGROUND TANK
                                                PAVING
id
                              VAPOR
                          VOLATILE
                          HAZARDOUS
                          LIQUIDS
                          SURFACE  IMPOUNDMENT CLOSED AS LANDFILL
                               HAZARDOUS
                                 LIQUIDS/SLUDGES
                  UNSATURATED
                       SOIL
Figure 1-2.   Subsurface gas generation/migration  from tanks and units closed as landfills

-------
1.4.1  Landfills







Landfills are the most likely  SWMIJ's to  generate  subsurface



gases resulting in a release.  The  underground  deposition  of



decomposable solid waste with  or without  hazardous  constitu-



ents provides a large source of gas and  a driving force  that



can carry other gases venting  to the atmosphere and/or migra-



ting horizontally as a subsurface gas.   The closure of land-



fills with impermeable caps is one  means  of retarding these



landfill gases from escaping as surface  emissions.  In these



instances, a large percentage  of those gases migrate  later-



ally, possibly causing significant  accumulations  in facility



structures or at property boundaries.







1.4.2  Sites Closed As Landfills







Inactive SWMU's that have been closed as  landfills may gen-



erate subsurface gases.  These sites include closed surface



impoundments or waste piles containing decomposable or vola-



tile wastes with in-place impermeable covers.   Similar to



landfills, gases generated in  sites closed as  landfills  may



migrate laterally, possibly causing significant accumula-



tions.  However, closed surface impoundments and  waste piles



generally contain small quantities  of decomposable  and vola-



tile wastes and are at shallow depths.   Thus,  significant  gas



migration and subsequent subsurface gas  releases  are  unlike-




ly.
                           1-22

-------
1.4.3  Unjj_e_rg_rpunid Tanks







Underground tanks will  not  normally  generate  subsurface



gases.  Only if the tank  is  leaking  is  there  an  opportunity



for a gas to migrate  into the  unsaturated  zone.   Since vola-



tile liquids are often  stored  in  underground  tanks,  the



potential for a subsurface  gas  release  exists.   However,



anticipated gas leaks under  these  conditions  would  be  small



and probably insignificant.







In summary, landfills,  sites closed  as  landfills,  and  under-



ground tanks are the  only SWMU's with characteristics  condu-



cive to subsurface gas  migration  problems.  That  is, the



depth of waste deposition or storage  is  adequate  to  allow



subsurface gas migration  and a  source of subsurface  gas is



present (generated by decomposition  of  organic wastes  or



volatilization).







Other types of SWMU's,  such  as  land  treatment  units, active



surface impoundments, and injection  wells,  do  not  exhibit  a



potential for gas migration  and are  not  applicable  to  sub-



surface gas releases.   For  instance,  in  land  treatment  units



the production of methane gas  is  absent  and wastes  are in-



corporated into the soil  surface to  allow  free venting of  any



generated gases to the  atmosphere.   Where  gases  are  generated



within an active surface  impoundment, they  likely  will  vent
                           1-23

-------
across the liquid surface to the atmosphere rather than migrate



through impoundment walls.  While it is possible that gases could



be generated from leaking leachate or volatile liquids  from the



unit, significant subsurface gas migration and accumulation are



unl ikely.
                                     1-24

-------
                            SECTION 2



           GENERATION AND MIGRATION OF SUBSURFACE GASES








The generation and migration of subsurface  gases are  two  distinct



processes that contribute to the potential  for a release  from  an



SWMU.  While gas generation centers primarily on waste types,  and



the type of SWMU, gas migration concerns pathways and barriers  for



movement through the surrounding soils.  This section reviews



factors that influence and promote subsurface gas generation and



migration of those SWMU's where releases may occur.







2.1  GAS GENERATION







2.1.IB i o1og i c a1 Decpmpos i t i o n







Gas generation and accumulation in SWMU's occurs by biological,



chemical, and physical decomposition of the disposed  or stored



wastes.  The type of SWMU relates to the extent of biological



decomposition and subsequent gas generation from a given  waste.



For instance, biological decomposition is significant in  most



landfills and sites closed as landfills due to anaerobic  microbial



degradation of organic wastes.  However, biological decomposition



is not a gas generating process in underground tanks  where



volatile liquids are stored.







Waste types will  significantly influence the rate of  gas



generation via biological decomposition and the ultimate  amount of
                               2-1

-------
gas produced at an SWMU.  Generally, the amount of  gas  generated



in a landfill is directly proportional to the  amount  of  organic



matter present.  In a landfill, the types of organic  wastes  can  be



divided into rapid and slow decomposables.  A  high  percentage of



rapid decomposables (such as food waste, sewage sludges, and



garden waste) will  result in gas generation shortly after burial



and high initial yields.  Slow decomposables include  paper,



cardboard, wood, leather, some textiles, and several  other



organic components.  Inorganics and inerts such as  plastics,



man-made textiles, glass, ceramics, metals, ash, and  rock do not



contribute to biological gas production.  At sites  closed as



landfills, waste types that undergo biological decomposition might



include bulk organic wastes, food processing sludges, treatment



plant sludges, and composting wastes.







In addition to waste type, how the wastes are  managed (stored,



treated, or disposed) and the specific waste characteristics will



both impact rates of gas generation from SWMU's.  Other  factors



important to biological  production include:



     •  waste characteristics,



     •  unit design,



     •  unit operations.







Waste characteristics can enhance or inhibit the rate of microbial



activity.  For instance, high moisture content (in  the as-receiv-



ed waste or through percolation, or both) will provide optimal



conditions to enhance anaerobic decomposition.  Other enhancement
                               2-2

-------
characteristics include adequate buffer capacity  and  neutral  pH,



sufficient nutrients (nitrogen and phosphorous),  and  mesophilic



temperatures.  Inhibiting characteristics include the  presence of



high or low pH, sulfur, and soluble metals, perhaps due to the



disposal of nonhazardous industrial wastes.







Unit design at landfills and sites closed as landfills can promote



gas generation.  Waste depth, fill configuration, and  cover  soils



are important.  Specifically, deep landfills are  better gas



producers than shallow ones.  They have a proportionately larger



anaerobic zone, better insulation and compaction, and  a better



opportunity to confine generated gases.  Fill configuration  and



landfill location impact gas production.  Deep  landfills, such as



trench  fills or canyon fills, trap gas along confining sidewalls



and bottom bedrock or ground water.  Conversely,  mound or shallow



landfills have large surface areas through which  gases can vent.



Daily,  interim, and final cover soils can retain  gases of



biological decomposition within the landfill.   Tight  cover soils



(e.g.,  clays) impede vertical migration of gases  better than



permeable soils.







Unit operations can have a  significant impact on  potential gas



generation.  Methods and procedures used to segregate  and isolate



inert wastes, to prevent moisture infiltration, to compact and



increase the density of the waste, and to minimize or  prevent



mixing  of waste types can affect resultant releases of subsurface



gases.  Biological decomposition can be inhibited by  containers
                               2-3

-------
and containment devices, such  as drums,  tanks,  liners,  soil  berm



dividers, and daily covers.  When organic material  is  landfilled



under anaerobic conditions,  it  is converted  by  microbial  action



primarily into carbon dioxide  and methane.   Hydrogen,  ammonia,



aromatic hydrocarbons, halogenated  organics,  and  hydrogen  sulfide



are also present as gases but  usually  in trace  amounts.   Due  to



the large volumes of decomposable wastes deposited  in  landfills,



landfill gas yields can be high.  The  primary gases  of  concern



resulting from biological decomposition  are  methane  (due  to  its



explosive properties) and other volatile organics that  may be



present  in amounts that pose a  threat  to human  health  or  the



environment.  Other volatile organics  that are  frequently detected



in landfill gases were presented in Table 1-4.







2.1.2  C hem i c a 1 necompj) s i tj_p_n_







Chemical decomposition of waste is  not a significant  gas-generat-



ing process in most SWMU's.  However,  gas production  by chemical



reaction can result from the disposal  or storage  of  incompatible



wastes.  In landfills, sites closed as landfills, and  underground



tanks, gas production from chemical reactions that  pose a threat



to human health and environment is  not expected under  normal  unit



operations.  Waste types can influence the potential  for  chemical



reactions to occur.  Reactive  or ignitable wastes can  produce



explosive or heat-producing  reactions, resulting  in  rapid



production of gases, increased  pressures, and increased tempera-



tures.   Volatile liquids stored in  underground  tanks  may  have a
                                2-4

-------
significant potential  for  gas  production  by  chemical  reaction.



However, most waste types  deposited  in  landfills  and  sites  closed



as landfills are not amenable  to  significant  chemical  reactions



and regulations require  special handling  for  reactive  wastes  to



minimize these problems.








In addition to waste type,  how the wastes  are managed  will  affect



the potential for  significant  chemical  reactions  and  subsequent



gas production.  In particular, the  proper design  and  operation



(e.g., pressure-relief valves  and leak  detection  systems) of



underground tanks  will prevent the occurrence of  chemical



decomposition by reaction.   In a  landfill  under acidic  conditions,



a strong oxidizing agent can react with organic wastes  to produce



carbon dioxide and ammonia.  Other chemical  reactions  that  might



occur in SWMU's are difficult  to  predict.  As-a result,  the



primary gases of concern from  chemical  decomposition may  include



all of the constituents  of  concern listed  in  Table  1-2.







2.1.3  Physical _Jtecpmj)_o_sj_tj_o_n







The type of SWMU relates to  the potential  for physical



decomposition and  subsequent gas  generation  from  a  given  waste.



In the context of  this document,  physical  decomposition  includes



volatilization and combustion.  Volatilization of  compounds is



most likely in underground  tanks  containing  volatile  liquids  where



a liquid and vapor-phase equilibrium  is established  in  the  tank.



Volatilization occurs to a  lesser extent  in  landfills  and sites
                                2-5

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closed as landfills, primarily  during  waste  application  or  other



exposure to air.  Sublimation is  the direct  conversion  of  solids



to gases without a  liquid  phase.   This  occurs  in  landfills  but



generation via this mechanism is  considered  insignificant.








Combustion processes can actively contribute to  subsurface  gas



generation.  For example,  underground  fires  are  encountered  at



landfills.  Combustion  processes  resulting in  subsurface gas



emissions are not expected  in sites closed as  landfills  (that



were previously surface impoundments  or waste piles) or



underground tanks.







Waste types will influence  the  potential for physical decompo-



sition to occur via volatilization and  combustion.   Volatility is



is perhaps the most important parameter affecting  subsurface gas



generation from liquids stored  in  underground  tanks.  The vola-



tilization (or vaporization) of a compound is  dependent on  its



vapor pressure and concentration  (relative to  the  surrounding



media) and the temperature, pressures,  and porosity  of the  wastes



and surrounding soils.  Theoretically,  gases generated from  liquid



wastes will  continue to be  generated until a liquid  and  vapor-



phase equilibrium is established  (i.e., the  rate of  vaporization



equals the rate of condensation).  The  greater a compound's  vapor



pressure, the greater will   be its  ability to volatalize.



Compounds with very low vapor pressures (generally  less than 0.1



mm Hg) tend to remain in the liquid phase.
                                 2-6

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Combustion requires a combustible  waste  type  in  addition  to  a



source of oxygen.  Typical waste types deposited  in  landfills



include paper, wood, and  flammable liquids.   Typical  wastes  in



underground tanks include flammable  liquids such  as  solvents,



waste oil, and other fuels.








Other factors that impact physical  decomposition  primarily  result



from waste management operations.   Unit  operations can  prevent



volatilization by providing maintenance  of underground  tanks



(pressure- relief valves  and  leak  detection systems).   At



landfills, operations to  inhibit underground  combustion center  on



the prevention and control of  fires.  In a landfill,  combustion



can convert wastes to by-products  such as carbon  dioxide, carbon



monoxide, and trace toxic components.  In addition,  the increased



temperatures from combustion  may enhance chemical  reaction  rates



and biological  decomposition,  and  create greater  driving  forces



for gas migration.  Volatility  is  compound-specific,  based on



physical properties, temperature,  and pressure.   Thus,  the primary



gases of concern from physical  decomposition  include  a  wide  range



of volatile constituents, including  all   those  listed  in Table



1-2.







2.2  GAS MIGRATION







Subsurface gas migration  towards facility structures  or property



boundaries concerns potential   pathways and barriers  for movement



through the surrounding soils.  Barriers affecting migration  are
                               2-7

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influenced by hydrologic and  geologic  site  conditions,  soil



properties, and unit design and operation  features.







2.2.1  Natural barri ers








Gas migration can be impeded  or prevented  by  hydrologic  barriers



such as surface water, ground water, and saturated  soils.



Subsurface gases that come  in contact  with  these  conditions  will



tend to migrate towards the pathway of  least  resistance,  usually



through a porous soil.  As  an uncommon  example, if  a  landfill  or



site closed as a landfill was surrounded (along all sidewalls  and



bottom) by water, gas migration beyond  the  confining  barrier would



not be expected.  In most cases, however,  ground  water  and



saturated soils only partially surround a  unit  (usually  along  the



bottom).  Thus lateral or vertical migration  can  occur.







Gas migration can also be impeded  or prevented  by geologic



barriers such as unfractured  rock  or soil with  low  permeability.



Soil permeability is perhaps  the most  important natural  barrier to



gas migration.  Permeability  is a  function  of  soil  type.  Clayey



gravels and sand and organic  clays will restrict  gas  flow at SWMU



sites.  Conversely, clean gravels  and  sands have  high



permeability, allowing subsurface  gases to  freely migrate.   Soil



permeability can be impacted  by climatic conditions such  as



precipitation or freezing.  Both tend  to reduce the porosity of



surface soils preventing upward gas migration.
                                2-8

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_2_._2._2___De_s_i_g_n___B_a r r i e r s








Landfills and sites closed  as  landfills  may  be designed with caps



and liners to prevent moisture  infiltration  and leachate



percolation to ground water.   If  subsurface  gases  are generated



from these units, these  same caps  and  liners  act  as  barriers to



gas migration.  Generally,  caps promote  lateral  gas  migration



since upward movement to the surface is  restricted.   Effective



liners restrict lateral  migration  into the  surrounding unsaturated



soils.  Similar to liners,  slurry  walls  are  used  to  border



landfill units and can  restrict gas movement.   Caps  and liners are



not typically designed  with underground  tank  units.   However,



these tanks are often placed into  soils  with  clay  backfill  during



installation, followed  by paving  on the  surface.   Thus, any



escaping gases from a leaking  underground  tank__may migrate



laterally or along the  least resistant pathways adjacent to the



units.







Control systems for subsurface  gas are designed to prevent



migration into structures or beyond property  boundaries.  Control



systems may be passive  or active.  Two basic  types of systems are



barriers and vents or extractive  systems.   Barriers  prevent



migration by providing  an impermeable  area  between the gas source



and the area to be protected.   Barriers  include synthetic



membranes and air injection systems.   Venting  systems provide an



easy path for the gas to vent  through  before  migrating to areas



needing protection.  Vent systems  include  passive  vent trenches



and active extraction systems.  The latter  also include flares to



burn the gases in order  to  control odors.
                                2-9

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Control  systems for subsurface gas are  almost  exclusively



associated with disposal sites for municipal-type  waste  rather



than for hazardous waste.  Thus they will  be  rare  at  hazardous



waste facilities and likely only present where municipal waste  is



codisposed with hazardous wastes or where  a  sanitary  landfill  is



operated on the same site.
                               2-10

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                           SECTION  3



                     IDENTIFYING  RELEASES







3.1  APPROACH



The preceding sections have  evaluated  landfills,  sites  closed  as



landfills, and underground tanks in  terms  of  the  potential  for



subsurface migration of methane  and  other  constituents  of  concern.



Since few SWMU's are presently monitored for  gases  and  since moni-



toring programs are difficult and  often unnecessary  to  establish,



a Preliminary Assessment  (PA) is appropriate  to determine  if



specific units will generate sufficient amounts of  methane or



other constituents to cause a subsurface gas  release.   Certain



units will not generate gases, or  will generate only minor amounts



so that further evaluation will  not  be required.  To make  these



determinations, information can  be collected 'from construction



documents, permit and inspection reports,  and  records of waste



disposal, unit design and  operation, and past  documentation of



accidents, spills, and releases.







As a first step, each SWMU at the  facility  should be identified



and located by the owner  or operator on a  topographic base map.



This would include former, existing  or new  SWMU's.   For example,



the location and aerial  extent of  each SWMU should  be confirmed by



historical records, aerial photographs, or  geophysical  surveys.



The depth, dimensions, and capacity  of underground  structures,



deposited wastes, and on-site buildings, should be  described to



assist the permit writer  during  the  PA.
                             3-1

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Existing construction, operation, and monitoring  records  can  be



used to determine if hazardous constituents  have  been managed  at



the SWMU.  Records of waste disposal, unit design  and operation,



and documentation of accidents, spills, and  releases should be



included during review by EPA to determine if  a potential  exists



for a subsurface gas release from the SWMU.








Waste disposal records include waste type, quantities managed,



location of wastes and the date of waste disposal.  This



information might include waste receipts, waste composition



surveys, and records of special wastes such  as municipal-type



refuse, bulk liquids, sludges, contaminated  soils, industrial



process wastes, or inert materials.  For underground tanks, this



information may address liquid waste compositions, quantities, and



physical properties.







Unit design and operation records provide background information



on site-specific construction methods.  Engineering design plans,



inspection records, operation logs,- regulatory inspection  and



enforcement logs, damage or nuisance litigation, and routine



monitoring such as ground-water sampling.  For landfills  and



surface impoundments closed as landfills, these data may  include



to the presence and thickness of a liner, ground-water levels,



waste moisture contents, type and amount of  daily cover,  records



of subsurface fires, in-place leachate and/or  gas collection



systems, etc..  For underground tanks, construction and monitoring



records may provide historical  information on  tank integrity,



indicating if a leak has occurred.
                              3-2

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Past documentation of accidents, spills, and  releases can be



helpful  if Federal, State, or local authorities were notified.



This information provides a historical  perspective on problems,



corrective actions, and controls initiated.








Further information may be obtained by  performing a site



investigation (SI), including field observations and interviews



with facility owners or operators.  The Si's  are technical



observations of SWMU's to detect evidence of  a potential  release.



Although not extensive, the SI is  conducted in the vicinity of



each unit for indications of a release, including settlement,



erosion, or cracking of covers, stressed or dead vegetation,



contamination of surface waters, odors, elevated temperatures in



control  or monitoring wells or active   venting of gases or smoke.







The Si's might address the condition of monitoring, containment,



or control systems and any obvious structural defects in  tanks,



liners,  etc..  Observations should be made to check overflow/alarm



shut-off systems, subsurface leak  detection systems, secondary



containment structures (e.g., concrete  pads,  curbs, or dikes), and



other safety triggers for early detection of  potential   releases.



If monitoring,    control, or leak detection  systems are  not



in-place at the SWMU, Si's may be  limited to  primarily  visual



aspects  and reviews of site conditions  to evaluate if a release is



suspected.
                             3-3

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3.2  PRELIMINARY ASSESSMENTS








A checklist for identifying actual  or  potential  subsurface  gas



releases during a Preliminary Assessment  (PA)  is  shown .in Table



3-1.  The checklist is designed  to  allow  the  permit  writer  to



review the PA data and to determine whether subsurface  gas  is



migrating or will migrate beyond  the facility  boundary  or into



on-site or off-site structures at concentrations  that are a  threat



to human health and the environment.







The permit writer will be concerned with  two types of subsurface



gas migration:  (1) methane (CH4) and  (2)  gases  containing  the



other constituents of concern, listed  in  Tables  1-2  and  1-3.



These other constituents of concern must  be evaluated only  if the



facility owner/operator or permit writer  believes they  are  present



in amounts that may pose a threat to human health or the



envi ronment.







The PA involves a desk-top evaluation  of  a facility  to  identify a



release or potential exposure from  future  releases.  Information



used by the permit writer includes  the  Part A  and Part  8 permit



applications.  Personal knowledge of the  site  is  important.



Additional information may be available from  the  owner/operator or



from other sources.







The PA Checklist guides the permit  writer  through the evaluation.



The checklist is divided into five  sections.   The first  three  are
                               3-4

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              TABLE 3-1 PRELIMINARY ASSESSMENT CHECKLIST
                                                     _ ___Resp o n s e *	
Criteria   	       "T    N     U   N/A

I.    Unit  Characteristics

     •  Unit is a landfill  that contains
        organic or volatile wastes.                  	  	  	  	

     •  Unit is a surface impoundment or
        waste pile that has been closed as
        a  landfill and covered, with organic
        or volatile wastes.                          	  	  	  	

     •  Unit is an underground tank that
        contains volatile wastes.
     If answers to all  above items are No,
     no further evaluation is needed.

II.  Boundary Conditions

     •  Unit is entirely surrounded within
        the property boundary by surface
        water, or impervious rock with no
        facility structures located inside
        the surrounding boundary or on top
        of unit.

     •  Unit has effective gas migration con-
        trol  system(s)  protecting both on-site
        and off-site structures.

     If either answer above is Yes, no further
     evaluation is needed.

III.   Quantitative Measurement of Release

     •  The methane level  is LEL at property
        boundary or 25% LEL in facility
        structures.

     •  Constituents listed in Table 1-4
        measured at PEL at property boun-
        dary or in facility structures.

     If answers to _b_p_t_n_ of above are No and
     permit writer is confident of reported
     results, no further evaluation is needed.

     If eithe_r answer above is Yes, a Site In-
     vestigatTon should be conducted.
                                   3-5

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Table 3-1 (Continued)
                                                        Respons_e_*	
Criteria                    	Y    N   _  U    N_/A_

IV.  Other Evidence of Release

     t  History of methane-related fires
        and explosions.                              	  	  	 	

     •  Leak detected and confirmed in
        underground tank.                            	  	  	 	

     •  Complaints on file with local/State
        health or fire authorities of odors
        seeping into basements and subsurface
        areas.                                       	  	  	 	

V.  Migration Distance

     •  Property boundary or structures
        on - or off-site less than 800 ft.
        at a landfill or landfill-type unit.         	  	  	 	

     •  Structures on - or off-site less
        than 300 feet from an underground
        tank unit.
 *Y   = Yes
 N   = No
 U   = Uncertain
 N/A = Not applicable
                                 3-6

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used sequentially to eliminate  facilities  with  virtually  no



possibility of a release or those with  good  monitoring  data  that



indicate no release.  These sections  will  eliminate  many



facilities from further evaluation because these  facilities  do  not



contain landfills or underground tanks.  However, most  landfill  or



underground tank sites will not be eliminated from further



evaluation in the first three sections, but  will  be  subjected to



Sections IV and V as part of the PA.







Sections IV and V of the checklist help assess  the majority  of



landfill and underground tank sites.  These  are sites with little



or no subsurface gas monitoring data.   Section  IV assesses



indirect evidence of a subsurface gas release and Section V  is



concerned with the distance from landfill  units or underground



tanks to the property boundary  and structuresT"







If a site "passes" the PA Checklist,  it is considered to  have no



current releases and the potential  for  exposure from future



releases is small.  Sites that  fail the PA Checklist should  be



subjected to a Site Investigation to  obtain  monitoring  data  and



other site-specific information for a more detailed  evaluation.



Pass/fail  criteria are presented in Section  3.2.5.







The use of predictive models was not  included in  the PA Checklist.



Several  models of subsurface gas (primarily  methane) migration



have been developed.  A simplified version was  included in the  in-



structions to the Open Pump Inventory.  Even the  simplified  ver-



sion requires data such as the  age of the  landfill,  depth of fill,
                                  3-7

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and soil  types around the fill.  This  informatioin  is  not  readily



available for closed units.  Thus predictive models  were



considered too burdensome on both the  permit writer  and the



owner/operator at this point in the  site  assessment.   The  question



of current and potential migration can  be better  answered  by  use



of the PA Checklist plus a later Site  Investigation  involving



actual monitoring.  Predictive models  may be applicable in a



later, more sophisticated evaluation when  detailed,  site-specific



information is available.







3.2.1  CheckJ_1st_Sect:ion I







The checklist is generally self-explanatory.  However, suggestions



for its use and sources of information  are presented in this and



subsequent sections.







Section I identifies the types of units of concern for subsurface



gas releases:  landfills and units closed  as landfills containing



organic or volatile wastes, and underground tanks with volatile



wastes.  Examples of wastes that are organic are  coal  and  peat



processing wastes; incinerator, composting, and resource recovery



residues; septic tank pumpings; wood;  sewage sludges;  and



municipal-type solid waste.  Volatile  wastes are  defined as those



compounds that have a vapor pressure at 20°C that exceeds  0.1 mm



Hg.  Tables 1-2 and 1-3 may be used to  identify the  types  of waste



likely to contain constituents of concern.
                             3-8

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Units that meet the criteria  in  Section  I  of  the  checklist  have



potentials to generate subsurface  gas.   Other types  of  units  will



not be evaluated unless the permit  writer  observes  evidence  of



migration by other means.  As  an example,  no  further  evaluation



would be necessary at a demolition  landfill accepting inert



materials that did not in the  past  or does  not  presently  accept



organic waste.








Sources of information for Section  I include  the  waste  type  and



waste characterization information  in the  Part  A  and  Part B



permit applications.  Little  information about  colocated  or



codisposed nonhazardous organic  waste will  be easily  available.



Contact may have to be made with1 the owner/operator  regarding



this.  Both current and past  operations  are of  interest.  In



addition, contact could be made  with the State's  solid  waste



permitting office, county planning  office,  or similar sources to



identify or confirm the presence or absence of  disposal  areas at



the sites in question.







3.2.2  Checklist Section II







Section II identifies situations where natural  or manmade control



systems effectively Control migration of subsurface  gas.  Natural



barriers completely surrounding  the units  will  be almost



nonexistent.  Although many municipal landfills have  gas  migration



controls, the controls often  protect specific portions  of the



perimeter from gas movement and  do  not control  the  entire site.



It is unlikely that closed sites have controls.
                                 3-9

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If a site is reported to have  a  control  system  completely  around



it, the permit writer must be  confident  that  it  is  operating



effectively.  This can be  shown  by  site  monitoring  data,  operating



manuals, and confirmed by  contact with  local  fire  and  solid waste



offices.  Very few, if any,  sites that  fail  Section I  will  pass



Section II and be released from  further  evaluation.







3.2.3  Checklist Section III







Subsurface gas monitoring  data may  be available  from the



facility; however, that is not likely.   Direct  quantitative



measurements can be made during  the  SI through  the  simple  field



sampling methods described later in  this  guidance.  However, when



any of the indicator constituents of concern  is  measured  at or



above the levels specified in  Section II  of  the  checklist, a



release has occurred and the permit  writer  should  initiate a SI as



soon as possible to fully  define the release  and to assess the



need for emergency action.   See  Section  4 of  this manual  related



to emergency situations.







An owner or operator may submit  monitoring  data  indicating no



release.  The permit writer must be  confident that  the monitoring



was done properly and completely before  passing  a  site.   Note  that



monitoring data must be available for both methane  and the



indicator constituents shown in  Table 1-4.
                               3-10

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Monitoring procedures should be  fully documented.   Information



needed is indicated later in the  section describing  SI  field



sampling methods.  Some items include:



     •  Locations and depths of  sampling



     •  Methods used including sketches or  photos



     •  Instruments used



     •  Date and atmospheric pressure



     •  Analytical  methods and laboratory used,  if any.







Monitoring subsurface gas is a specialized  field.  The  permit



writer should review submitted data with someone experienced in



the area.  Sources include solid  waste management offices  in major



cities or at State offices or consultants experienced in the



topic.







3.2.4  Checklist Sections IV and  V







These sections include the evaluation of indirect evidence of



releases or potential  exposure from future  releases.  Sources of



information will vary widely.  The owner or operator can be asked



about the history of methane-related incidents,  leaks from



underground tanks, and odor complaints.  The  responses  should be



verified through contacts with State or local government



personnel.  The owners or operators should  be able to provide



appropriate contacts.  Possible  sources of  information  include:
                             3-11

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     •  Methane-related  fires  or  explosions



        -  local fire department



           local solid waste management  office



        -  local emergency  response  or disaster  teams







     •  Odor complaints



        -  generally same as above








     0  Underground tank leaks



        -  EPA Regional  or  State  inspectors  or enforce-



           ment personnel



        -  local fire departments or emergency response



           teams







The distances noted in Section V may be  available  on the  maps



submitted with Part A or Part B permit applications.   However,



closed units or active sanitary landfills  may not  be shown.



Likewise all  on-site and off-site structures may not be shown.



The owner or operator should be contacted  for the  necessary



information.   For purposes  of the checklist, the term  structure



should be used in the broad sense of any enclosed  building that



personnel  enter even infrequently.







3.2. 5  ChC k   s t   ^j   on
Sites will either pass the PA Checklist evaluation  and  not  be



subjected to further evaluation of subsurface gas migration  or
                          3-12

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they will fail and a Site  Investigation  will  be  conducted.   Sites



can fail  either in Section  III of  the  PA Checklist  if  a  release  is



shown or in Sections IV and V.   If a  site is  subjected to



evaluation on criteria in  Sections IV  and V of  the  checklist  it



should be failed and a SI  conducted  if either of the  following



occur:



     •  One or more Yes responses  in Section  IV  or  V



     0  Two or more Uncertain responses  in Sections  IV



        and V combined.








Personal  knowledge of the  facility will  be important during  the



PA.  Responses of the permit writer on  the PA Checklist  should be



tempered with experience with the  site.   If there is any



uncertainty, the U response should  be  made rather than the N



response in Section IV and V.  Examples  are tfie  distance criteria



in Section V.  A structure may be  more  than 300  ft.  from an



underground storage tank.  However,  if  the surface  between the



tank and the structure is  paved,, migration to the building is



possible and a U response  is appropriate.







The decision criteria are  strict but appropriate.   Injury or  death



from a methane explosion can come  quickly and with  virtually  no



warning.  Often there is little  or no  concern about  subsurface



gas until there is a tragic accident.   The effort required for a



SI is well  spent if there  is _any_ uncertainty  in  order  to identify



releases or potential  releases so  that  they may  be  controlled  or



prevented.
                              3-13

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3.3  SITE  INVESTIGATIONS







Site Investigations  (Si's)  should  be conducted at sites that fail



the PA Checklist criteria,  either  in Section III or Sections IV



and V.  The most important  results of a SI  will  be the monitoring



and sampling for subsurface  gases  in the soil  and in on-site



structures.  Other information  to  be collected during a SI include



soil characteristics,  presence  and effectiveness of any gas



control systems, and  the  proximity and  construction of buildings



on  - and off-site.







For simple field tests  conducted during the SI,  the locations of



probes and timing of  samples  is  important.   Sampling locations  and



probe depths should  be  based  on  soil  types, structure locations,



vegetative stress patterns,  and  the  waste typ'e~.
_3._3_.JL __ ^AJJPJJ-PJL-P-ri Sampling  Inside  Structures







To test for subsurface  gases inside a facility  structure,  sampling



conditions favorable to detecting  gases  are  desired.



Specifically, monitoring  should  be conducted after the building



has been closed overnight or for a weekend,  and  when  the  soil



surface has been wet or frozen  for several  days.  Sampling should



be performed in confined  areas where  gas  may accumulate,  such  as



basements, crawl spaces,  near  floor cracks,  attics,  around



subsurface utility connections,  and in untrapped drain lines.   Gas



recovery and gas control  equipment need  not  be  sampled.   The re-
                            3-14

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suits, location, date, barometric  pressure  and  time for each



sample should be recorded.   It might  be  desirable  to  repeat  the



tests at a later date or  under different climatic  conditions to



verify the readings, particularly  if  the facility  is  considered



high priority based on structure  locations  and  migration



distances.  Monitoring results should  be tabulated  and  plotted  on



a map of the facility.








3.3.2  Subsurface Monitori ng or_ Sam_p_1J_n_g







Subsurface monitoring should begin  around the units  identified  in



Section 1.  Initial monitoring should  be done as  near the  edge  of



the unit as possible, but  not in the  unit.   If  gases  are detected,



monitoring should be done  further  from the  unit  to  identify



general migration paths.   The exact location and  depth  of  the



monitoring points should  take into  account  any  gas  permeable



seams, such as dry  sand or gravel,  alignment with  an  off-site



structure, proximity of the  waste  deposit,  areas  where  there is



dead or unhealthy vegetation that  m-ight  be  due  to  gas migration,



and areas where underground  construction might  have created  a



natural path for gas flow  (utility  lines).







In soils that are of uniform depth, subsurface  gas  probes  or



sampling points should be  at least  three feet below the ground



surface.  Where dry sand,  gravel,  or  more gas permeable soil



strata might interconnect  the waste deposit and  the property



boundary, multiple  sampling  points  should be used,  with the  upper-
                              3-15

-------
most three feet deep and  additional  ones  in  the  deeper  permeable



soil layers.  General techniques  for  installing  monitoring  and



sampling probes are  provided  in Table  3-2  and  Figure  3-1.







3.3.3 Methane








Simple field sampling methods  for  methane  have been described



previously and in 40 CFR  Part  257.3-8(a).  Methane  field sampling



can be performed with combustible  gas  meters,  or  by volumetric



sampling and subsequent analysis by gas chromatography.  A



combustible gas meter will provide a  reliable  determination  of



methane concentrations.   Reported  experience indicates  0 to  100



percent LEL detection to  be accurate with  hot-wire  catalytic



combustion principal instruments.  Since subsurface gas release



determinations only  require readings of metha'ffe  concentrations up



to  LEL (5 percent methane), this single scale  is  sufficient.



However, many users  prefer instruments with  the  capability  of



determining both the 0 to 100  percent  LEL  and  the percent methane



present when the concentration exceeds 100 percent  LEL  (5 percent



methane).  Dual  scale instruments  are  available  for this



application.  Typically,  the 0 to  100  percent  gas scale uses a



thermal  conductivity sensor.   The  carbon dioxide  in landfill-



generated gas is reported to  interfere with  the  thermal



conductivity sensor, so the readings above 100 percent  LEL,  while



useful,  cannot be assumed to be accurate.  Some  of  the  single



scale 0 to 100 percent LEL instruments can also  be  fitted with air



dilution tubes or valves  to allow  readings of  the percent gas when
                                3-16

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                                   TABLE  3-2

                        SUBSURFACE  SAMPLING  TECHNIQUES
  SHALLOW (Up to 6 ft. deep)

   •  Select locations as described  in  text.

   •  Penetrate soil  to desired  depth.   A  steel  rod 1/2 to 3/4 in. dia.
      and a heavy hammer are  sufficient.   A bar  punch  is better for num-
      erous holes.   It is a small,  hand  operated  pile  driver with a slid-
      ing weight on  the top.   Hand  augers  may  also  be  used.

   •  Insert plastic tubing to bottom of  hole.   Tubing may be weighted or
      attached to a  small diameter  stick  to assure  that it gets to the
      bottom of the  hole.  Tubing  should  be perforated along bottom few
      inches to assure gas flow.

   •  Close top of hole around tubing.

   •  Attach meter or sampling pump  and  evacuate  hole  of air-diluted  gases
      before recording gas concentrations  or taking samples.

   •  When using a meter, begin  with  the  most  sensitive range (0 - 100
      percent LEL for methane).   If meter  is pegged,  change  to the next
      least sensitive range to determine  actual  gas concentration.

   t  Tubing shall be marked,  sealed, and  protected if sampling will  be
      done later.

   •  If at all possible, monitoring  should be  repeated a day or two  after
      probe installation to verify  readings.

DEEP (More Than 6 ft. deep)

   •  Same general procedures  as  above.

   •  Use portable power augers  or  truck-mounted  augers.

   •  For permanent  monitoring points,  use rigid  PVC  tubing  and the
      general construction techniques shown in  Figure  3-1.

CAUTION

   •  When using hand powered  equipment,  stop  if  any  unusually high
      resistance is  met - it  could  be a  gas pipe  or an electrical  cable.

   •  Before using powered equipment, confirm  that  there are no
      underground utilities in the  locations selected.
                                        3-17

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                            FIGURE 3-1

             TYPICAL DEEP SUBSURFACE GAS MONITORING WELLS
       PC,
                • 1/2" DIA. SCH. 40
                 PVC PIPE
                    1/8"  DIA.
                    PERFORATIONS
                     FIBERGLASS
                     SCREENING TO
                     BE WRAPPED
                     AROUND  8 TAPED
                     TO TUBE.
MONITORING PROBE  DETAIL
                      1/2" DIA. SCH. 40
                      PVC PIPE
                                                      SOIL BACKFILL
                   g ( i i   l i *   ' '
                   flE-r-2' BENTONITE
                   " II   PLUG
                    e-SOIL BACKFILL

                       t PEA  GRAVEL
                       SOIL BACKFILL


                       '-2'  BENTONITE
                       PLUG

                       SOIL BACKFILL
MONITORING
PROBE
                       2' PEA GRAVEL
                                                       SOIL BACKFILL


                                                       '-2' BENTONITE
                                                       PLUG

                                                       SOIL BACKFILL


                                                       2' PEA GRAVEL
                               3-18

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the concentration is above  the  LEL.   Instructions on the use and
calibration of these instruments  should  be obtained  from the
manufacturer.

When sampling with  a combustible  gas  meter, samples  should be
withdrawn slowly with the hand  bulb  until  a high or  constant
reading is obtained.  For small diameter holes in tight soils,  a
spike reading may be obtained  initially  and the concentration will
then drop to a low  value.   This is  caused  by exhausting the gas in
the hole.  The spike reading  should  be  recorded and  checked by
allowing the gas to  return  for  a  few  minutes and taking another
reading.  The location or probe number,  the time and date,  and  the
results should be recorded.

For volumetric sampling, subsurface  gas  can be- collected in an
evacuated flask or  bottle with  a  vacuum  pump.   The  volume  of air
in probes or gas lines should  be  purged  prior  to obtaining the
sample.  Generally, a 150 ml  sample  is  appropriate.   This  sample
is then sent to the laboratory  for  analysis of methane  by  volume.

3_.3.4  _0ther Ijidicator Constituents

The other indicator constituents  listed  in Table 1-4 can be
measured by several methods,  all  of  which  require more  extensive
sampling procedures, equipment, and  instrumentation  than
combustible gas meters for  methane.   There are two  basic methods
for collection of subsurface  gas  samples.   In  one,  a gas sample is
                            3-19

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obtained in a flask, bottle, bag,  or  other  suitable  container;  in



the other, gases or compounds are  removed from  the air  and



concentrated by passage through  an  absorbing  or adsorbing medium.







The first method involves the collection of volumetric  samples,



usually a liter or so depending  on  concentration  and  desired



detection limits.  This type of  sampling is convenient  and  easily



performed in the field.  Evacuated  stainless  steel cylinders  are



frequently used for sample collection.  However,  sample  loss  or



decay can occur with various containers (such as  plastic bags)  and



prompt laboratory analysis is required.  To detect the  indicator



constituents at levels fitting the  definition of  a release, the



volumetric sample collection method is acceptable, coupled  with



the appropriate analytical methods.   This type  of sampling  is  less



reliable when compound concentrations fluctuate with  time,  or  are



low, or when the gas sample is a complex mixture  of many



compounds.







Because low concentrations of a  wide  variety  of volatile organics



are frequently observed in subsurface gases, many compounds can be



more efficiently collected and simultaneously analyzed  by



continuous sampling and collection  onto a solid adsorbent.  The



solid adsorbent concentration method  uses a vacuum pump  and



adsorbent traps to collect and concentrate volatile organics.



Specific adsorbents (such as activated charcoal  or silica gel)



can be selected according to compound volatility  and  the type  of



organics sampled (such as chlorinated hydrocarbons or pesticides).
                           3-20

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Flow rates through the adsorbent traps  and  sample  volumes  must  be



selected prior to sampling, and then  carefully measured  during



sampling with calibrated meters.  After  sampling  is  completed,  the



traps are sealed and shipped to a laboratory  for  analysis.







Several analytical methods are  available  for  both  volumetric  and



concentrated trap samples.  For quality control requirements, EPA



has approved Method 1624 for volatile organics in  40 CFR Part 136.



This method is amenable to the  indicator  constituents of concern.







Portable detection meters are not recommended  for  monitoring  for



constituents other than methane.  These instruments must be



recalibrated for each different constituent.
       Factors Not
During a SI no release or even no migrating gas at all may be



found.  However, there is the possibility of  future  releases



resulting in exposure of the public.  SI inspections  should



include factors related to the potential for  releases  and



migration.  These factors are generally related to site  location



and soils, subsurface gas control systems, and construction of



on - and off-site buildings.







Site location, soils, and surface and ground  water influence the



potential  for subsurface gas migration.  Tight, uniform  soils  such



as clays at least to the depth of the unit are good  barriers.
                                3-21

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Sand and gravel  lenses  below a  less  permeable cover are excellent
conduits for gas migration.   However,  sandy soil  will  likely
encourage venting of  gas  to  the  atmosphere with little chance of
horizontal migration.   Observation  of  soil  types  at the site is
important.  Other soil  information  from the Part  B permit
application will also be  helpful  in  assessing future migration
potential.

Water is a barrier  to gas  migration.   Subsurface  gas does not
penetrate ground water  and  surface  water  is usually a  good
barrier.  An exception  is  a  pearched  body of surface water with
unsaturated soil below  it.   Thus  if  there is a  lake or perennial
stream between  the  unit and  any  structure,  future migration and
exposure is unlikely.   High  ground  water  restricts migration to
the unsaturated  zone.   This  focuses  interest i_n soils  to  only that
zone.  High water tables  also allow  for the use of effective but
relatively inexpensive  trenches  as  gas  control  devices.

Some sites may  have gas migration controls.  If properly  designed
and located, they can greatly reduce the  possibility of future
releases, even  if the controls do not  completely  surround  the
unit.  Control  systems  are  usually  constructed  to protect  existing
structures.  If  future  building  is  possible,  a  system  may  have to
be expanded.

Control  systems nay be  either passive  or  active.   Passive  systems
require  no energy and little maintenance.   They are  vents  to the
atmosphere or barriers.  Assuming proper  design and  construction,
                              3-22

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the only passive system not  considered  effective is a series of
vent wells.  Active systems  withdraw  gas  through wells or develop
pressure curtains by  injecting  air  into the soil.   Assessment of
effectiveness should  be done  by  personnel  experienced with  gas
migration control.  Control  systems are described more fully in
Section 5.

Exposure to subsurface gas may  be affected by  the type of
construction used for buildings  on or off  the  site.   SI
inspections should at least  determine the  general  construction
techniques used.  Subsurface  gas accumulates  in  basements,  crawl
spaces, and other confined areas where  there  is  easy  passage for
the gas from the soil into the  building.   Buildings built with
slab-on-grade or with well ventilated crawl  spaces are less likely
to have gas accumulations than  other  types;  however,  cracks in
floors and gaps around utility  penetrations  can  provide  good
conduits.

3.3.6  Evaluation

SI monitoring data may identify  a release  or  even an  emergency
situation (see Section 4).   This will likely  lead to  permit
conditions to correct the situation or  to  more detailed  studies to
prove that risk of future exposure is low.

Monitoring data may indicate  that no  indicator constituents are
present or they are at concentrations less than  the criteria for a
release.  In these situations,  future releases are possible.  SI
                                3-23

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investigations should assess  the  likelihood  of  future  releases  and
potential exposures of the public.   Provisions  of  RCRA  regulations
should be kept in mind related  to  reopening  permits  and the
10-year  life of permits.   If  a  site  poses  a  threat of  future
release  and exposure of  the public  before  regulatory corrections
can be applied, the site  should be  failed  and more detailed
Remedial Investigations  conducted.
                                3-24

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                            SECTION  4
                     REMEDIAL  INVESTIGATIONS
4.1  EMERGENCY SITUATIONS
4.1.1  Criteria

An emergency situation with regard to  subsurface  gas  exists when
gas has accumulated in a structure to  the  degree  that an  imminent
hazard to human health is present.  For methane,  an emergency
situation exists when the gas  is found at  concentrations  equal  to
or above its lower explosive limit (LEL).  The LEL for methane  is
five percent in air.  Any concentration of methane between 5 and
15 percent is explosive.  Above 15 percent in air, the methane  is
flammable.  Both situations should be  considered  as emergencies.
The criteria for a methane-related emergency  situation should be
applied to structures both on  and off-site.   Likewise both
occupied and non-occupied structures should be included.

Emergency situations may also  exist due to the presence of other
subsurface gases.  For subsurface gas  constituents of concern
other than methane, an emergency situation exists if:
   •  o  a constituent of concern is present in a  structure
        at concentrations greater than its PEL (or other  ex-
        posure limit as discussed in Section  2),  and
     o  the structure is occupied routinely (five or  more days
        per week) by the same  personnel for eight hours or more
        each day of occupancy.
                               4-1

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This definition includes  structures  both  on-site and off-site.
Obviously, dwellings on-site  and  off-site are  included.   Other
on-site structures  that would be  included are  offices,  scale
houses, laboratories, maintenance  garages,  and other buildings
with essentially continuous occupancy  during  an eight hour work
shift.  Buildings such as  locker  facilities,  lunch  rooms,  and
break areas that are only  occupied for short  periods are  not
included.

4.1.2  Identification

Potential and actual emergency situations can  be identified
through reviews of  historical  information and  gas monitoring data.
A potential emergency situation exists if there have been  any re-
ported explosions or fires  (inside or  outside "of a  structure)
likely caused by subsurface methane.   Also  illnesses or  deaths
verified as related to exposure to gases  within a building on-  or
off-site would  indicate a  potential  emergency  situation.   Know-
ledge of the above  will be  extremely  rare.  Thus identification
of actual emergency situations will  rely  almost entirely  on moni-
toring data.

Historical monitoring data  for subsurface gas  within occupied
buildings may be available, but is also unlikely.   Probably only
sites with a history of subsurface gas migration will  have
monitored inside buildings.
                                4-2

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The possibility of an emergency  situation  due  to  subsurface gas is
extremely low.  Unless there  is  strong  evidence,  other than moni-
toring data,  site visits  only  to  monitor  for subsurface gas are
not warranted.  Evidence  to trigger  a  visit  to monitor for sub-
surface gas emergency situations  include:
     •  Municipal-type refuse  is  or  was disposed  in  a
        landfill within the property boundary  or

     t  An underground tank containing  constituents  of
        concern  is known  to be  leaking.

Emergency situations will  likely  be  identified only  through moni-
toring by EPA or State regulatory  personnel.   This monitoring
shall be done using the instruments  identified in Section  3.
Monitoring should be done  in  areas within  structures where sub-
surface gas is most likely to  enter  and accumulate.  These areas
include basements, crawl  spaces,  and other enclosed  areas  such  as
storage rooms, closets and other  areas  with  no windows.  Gas con-
centrations should be checked  near cracks  or joints  in founda-
tions or floors and around pipes  and other utilities that  enter
the building  through a foundation  wall  or  through the  floor

Atmospheric pressure can  influence the  migration  of  subsurface  gas
into structures.  When monitoring  is being done,  the barometric
pressure should be recorded.  The  best  time  to sample  is when  the
pressure is low.  If possible,  schedule visits for days with low
pressure.  If that is not  possible and  gas concentrations  are  just
                               4-3

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below the criteria  for  an  emergency  situation,  schedule a return
visit for a time of lower  atmospheric  pressure.

Off-site buildings  probably  cannot be  monitored  for subsurface
gas.  Permission may be obtained  to  monitor  in  buildings  owned by
the facility owner  and  possibly  publically-owned buildings  near
the site.  Monitoring inside  privately-owned  buildings  should  not
be attempted unless there  is  a great likelihood  of  an  emergency
situation.  If occupied off-site  buildings are  extremely  close to
the property boundary (less  than  100 ft)  and  subsurface gas  at the
boundary is above the LEL, contact with  local  fire  or  health
officials should be made  and  interior  monitoring coordinated
through  them.

4.1.3 Fast-Track Corrective  Actions

If monitoring data  indicate  an emergency  situation  related  to
subsurface gas, steps should  be  taken  promptly  to  reduce  the
hazard whether it is related  to  human  health  or  to  the  explosive
potential of methane.   A  checklist of  steps  recommended in  case of
a gas emergency is  shown  in Table 4-1.  The  steps  should  be  com-
pleted generally in the order shown; however,  variations  may be
appropriate due to  site-specific  circumstances.

Corrective actions  for  subsurface gas  releases  are  highly site-
specific.  In general,  they  involve  either the  venting of gas  to
the atmosphere where it is diluted or  incinerated,  or  the pre-
                                4-4

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                            TABLE 4-1

                 Actions to Take in Gas Emergency
                     Situations in Buildings
1.   Evacuate the building.

2.   Advise fire department.

3.   Ventilate by opening windows and  doors.

4.   If methane is present shut off utilities - gas, electricity,
     telephone.

5.   Monitor to identify source if possible.  Source could be
     leaking natural gas appliance or  supply system.  Contact
     local gas utility and fire department  for monitoring and
     sampling assistance.

6.   Take samples and have analyzed to  identify source.

7.   Control  source, repair leak, etc., if  source  is not subsur-
     face gas.  Continue to monitor until safe levels return.

8.   If source is subsurface gas, call  in experienced and quali-
     fied experts to locate sources and develop corrective
     actions.
                               4-5

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vention of migration  through  the  use  of barriers.   Specific cor-
rective actions should  be  identified  by experts  at the site.  Some
common actions are  presented  in  Section 5.

4.2 ROUTINE SITUATIONS

Routine situations  are  those  that are not emergencies but which
are indefinite as to  the potential  for future  releases and the
resultant public exposure  and health  impacts.   Either regulatory
agencies or owners  and  operators  may  decide  that more detailed
data collection and analyses  are  appropriate.   These efforts could
be used to support  or refute  decisions related to  permit condit-
ions or the denial  of a permit.   Efforts related to such decisions
will be referred to as  Remedial  Investigations (RIs).

Owners and operators  may want to  conduct an  RI to  show that even
though a subsurface gas  release  has occurred,  exposure to the
public is unlikely  and  thus  the  potential  risk to  human health and
the environment is  not  substantial.   Similarly they may wish to
propose a corrective  action  that  is different  from that required
by the EPA or State.  This  latter situation  is similar to a  re-
quest for an Alternate  Concentration  Limit  for ground-water pro-
tection.

Regulatory agencies may wish  to  initiate an  RI to  defend decis-
ions imposing permit  conditions  even  though  no release of subsur-
face gas was detected during  an  SI.   Such an RI  would be focused
on establishing that  a  substantial  potential  risk  exists of ex-
posure to subsurface  gas if  a release occurs in  the future.

                                4-6

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Two general approaches  are  available  for the conduct and evalua-
tion of an RI related to  an  actual  or potential  subsurface gas
release.  One approach  is  the  use  of  predictive  models for sub-
surface gas migration coupled  with  site-specific information con-
cerning the potentially exposed  population.   The other approach is
the use of an independent  consultant  experienced in  control  of
subsurface gas migration.   This  approach might be considered a
form of arbitration  and both the  regulators  and  the  regulated or-
ganization should  agree to  honor  the  conclusion  of the consul-
tant.  The consultant firm  may use  predictive models,  however, it
may also use more  extensive  monitoring and  sampling  than was done
in the SI and make more thorough  soils analyses  and  evaluation of
other factors such as the  abilities of buildings to  prevent  the
intrusion of subsurface gas.

4.2.1  Predictive  Models

Models have been developed  to  predict the migration  of subsurface
gas.  Essentially  all of  them  have  been used to  predict migration
of landfill gas from open  dumps  and sanitary landfills where
municipal refuse has been  disposed.   They are also applicable to
the assessment of  migration  control system  effectiveness.

A generalized model  was developed  for use in the Open  Dump Inven-
tory Manual and was  presented  in  Chapter 2(a) of that  manual.  It
was developed to predict  the distance to which landfill gas  would
likely migrate from  an  open  dump.   Its data  requirements and de-
                                4-7

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gree of accuracy are appropriate  to  landfill  or  landfill-type
sites subjected to an RI.  The model was  not  designed  for  appli-
cation to a leaking tank  situation,  and  its use  for  underground
tanks is discouraged.

The model yields a subsurface  gas migration contour  map.   It
predicts the distance that gas will  migrate from  each  unit  based
on the unit's age, depth, soil characteristics,  and  other  fac-
tros.  These distances for two concentrations  of  methane (LEL or 5
percent methane and 25 percent of LEL or  1.25  percent  methane)  can
be plotted on a facility  map.  The resulting  contours  enclose
areas where methane could be expected at  these concentrations.   If
on-site structures are within  the 1.25 percent methane contour  or
the 5 percent contour extends  beyond the  property boundary, a re-
lease of subsurface gas as defined in Section!  is possible.  In
such situations continued monitoring and/or corrective measures
should be implemented.

4.2.1.1  Data Requirements
Data requirements for use of a predictive model  are  likely  more
extensive than will be found in Part A and Part B  permit applica-
tions and information collected during an SI.  This  is especially
true of sanitary landfills and other nonhazardous  disposal  units
located at the facility.  Information requirements are listed be-
low:
                               4-8

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•  Map of the facility showing all  landfill  units
   or units closed as landfills that  contain  organic
   or potentially volatile wastes.  The map  should  in-
   clude land use at least 1/4 mile outside  the  prop-
   erty boundaries and all structures within  that area
   including those on-site.  A sample map  is  shown  in
   the example explained  later.

•  Information about the  degree to which the  surface
   between the landfill units and structures  is  imper-
   vious to gas  (see example)

•  For each of the above  units the  following  is  needed
      ••  area!  extent of each unit
      ••  topography including elevation "contours at
          least  1/4 mile  beyond property boundaries
      ••  average elevation  of the  bottom  of  solid
          waste  in each unit
      ••  years  in which  solid waste  was first put  in-
          to each unit
      ••  average elevation  of a gas  impermeable barrier
          below  the solid waste (usually ground  water or
          bedrock).
      t«  information on  soils surrounding each  unit  at
          least  to the depth of the bottom of the solid
          waste  (descriptive soil names and  classifica-
          tions  are included in the example).
                           4-9

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Accurate information  on  subsurface  conditions  win  be the most
difficult to obtain.  Surface  features  can  be  observed directly
and maps are usually  available including  those used in Part A and
Part B permit applications.  The  age  of each  unit  may be  a matter
of record; however,  for  older  units,  knowledge of  local  govern-
ment personnel should confirm  owners'  statements.   The depth  of
fill can be estimated by  comparing  contour  maps  of the area,
before and after  filling.  Depth  to ground  water or bedrock may be
available from on-sits or nearby  water  wells  including ground-
water monitoring  wells.   Soils classifications may  be available
from boring logs  of  ground-water  monitoring wells.   However they
may describe the  soils only  on two  sides  of the  site.   Other  bor-
ing logs may be available from local  water  well  or construction
drilling firms or local  offices of  the  Soil Conservation  Service
In some instances,  soil  boring may  have to  be-made.

4.2.1.2  Example  Application
The predictive model  is  best explained  through the use of an
example situation at  a hypothetical landfill.  The  example and the
migration model and  associated graphs were  taken from the Open
Dump Inventory Manual.   The  example landfill  is  shown in  Figure
4-1.  Both a plan view and two cross  sections  of the landfill  are
shown.  They include  most of the  physical  data needed for the
model.

Other information includes the age  of  the landfill  since  it first
received waste and  soils  information.   In Figure 4-1, soils are
                                4-10

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»*.
                              I     »r.
                                                           ATMkMI.
                 Figure 4-1



              Examole Landfill
                    4-11

-------
shown as either sand or  clay  and  are  assumed to  be  uniform from
the surface to the ground-water level.   Site-specific  soil  data
should be available.  Soils may be  described by  names  or via a
classification system.   A  common  system  is  the USCS  Classifica-
tion.  Soil names, USCS  Classification,  and related  graph use in
the model are shown below.

Soil Name	       USCS Classification     Graph  Use
Clean (no fines)
gravels  and sands        GW,  GP,  SW,  SP              Sand

Silty gravels and  sands,
silt, silty and sandy
loan, organic silts      GW,  SM,  ML,  OL,  MH         Interpolate

Clayey gravels and
sands, lean, fat  and
organic  clays            GC,  SC,  CL,  CH,  OH         Clay

The model includes three basic steps.  The  first is  the  estima-
tion of  migration  distances related to the  landfill's  age and type
of soil   being evaluated.   The next  two steps apply  correction fac-
tors related to the depth  of  the  landfill  and to the degree to
which surface venting is likely.

Figure 4-2 is the  graph  for the uncorrected migration  distance.
To use the graph  the age of the landfill  and the soil  type must
                                4-12

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be known.  Enter the graph at the  site's  age.  Continue  up  to  the
curve describing the soil type and concentration  of  interest.
Contours (migration distances) should  be  drawn for both  5 percent
and 1.25 percent methane.  If the  soil  type  is between day  and
sand, interpolate between the curves.   If in  doubt about soil
types use the sand curves as the worst  case  (greatest migration
distance).  Read the uncorrected migration distances (5  percent
and 1.25 percent) on the vertical  axis.   For  the  example  landfill
in Figure 4-1, the uncorrected 5 percent  methane  migration
distances for a 10-year old landfill would be (Figure 4-2):
     Section A-A:  East side, 10 years, sand  = 165'
                   West side, 10 years, sand  = 165'
     Section B-B:  South side, 10 years,  sand = 165'
                   North side, 10 years,  clay = 130'
The corresponding uncorrected distances for  tfie 1.25 percent
methane migration would be:
     Section A-A:  East side, 10 years, sand  = 255'
                   West side, 10 years, sand  = 255'
     Section B-B:  South side, 10 years,  sand = 255'
                   North side, 10 years,  clay = 200'
The next step is the selection of  a correction factor related  to
the depth of the landfill.  The deeper  the waste, the greater  is
the potential migration distnce.   A graph  of  depth correction
factors is shown in Figure 4-3.  Enter  Figure 4-3 with the  unit's
age along the horizontal axis.  Move upward  to the appropriate
depth curve.  The correction factor is  found  on the  vertical axis
and ranges from - 0.5 to + 2.2.  Note  that the curve for a  land-
                               4-13

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                                                                 fl
                                              •         10        12

                                                  •ITE AOC-ViARI
                                                                        14
II
20
                                                Figure 4-2
                                 Unconnected  Methane Migration Distance

-------
fill 25 ft deep is  a  straight  line  and  yields  a  correction  factor
of 1.0.  For units  of  different  depths,  interpolate  between the
curves,  The depth  corrective  multipliers  for  the  example  site
would be:
     Section A-A:   East  side,  10 years,  20'  deep =  1.0
                    West  side,  10 years,  20'  deep =  1.0
     Section B-B:   South  side, 10 years, 10' deep =  0.95
                    North  side, 10.years, 50' deep =1.4

The corrective factors for  the surrounding  soil  venting conditions
are next obtained using  the  graph in  Figure 4-4.  This graph  is
based on the assumption  that the surrounding surficial soil  is
impervious 100 percent of the  time.   Thus  the  value  read from the
graph must be adjusted,  based  on the  percentage  of  time the
surrounding surficial  soil  is  saturated  or  frozen and the
percentage of land  along  the path of  gas migration  from which gas
venting to the atmosphere is blocked  all year  (asphalt or concrete
roads or parking lots, shallow perched  ground  water,  surface  water
bodies not interconnected to ground water).  The totally
impervious corrective  factors  on the  vertical  axis  of Figure  4-4
are only used when  the landfill  is  entirely  surrounded at all
times by these conditions.   An adjusted  corrective  factor  is
obtained by entering  the  chart with site age and obtaining  the
totally impervious  corrective  factor  for the appropriate depth and
soil type and then  entering  this value  in  the  following equation:
     Adjusted corrective  factor = [{Impervious corrective  factor
        from Figure 4-4)  -  1] x  (%  of impervious time or area] +  1
If both time and area adjustments are necessary, the percentages
are additive.  Estimates  to  the  nearest 20  percent  are sufficient.
                               4-14

-------

• - • - • • • ' .. i .''.'".:
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^ 5 ,«•' ...«:-''
tn *•• ill
I ,:.;}•{ fr t
„ 1 « ' .... 26


' ••••'•
- - - **- • • - • 1
• - ' - - - - -
_jl ........ 1 .... ^ -

-------


- - - - • - - - - • - 	

. . _ . ... ._ _ 	 _ ..

, , • taa* O*«P
' * * _1
	 s • ' !r 	
i
«
- - - - - - - - - 	 — • - - - -
--•••-•--- 1 ,,. 	 • 	 • •

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	 - • ..-.--. 	 	 - 	 -
1' DEEP 	 '...''.'...I.'. . . ........ . , ". . . . . :




.... 	 - . - 	

	 	 - . . - - - 	 - .

	 - ..... _ 	
- 	 -...--.
10
                                     12
tO
                   Figure 4-3



Correction Factors for Landfill Depth Below  Grade

-------
I
I—•
en
                                                                              IMPERVIOUS-BO* DEEP
                                                                IMPEHVIOUB-IOO* DEEP
                                                               TTTTnnrrrrnwffl
                                                                IMPEHVIOUS-IOO' DEEP
                                                                                    IMPEnviOMB-2B' DEEP
                                                      •         10        12

                                                          GlfE AQE-VEAHS
M        ia
                                                         Figure 4-4

                           Correction Factors  for Soil  Surface Venting Condition Around Landfill

-------
When  free  venting  conditons are prevalent most of the year, simply
use 1.0  (no  correction).   For depths less than 25 feet deep, use
the 25 foot  value.   For the example site, the adjusted corrective
factors  for  frozen  or wet soil  conditions 50 percent of the year
are:
   Section A-A:  East side (ignore
                 narrow road,  sand,
                 20'  deep, 10  years  old)  = (2.1-1)  (.50) +1  = 1.55
                 West side (sand,  20'
                 deep,  10  years  old)     = (2.1-1)  (.50) +1  = 1.55
   Section B-B:  South  side (sand,  10'
                 deep,  10  years  old)     = (2.1-1)  (.50) +1  = 1.55
                 North  side (clay,  50'
                 deep,  10  years  old)     = (1.4-1)  (.50) +1  = 1.2

For ease of  calculation,  the  above  data  are  entered  into a  table
similar  to Table 4-2.   Table  4-2  includes the data  from the
example  problem.  The  corrected distances of probable  gas
migration  resulting  in 5  and  1.25 percent concentrations in each
direction  from the  landfill are obtained  by  multiplying across  the
table for  each side  of the landfill.   These  values  can then be
plotted  on the scale plan as  contours  of  the 5 and  1.25 percent
methane  concentrations or simply  compared to the  distnces from  the
waste deposit to structures of  concern.

The corrected distances from  Table  4-2 are plotted  on  the map  in
Figure 4-5 and the  resulting  contours  sketched.   Mote  that  surface
water along  the  western and southern boundaries  are  barriers to
gas migration and override the  distances  in  Table 4-2.
                               4-17

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-pi
I
Landfill Methane Uioorrected
Side Concentration Distance
E 5%
1.25%
W 5%
1.25%
S 5%
1.25%
N 5%
1.25%
165'
255*
165'
255 '
165 •
255 •
130'
200 '
X
X
X
X
X
X
X
X
Correction
for Depth
1.0
1.0
1.0
1.0
0.95
0.95
1.4
1.4
X
X
X
X
X
X
X
X
Correction Corrected
for Venting Distance
1.55
1.55
1.55
1.55
1.55
1.55
1.2
1.2
- 256'
- 395 •
- 256* *
«= 3951 *
- 243* *
= 375 ' *
•* 218 •
« 336'


(225* max.)
(225* max.)
(225* max.)
(225* max.)


. . . . t .......
            * IJhen these distances are plotted on  the landfill sketch,  they exceed the distance to the creek,


              which acts as a barrier to the gas migration,   Ihus the distance to the creek is the naxinun


              migration distance.







                                                       Table 4-2



                                      Methane Migration Distance Tabulating Form

-------
            SI-
SI
           Figure i\-*>



Example  Landfill Methane Contours
              4-19

-------
The contour for 5 percent methane  extends  beyond  the  property
boundary.  A release of  subsurface  gas  is  possible  even  if it has
not yet occurred.  The 1.25  percent methane  contour encloses
on-site buildings but does not  reach  off-site  structures.   Thus
there is a possibility of gas accumulation in  on-site structures.
Both contours indicate that  a release of  subsurface gas  (as
defined in Section 1) is possible.   This  should  trigger  concern
for potential risk to human  health.

A situation shown in Figure  4-5  should  lead  to some type of
corrective action as described  in  Section  5.   However, the owner
or operator may want to  demonstrate that  the  risk to  human health
is not substantial.  The fact that  off-site  structures are beyond
both the 5 and 1.25 percent  contours  indicates that problems  in
these buildings are not  likely.  On-site  buidTings  are close  to
the 5 percent contour.   Factors  such  as type  of  construction,
quality of sealing cracks in floors,  or a  gas  monitoring program
may be used to demonstrate that  the risk  is  not  substantial or
that any potential problem will  be  identified  before  damage
occurs.  Thus site-specific  factors may be used  to  confirm or
refute the apparent results  of  the  predictive  model.
Essentially, any  site can be made  safe  from  releases  of  subsurface
gases.  Monitoring programs, construction  techniques,  and  gas
control features  can be  used singly or  in  combination as
warranted.  The corrective actions  that will  provide  advanced
warning or will prevent  future  releases are  described in Section 5.
                                4-20

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4.2.2   Use of Experts
The predictive model may yield  ambiguous  results or either the EPA
or the owner may know of factors  not  considered in the model  that
either raise or lower the  potential  for a release and for a
substantial risk to  human  health.   In such situations, experts in
the area of subsurface  gas  generation and control  should be used.
Experts may also be  used in  lieu  of  the predictive model.   Experts
may be used by either the  regulatory  agency or the owner,  or  both.
If possible, an agreement  to abide  by the expert's findings should
be developed.  If  not,  the  assessment of  the expert's findings by
the regulators will  usually  be  binding on the owner.

Experts in subsurface gas  generation  and  control  are  relatively
rare.  Few are employed by  the  EPA  or States and only a few major
disposal firms will  have experts  on  staff.  Most gas  experts  are
employed by a small  number  of environmental  consulting firms  or by
natural gas utilities;  however,  the  latter are less familiar  with
gases generated at waste disposal  sites and their control.
Identification of  qualified  consulting firms can be made by
contacting the Governmental  Refuse  Collection and Disposal
Association (GRCDA).  GRCDA  is  located in Silver Spring, MD,  and
the telephone number is (301) 585-2898.

Gas experts can conduct detailed  subsurface exploration and
monitoring for the presence  of  gas.   Information obtained through
this field work can  verify  the  extent of  a landfill (both area!
and vertical extent), identify  soil  and other conditions specific
                                4-21

-------
to the site that will encourage  or  impede  migration,  and  identify
gas concentrations at various depth  and  in  directions  related  to
occupied structures.  Predictive models  more  sophisticated  than
the one described above may  be used  or the  expert  may  use past
experience coupled with site conditions  to  assess  the  presence or
potential for a release.

Conditions that would reduce the consequences  of a release  should
also be identified.  These include  the design  and  quality of
construction of buildings.   These impact on the likelihood  that
gas would enter a building if it was  present  in the adjacent soil.
Experts can also recommend systems  that  will  provide  adequate
protection.  These may include relatively  simple and  inexpensive
monitoring systems.  As appropriate,  venting  or barrier systems
for gas migration control can be identified.  "The  experts used
should also be experienced in both  the design  and  operation of
control systems.  Protective systems  may be necessary  as  part  of
permit conditions and should be  designed by experienced experts
and the designs be reviewed  by equally qualified personnel.  This
review is particularly important for  designs  submitted by an
owner.
                               4-22

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                            SECTION  5
                       CORRECTIVE MEASURES

5.1  MONITORING PROGRAMS

After the PA/SI is complete,  the owner/operator  may  be  required  to
establish a gas monitoring program for the  site.  A  monitoring
program consists of the design of sampling  probe  types  and  site
locations, well construction  and probe installation, development
of a written protocol  for field sampling procedures, maintenance
of the monitoring wells, data interpretation, and reporting
requirements.  For purposes of this  guidance, a  general  protocol
for subsurface gas field monitoring  is described  below.  This
protocol addresses field data forms, equipment, monitoring  and
sampling procedures, and record keeping for methane  and  the  in-
dicator constituents of concern.

5.1.1  Methane
5.1.1.1 General
An example data form for methane field monitoring is shown  in
Table 5-1.  Data requirements specified include:
     •  General background data.  These include  date and time,
        monitoring personnel, barometric pressure and atmos-
        pheric temperatures,  general weather conditions, and
        the types of instruments used.
     •  Ground-water data.  Most monitoring probes are  expected
        to be dry since they will be installed above the water
        table.  However, precipitation or a rising ground-water
                                5-1

-------
                        Date:
                        T ime:
                                              a.m.  p.m.
                                            Ihstruuients Used:
                                              t Water  Level:
                        Monitoring Personnel:  	
                        Barometric Pressure  Reading:
                        Atmospheric Temperature:  	
           in.  tig
in.  II20
• Probe  Pressure:
• Methane:
       "F
                  •  Barometric Pressure:	
                  •  Atmospheric Temperature:
                        General Weather Conditions:
en
 i
r\j

Well No.
1
Ground Water
QDry
DWel
Probe
No.
A
B
C
Probe Pressure (jn.H;>0) Methane
Gage Absolute % LEL % Gas



Notes



                                   QDry
                                   Q Wet
                                   Q Dry
                                   QWet
A
B
C

A
B
C
                                                                       Table 5-1
                                                 Field  Data  Form  for  Subsurface  Gas  Monitoring

-------
        table can cause  soil  saturation  and  probe  clogging.   The
        condition of the probe  should  be  marked  as  either wet or
        dry.
     •  Probe pressure.  The  pressure  or  vacuum  is  read from a
        pressure gauge.  The  reading then  can  be corrected to
        "absolute" pressure in  conjunction with  barometric pres-
        sure and temperature.   Pressure  is usually  reported  as
        in. of H20 and ranges  from  very  slightly negative to
        about 5 in. H20  positive.
     •  Methane content.  Through the  use  of a combustible gas
        meter, methane content  of the  subsurface gas  can  be
        measured in terms of  percent of LEL or percent  volume in
        air.

Completion of the data form should  be  routine."  The  date  and time
of sampling should be consistent.   That  is,  if field  monitoring
is performed at weekly intervals, use  the  same day  of the week.
For monthly intervals, field monitoring  should be performed  on
about the same day of the month.  Similarly, field  monitoring
should be performed consistently at the  same time of  day,  prefer-
ably in early afternoon  when  subsurface  pressures are most likely
to be positive.

For the barometric pressure reading, a sturdy  field  barometer
should be used.  The current  direction of  movement  (i.e.,  rising,
falling, or steady) should be  recorded.   For each monitoring day,
                               5-3

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a phone call should  be  placed  to  the  National  Weather Service to
obtain a current  reading  as  a  check  of  the  field  barometer's
accuracy.  The barometric pressure  reading  obtained in the field
is recorded on the data  form in  inches  of Hg.   If desired, it can
be converted to  inches  of water  by  multiplying by 13.4.   The
general weather  conditions (i.e., wind  conditions,  snow  or rain,
cloud cover, etc.) and  instruments  used should also be noted on
the form.

5.1.1.2  Equipment
The following equipment  and  other materials  should  be taken  into
the field for each subsurface  gas or  facility  structure  monitoring
round: watch, thermometer (°F  or  °C), barometer  (inches  Hg),
looseleaf binder  notebook,  blank  data forms, copy of protocol,
clipboard and pen, pressure  measuring devices-,-and  combustible  gas
meter.  The gauges used  are  differential  pressure gauges with a 0
to 0.5 inch range or a 0  to  5  inch  range.   Other  pressure reading
accessories might include spare  tubing,  a mounting  board for
leveling, and a  peristalic hand  pump.

The combustible  gas  meter should be calibrated for  methane,  with
percent LEL and  percent  gas  ranges.   Other  accessories might
include spare batteries,  spare aspirator, water trap,  extra
tubing, spare filaments  and  cotton  filters,  and calibration  gas.

5.1.1.3  Probe pressure
The purpose of recording  probe pressure is  to  determine  whether
subsurface gases are  at  a higher or  lower pressure  than  the
                                5-4

-------
atmosphere.  Often,  subsurface  pressures  lag  behind changes in
atmospheric pressure,  particularly  for  deep probes,  and/or probes
that are separated  from  the  ground  surface by relatively imperm-
eable strata.

When subsurface gases  are  found to  have positive  gauge  pres-
sures they can easily  be extracted  from the subsurface,  and an
accurate methane content reading can  be recorded.   However, with
negative pressure  (i.e., vacuum)  relative to  the  atmosphere,  the
tendency is for atmospheric  gas to  move into  the  probe.   The
result is that an  accurate reading  of subsurface  gas  methane
content cannot be  made.  Thus,  a methane  reading  should  be taken
only when probe pressures  are zero  or positive.

To determine probe  pressure, the following steps  should  be
employed:
     •  Zero the gauge in  the vertical  position using the zero
        adjustment  screw located in the plastic cover at the
        bottom of  the  gauge.
     •  Connect flexible tubing from  the  "high" (positive) port of
        the gauge  (range of  0 to 0.5  in.  water) to  the  test
        probe.  Connections  must be air-tight,  and  clamps should
        be used if  necessary.   If the pointer moves  to  the left,
        remove the  tubing  from  the  high port  to the low  port.
        For test probes exceeding +_ 0.5 in. water,  reconnect  the
        tubing on  the  same port to  the  0  to 5.0 in.  water range
        gauge.
                               5-5

-------
•  Before recording the  reading,  push  the  tubing  further on
   to the test probe after a period  of time.   If  there  is  no
   sudden increase in pressure,  this  indicates  the  test
   probe and connective  tubing  are both  free  of foreign
   material that might clog these openings,  and could
   otherwise give false  readings.  Record  the  pressure
   reading on the data form.
•  If the pressure increases perceptively  as  the  tubing is
   slid further onto the  test probe,  the test  probe  is  like-
   ly clogged with foreign material,  or  filled  with  water
   (i.e., either condensate or  ground  water).   This  indicates
   that the gas between  the tube  blockage  and  the pressure
   indicator becomes compressed  as the tube  is  pushed further
   on.  The test probe and connective  tubing  should  be
   separated.  The end of the test probe "should be  inspected
   for water, debris, or  other  foreign material.  If these
   are present, they should be  removed.
t  If the spurting pressure response  remains,  but no foreign
   material appears to be present, the test  probe is probably
   filled with ground water or  condensate.   A  peri static
   hand pump should be used for  approximately  10  to  15
   seconds to force air  into the  probe and flush  ground
   water or condensate through  the bottom  perforations.
   After this has been performed, the  pressure  indicator
   tubing should again be attached to  the  probe,  and the
   procedures above repeated.   If a  valid  reading can be
   obtained, it should be recorded.
                           5-6

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Differential pressure  gauges  are  fairly  accurate  devices,
requiring little maintenance.   For  quality  control  purposes,
checks should be made  of  their  readings  from  time to  time.   It is
suggested that instruments  used regularly in  the  field  be  returned
to the manufacturer  every  six months.  This will  allow  accuracy
checks to be made, and  appropriate  repairs  and  recalibration  to be
performed.

5.1.1.4  Methane monitoring
The determination of methane  content  is  the most  significant
parameter of the monitoring program.  Methane is  colorless, odor-
less, explosive, and an excellent indicator of  subsurface  gas
migration.
Combustible gas meters  are  available  from several  manufacturers.
Generally, filaments inside the instrument  aVTow  measurement  of
combustible gases on either the percent  LEL or  percent  gas  (volume
in air) scales.  The scales are typically printed on  the meter's
face with a switch used to  select the desired range.

Besides the instrument  itself,  inlet  and outlet tubes are  usually
provided.  The inlet tube  allows  connection between the meter and
the gas probe being monitored.  The outlet  probe  usually has  a
hand-held aspirator  on  it.  This  creates a  vacuum for gases  to be
drawn through the meter.

To determine methane content, the manufacturer's  instructions
should be followed and  the  following  general  steps should  be
employed:
                                5-7

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     t  Set the  on/off  switch  to  the on position.
     •  Zero the meter  on  both  ranges  alternately  by
        following  the manufacturer's instructions  until
        the needle  remains  on  zero  when atmospheric air
        is drawn through  the meter.
     •  Connect  inlet tube  to  test  probe.   The  connection
        between  the instrument  and  test probe must be com-
        pletely  air-tight.  Clamps  should  be used  to ensure
        air-tight  conditions at connection of 2 tubes.
     •  Set the  "range"  switch  to the  0 to 5 percent volume
        in air  scale.   Squeeze  the  aspirator bulb  to draw gas
        from the test probe into  the instrument.   When the
        needle  stabilizes,  record the  methane  reading on  the
        data form.   If  the  needle goes off the  0  to 5 percent
        volume  in  air scale, set  the range swftch  to the  0 to
        100 percent volume  in  air scale and take  the reading.
        If the  aspirator  remains  deflated  or does  not inflate
        within  2 seconds  after  squeezing,  disconnect the  inlet
        probe from  the  test probe.   If the aspirator bulb then
        inflates,  the test  probe  may be clogged and/or saturat-
        ed with  water.   Check  the water level  and  repeat  the
        procedure  described earlier  for pressure  monitoring.

Before each monitoring  round,  a calibration gas should be used to
check the accuracy  of the  instrument.   If  recalibration  or other
repairs are required, the  instrument should be  returned  to  the
manufacturer.   Regardless  of comparisons between  calibration gas
                                5-8

-------
gas and actual readings,  the  instrument  should  be  returned  to  the
manufacturer every six months  for  routine  maintenance  and  repair.

5.1.1.5  Interpretation
To interpret gauge pressure readings  and barometer  conditions
the following combination of  possible  field  readings are cited:
     t  Gauge Pressure Positive, Barometer Falling.  Under
        these circumstances,  subsurface  pressures are  higher
        than atmospheric  conditions.   Monitoring personnel
        should get an accurate  reading of  any methane.  This
        condition increases the  potential  for methane  migration.
     0  Gauge Pressure Positive, Barometer Rising.  This con-
        dition is unusual and  it will  exist  for only a  short
        time.  Normally,  when  atmospheric  barometric readings
        are rising,  subsurface  pressures lag 'behind, causing
        negative subsurface gauge  pressures.  As long  as gauge
        pressure is  positive,  accurate subsurface methane  read-
        ings are likely.
     •  Gauge Pressure Positive, Barometer Steady.  Under  these
        circumstances, subsurface  pressures  are higher  than
        atmospheric.  With barometric  pressures steady, subsur-
        face absolute pressures  are likely to decrease  to  atmos-
        pheric levels.  Field  personnel  should  be able  to  take
        accurate subsurface methane readings.
     •  Gauge Pressure Negative.   When subsurface  gas  is at  a
        lower pressure than atmospheric, air will tend  to  be
                                5-9

-------
        drawn into the subsurface, diluting  gases  there.
        Thus accurate sampling cannot  be made when  subsur-
        face gas is negative with  respect  to atmospheric
        pressure.
     0  Gauge Pressure 0.   If this is  an accurate  reading  and
        is being measured on the 0 to  0.5  in. range of  the
        meter it should be  a temporary condition.  Methane
        meter readings should be attempted.  If subsurface
        gauge pressure remains 0 over  several days, the probe
        is likely clogged with condensate  or moisture.  A peri-
        static hand pump or wire should be used to unclog the
        tubing.

To interpret methane content readings, the following combinations
of instrument readings allow evaluation of subsurface gas
migration potential:
     •  0 Percent LEL, 0 Percent Gas.  If  these readings are
        taken in conjunction with a positive subsurface pres-
        sure reading they are an indication  that subsurface soils
        are truly "clean" of any combustible gases.
     •  1 to 25 Percent LEL, 1 to 1.25 Percent Gas.  These  read-
        ings indicate that  some migration  of combustible gases
        from a SWMU may be  occurring,  but  at sufficiently  low
        levels that a release is not likely.  However,  an  in-
        crease in the methane monitoring frequency may  be  appro-
        priate.
                               5-10

-------
     •  25 to 100 Percent LEL, 1.25 to 5 Percent Gas.  These
        levels of combustible gas indicate that a  release has
        occurred if measured within any structure  on  the
        facility.  They are reason for concern, and contingency
        activities should be implemented.  These include
        increased frequency of methane monitoring, ventilation,
        or other emergency response measures.
     •  More than 100 Percent LEL, 5 to 100 Percent.Gas.  This
        indicates an emergency condition inside a  structure.
        See Section 4.1 related to emergencies.  If methane at
        these levels is found in the soil at the property line,
        a release has occurred.  Some corrective actions should
        be implemented in the near future unless the  likelihood
        of human exposure is remote, e.g., no occupied buildings
        within 1/4 mile.  If these concentrations  are found be-
        tween a unit and the property boundary, gas migration is
        occurring.  Some corrective actions should be planned
        and monitoring frequency increased.

5.1.1.6  Record Keeping

The field data form for field gas monitoring included earlier as
Table 5-1 should be completed each time that monitoring activities
for methane and subsurface pressures are performed in the field.
These forms should be collected in a single loose!eaf binder
notebook.  Other observations about well conditions,  weather
conditions, and contingency actions taken should also be recorded
in the appropriate spaces for "Notes".
                               5-11

-------
Field monitoring data  should  be  evaluated  by  the  facility  owner or
operator in a timely manner.   If  a  release  has  occured,  EPA  per-
sonnel should be notified  and appropriate  field data  forms should
be transmitted.
Chronological logs  should  be  kept for  each  monitoring well  and
each probe in the well.  Review  of  this  historical  data  will  in-
dicate trends of migration  and will  aid  in  predicting if and  where
a release may happen.

5.1.2  Indicator Constituents of  Concern
5.1.2.1  General
The monitoring  procedures  described below  are  for  sampling of
vapor-phase  (volatile)  organics  present  in  subsurface gas  at  a
facility boundary or in  ambient  air within  a  facility structure.
Several methods of  sample  collection are acceptable depending on
site conditions, concentrations,  and method of  analysis.   Anal-
ytical methods  are  not  presented  in this guidance.  Development  of
a monitoring program for the  indicator constituents of concern,
field sampling, and subsequent laboratory  analysis  should  be  con-
ducted by qualified personnel.

To monitor for  the  volatile organic constituents  (VOC's) similar
procedures performed during methane monitoring  are  appropriate.
For example, probe  pressures  should be monitored  and  if  negative,
collection of VOC samples  should  not be  performed.  If probe  pres-
sures are positive, a VOC  sample  may be  obtained.
                                5-12

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5.1.2.2  Equipment
The following equipment  is  typically  used  for collection and
concentration of VOC's onto  adsorbent traps.   Alternatively,
volumetric samples can be obtained  from  the  well  probes  or from
within structures.  Figure  5-1  illustrates a VOC  sampling  assem-
bly appropriate for monitoring.

     •  A portable field  sampling pump is  necessary  for  VOC
        sample collection.   The  pump  should  be  capable of
        operating on 110 volts  AC or  12  volts DC.  This  por-
        table vacuum pump should maintain  constant flow  for
        the duration of  the  sampling  and be  explosion-proof.
     •  An adsorbent trap appropriate to the VOC  being monitor-
        ed should be selected.   Trap  materials,  sizes, and adsor-
        bent resins are  variables that qualified  personnel must
        determine to fit  site conditions.  Typically,  sample
        traps are glass  or  stainless  steel.
     •  A glass-tube, variable-area flowmeter (rotameter)  can  be
        used to accurately  set  and maintain  the  gas  flow rate
        through the sample  trap.  The rotameter  is available
        through a variety of manufacturers.   It  should be  capable
        of accurately measuring  flows up to  30  to 50 ml  per
        minute and include  a standard needle-type metering valve.
        The rotameter is used during  the calibration procedures  to
        set the metering valve  at the desired sampling flow  rate.
                                5-13

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Gas Probe

Simol 119 ?robe
Toggle
Shut -off
N/l

/N
/alve
Re

tameter
Togg
Shut-
N/^
L/N
Valv
e
off
e \


Trap
\

Teflon


Putnp
Tub ino

F



iuflble
owneler
     Figure 5-1



VOC Sampling Assembly
         5-14

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   Throughout the  sampling  period,  the rotameter serves as a
   check that the  desired flow  rate is maintained.
•  A gas chromatography-type  bubble flowmeter can be used
   to accurately calibrate  the  sampling assembly.  While
   the sampling pump  is  intended  to deliver constant flow
   rates from the  gas  probe,  pressure  variations may occur
   throughout the  sampling  assembly.   During the initial
   calibration procedures,  the  bubble  flowmeter  is  used to
   determine the gas  flow rate  through a calibration trap.
   During actual sampling,  several  readings  are  taken  from
   the bubble flowmeter  to  accurately  measure the flow rate
   through the sample  trap.   A  10-ml bubble  flowmeter  is
   typical for the volatile organic gas  samples.
0  Toggle-type shut-off  valves  can  be  placed upstream  and
   downstream of the  rotameter.   These sfiut-off  valves are
   used to test for a  complete  gas  seal  along the sampling
   assembly prior  to  sampling and to stop  gas flow  to  the
   sample trap after  the desired  sampling  volume  has been
   attained.

•  A spare parts box  is  recommended to supply the necessary
   replacement fittings, extra  bubble  flowmeter,  miscellan-
   eous tools, and special  plumbing required.  Assorted fit-
   tings and tools, such as screwdrivers,  adjustable and
   open-end wrenches,  tubing  cutters,  Teflon tape,  etc.,
   should be available.
                          5-15

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     •  Teflon tubing  (1/8 in.  OD)  is  typical  for  small  flow
        rates.  The tubing is  used  to  make  connection  between
        the gas probe, the rotameter,  and the  sample  trap.
        Larger tubing  (1/4 in.  OD)  may  be necessary between
        the sample trap,  the pump,  and  the  bubble  flowmeter.

5.1.2.3  Preparation of Sample  Traps
The sampling traps must be prepared in  the  laboratory  prior  to
field collection.  This includes  proper  packing, sealed  fittings,
and "bake-out" of extraneous organic compounds.  Specifically,
virgin adsorbent resin should  be  extracted  in  a  Soxhlet  apparatus
for a minimum of 18 hours prior to  use.  The sorbent  should  then
be dried in a vacuum oven and  subsequently  sieved  to  provide a
desired packing fraction.  This fraction is used to pack  the traps
which are then conditioned with an  inert gas flow  for  an  appro-
priate time.  Afterwards, they  should  be capped  and stored.

More than a single sample should  be taken at each  field  sampling
site to ensure that a  sample will be available for analysis.
Sampling with adsorbent resins  results  in a "one-time" analysis
opportunity on the laboratory  instrument.   When  a  sample  is
desorbed and run through  the gas  chromatography/mass  spectrometer
(GC/MS), that sample cannot be  reanalyzed.  At a minimum,
duplicate samples must always  be  taken  for  each  sampling  site  (gas
probe).  The purpose of these  duplicate  field  samples  are two-
fold:  (1) if a sample is lost, either  during  shipping or
laboratory analysis, then the  field duplicate  serves  as  an
                                5-16

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identical back-up  sample,  and  (2)  for  quality  assurance purposes,
duplicate pairs should  be  periodically analyzed by GC/MS to
establish the precision  of the  sampling technique.

The size of the sample  depends  on  the  type  of  sample trap  and the
site being sampled.   Often landfill  and subsurface gas  streams
yield complex matrices  of  volatile organic  compounds.   Highly
concentrated gas  streams can  saturate  the adsorbent resin,  and
breakthrough occurs  during sample  collection.   Thus,  when  samp-
ling a previously  unsampled site,  or a site of high variability,
samples should be  taken  at different volumes to establish  the
optimum sample volume  for  an  individual  site.

A permanent log of field sampling  must be maintained throughout
the collection period.   A  recommended  format "For data recording  is
shown in Table 5-2.

5.1.2.4  VOC Monitoring
To accurately sample  the indicator constituents of concern,  the
following general  steps  should  be  employed  for collecting  and
concentrating the  VOC's.
     •  Libel and  set  aside a  sample trap to be used for cali-
        bration purposes only.   Only one calibration trap  is
        necessary  per  sampling  round.   This calibration trap is
        used to set  the  desired flow rate of gas through the
        sampling assembly  at  every site (gas probe).
                                5-17

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                                      Table 5-2
                                 VOC Field Data  Form
Date:
Weather: 	
Barometric Pressure:
Air Temperature  (°F):_
Sampl ing  Personnel :_

Trap
Number












Time of
Day
(hr :min)












Elapsed
Time
for 10 ml
(sec.)












Fl ow
Rate
(ml /min)












Rota-
Meter
Reading
(ml /min)












Total
Sample
Time
(min :sec )


-_•









Sample
Vol ume
(ml)












Sar
Well
No.












nple Sit
Probe
No.












:e
Depth
(ft)





i
I





                                           5-18

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•  Prior to sampling,  determine  the volume and number of
   each type of of  sample  to  be  taken.   Set aside the
   necessary number of traps,  including traps for dupli-
   cate samples.  In addition,  set aside a sample trap
   and label it "field blank".   For every 25 sample traps,
   two field blank  traps  should  be set  aside.  Handle all
   of the traps in  a similar  manner.  Use a Ziplock plastic
   bag to store all  traps  as  samples  are collected.
•  The purpose of the  field blank  is  to ensure that no
   sample contamination occurs  during sample shipment and
   handling.  The field blanks  are analyzed in the labora-
   tory, but will not  have subsurface gas passed  through
   them.
•  Leak test the gas sampling  using the following steps:
   - Ensure that all connections are  free of dirt and
     moisutre.
   - Install the calibration  trap.   Use appropriate fit-
     tings for all  connections.
   - Close the toggle  valve on  the rotameter's inlet side
     (nearest the gas  probe)  and turn on the sampling pump.
   - Check to see if flow  is  detected by the bubble flow-
     meter when the needle control  valve of the rotameter
     is fully opened.
   - If flow is detected,  check  the entire gas sampling
     system for leaks.  Replace  Teflon  tape or fittings at
     suspected leaks.
                           5-19

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   - As an additional  check,  test the second toggle valve
     (on the rotameter's  outlet  side) in  the same manner.
   - If a no-flow condition  is  detected using the bubble
     flowmeter, the  system  is  free  of leaks.  Leak test the
     gas sampling assembly  at  each  monitoring well.
•  The gas flow rate can  be  calibrated as  follows:
   - Close only the  second  toggle valve (on  the  rotameter's
     outlet side)-   The first  toggle  valve remains open.
   - Install the calibration  trap and turn the sampling
     pump on.
   - Open the  second toggle  valve to  allow subsurface  gas
     through the sampling assembly.
   - Adjust the flow using  the  needle control  valve on the
     rotameter so that a  desired  flow rate is  established
     from bubble flowmeter  readings.   As~a minimum, tripli-
     cate readings of  the bubble  flowmeter (start time at
     0 ml and  end time at 10 ml)  should be used  to establish
     the flow  rate.
   - Close the second  toggle  valve  (rotameter's  outlet side),
     shut off  the sampling  pump,  close first toggle valve,
     and remove calibration  trap.
   - Do not change setting  of  the needle  control  valve on
     the rotameter while  the  series of volatile  organic
     samples is being  collected,  but  do calibrate the
     sampling  assembly for  each  probe.
•  Sample collection should  be completed  by  following  these
   steps:
                           5-20

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   - Select a sample trap,  note  the  identification  number
     in the field notebook,  and  install  the  trap  in  the
     sampling assembly.  Determine and  record  the required
     sample volume.
   - With the first toggle  valve  open and  the  second toggle
     valve closed, turn on  the sampling  assembly.   Open  the
     second toggle valve and start the  stopwatch  (one  of two)
     to measure elapsed sampling  time.
   - Time and calculate the flow  through the bubble  flow-
     meter using the second stopwatch.   Calculate the  time
     to obtain the required sample volume  (if  different
     from the previous calibration test).
   - Monitor the gas flow through the rotameter by  visually
     inspecting the scale.   Close the second toggle  valve
     and stop the stopwatch at the time  needed to obtain the
     required sample volume.  Shut off  the pump.
   - Close the first toggle valve.   Remove and securely  cap
     the sample trap.  Place trap in Ziplock bag.
   - Reset the elapsed time clock/stopwatch.   Repeat the
     above steps for all samples.
•  All  traps and sampling devices should be  subject  to
   similar handling, shipping, and storage conditions.   A
   chain-of- custody from sample  trap preparation through
   GC/MS analysis and ultimate "bake-out" must be established
   and strictly enforced.   The chain-of-custody should be as
   streamlined as possible.   That is, the  samples should not
                           5-21

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        change hands frequently,  should  not  be  shipped  using
        unknown conditions, and  should be  received  and  analyzed  in
        an expeditious manner.

5.1.2.5  Handling and Record Keeping
The VOC samples collected  using  sorbent  traps must  be capped with
proper fittings.  Each sample should be  labeled appropriately with
sample number, sample location,  date, etc.,  and immediately stored
in a cool, dry container.  Care  should be  taken with regard to the
integrity of the airtight  seal and  the storage  location to avoid
direct contact with heated surfaces.  If the ambient temperature
is expected to rise above 80°F (26.5°C)  during  shipment or
storage, the samples should be placed in a container that can keep
the samples below that temperature.

Sample analysis should be performed as soon  as  possible following
collection.  All analyses  should  be completed within seven days
following receipt of samples in  the laboratory -

5.1.2.6  Interpretation
To interpret the analytical results from VOC sampling,  the
laboratory should convert compound-specific  concentrations to
volume parts per million (Vppm).  Levels detected can then be
compared with compound PEL's (in  Table 1-2 or 1-4)  to determine  if
a release has occurred.  As for  methane, if  a release is
documented, EPA personnel should  be notified and appropriate field
and laboratory data forms  should  be transmitted.
                                5-22

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5.2  CONTROL SYSTEMS

If a release has occurred,  a  subsurface  gas  control  system may be
required to prevent potentially  harmful  migration  into  facility
structures or beyond  a  facility  boundary.   Selection  or evalu-
ation of a system to  control  subsurface  gases  must consider
several site-specific characteristics  including:
     o  Landfill, ground water,  and  bedrock  depth.
     o  Age, composition,  and moisture content of  the waste.
     o  Distance to property  boundary and  facility  structures.
     o  Type and location  of  proposed on-  and  off-site  develop-
        ments.
     o  Soil characteristics.
     o  Characteristics of cover material  and  final  surface
        treatment.
Control systems can be  either passive or active.   In  some  in-
stances, passive control systems such as interceptor  trenches  or
barriers can provide  adequate control for  migrating  subsurface
gases.  However, in general,  when a  facility surface  or adjacent
property is developed for  public use, passive  control methods  are
used as backup for an active  subsurface  gas  control  system.

5.2.1  Passive Systems

Two types of passive  systems  are commonly  used to  control  gas
migration from landfills and  can be  employed at other sites closed
as landfills or possibly for  underground tanks.
                                5-23

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Passive vents provide  a  permeable,  low resistance  pathway to the
surface for gases moving laterally  from an  SWMU.   The intercepted
gases are vented safely  into  the  atmosphere.

Installation of passive  vents  can  be  by excavation of a  trench,
subsequently backfilled  with  gravel  or crushed stone. An alter-
native is a series of  well  points,  essentially performing the  same
venting function.  However, well  points are not always an effec-
tive control system.   Passive  vents  are typically  installed  around
landfill perimeters  to protect adjacent areas  as  shown in Figure
5-2.

A passive trench barrier shields  or  isolates areas from  subsurface
gas migration by installation  of  an  impermeable material.  A
passive trench barrier promotes gas  venting thorough  the  more
permeable soil adjacent  to  the trench  by  blocking  the lateral
movement of gas and  forcing it to  move upward  to  the atmosphere.
This system is created by excavating  a trench  and  backfilling  it
with either an impervious synthetic  liner or compacted clay  soil.

The advantages of passive vents and  trench  barriers  include:
     1.  Operation and maintenance  costs  are low  and initial
         capital costs are  generally  lower  when compared to
         active gas  control systems.
     2.  The effectiveness  of  passive  control  system is  not  de-
         pendent on  power supply  and  mechanical dependability.
                                5-24

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                           Plan View
BUILDINGS
     PASSIVE
     TRENCH VENT
     REFUSE
                        Section View
                   LANDFILL GAS VENTED"
                   TO. ATMOSPHERE
                    y^t
      &£%S&8-3
     > 00~ V^V'O.
nC  .'. ' \?L'»^-S?--:?>.LV!?l
                                            •VENT PIPE
                      LANDFILL
                       GAS FLOW
                                                  PASSIVE
                                                  TRENCH VENT
           £&$.$>$&
   .x-j IMPERVIOUS  LAYER OR  GROUND WATER  TABLE
                           Figure 5-2

                     Gas Migration Control Vents
                              5-25

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     3.  Passive  systems  do  not pull  surface air into the waste
         mass, posing  a potential  combustion hazard.   Rather they
         only collect  and vent migrating subsurface gases.
     4.  Construction  methods  are  relatively simple.
     5.  A properly  designed and installed passive  system can
         provide  effective gas control  for many  years.

Some disadvantages of  passive  systems  include:
     1.  Due to construction equipment  limitations,  passive  trench
         barriers become  prohibitively  expensive at depths  greater
         than 30  feet.
     2.  Passive  systems  alleviate migration but do not  serve  as
         control  devices  unless  they extend to the  ground water
         table, to another impervious zone,  or below  the  greatest
         depth of migrating  gas.
     3.  Passive  systems  may become covered over at the  surface.
         This restricts their  effectiveness  and  does  not  provide
         a permanent pathway to  the surface.

5.2.2  Active Systems
Active control systems include extraction  well or trench  systems
and air injection well or trench  systems.   Perimeter  extraction or
injection well and trench systems  are used to control 1 off-site
gas migration.  Well  extraction  and subslab  extraction or
injection systems are  designed to  protect  on-site facilities.
                                5-26

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5.2.2.1  Perimeter  Extraction  Wells
These systems  consist  of  a  series  of vertical  wells installed
along the  perimeter of the  SWMU.   Extraction wells are connected
by a common  horizonal  header pipe  to a suction blower.  Extracted
subsurface gas  is  subsequently vented, flared, or incinerated.

Perimeter  extraction well systems  are typically installed in  sites
20 feet or deeper where  there  is  little or no  distance between  the
limits of  deposited refuse  and the property line or off-site
facility to  be  protected.

The electrically driven  suction blower for the perimeter system
creates a  negative  pressure in the extraction  well  which is
extended as  a  negative zone of influence into  the waste around
each well.   Wells are  spaced such  that their zones  of  influence
overlap.   Gas  generated  or  migrating into an area of influence  is
drawn to the wells  from  the soil  surrounding the SWMU.

To verify  system effectiveness, monitoring wells are typically
installed  along the property line  or between the wells and  the
area requiring  protection.   Data  collected from the monitoring
wells are used  to adjust  extraction rates to obtain the desired
control.

Venting collected gases may pose  odor and/or air quality problems;
therefore a  flare may  be  required  to combust collected gases.   The
cost for perimeter  extraction  well  systems is  dependent on  depth
                                5-27

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and density of the waste  mass,  and  any  flaring requirements for
recovered gases.

5.2.2.2  Perimeter Extraction Trench.
These systems consist  of  a  gravel-filled  intercept  trench
containing perforated  pipe.  The  perforated  pipe  is connected  by
laterals to a collection  header and  suction  blower.   Collected
gases are vented  or  flared.  Perimeter  trench  systems are
installed in natural soils,  and are  applicable to shallow  SWMU's,
20 feet deep or less.  The  suction blower  creates a negative
pressure in the intercept trench  which  has an  influence  zone
extending toward  the deposited wastes.  Gas  migrating into this
zone is drawn into the perforated pipe, and  subsequently vented or
flared at the blower station.  The gravel  trench  is sealed at  the
surface; it extends  vertically from  the ground"surface down  to  the
refuse depth or to ground water,  and laterally along  the SWMU
perimeter.  Laterals connecting perforated pipe to  the collection
header contain valves  to  allow adjustment  of flow.   As with  other
control  systems,  monitoring  wells to verify  system  performance  are
installed between the  intercept trench  and the property  line or
other location requiring  protection.

5.2.2.3  Perimeter Well Injection.
These systems consist  of  vertical wells installed in  natural soils
between deposited wastes  and the  property  line or area requiring
protection.   Perimeter well  injection systems  are typically
selected for SWMU's 20 feet  deep  or  greater  and having available
                               5-28

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undisturbed soil between  the  limits  of  wastes  and  the  area
requiring protection.   Injection  wells  are  connected by  a common
header pipe to  a blower.  Air is  forced through  header lines  and
wells into the  soils  surrounding  the  landfill  site,  therby
creating a zone of  positive air pressure  around  each well.

Injection wells are spaced such that  their  zones of  influence
overlap, creating an  air  curtain  along  the  perimeter-   Gas  that
migrates toward this  barrier  is blocked by  high  positive pressures
produced by the induction blower.

Monitoring wells are  installed between  the  injection wells  and the
property line or area  being protected.   Adjustment of  wells to
evenly distribute forced  air  is based on  test  data from  the
monitoring wells.

Well injection  systems  provide gas control  for deep  landfills.
However, they do require  some undisturbed ground located between
the limits of the wastes  and  the  area requiring  protection.   Since
this type of system is  installed  in  natural  ground,  there are no
problems with differential settlement.   Forcing  air  into the
system eliminates condensate  and  odor problems associated with
extraction systems.

Reduced permeabilities  in natural  soils relative to  the  deposited
wastes limit the influence area for  an  air  injection well.  More
wells may be required  to  protect  a given  perimeter distance than
                                5-29

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would be required for  the  equivalent  extraction  well  system
located in refuse.  However,  air  injection  systems  do  not  require
a vent or flare for odor control.

5.2.2.4  Perimeter Injection  Trench
These systems are similar  in  design to  the  extraction  trench
described above.  However, air  is  forced  into  the system creating
a positive air curtain  barrier  in  the gravel trench.   Air
injection trenches are  installed  in natural  soils around shallow
SWMU's (20 feet deep or less),  having some  distance  available
between the refuse limits  and the  area  requiring protection.

Air pumped into the injection trench  creates a positive pressure.
This pressure blocks gas migration resulting from convective
forces, and dilutes gas movement  resulting  from  diffusive  flow.

5.2.2.5  On-Site Extraction Well.
Control of subsurface  gas  around  structures  located  directly on
the SWMU requires systems  installed as  an integral  part of the
structure.  These systems  must  be  designed  to  accomodate the
differential  settlement often experienced with landfilled  wastes.

The on-site extraction  well system consists  of vertical extraction
wells placed in refuse  that are connected to a suction blower.
Collected gas is vented or flared.  This  system  is  recommended
when buildings are founded on piles.  However, it is  also
applicable for buildings on floating  foundations.
                                5-30

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These well systems are  typically  installed  in  deep  landfills  with
high generation rates.   Extraction  wells  are  located around
proposed on-site  structures  (or  the area  designed for protec-
tion).  The blower creates a  negative  pressure in the wells.
Wells are spaced  such that the area of influence  of each  well
overlaps, providing a continuous  draw  on  gases generated  or
migrating into the controlled area.  The  extraction rate  is. set to
be slightly higher than  the  gas  generation  rate  (if possible)  to
prevent overpulling and  subsequent  air infiltration in the  waste
mass.

The well and  header systems  must  be designed  with flexibility to
accommodate the differential  settlement that  can  occur at landfill
SWMU's.  Subslab  monitoring  probes  are used to verify system
performance and to aid  in well adjustments.   A~neutral  or slightly
negative pressure is maintained  at  the ground  surface to  preclude
gas venting or excess air movement  into the waste mass.   A  subslab
or sandwiched membrane  liner  is  typically used as backup  to
provide protection during extraction system downtime.   Automatic
sensors can be installed inside  the structures to sound alarms  or
actuate fans  if gas concentrations  reach  levels  indicating  a
release.

Deep well extraction systems, when  combined with  a  backup passive
or alarm system provide  effective subsurface  gas  protection for
on-site structures.  Since these  systems  are  located within the
deposited wastes,  the associated  problems of  settlement,  conden-
                                5-31

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sate removal, odor, and maintenance  exist.   Access  for maintenance
and adjustment of wells must  be  readily  available.

5.2.2.6  Subslab Gravel Bed Injection  or Extraction
These systems consist of a network of  perforated  horizontal
collection pipes installed in  a  gravel bed  beneath  the floor  slabs
of on-site structures.  The gravel bed system  is  not  recommended
for pile-supported  structures.   Collection  pipes  are  connected  by
header pipes to a blower where extracted gas is vented or  flared.
For the injection system, air  is  pumped  to  the pipes  in  the gravel
layer.

Gravel bed systems  are typically  installed  under  structures
located atop shallow fills with  low  gas  generation  rates.  The
suction blower creates a zone  of  negative pressure  in the  gravel
bed.  Gases migrating into this  zone of  influence are collected,
and either vented to the atmosphere  or flared.  Monitoring and
backup membrane systems are installed  similar  to  those for the
deep well extraction systems  described above.   Because subsurface
gases may contain high concentrations  of methane  and  be  present in
the subslab gravel  layer, the  concentration  gradient  necessary  for
diffusion will still exist.   A low-permeability membrane,  such  as
a chlorinated polyethylene material, is  necessary to  insure
adequate protection of the structure.

In the injection system, air  is  forced into  the gravel  bed
providing a zone of higher pressure  and  dilution.   In some in-
                                5-32

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stances, a backup membrane may  not be  necessary in this type of
control system.

Gravel bed systems have  the  disadvantage  of limited access for
repair.  Settlement may  pose  problems  depending on the age,  depth,
and composition of the deposited  wastes.

In summary, both passive  and  active systems can be used
effectively for control  of  gas  migrating  off-site to adjacent
properties, or as an  integral  part of  a  facility to be constructed
directly on the SWMU.  Active systems  involve mechanized equip-
ment.  This fact, coupled with  the dynamic  nature of gas genera-
tion  and migration,  requires  that regular maintenance and
monitoring be  scheduled  for  these control  systems.
                                5-33

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