TSCA LANDFILL INSPECTION
GUIDANCE MANUAL
MARCH, 1990
U.S. ENVIRONMENTAL PROTECTION AGENCY
PESTICIDES AND TOXIC SUBSTANCES BRANCH
REGION V
230 SOUTH DEARBORN STREET
CHICAGO, ILL 60604
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TSCA LANDFILL INSPECTION GUIDANCE MANUAL
CONTi ,5- Page
FORWARD viii
EXCLUSIVE USE OF THIS DOCUMENT . ix
I. INTRODUCTION 1
II. LANDFILL TECHNOLOGY AND BACKGROUND 3
A. LANDFILL SITING CONSIDERATIONS 3
1. Soils 3
2. Hydrologic Condition 3
3. Flood Protection 4
4. Topography 4
B. GROUND WATER PROTECTION SYSTEMS 5
1. General Description and Purpose 5
2. Modes of Chemical Contamination 7
3. Environmental Standards 7
4. Design of a Secure Landfill 9
4.1 Liner Systems 11
4.1.1 Overview 11
4.1.2 Soil Uners 14
4.1.3 Synthetic Liners 14
4.2 Leachate Management Systems 15
4.2.1 Overview 15
4.2.2 Leachate Generation 16
4.2.3 Leachate Collection Systems 16
a. Simple Leachate Collection 18
b. Compound Leachate Collection 18
c. Lysimeters 18
4.2.4 Leachate Treatment 18
4.3 Landfill Cap (Final Cover) Technology 21
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CONTENTS (continued)
Page
4.3.1 Overview 21
4.3.2 Design 21
a. Vegetative Layer 2 3
b. Drainage layer 23
c. Low Permeability Layer 24
d. Optional Layers 2 5
5. Ground Water Monitoring Systems 2 7
5.1 Overview 2 7
5.2 Components of Ground Water Monitoring Systems 2 9
5.2.1 Ground Water Monitoring Wells 2 9
a. Well Placement 2 9
b. Subsurface Investigation 3 0
c. Well Design/Construction - Installation 3 0
d. Well Development 31
e. Surveying 33
C. SAMPLING AND ANALYSIS 34
1. Pre-Sampling Protocol - Ground Water 3 4
1.1 Water Level Measurement 3 4
1.2 Monitoring Well Evacuation 34
2. Pre-Sampling Protocol - Leachate 35
2.1 Leachate Standpipe Evacuation 3 5
2.2 Lysimeter Evacuation 3 6
2.3 Underdrain and Leak Detection System Evacuation 3 6
3. Water Sampling 3 6
3.1 Ground Water and Leachate Sampling 3 6
3.2 Surface Water/Stream Sampling 37
3.3 Field Analyses 3 7
3.4 Sample Containers 3 9
3.5 Sample Preservation 39
3.6 Special Handling Considerations 3 9
3.7 Sample Labels 4 2
• •
I I
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CONTENTS(continued)
Page
3.8 Sample Seals 42
3.9 Field Logs 42
3.10 Chain-of-Custody Record 43
4. Analytical Procedures 46
5. Field and Laboratory Quality Assurance/Quality Control 4 6
5.1 Field QA/QC Program 46
5.2 Laboratory QA/QC Program 5 0
6. Data Analysis and Interpretation 5 0
6.1 Establishment of Background Conditions 5 0
6.2 Statistical Analysis of Monitoring Data 51
6.3 Assessment of Contamination Extent 5 2
III. REGULATIONS AND PERMITTING 53
A. TSCA OVERVIEW 53
1. Introduction 5 3
2. TSCA Synopsis 53
B. TSCA LANDFILL REGULATIONS - PCB CONTROL 5 4
1. Introduction 5 4
2. Landfill Regulations 54
3. Related Disposal Regulations 5 6
4. Related Storage Regulations 5 7
5. Related Marking Regulations 5 9
6. Related Reoordkeeping Regulations 6 0
C. PERMITTING 62
1. Application Process 62
2. Approvals 62
IV. TSCA LANDFILL INSPECTION 63
A. INTRODUCTION 63
B. PREPARATION FOR A TSCA LANDFILL INSPECTION 6 4
1. Review of the Permit (Conditions, Waivers) 6 4
2. Meeting with the Permit Writer 65
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CONTENTSfcontinued)
Page
3. Review of Previous Inspection Reports/Reports of Violations 6 6
4. Formulation and/or Review of Inspection Checklist 6 7
5. Safety and Field Equipment Preparation 6 8
6. Making Inspection Arrangements 7 0
C. THE INSPECTION 71
1. Entry 71
2. Opening Conference 71
3. Scope of Inspection 72
3.1 Monitoring System Integrity 73
3.1.1 Ground Water Monitoring Wells 73
3.1.2 Leachate Collection Systems 74
3.2 Landfill Cell Integrity 74
3.2.1 Landfill Cap 74
3.2.2 Landfill Walls and Berms 74
4. Receiving Area 7 5
5. Storage Area 76
6. Laboratory 7 7
7. Recordkeeping 78
7.1 Annual Reports 79
7.2 Operations Plan Conformance 8 0
7.3 Permit-specific Requirements 80
8. Active Versus Closed Landfill Inspection 81
8.1 Conformance with Permit Conditions 81
8.2 Conformance with Construction Specifications 8 2
8.3 Conformance with the Operations Plan 8 2
9. Sampling 83
9.1 Observation/Supervision 83
9.2 Split Sampling 8 3
10. Closing Conference 84
11. The Inspection Report 8 4
12. TSCA Inspection Checklist 86
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CONTENTSfcontinuedl
Page
V. FOLLOW-UP AND SPECIAL ISSUES 92
A. Follow-up to the Inspection 9 2
B. Special Issues 9 2
VI. REFERENCES 93
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LIST OF TABLES
Table 1 Sample Collection Sequence 38
Table 2 Recommended Containerization and Preservation of Samples 40
Table 3 Analytical Test Methods 47
Table 4 Volatile Organic Compounds, Practical Quantitation Limits 49
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LIST OF FIGURES
Page
Figure 1 Schematic of a Toxic Waste Landfill 6
Figure 2 Schematic of a Toxic Waste Landfill with a Liner/Drain 1 0
Layer System at the Bottom End in the Final Cover
Figure 3 Schematic of a Toxic Waste Landfill with 1 2
Double Liner/Drain Layer Systems at the Bottom
Figure 4 Schematic of a Liquid Routing Diagram 1 7
in a Toxic Waste Landfill
Figure 5 Trench Lysimeter 19
Figure 6a Caisson Lysimeter 20
Figure 6b Caisson Lysimeter 20
Figure 7 Final Cover System Design 2 2
Figure 8 Optional Final Cover System Design 2 6
(Gas Venting System Design)
Figure 9 Optional Final Cover System Design 2 8
(Biotic Barrier Design)
Figure 10 Ground Water Monitoring Well Schematic Diagram 32
Figure 11 Example Field Log Sheet 4 4
Figure 12 Example Chain-of-Custody Form 45
VII
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FORWARD
The Pesticides and Toxic Substances Branch of the U.S. Environmental Protection Agency, Region
V, was tasked by the Office of Pesticides and Toxic Substances to take the lead in the development
of this "TSCA Landfill Inspection Guidance Manual." It has been developed in consultation with
U.S. Environmental Protection Agency headquarters and the Regional TSCA offices to produce a
document that will be useful to field inspectors from all Regions. This manual is also intended
to be practical and appropriate for use by cooperative agreement state inspectors working in
regions in which permitting is a RCRA responsibility.
viii
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EXCLUSIVE USE OF THIS DOCUMENT
The policy and procedures set forth herein, and internal inspection procedures adopted pursuant
hereto, are intended solely for the guidance of TSCA compliance personnel employed by or
representing the U.S. Environmental Protection Agency or comparable state regulatory agency.
They are not intended to nor do they constitute rule-making by the Agency, and may not be relied
upon to create a right or benefit, substantive or procedural, enforceable at law or in equity, by
any person. The -Agency -may -take any action at variance with 4he policies or procedures
contained in this manual, or which are not in compliance with internal office procedures that
may be adopted pursuant to these materials.
This document is not for public use and is withholdable under the Freedom of Information Act, 5
U.S.C. Section 552, Exemption (b)(7)(E).
IX
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CHAPTER 1
INTRODUCTION
This manual was developed as a guidance document and training tool for EPA, state, and local
inspectors who conduct inspections of PCB disposal landfills permitted under the Toxic
Substances Control Act (TSCA). A secondary audience is the TSCA landfill permit writer, who
may learn more about the contents of an enforceable permit by understanding the needs of
inspectors. .The manual provides:
* Background information on landfills and associated technologies:
landfill siting, groundwater protection systems (liners, leachate
management systems, cover technology) and ground and surface water
monitoring technology and procedures.
* A TSCA overview, and an extended discussion of TSCA landfill
regulations and the permitting/approval process.
* A detailed description of the approach to preparation and
completion of a TSCA landfill inspection.
* A discussion of objectives and priorities for inspections, and an
example of a generic regulations-based checklist.
This manual serves as a landfill-specific supplement to the TSCA Inspection Manual and is not
intended to cover all of the general activities of a TSCA Compliance Evaluation Inspection.
Although the scope is limited to "landfilling," as defined by TSCA, much of the information and
the approach presented in this manual could be useful in planning inspections of other PCB
disposal facilities.
This manual reflects the current state-of-knowledge of the TSCA landfill program (as of
January 1990). Regulations and guidance may change as new knowledge and experience are
gained. With only a few years experience in evaluating landfills after they have been permitted,
the TSCA landfill program does not have extensive knowledge of "typical" or "predictable"
long-term operational and maintenance problems associated with these facilities. As more
experience is gained in this area, some changes in the approach to landfill inspection may
become appropriate.
The inspection approach and activities detailed in this manual reflect the necessity for an
inspector to identify the specific needs of an inspection for a particular facility and to establish
inspector time-use priorities. The contents of an inspection are based on limits and conditions
established by regulation and in a permit. However, a successful inspection also requires an
inspector who can combine an inquisitive nature and a knowledge base to make the judgments
needed in the field to provide clear, comprehensive documentation of the status of the landfill's
compliance with TSCA regulations and permit conditions.
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Chapter II of this manual provides background information of potential use to inspectors
concerning landfill technology and monitoring system technology and procedures. It reviews
basic concepts and serves as a quick reference to assist the inspector in understanding the
function and potential problems associated with landfill technology and monitoring.
Chapter III provides an overview of TSCA landfill regulations and the permitting process.
Chapter IV deals directly with the preparations to be made prior to inspection and the approach
to be employed to conduct and complete a TSCA landfill inspection. It also lists and describes
some of the permit or Operations Plan conditions that an inspector may evaluate during an
inspection. A regulations based checklist is provided at the end of Chapter IV.
Chapter V addresses appropriate follow-up activities to the inspection.
Chapter VI provides a list of the references that support this document.
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CHAPTER II
LANDFILL TECHNOLOGY AND BACKGROUND
Three major components are linked to form the chain of measures taken to assure that hazardous
or toxic constituents do not migrate from a TSCA landfill facility. This safety chain, which is
intended to provide long-term protection of human health and the environment, is composed of
the following elements: landfill siting considerations; ground water protection systems
(includes landfill design features such as liner, leachate and landfill cover systems, and ground
water monitoring systems); and a comprehensive program of ground water and surface water
sampling and analysis. If one of these elements is ill-conceived, or improperly executed or
constructed, the protective ness of a landfill is greatly diminished. The following three sections,
therefore, address these major components in turn, and are intended to provide a TSCA inspector
with a basic understanding of proper landfill siting, design/monitoring, and analytical
considerations/procedures.
A. LANDFILL SITING CONSIDERATIONS
There are several factors which must be considered in an evaluation of the suitability of a
particular site for construction of a TSCA landfill. The first of these is whether or not the site
meets the regulatory criteria as presented under 40 CFR 761.75(b). The subtopics addressed
by the regulations which could collectively be grouped under landfill siting considerations
include soils, hydrologic conditions, flood protection and topography.
1. Soils
The TSCA regulations specify that PCB landfills must be sited in thick, relatively impermeable
formations or where the soil has a high clay and silt content (>30%). The minimum thicknesses
for in-place and compacted soil liners must be 4 and 3 feet respectively. These soils must also
have low permeabilities (no greater than 10-7 cm/sec), a liquid limit > 30 and a plasticity
index > 15. These considerations are based upon a desire to place the facility into a setting which
inhibits the migration of hazardous or toxic constituents from a TSCA landfill regardless of
design or monitoring specifications.
2. Hvdroloqic Conditions
The regulations state that the bottom of the landfill liner system or natural in-place liner must
be at least 50 feet from the historical high water table, that floodplains, shorelands and ground
water recharge areas shall be avoided as landfill sites, and that there shall be no hydraulic
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connection between a site and surface waters. Clearly, it is desirable to site all landfills in
locations that are as far removed as possible from a direct connection with ground water and
surface water sources.
3. Flood Protection
The TSCA landfill regulations provide two specifications depending on the site's elevation
relative to that of the 100-year flood plain. If the landfill site is below the 100-year
floodwater elevation, diversion dikes having a minimum height equal to 2 feet above the
100-year floodwater elevation must be provided around the perimeter of the site. If the site is
above the 100-year flood plain, diversion structures capable of diverting all surface runoff
from a 24-hour, 25-year storm must be provided for the facility. Because of the potential for
dispersal of contaminants due to flooding, it is required that these flood protection requirements
be met for TSCA landfill sites.
4. Topography
TSCA landfill sites must also be located in areas of low to moderate relief to minimize erosion
and to prevent landslides and slumping.
Provisions exist within the TSCA landfill regulations to allow these specifications to be waived
on an individual basis, if, in the Regional Administrator's opinion, the facility is judged to be
protective of human health and the environment. (See regulations discussion in Chapter III.)
Historically, the 50-foot ground water rule and the plasticity index/liquid limit rules have
been waived for some facilities in exchange for EPA-imposed compensatory requirements (such
as increased liner thicknesses, etc.).
Seismic considerations may be important for landfill siting in some regions. Although TSCA
regulations do not address this subject, a landfill facility should not be built within 200 feet of
an active Holocene fault if it is to be located within EPA Regions VIII, IX and X (see 40 CFR 264,
Appendix VI).
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CHAPTER II
B. GROUND WATER PROTECTION SYSTEMS
1. General Description and Purpose
A landfill is an engineered facility where hazardous, toxic, or other wastes are placed in or on
the land. Landfills for hazardous or toxic wastes usually are regarded as a technology of last
resort to be implemented after approaches to minimize or reduce the hazard or volume of the
wastes have been evaluated. The intent is to bury or modify the wastes in a manner that does not
pose an environmental or public-health threat.
Landfill technology is based on containment rather than treatment or detoxification for control
of hazardous and toxic wastes. Landfilling is a very common technique for management of both
untreated wastes and the residues from treatment technologies. Landfill designs require careful
construction, continuous maintenance and monitoring, and a high degree of management and
technical attention.
Landfills are typically non-homogeneous and are built in subcells in which partial volumes of
the waste are isolated from adjacent subcells and wastes by suitable barriers. Figure 1 is a
schematic cross section of a toxic waste landfill.
Barriers between cells and subcells or liner systems between the landfilled waste and the
natural soil consist of a continuous layer(s) of natural and/or man-made materials which limit
downward or lateral movement of the hazardous or toxic waste, waste constituents, or leachate.
These barriers or liners may consist of compacted clay, soil, or man-made plastic material
having very low permeability.
In any landfill designed for the disposal of hazardous and toxic wastes, careful consideration
should be given to the long-term protection of the environment. For example, the Resource
Conservation and Recovery Act (RCRA) demands that new secure landfills be able to maintain
their integrity and security for 30 years after closure. This arbitrary time frame may not
adequately consider the safe long-term disposal of some wastes which retain their hazardous or
toxic characteristics for long periods of time.
A "secure" landfill may not be completely secure over its lifetime. Some of the reasons for
failure are the following:
* Operating methods may permit too much fluid to enter the landfill prior
to closure.
* Construction procedures or waste placement methods may produce tears, punctures or
other physical failures in synthetic or soil/clay liners.
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PRECIPITATION
RELATIVELY
IMPERMEABLE
INTERMEDIATE
COVER
LEACHATE
DRAIN
SYNTHETIC LINER
:\\* \\ifgs i^z-ft-
'
NATURAL SOIL
LEACHATE
LOW PERMEABILITY LAYER
DRAINAGE LAYER
Figure 1: SCHEMATIC OF A TOXIC WASTE LANDFILL
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* Leachate collection systems may include design or installation defects.
* Post-disposal consolidation and subsidence over time may result in
breaks in the liner or cover material.
* Solvents can affect the permeability of clay liners by causing the clay
to shrink or crack.
In order to understand the most important aspects of a secure landfill design, it is proper to
briefly discuss possible contaminant migration pathways. If the cap of a landfill is disturbed or
breached, contaminant migration may be caused by surface runoff, volatilization,
wind-activated sediment suspension or infiltration, followed later by a substantial increase in
the production of leachate. The most common of these, the leachate production problem, is one
which is usually difficult and costly to resolve.
2. Modes of Chemical Contamination
There are several pathways by which chemical contamination can spread to an aquifer from a
disposal site. In facilities where water infiltration is restricted and unsaturated conditions
exist near the ground surface, a sudden release from a storage tank, surface impoundment or
landfill will migrate downward and, if the ground water table is extremely deep, respond to a
steadily decreasing driving force (hydraulic gradient) by slowing its advance to a rate of
centimeters per year. In rainy climates where water tables are higher, or where sites tend
toward saturation and hold much larger quantities of fluid, the driving force is not likely to
decrease significantly before a contaminant plume reaches an aquifer. This is the most common
situation, and the most difficult to rectify. In this case, the contaminants are carried by
continuous flow until reaching the aquifer. At that point, flow, fluid, and chemical factors
govern the ultimate fate of the involved contaminants.
Because of the seriousness of potential releases via any of the above-mentioned pathways,
secure landfills intended for hazardous and toxic waste disposal must include additional design
features above those required for conventional sanitary landfills to assure long-term protection
of ground water, surface water, air, and human health.
3. Environmental Standards
Various techniques are available for reducing the potential for negative effects due to landfilling
of hazardous and toxic wastes. Standards have been developed by the U.S. EPA with regard to
most of these techniques. An environmental performance standard issued by the U.S. EPA (40
CFR 267.10 Subpart B) for new hazardous waste landfills dictates that they shall be located,
designed, constructed, operated, and closed in a manner that will assure the protection of human
health and the environment. Protection of human health and the environment would include but
not be limited to the following:
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a. Prevention of negative effects on ground water quality considering:
(1) The amount and physical and chemical characteristics of the waste in the
facility, including its potential for migration through soil or through synthetic
liner materials.
(2) The hydrogeological characteristics of the site and surrounding land.
(3) The quantity, quality and direction of ground water flow.
(4) The proximity and withdrawal rates of ground water users.
(5) The health risks involved by human exposure to waste constituents.
(6) The potential damage to wildlife, livestock, crops, vegetation and
physical structures caused by exposure to waste constituents.
(7) . The persistence and permanence of potential adverse effects.
b. Prevention of negative effects on surface water quality, considering:
(1) The volume and physical and chemical characteristics of the waste in
the facility.
(2) The hydrogeologic characteristics of the facility and surrounding
land, including the topography of the area around the facility.
(3) The quantity, quality and direction of ground water flow.
(4) The distribution of rainfall in the region.
(5) The proximity of the facility to surface waters.
(6) The existing quality of surface water, including other sources of con-
tamination and their cumulative impact on surface waters.
(7) The persistence and permanence of potential negative effects.
c. Prevention of negative effects on air quality, considering:
(1) The volume and physical and chemical characteristics of the waste in the
facility, including its potential for volatilization and wind dispersal.
(2) The existing quality of the air, including other sources of contamination and
their cumulative impact on the air.
d. Elimination of negative effects due to migration of waste constituents in the subsurface
environment, considering:
(1 ) The amount and physical and chemical characteristics of the wastes in
the facility including its potential for migration through soil.
(2) The geologic characteristics of the facility and the topography of the
surrounding land.
(3) The patterns of land use in the region.
(4) The potential for migration of waste constituents into subsurface
physical structures.
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Compliance with these standards is required under RCRA and recommended under TSCAifof; .(1)
the impermeable liner design; (2) the design and operation of leachate and runoff control
systems; (3) closure and post-closure activities; and (4) any additional measures deemed
necessary.
4. Design of a Secure Landfill
The proper design of a particular secure landfill is dependent upon a number of variables, most
of which are outlined for TSCA facilities under 40 CFR Part 761.75. Climatic conditions could
also be added as an important consideration due to the substantial impact that the
evapotranspiration to precipitation ratio can have on landfill design requirements. Some
arid/semi-arid regions in the United States have evapotranspiration rates which greatly exceed
precipitation. In such a case, little or no water moves from the ground surface to the water
table, which typically is found at a considerable depth. This greatly reduces the potential for a
leachate problem, particularly where liquid waste disposal is restricted in a landfill having a
suitable cover. In wet regions, however, it is likely that leachate will be produced in landfills.
Here, control measures are required to prevent leachate from contaminating ground water and
surface water supplies.
Figure 2 illustrates the design of a secure landfill that has a cover to control the amount of
leachate produced and which provides a backup system to collect and remove the leachate should
the cover fail or be removed.
The principal design components from cap to base are as follows:
1. A layer of topsoil over the landfill cap, seeded with vegetation for cover
stabilization and to encourage evapotranspiration of moisture that infiltrates
the cover.
2. A drainage system at the edge of the cover to move runoff away from the cell.
3. A highly permeable drainage layer of sand or gravel between the soil cover and
the sealing layer to divert infiltration to drains located at the sides of the
landfill.
4. A sealing layer (e.g., fine clay or flexible plastic membrane) to stop infiltration
of precipitation into the waste.
5. An underlayer (e.g., fine soil or sand) to provide a base for the sealing layer.
6 Buried waste surrounded by fill material.
7. A venting system to remove gases generated by microbial degradation of the
waste.
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LEACHATE
REMOVAL
LOW PERMEABILITY
LAYER
VEGETATED LAYER
GAS VENT
UNDER LAYER
DRAINAGE
LAYER
HAZARDOUS WASTE
RUNOFF
DRAIN
SEEPAGE
DRAIN
FLEXIBLE
MEMBRANE
LINER
•DRAINAGE LAYER
LOW PERMEABILITY LAYER-
(COMPACTED SOIL)
Figure 2: SCHEMATIC OF A TOXIC WASTE LANDFILL WITH A LINER/DRAIN LAYER
SYSTEM AT THE BOTTOM AND IN THE FINAL COVER.
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8. . A drainage layer to collect teachate from beneath the waste accumulation and to
divert it to drains at the edge of the landfill for removal to the surface.
9. A sealing layer of compacted soil and clay with or without a synthetic liner at the
base of the landfill cell to prevent leachate from infiltrating into ground water.
If considerable subsidence of the landfill is predicted, a well-sealed cover may not be practical.
In this case, protection of ground water from leachate contamination will depend on
liner/drain-layer leachate collection systems at the bottom of the landfill, as shown in Figure 3.
The primary drainage layer conducts leachate to a collection system for removal and treatment
at the surface. The secondary drainage layer acts as a backup and leak detection system.
Additional ground water protection is also provided by placement of two impermeable flexible
membrane liners, one above the lowermost compacted soil liner and one between the two
drainage layer systems. In some cases, a secondary low permeability soil liner may also be
placed above the secondary leachate drainage layer. The cover of the landfill is again constructed
to provide vegetative cover for increased evapotranspiration and is sloped to carry runoff to a
drainage system. The double liner/drain system is suggested for areas where there is a
possibility that ground water could be affected by the landfill.
It is the intent of the following sections to provide the reader with a detailed description of the
design aspects of a secure landfill. A complete understanding of landfill design components
should then enable an EPA inspector to conduct an effective and knowledgeable inspection of a
TSCA landfill facility.
4.1 Liner Systems
4.1.1 Overview
Ground water protection is a fundamental objective of secure landfill design. This can be
accomplished by keeping water out of the landfill by one of the following means:
1. Proper siting to avoid wetlands, flood plains and high ground water
areas.
2. Diversion of surface runon.
3. Avoiding ponding of site precipitation.
4. Minimization of exposed waste surfaces through the use of adequate
intermediate cover material.
5. Proper landfill cap construction and closure and post-closure monitoring.
6. Adequate subsurface preparation, using suitable liner and leachate collection
systems.
Of the above-listed means for restricting the access of water to a landfill, the latter two
involving subsurface preparation (liners/leachate collection systems) and landfill cap
construction and closure/post-closure care are the most critical. The following discussions
focus on these particular landfill design components.
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LEACHATE
REMOVAL
VEGETATED LAYER
RUNOFF
DRAIN
DRAINAGE
LAYER
PRIMARY LEACHATE
COLLECTION AND
REMOVAL SYSTEM
FLEXIBLE
MEMBRANE
LINER
SECONDARY LEACHATE
COLLECTION AND
REMOVAL SYSTEM
PERMEABILITY LAYER
(COMPACTED SOIL)
Figure 3: SCHEMATIC OF A TOXIC WASTE LANDFILL WITH DOUBLE
LINER/RAIN-LAYER SYSTEMS AT THE BOTTOM.
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Proper subsurface preparation depends on site conditions. Subsoils with high permeability
(transmit fluids easily) must be sealed with natural or man-made materials to provide an
unbroken barrier which prevents the migration of liquids from the landfill into ground water.
The depth and area! extent of subsurface preparation depends upon local soil conditions.
In addition to subsurface sealing, liners are required to be placed on the sides and bottom of the
landfill excavation. Liner systems are composed of man-made materials combined with natural
low permeability soils and clays either available at the site or brought to the site and compacted
to reduce permeability (restricts fluid flow) and to increase strength. There is no such thing as
an impermeable liner. Liquid is transmitted through all liners to some degree. All hazardous
and toxic waste landfills require liners having a very low permeability.
The liner must be designed and constructed to accomplish containment of fluids during the life of
the landfill, by preventing the leakage of contaminants to surrounding soils and ground water.
The liner should ideally be constructed wholly above the seasonal high water table and must
cover all areas to be exposed to waste and to leachate. All material used for the liner system
must be resistant to the chemicals it will encounter in the wastes and in the leachate and be of
sufficient strength to withstand the forces encountered during installation and daily operation.
The liner must also rest on a foundation or base capable of providing support and resistance to
settlement or buckling.
Liners function in two ways: (1) they restrict the flow of pollutants and pollutant carrier
(ground water); and (2) they absorb or minimize suspended or dissolved constituents. A liner
with low permeability is required to limit the rate of pollutant migration. The absorptive or
attenuative capability of a liner system depends on the chemical composition of the liner(s) and
its/their mass.
Most liners include flow-control and filtration mechanisms to various degrees. Synthetic
membrane liners are the most impermeable but have little absorptive capacity. Soils have a
large absorptive capacity but can be more permeable. As soil liner thickness increases,
transmission of pollutants is significantly reduced. The favorable properties of both soil and
synthetic liners can be utilized when they are used in combination.
Landfill cells (i.e., units or discrete parts) should be designed with an underliner system
consisting of the following, as a minimum:
- leachate detection, collection and removal system
- a synthetic liner
For large area landfills, particularly those designed to accept multiply layered wastes, the final
cover may not be applied until the entire cell is closed. If final closure is not scheduled for
many years, a double liner-double leachate collection system incorporating two synthetic
liners, a secondary soil-based liner, and primary and secondary leachate detection, collection
and removal systems is recommended. The leachate detection, collection, and removal systems
between the liners function to reduce the liquid head on the secondary soil liner to a minimum,
thereby severely reducing the rate of liquid transmission.
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4.1.2 Soil Liners
Soils normally are considered as the first alternative for a hazardous or toxic waste landfill
liner and should be clay-rich. They should have a saturated hydraulic conductivity
(permeability) of not more than 1 x 10-7 cm/sec and be at least 4 feet thick if in-place soil is
used or 3 feet thick if the soil is imported and compacted in place. The soil liner should be as
tightly compacted as possible. Many clay soils can readily be recompacted to meet the specified
permeability requirement. The tighter and more impermeable the clay layer is, the less fluid
will penetrate, thereby increasing the efficiency of fluid removal by the overlying leachate
detection, collection and removal systems.
Soil liners serve as backup systems and are depended upon to minimize the rate of liquid flow
through them. A minimum thickness of the soil is necessary to retain structural stability
(reducing cracking potential, etc.). Therefore, under TSCA regulations 3 feet is the minimum
stable thickness for recompacted clay. In-place soil can be considered acceptable as a soil liner
material provided the specifications in this guidance are met. In-place soil liners should be
free of permeable zones, fractures, sand lenses or channels which increase the conductance of
liquids through the liner.
4.1.3 Synthetic Liners
Liners consisting of synthetic membranes can be used for hazardous and toxic waste landfills.
Such liners have very low permeabilities and are commonly used in waste disposal facilities.
Synthetic liners should consist of a membrane that is at least 30 mils thick and is chemically
resistant to the waste managed at the landfill. In judging chemical compatibility of wastes and
membranes, the EPA considers adequate historical data, demonstrations involving theoretical
chemistry and actual test data. TSCA landfills typically employ high density polyethylene liners
that are known to be compatible with PCBs.
The estimated service life of a liner under particular exposure conditions is an important factor
in the liner material selection process. For secure landfills, a very long service life is
required. Physical, chemical and biological failure of liners can occur. Principal causes of
such liner failure are:
Physical - Puncture, tear, differential stress, settling, thermal stress, hydrostatic
stress, abrasion, cracking.
Chemical - Solvents, hydrolysis, acid/base incompatibility,
chemical oxidation.
Biological - Microbial degradation.
Physical failures are commonly due to faulty subgrade preparation and improper operating
conditions at the landfill and to changing hydrostatic pressures. Chemical failures normally are
related to characteristics of the waste in contact with the liner.
14
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Synthetic liners must be protected from damage that may occur during installation or operation.
It is good practice to protect synthetic liners both from above and below by a minimum of six
inches of bedding material. This will help protect against punctures or tears due to contact with
sharp objects or other contingencies. The waste itself may contain sharp objects or abrasives
which cause damage. Careless handling and placement of wastes and improper vehicle usage may
also cause damage.
EPA, therefore, suggests that a bedding layer be installed above the liner as well as below it.
The top bedding layer protects the synthetic membrane from damage due to exposure to sunlight
and wind during operation. In addition, the first lift of solid waste placed upon the liner should
not contain sharp protrusions, such as pipes that might puncture the liner. The bedding layer
which underlies the liner in this case should consist of materials which are no coarser than sand
as defined by the Uniform Soil Classification System (USCS) and which is free of objects such as
large rocks and cobbles, concrete, branches, debris, rubbish and roots that could also puncture
the liner.
Experience with these liners at hazardous waste landfills is limited. Of concern is their ability
to maintain integrity and impermeability over the life of the landfill. Ground water monitoring,
leachate collection and/or clay soil liners are invariably included in the design and construction
of hazardous and toxic waste landfills when synthetic membranes are used.
4.2 Leachate Management System
4.2.1 Overview
For a better understanding of the mechanism of leachate production and movement, one must also
be fully acquainted with the natural processes involved in the whole cycle of water movement in
the environment. These natural processes together make up what is commonly known as the
hydrologic cycle. Important terms relating to water movement are:
Process Definition
Infiltration Passage of water into the soil surface.
Percolation Movement of water through the soil surface.
Evaporation Moisture returned to the air by vaporization
of precipitation.
Transpiration Moisture returned to the air as water vapor
from the surface of plants.
When rainfall in excess of the soil's infiltration capacity reaches the ground, the result is
runoff. This runoff then flows over the ground at a velocity determined by the slope of the land
and limited by the roughness of the surface. In any landfill design, the runoff velocity is an
important consideration because steep slopes are prone to erosion which may result in exposure
of waste materials. After runoff occurs, a certain amount of water determined by the geographic
location and climate of the site is lost due to evaporation and transpiration.
15
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A major objective in landfill design should be to minimize the quantity of water infiltrating .the
soil, and percolating through the waste to yield leachate.
4.2.2 Leachate Generation
The amount of leachate produced at any particular site is determined by absorptive capacity, the
area! extent of the landfill, the composition and placement of waste, cover material usage,
operations procedures, and the quantity of recharge water available for infiltration.
Leachate is a fluid which has percolated through solid waste and has removed dissolved and/or
suspended materials from it. When water comes into direct contact with solid waste, it becomes
contaminated to a certain extent. Many materials in solid wastes are highly soluble in water.
Others, such as PCBs, are very insoluble. In some instances, soluble materials are formed as
products of the natural degradation of solid waste constituents. Some materials also become
soluble through the action of leachate upon them. Generally, as infiltration of water through a
solid waste increases, rates of pollutant leaching and leachate production also increase. As a
result of all the possible waste/water interactions, leachate generated by each landfill is
unique, with its characteristics being primarily determined by the specific types of waste(s)
disposed.
4.2.3 Leachate Collection Systems
A leachate collection and removal system at a hazardous or toxic waste landfill must be designed,
installed, and managed in a manner that allows its anticipated life span to be attained. It must
also be compatible with the characteristics of the leachate to be collected, strong enough to
resist collapse due to the pressure imposed by equipment used at the site and by the accumulated
waste and cover materials, and capable of withstanding possible changes in hydrostatic
pressure.
It is always desirable to have a water balance at the site to determine the relative need for a
leachate collection system as well as its capacity. The amount of leachate generated at a landfill
depends on the volume of water flowing through the landfilled material plus the amount of free
liquid produced during waste decomposition and compression.
Precipitation and runon are extremely important variables affecting the volume of leachate
produced. External runoff should be diverted from the landfill site, and both intermediate and
final cover should help divert the precipitation that falls on the site. Figure 4 illustrates a
liquid flow diagram that can be used to determine water movement and leachate volume. The
collection system acts to reduce the hydraulic head generated at the bottom of the landfill,
thereby lessening percolation through the underlying soil/clay liner.
A leachate collection system can consist of perforated pipes placed in a permeable media that
allows discharge by gravity to a sump from which the leachate is pumped. For chemical waste
landfills slated to accept PCB wastes under TSCA (40 CFR 761.75(b)(iii)(7)) leachate
monitoring/collection systems can be based upon any of the following designs:
16
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UNDER LAYER
HAZARDOUS-WASTE CELL
INTERMEDIATE COVER
HAZARDOUS-WASTE CELL
ACTUAL
EVAPORTRANSPIRATION
PRECIPITATION
SURFACE
RUNOFF
INTERFLOW
GENERATED
FREE LIQUIDS
PLUS LEACHATE
GENERATED
FREE LIQUIDS
PLUS LEACHATE
TO LEACHATE
COLLECTION SYSTEM
UNDISTURBED SOIL
Figure 4: SCHEMATIC OF A LIQUID ROUTING DIAGRAM IN A
TOXIC WASTE LANDFILL.
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a. Simple Leachate Collection
This system includes a gravity flow drainfield placed under the waste disposal facility liner.
Figure 2 illustrates a design of a secure landfill that has a liner/drain-layer system which
operates to divert leachate to collection system for removal and treatment at the surface.
This design is suggested for use when semi-solid or leachable solid wastes are placed in a
lined pit excavated into a relatively thick, unsaturated homogeneous layer of low
permeability soil.
b. Compound Leachate Collection
This system includes a gravity flow drainfield placed under the waste disposal facility liner
and above a secondary installed liner. Figure 3 illustrates a design of a secure landfill that
has a compound leachate collection system. A dual leachate collection system includes a
primary collector and a secondary or leak detection system which functions as a backup
collector in case of failure of the primary system. In some cases, a dual soil liner design is
also employed in which both primary and secondary leachate collection systems are
underlain by thick compacted soil liners. This type of design is recommended for use when
semi-liquid or leachable solid wastes are placed in a lined pit excavated into relatively
permeable soil.
c. Lysimeters
Gravity is the driving force behind which lysimeters operate. The two basic types, trench
and caisson lysimeters, are described below.
A trench lysimeter is a trough made of any of a variety of metals and plastics. In its simplest
form, the trench lysimeter is a halved section of piping. Trench lysimeters are then
oriented so that leachate flows into them (see Figure 5).
A caisson lysimeter (see Figures 6a, 6b) is a section of corrugated steel pipe. The pipe is set
vertically in place with a system of collector piping connected to it. This type of system
works best when installed in a relatively permeable unsaturated soil immediately adjacent to
the bottom and/or sides of the disposal area.
The advantage of both lysimeters is that a large leachate volume can contained and production
rates can be measured. The disadvantages include construction-related alteration of ground
water flow patterns and limitations in number of units that can be installed due to their cost.
4.2.4 Leachate Treatment
Once leachate has been collected, numerous alternatives exist for treatment and disposal.
Selection of a leachate treatment process is not simple. The leachate characteristics depend on
the nature of the landfilled wastes and on the stage of fermentation in the landfill. If the
characteristics of the collected leachate indicate it is a RCRA hazardous waste, the leachate must
be managed as such in accordance with the applicable permits and requirements. All leachate
generated at TSCA landfills must be treated and disposed of by means that are generally specified
as conditions written into the TSCA permit/approval.
18
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FIBERGLASS SCREEN
0.3 cm DIAMETER
METAL RODS
Figure 5: TRENCH LYSIMETER (REPRODUCED FROM SOIL SCIENCE,
VOL. 105, 1968, PAGE 83, WILLIAMS AND WILKENS CO.).
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SURFACE OF
SAND BED
WATER
SIDE
WALL
V
PVC
HALF SCREEN
10" DIAMETER
CORRUGATED
STEEL PIPE
COLLECTOR
PIPE
SAMPLE COLLECTION
Figure 6a: CASSION LYSIMETER.
LEGEND
GRAVITY SAMPLER
NEUTRON-PROBE
ACCESS HOLE
A TEMPERATURE
PROBE
|W| WATER LEVEL
•—' RECORDER
S SAMPLING WELL
BASIN
FLOOR \.
•i
MB
« -J t*
17
A
<
(
<
<
(
i
i
i
i
i
i
*
;
•
•
4
I
,
,
f
S
^
|
nc i MIWIIIU
WALL
0.75m =
0.9m 1 0.9m
2.25m '
x^f
5.34m
X^L,
7.50m'
i
Figure 6b: CASSION LYSIMETER WITH HORIZONTAL COLLECTOR PIPES
(REPRODUCED FROM AIR, WATER, AND SOIL POLLUTION, VOL 14, 1980,
D. REIDEL PUBLISHING CO., HAURE, NETHERLANDS).
-------
The treatment processes applicable at a particular site depend upon leachate volume,
characteristics, treatability and available discharge options. Residues, gases, and by-products
that are formed during treatment may require additional control and management. Because
leachates vary in composition, combinations of processes may be needed to achieve required
levels of treatment.
4.3 Landfill Cap (Final Cover) Technology
4.3.1 Overview
According to EPA regulations, when landfills have reached the end of their useful life they must
be closed. The landfill must be sealed in a way that prevents the need for additional maintenance
and control, and eliminates post-closure escape of the hazardous or toxic wastes, other
contaminated emissions (including leachate), contaminated rainfall and waste decomposition
products to ground or surface waters or the atmosphere.
Upon closure, the top surface of the landfill must be sealed with soil and an impermeable layer
of suitable material and graded to minimize the accumulation of surface water and erosion.
Natural or planted vegetation is encouraged to grow on the cover to further reduce erosion.
Deep-rooted vegetation should be avoided since it can damage any impermeable barrier.
Landfill covers can be damaged by soil erosion, uneven settling of fill material, vegetation and
animal and human activity that can affect the integrity and performance of the liner. A
sufficient final cover thickness is important for minimizing these potential problems. The
thickness employed in the cover design is determined based upon the following considerations:
freezing and thawing effects; moisture content effects; trafficability need; support
requirements; gas migration control; expected infiltration rates; differential settlement; and
liner protection.
4.3.2 Design
Final cover should be designed and constructed to:
* Reduce the need for additional maintenance and provide long-term minimization of
migration of liquid through the sealed facility.
* Promote drainage and minimize erosion or abrasion of the cover.
* Adjust to settling and subsidence to maintain the integrity of the cover.
* Provide a hydraulic barrier with a hydraulic conductivity below that of the landfill liner(s)
or subsoil. By this means, the infiltration of precipitation into the cell is limited to the
maximum extent possible.
According to the Minimum Technology Guidance on Final Covers for Landfills and Surface
Impoundments (EPA 1987), the suggested final cover should consist of a multilayer design
(Figure 7) employing the following layers from top to bottom:
1. A vegetated layer composed of an erosion control component (vegetation, gravel, mulch,
etc.) and a 60 cm (24 inch) minimum thickness topsoil component.
21
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60cm VEGETATED LAYER
DRAINAGE LAYER
.FLEXIBLE
MEMBRANE LINER
'."."*'.".";>'
LOW PERMEABILITY
££ 60 cm LAYER
:"•••.".***".*••.*;•••"
-'.""•"•'•".- -".••"•**
V-'i-U^V-r^^:--:^
HAZARDOUS WASTE
NOTE: GEOTEXTILE FILTERS ARE TO BE INSTALLED BETWEEN LAYERS
Figure 7: FINAL COVER SYSTEM DESIGN.
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2. A 30 cm (12 inch) minimum thickness drainage layer to eliminate ponding on the
underlying low permeability layer and to remove water that infiltrates through the top
layer of the cover. This layer also acts as a protective bedding for the flexible membrane
liner (FML).
3. A low permeability layer which includes a 20 mil minimum thickness flexible membrane
liner (FML) and a 60 cm (24 inch) minimum thickness, compacted soil component. This
layer is intended to increase the efficiency of liquid removal in the drainage layer and
supplies backup to further reduce liquid infiltration.
A case-by-case evaluation is required to determine the appropriate type and thickness of
landfill cover material. For instance, in highly arid regions, a gravel mulch could be needed
above the topsoil to balance less extensive vegetative coverage; alternatively, the drainage layer
may not be required. At a unit that is expected to produce gases, a gas vent layer between the
waste and the low permeability layer must also be included.
a. Vegetated Layer
The vegetated layer should include the following:
* Soil material that is free from large rocks or debris and is at least 2 feet thick and
capable of maintaining plant species to effectively reduce erosion. The soil must
accommodate the root systems of most non-woody cover plantings.
* The layer should be sloped to carry runoff to a surface drainage system. It is suggested
that the final slope (after settling and subsidence) should be at least 3 percent to avoid
pooling due to surface irregularities and vegetation, but less than 5 percent to reduce
excessive erosion. For slopes higher than 5 percent, the maximum erosion rate should
not be higher than 2.0 tons/acre/year using the USDA Universal Soil Loss Equation.
* A drainage system at the edges of the cover to conduct runoff away from the site without
creating erosion rills and gullies in the topsoil layer.
* Persistent species vegetation that will completely reduce erosion having a root system
that will not penetrate beyond the vegetative and drainage layers. The plant species
should not require unnatural applications of water or fertilizers to sustain growth.
b. Drainage Laver
The final cover should include a drainage layer for the removal of water that infiltrates through
the vegetative layer. The drainage layer must be designed to reduce infiltration of water into
the underlying low permeability layer, thus lowering the potential for leachate generation. In
arid locations, this layer may not be required.
23
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If composed of sand, the drainage layer should:
* Have a thickness of no less than 30 cm (12 inch) to facilitate transfer of liquids
infiltrating through the vegetative layer and provide protection for the underlying FML
component of the low permeability layer. To perform as protective bedding material for
the FML, the drainage layer material must be no coarser than Uniform Soil
Classification System sand (USCS) and must be free of debris that could damage the FML.
* Have a minimum hydraulic conductivity of 1 x 10-2 cm/sec.
* Include a final bottom slope of at least 2 percent after allowance for settlement.
* Have a filter (granular or geotextile) placed above the drainage layer to minimize
clogging by infiltration of fine materials from the overlying layer.
Other drainage systems, such as geonets and geogrids, may also be utilized if it is demonstrated
that they are equivalent to the recommended granular system in terms of hydraulic conductivity
and FML bedding protection. These systems must be capable of removing liquid from the cover
system while withstanding the effects of external forces.
C. Low Permeability Layer
The final cover system must be designed to have a permeability less than or equal to the
permeability of the bottom landfill liner system(s) or natural subsoils. The low
permeability layer should be situated below the average depth of frost penetration and
should consist of the following two components at a minimum:
1. An upper FML component with the following characteristics:
* The FML should be at least 20 mils in thickness. Some facilities may require a
thicker FML to prevent failure during the post-closure care period or during
construction. FML thickness is also dictated by the specific type of FML material
used.
* The FML surface should possess a minimum 2 percent slope after allowing for
settlement.
* The FML material and seam specifications should meet or exceed those set by the National
Sanitation Foundation Standardise. 54 (NSF.1985).
* The FML should be protected from above and below by at least 30 cm (12 inch) of
bedding material which should not be coarser than sand and should be free of rocks,
debris, rubbish, roots and sudden changes in grade that may affect the FML.
* Penetration of the FML by designed structures (e.g., gas vents) is not recommended.
24
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* Stressed conditions in the FML should be avoided by providing proper slack allowance, for
shrinkage of the FML during installation and prior to placement of the protective layer
or drainage layer.
2. A bottom component with the following characteristics:
* A compacted soil layer at least 60 cm (24 inch) thick composed of low permeability soil
with an in-place saturated hydraulic conductivity of 1 x 10-7 cm/sec or less. This
compacted soil must again be free of rocks, debris, rubbish and roots that may increase
the hydraulic conductivity or create preferential flow paths for infiltration.
* The upper surface of the compacted soil (which is in contact with the FML) must have a
minimum slope of 2 percent after allowing for settlement.
d. Optional Layers
There are cases where an alternative design (optional layers) are applicable. The optional
layer designs discussed below are gas vent and biotic barrier layers.
Gas Vent Layer
The purpose of a gas vent layer is to monitor and control combustible, malodorous or toxic
gases produced by biodegradation of organic matter buried in a landfill.
The gas vent layer should include 30 cm (12 inch) of coarse-grained material (similar to
that used in the drainage layer) lying between the waste itself and the low permeability
layer soil component. Gas is vented to a collection point for disposal or treatment through
horizontal perforated pipes connected to vertical risers placed at high points in the landfill
cross section.
The following design criteria are suggested for the gas vent layer
* The layer should be a minimum of 30 cm (12 inch) thick and should be placed between
the compacted soil liner and the waste layer (Figure 8).
* Venting to an exterior collection point for treatment or disposal should be provided by
means of horizontal perforated pipes patterned laterally throughout the gas vent layer to
channel gases to vertical risers. Penetration of the cover should be avoided.
* Materials for the construction of the gas vent layer should be of the porous, granular
type similar to those used in the drainage layer.
Other gas layer designs will be considered if it can be demonstrated that they can provide
equivalent performance. Equivalence is determined by the ability of the design to consistently
remove any gases produced, minimize clogging, infiltration, withstand expected overburden
pressures, and perform under the stresses of construction and operation.
25
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VEGETATED LAYER
DRAINAGE LAYER
FLEXIBLE
MEMBRANE LINER
LOW PERMEABILITY
LAYER
GAS COLLECTION AND
VENTING LAYER
3£££#^^
'HAZARDOUS WASTE*
Figure 8: OPTIONAL FINAL COVER SYSTEM
DESIGN (GAS VENTING SYSTEM DESIGN).
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Biotic Barrier Layer
Burrowing animals or plant roots may affect the structure of the drainage and low
permeability layers. Biotic barriers, such as layers of cobble- stones or coarse gravel
beneath the drainage layer, minimize the effects of biointruders (see Figure 9).
The performance of biotic barriers has been documented by Hakonson (1986) who found
that large or tightly packed objects placed in a burrowing animal's path, effectively stopped
its progress. It was also found that the occurrence of large void spaces lacking water and
nutrients within a layer of stone reduced the intrusion of plant roots.
The design of a biotic barrier is site-specific and is dependent upon the overlying topsoil
layer, biotic barrier material, natural precipitation and anticipated biointruders.
5. Ground Water Monitoring Systems
5.1 Overview
The primary objective of ground water monitoring systems utilized for TSCA landfills is to
provide high quality geohydrologic data to assure accurate detection of a release of contamination
from operating or closed landfill cells to any aquifers that may underlie the site.
It is appropriate, before addressing the topic of ground water monitoring detail to briefly
discuss the behavior of PCBs with respect to ground water flow.
The mobility of organic compounds in soil and ground water is controlled primarily by sorption
to organic (carbonaceous) material in the soil or aquifer matrix. The octanol/water partition
coefficient (Kow) for a specific compound is related to the compound's affinity for sorption to
organic material. A high Kow indicates that the compound readily sorbs to organic material and
would therefore have a low mobility; a low Kow indicates that the compound does not sorb
readily and is therefore mobile. Volatile organic compounds (VOCs) have low Kows and are
generally quite mobile with respect to ground water flow. PCBs, on the other hand, have very
low solubilities in water and very high Kow values, indicating that they should be very
immobile.
Retardation factors, which express the rate at which a particular chemical travels relative to
ground water, can be calculated given the amount of organic matter in the soil and the
carbon/water partition coefficient (Kcw) for the chemical being considered. As a comparison,
the organic solvent acetone and the herbicide 2, 4-D have retardation factors of 1.0 and 2.6,
respectively. These values indicate that acetone travels at the same rate as ground water and 2,
4-D travels 2.6 times slower. The retardation factor for PCBs ranges from 600 - 3,000. This
shows that the tendancy of PCBs to sorb onto soil/organic matter versus ground water is so
overwhelming that the movement of PCBs takes place at a rate which is up to 3,000 times
slower than that of ground water.
27
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VEGETATED LAYER
DRAINAGE LAYER
LOW PERMEABILITY
LAYER
-^ •a'f^pa'ff &.^*fff**:*^i*'*y*'i"-- ^•f"i~-:':?"-tt^*:'vi?y&:--?~^±**^
'^^''•••-^•'^'^•'•••^
^>-.:::-V-.0.^;-.V:->0Vv-.;::UNDER LAYER ^>-^^O v^'/^
• -o••'.".>• --.•••?•-; _• • .•.•.•••%.-.='.'-:.'-.ov.v.-.0-.^-."••-.•°:-.^-'.--••-»• • :•-.•/.>-/q;.-.
HAZARDOUS WASTE
GAS VENT LAYER
S. OPTIONAL FINAL COVER SYSTEM
DESIGN (BIOTIC BARRIER DESIGN).
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The above discussion of PCB mobility suggests that landfilling in a highly engineered and
well-monitored facility should be an environmentally protective means of disposal of PCB
wastes.
It must be kept in mind, however, that the mobility of PCBs is known to be significantly
enhanced in the presence of some RCRA wastes, particularly the organic solvents. The specific
provisions in the TSCA landfill regulations which prohibit the comingling of incompatible
compounds with PCBs are the direct result of this understanding of the behavior of PCBs. In
this light, it is therefore important for the TSCA landfill inspector to make an assurance that
facility disposal practices do not allow PCBs and incompatible wastes to be comingled.
5.2 Components of Ground Water Monitoring Systems
Two primary components make up the ground water monitoring systems employed at TSCA
landfill facilities; the array of ground water monitoring wells, and the sampling and analysis
protocols. The ground water monitor wells must be placed, constructed and developed in a
manner that assures that representative ground water samples can be consistently obtained for
analysis. Monitor well placement, construction, and development information and protocols
must be part of the facility's Operations Plan or must be included with the engineering drawings
and other materials submitted as part of the TSCA approval application.
Given proper monitor well installation, it is vitally important that ground water sampling and
analysis be carried out in accordance with guidelines set forth in the facility's sampling and
analysis plan. This plan, which is typically included as part of the Operations Plan, is
enforceable and must be strictly followed by facility personnel involved in sampling and/or
analytical activities. The sampling and analysis plan should include the following at a minimum:
sampling protocol (water level measurement, well purging, sampling equipment to be used,
sample preservation/holding times, chain of custody); analytical parameters; analytical
methods; quality assurance; and data analysis/interpretation procedures. The TSCA landfill
inspector should be familiar with monitor well construction and development and the sampling
and analysis plan if a planned inspection's interest is observation or oversight of well
installation or sampling operations on site.
5.2.1 Ground Water Monitoring Wells
a. Well Placement
The proper placement and siting of ground water monitoring wells must involve
consideration of horizontal and vertical perspectives. The horizontal and vertical
distribution or array of wells placed around a TSCA landfill cell or facility must be
arranged in order to intercept any ground water flows which could potentially carry
contamination off site. Even though TSCA regulations call for a minimum of three sampling
points per disposal area, this number is greatly exceeded at most facilities which typically
employ a perimeter monitoring scheme. Under such a scheme, monitoring wells are placed
on 200 to 400 foot centers surrounding the facility or waste disposal area. In addition, the
wells may be nested where appropriate in order to provide ground water samples from
several different permeable zones or aquifers located at various depths beneath the ground
surface. This type of horizontal and vertical array of sampling points assures that the
29
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extent of any released contamination can be accurately determined regardless of any changes
in ground water flow direction due to construction or dewatering activities on site. In some
cases, a RCRA-style detection monitoring program may be employed at RCRA/TSCA
facilities. In this instance, only the downgradient perimeter of the waste management area
is monitored, again with a horizontal and vertical array of ground water monitoring wells.
In general, any saturated, permeable zone exceeding a thickness of 1 foot and capable of
yielding adequate water to a well should be monitored.
b. Subsurface Investigation
Proper monitor well installation must be proceeded by subsurface investigations involving soil
sampling and soil description. The intent of these efforts is to characterize the subsurface
geology, and locate and describe all potential water producing zones (aquifers) so that the
monitoring well screens can be placed at the correct depth to allow representative samples to be
obtained. Soil sampling and soil description should be done during the initial boring of the well
and must be overseen by a qualified geologist. Soil samples should be collected continuously from
hollow-stem auger borings using a 2-inch OD split-spoon sampler according to ASTM D-1586
guidance and should be logged using a standard soil classification system (ASTM D-2488). All
sampling equipment should be thoroughly cleaned before collection of each soil sample. Where
multiple water-bearing zones are encountered during drilling, additional borings shall be
augered to install monitoring wells in each zone. Where nested wells are to be installed in such
a setting, it is expedient to continuously sample and log the deepest hole first in order to locate
the zones to be monitored. The remaining borings slated for monitoring wells then can be blind
augered to within 10 feet of the appropriate target zone prior to their completion using
continuous split-spoon sampling techniques to a depth of 3 feet below the bottom of the
water-bearing zone.
In settings where a bedrock aquifer exists, rock coring is required for wells to be completed as
bedrock monitoring wells. Rock cores will provide information on the bedrock present and the
Rock Quality Designation (ROD). Coring, logging, and ROD determinations should be overseen by
a geologist. A complete geologic description of the rock cores obtained should be produced for
each cored hole. Cores must be carefully removed from the core barrel and placed in core
boxes, noting the depth interval contained in each box. The project name, project number,
borehole number, depth interval, and box number should be clearly marked on each box along
with run number, run depth, recovery, and ROD data.
c. Well Design/Construction - Installation
Stringent drilling and installation protocols must be followed during the monitoring well
construction process and should include steam cleaning of all equipment and material between
well locations.
Monitor well construction typically involves one of two methods depending on well diameter:
1. For 4-inch wells, 8-inch temporary casing should be set to the bottom of the hole to
facilitate well construction.
30
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2. For 2-inch wells, 6 1/4-inch I.D. hollow-stem augers are utilized to drill th& hole
and the well is then constructed inside the augers.
After the stainless steel, teflon, or PVC well string is in place, the 8-inch casing or the 6
1/4-inch I.D. augers are slowly withdrawn as the sand filter pack, bentonite seal and grout
backfill are placed in the annulus.
Each monitoring well installed is intended to provide representative ground water samples from
a particular water-bearing zone or aquifer. As shown on Figure 10, a schematic drawing
showing construction details for a typical 2-inch PVC well, a slotted or perforated well screen
allows ground water to enter the otherwise impermeable riser pipe. Well screens are typically
5 to 10 feet long. The well string is plugged at the bottom and screwed together in 5 to 10 foot
flush threaded sections. In order to allow communication between the permeable zone to be
monitored and the well, the well screen must be surrounded by a permeable sand or gravel pack
which should extend from the base of the well to a height at least 2 feet above the top of the well
screen. It is critical that the sand pack and well screen be set at the correct depth. The bottom
of the well screen should always be placed slightly below the depth of the base of zone to be
monitored to assure that a maximum volume of water may be obtained for sampling. A 2-foot
thick bentonite clay seal should overlie the sand pack. In accordance with TSCA regulations, the
annular space above this seal should then be completely filled with Portland cement-bentonite
grout and then topped with a concrete or Portland cement pad to effectively prevent percolation
of surface water into the well bore. In addition, a steel protective pipe with a removable but
locking cap must also be installed over the well top in order to provide access and prevent
entrance of rainfall or storm water runoff.
During the construction of all monitoring wells, accurate records must be maintained of the
depths at which various materials are installed (nearest 0.1 foot) and the quantity of various
materials utilized in constructing the monitoring well. All sections of well screen and riser
pipe should be measured prior to emplacement in the hole to accurately measure the depth of the
monitoring well. The amount of all backfill materials emplaced around the well screen and
riser pipe should be noted and the depth of emplacement of the sand pack and bentonite seal
sounded utilizing a weighted steel tape. After the monitoring well construction has been
completed, the well must be tagged and the well number permanently marked in at least two
places on the well cover. Well construction data should be recorded and presented for each well
on monitor well completion diagrams.
d. Well Development
The objective of monitoring well development is to assure that ground water obtained for
samples is representative of the formation or zone being monitored. To this end, well
development procedures are designed to eliminate the effects of well vicinity disturbance
caused by drilling and installation processes. For instance, the boring walls may be
smeared with clay or the well screen and sand pack may contain fine sediments derived
from the formations adjacent to the screened interval. Proper well development using a
surge block and bailer or pump assures that the well screen and sand pack are cleared of
any accumulated sediments, and that representative formation waters can be obtained for
sampling.
31
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4" DIA. STEEL CASING
W/ HINGED, LOCKING CAP
1/8" DIA. WEEP HOLE
CONCRETE CAP
CEMENT-BENTONITE
GROUT
6" BORE HOLE (MIN.)
2" PVC RISER PIPE
(SCHEDULE 80)
THREADED FLUSH JOINTS
SAND
2" PVC WELL SCREEN
(0.010 SLOT, SCHEDULE 80)
" PVC PLUG
70. GROUND WATER MONITORING WELL SCHEMATIC DIAGRAM
-------
Following installation, all wells must be fully developed. Ideally, each well should be surged for
approximately two hours, then bailed or pumped. If after bailing, the water produced is sand
free and the water level recovers, the well shall be considered developed. If the water produced
is not sand free, additional surging is necessary, followed by bailing or pumping until the well
is judged satisfactory. In a completely developed well, the water quality parameters
(temperature, pH, specific conductivity) should have become stabilized. If readings indicate
that these water quality parameters have not stabilized, additional development is required.
A well development data sheet must be completed for each monitoring well installed. All well
development activities should be carefully recorded including an accurate record of the amount
of time spent surging each well. In addition, all records of specific conductance, temperature,
and pH should be carefully recorded including the time of measurement. The amount of water
removed from the well must be recorded along with the time of removal.
e. Surveying
All monitoring wells installed must be surveyed by a licensed surveyor. A point on the top of
each well casing should be identified and surveyed to the nearest 0.01 foot. In addition, the
ground surface elevation at each monitoring well must also be surveyed to the nearest 0.01 foot,
and the well located within a site coordinate grid system to the nearest 1.0 foot.
33
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CHAPTER II
C. SAMPLING AND ANALYSIS
The objective of any sampling and analysis plan is to obtain high quality, reproducible results
from representative-samples. Consistency in both sampling and analytical procedures is
essential to yield high quality data. The procedures outlined below have been field or laboratory
tested and proven to be practicable, reproducible and capable of yielding quality results.
Sampling points invariably include ground water monitoring wells but may include
under-drains, leak detection systems, leachate standpipes, and surface water locations
depending on the type of leachate collection system employed and the hydrologic setting of a
particular TSCA landfill. Presampling procedures involving water level measurements and/or
purging of stagnant fluid must be followed for all wells and leachate collection systems as
described below.
1. Pre-Sampling Sampling Protocol - Ground Water
1.1 Water Level Measurement
Water level elevations must be taken and recorded at each ground water monitoring well just
prior to sampling. In addition, the potentiometric surface of each significant water-bearing
zone beneath a TSCA landfill facility should be mapped on a regular basis (semi-annual or
quarterly) to determine horizontal and vertical ground water flow gradients. In this case, the
measurements should all be made on the same day or at most over a two-day period.
Water levels should be measured using an electric water level indicator and must be made from
the surveyed top of the well reference point to the static water level, and recorded to the nearest
0.01 foot. This value is then subtracted from the surveyed top of the well elevation to obtain the
water elevation above mean sea level (msl). The date and time of each measurement should be
logged as part of the sampling record by the personnel conducting the sampling effort. The
electric sounder and tape that contacts well water must be thoroughly cleaned with deionized
water prior to use in each well.
1.2 Monitoring Well Evacuation
Ground water sampling involves several steps including measures to remove stagnant water
from the well prior to sample withdrawal and to further ensure that the method used for sample
collection provides representative samples. The first step in sample collection js the
determination of the volume of water in the well. The depth to static water should be measured
prior to each sampling event as previously described and subtracted from the depth to bottom.
The depth to the bottom of the well should also be measured for each sample event and recorded
to the nearest 0.01 foot.
34
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The difference between the depth to water and the total well depth is equal to the height of .the
standing water column within the casing. The volume of this water is calculated using the
following equation:
V = pi r2h/231
where,
V = volume of the standing water column in gallons
(one well volume)
pi = a mathematical constant approximately equal to 3.14
r = inside radius of the well casing in inches
h = height of the standing water column in inches
231 = a constant that converts cubic inches to gallons
Even though the TSCA regulations call only for the removal of one well volume prior to
sampling, it is strongly recommended that a minimum of three well volumes be removed from
wells with high hydraulic yields (recharge rate exceeds purge rate); low yielding wells should
be evacuated to dryness.
Wells should be evacuated using bailers equipped with bottom-fill check valves. Under ideal
conditions, one bailer is to be dedicated to each monitoring well to reduce the potential for
cross-contamination between wells. Prior to initial use in a monitoring well, bailers must be
cleaned using a hot non-phosphate detergent solution wash, hot tap water rinse, a deionized
water rinse, and air dried. Bailers should then be wrapped in plastic and placed in a clean,
secure area until use. After initial use in a well, the bailer should be dedicated to that well.
The volume of water purged should be monitored by pouring purge water into a calibrated
container. Purge water in general should be contained and treated as a hazardous waste. Purge
water from any upgradient background wells may be disposed of on the ground near the well.
Wells with high hydraulic yields must be sampled immediately following evacuation. Wells
with low hydraulic yields may be sampled when adequate water has recharged to collect a
complete sample set, usually within two hours. Wells with extremely low hydraulic yields may
require sample withdrawal on an individual aliquot basis.
2. Pre-Samplinq Protocol - Leachate
2.1 Leachate Standpipe Evacuation
Although the composition of landfill leachate varies with time, attempts should be made to
collect representative samples from any leachate standpipes at the site. Each leachate standpipe
should be evacuated in the following manner prior to sample withdrawal. The first step in
sample collection is a determination of the volume of fluid in the leachate standpipe. The depth
to the bottom of the standpipes should be measured annually using a weighted surveyor's tape
and recorded to the nearest 0.1 foot. The depth to the static fluid level must also be measured
prior to each sampling event using the weighted tape. The difference between the total standpipe
35
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depth and the depth to fluid is equal to the height of the standing fluid column inside the leachate
standpipe. The volume of this fluid (one casing volume) can be calculated using the equation
presented above. Three casing volumes should be removed from standpipes with high hydraulic
yields (recharge rate exceeds purge rate), when possible. Standpipes with low hydraulic yields
(purge rate exceeds recharge rate) should be evacuated to dryness.
Standpipe evacuation is normally accomplished by use of a small dedicated submersible electric
pump. Also dedicated to each leachate standpipe are sufficient lengths of tubing and electrical
wire to place the pump at the base of the leachate standpipe. All fluid evacuated from each
standpipe should be contained and treated as a hazardous waste. Samples must be collected
within 24 hours of standpipe evacuation.
2.2 Lvsimeter Evacuation
Some TSCA landfills, particularly those excavated into relatively permeable unsaturated soils,
employ suction lysimeters as their leachate collection system. Samples from lysimeters should
be collected using a two-way hand pump which is used to place a vacuum on the lysimeter. The
lysimeters should be placed under a vacuum 24 hours prior to sampling to allow sufficient time
for moisture to collect in the lysimeter.
2.3 Underdrain and Leak Detection System Evacuation
Some highly engineered TSCA facilities are equipped with underdrains and leak detection
systems as components of their leachate collection and management systems. Underdrains
should be evacuated by one of two methods. The first method employs non-dedicated electric
venturi surface pumps and dedicated jet-type pressure nozzles. Also dedicated to these
underdrains is a length of tubing sufficient to place the jet nozzle at the base of the underdrain
sump. The venturi pumps should be thoroughly cleaned with a deionized water rinse after each
use.
The second method of underdrain evacuation which also applies to a leak detection system
involves use of a dedicated submersible electric pump. Also dedicated to these underdrains are
sufficient lengths of tubing and electrical wire to place the pump at the base of the underdrain
sump.
Purge water from underdrains and the leak detection system should be contained and treated as a
hazardous waste. Each underdrain should be purged to dryness or until approximately 200
gallons have been removed. This insures that samples collected will be representative of the
water contained within the underdrain and leak detection drainage media.
3. Water Sampling
3.1 Ground Water and Leachate Sampling
Ground water monitoring wells, leachate standpipes, lysimeters, underdrains, and leak
detection systems must be sampled immediately after purging, except as previously described
for low-yielding monitor wells and leachate stand- pipes. The sampler should wear clean PVC or
36
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latex gloves when handling all evacuation and sampling equipment and sample containers- The
gloves are discarded once sample withdrawal is complete. PVC or stainless steel bailers are
normally used to purge wells; stainless steel bailers should be used to obtain the samples.
Sample water must be transferred from the bailer or pump directly into a sample container
that has been specifically prepared for that constituent or set of constituents. For bailed wells,
the bailer should be lowered slowly into the water to avoid agitation. For samples collected with
pumps, the pumping rate should be lowered below one gallon per minute, if possible, and the
sample containers filled directly from the pump discharge.
Each sample container must be carefully filled to minimize aeration and capped in sequence of
decreasing volatilization potential as listed in Table 1. After filling all sample containers, a
clean beaker should be filled with a sample for a field chemical analysis. The beaker must be
cleaned between sampling points using a deionized water rinse.
3.2 Surface Water/Stream Sampling
Stream sampling does not require evacuation. A similar sampling technique and sequence as
outlined in the water sampling section should be followed except that the procedures call for
pre-cleaned sample containers to be inverted and slowly submerged into the midpoint of the
stream channel. The sample container should then be gently righted in the upstream direction
until fully upright and filled. The sample container is then removed from the stream and
capped.
3.3 Field Analyses
Due to the physical and chemical instability of the parameters, temperature, pH, and specific
conductance, they must be measured in the field immediately following sample withdrawal.
Each instrument used for field analyses must be calibrated to operation manual specifications.
The pH meter should be calibrated with 7 and 10 pH buffers at least once daily during use.
Although a specific conductance meter cannot be calibrated in the field, it should be checked
against a standard potassium chloride solution at least once daily during use. All specific
conductance measurements should be compensated to a reference temperature of 25 degrees
Celsius, using correction factor curves for a 0.1 N KCI solution such as those presented in
American Water Works Association (1985). Field and temperature compensated specific
conductance and pH readings must be recorded in a field log book.
37
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TABLE 1
SAMPLE COLLECTION SEQUENCE
Sample Order
Volatile Organics (VOA) ** First Aliquot
Total Organic Halides (TOX) *
Total Organic Carbon (TOO)
Semi-Volatile Organics and Pesticides
Polychlorinated Biphenyls (PCB) **
Total Metals
Dissolved Metals
Cyanide
Other Inorganic Ions Last Aliquot
NOTE: A separate sample aliquot should be collected for field analysis
after all other sample containers have been filled. This applies to
the pH, and specific conductance measurements required under
TSCA, 40 CFR 761.75(b)(6)(iii).
* Analyses sometimes required under special permit conditions.
** Analyses required specifically under TSCA, 40 CFR
38
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3.4 Sample Containers
Only new sample containers may be used for collection of samples. The appropriate container
type and preservatives to be employed are specified in Table 2. All containers must be
pre-cleaned and capped by the manufacturer, distributor or laboratory prior to use. Each
sample container must also be assigned a unique container number or lot number once cleaned
and capped. Documentation verifying the cleaning procedure followed in preparation of each
container should be maintained. To track containers from cleaning through analysis, the
container number must be recorded on field log and chain-of-custody forms.
Sample containers to be used for analysis of organic constituents must be constructed of glass
with Teflon-lined caps. The proper cleaning procedure for glassware consists of a
non-phosphate detergent wash, hot tapwater rinse, pesticide-grade hexane rinse, deionized
water rinse and kiln drying at 110 degrees Celsius. Cap liner preparation should be the same
except they should be air dried.
Sample containers to be used for analysis of inorganic constituents (metals) should be
polyethylene with polyethylene or polypropylene-lined caps. The cleaning sequence for plastic
containers consists of a non-phosphate detergent wash, hot tapwater rinse, 10 percent nitric
acid rinse, deionized water rinse and air drying.
The sample in each container may be analyzed for several constituents or parameters, provided
the sample is of adequate volume and appropriate preservation and handling considerations have
been employed.
3.5 Sample Preservation
Samples must be preserved (if necessary) at the sample location immediately after collection
(see Table 2). Once collected and preserved, each sample must be stored in an ice chest
containing frozen refrigerant packs. Any dissolved metal samples must be field filtered on-site
prior to their transport to the analytical laboratory.
3.6 Special Handling Considerations
In some cases, analysis for metals may be required for certain TSCA landfill facilities. Samples
to be analyzed for metal parameters should be collected in two aliquots, one to be analyzed for
total metals and one for dissolved metals. The aliquot for dissolved metals analysis must be
filtered at the sample location using a pressure filtration system. The filter assembly must be
cleaned after each use following the procedure outlined for metals sample containers.
39
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TABLE 2
RECOMMENDED CONTAINERIZATION AND PRESERVATION OF SAMPLES
Constituent
Metals (Dissolved)
Metals (Total)
Sulfate, Chloride,
Bicarbonate
Phenol
Total Organic
Carbon (TOC)
Total Organic
Halides (TOX)*
Polychlorinated
Biphenyls*
Volatile Organic
Compounds**
Pesticides
Fluoride
Nitrate
Cyanide
Semi-Volatiles
fmn
200
200
50
200
500
4x 15
4x15
1,000
2x50
2,000
300
1,000
500
1 gal.
teflon
liner
Container
P.G
P.G
P.G
P.G
G
G. amber,
Teflon-
lined cap
G. amber,
Teflon-
lined cap
or septum
G. Teflon-
lined cap
G. Teflon-
lined
septum
T.G
T.P
T.P.G
G
G
Preservation
Field-filter
HN03topH<2
HN03topH<2
Cool, 4°C
Cool, 4°C
hfeS04 to pH <2
Cool, 4°C
HCI to pH <2
Cool, 4°C
Cool, 4°C
1 ml 1.1M
Sodium sulfite
Cool, 4°C
Cool, 4°C
No headspace
Cool, 4°C
Cool, 4°C
4°C/HaSO4 to
pH<2
Cool, 4°C
Cool,4°C
Holding Time
6 months
6 months
28 days
14 days
28 days
8 days
7 days
7 days to ex-
traction, 40
days from ex-
traction to
analysis
14 days
7 days
28 days
14 days
14 days
7 days to ex-
extraction, 40
days from ex-
traction
analysis
40
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TABLE 2 (Continued)
References:
1. U.S. EPA (1986a) RCRA Groundwater Monitoring Technical Enforcement Guidance
Document, OSWER-9950.1.
2. U.S. EPA (1986b) Test methods for Evaluating Solid Waste, Physical/Chemical
Methods, SW-846, third edition.
NOTES:
** Analyses sometimes required under special permit conditions.
* Analyses specifically reauired under TSCA, 40 CFR 761.75(b)(6)(iii).
41
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Samples to be analyzed for volatile constituents must be collected and capped with zero
headspace. Samples must also be transported to the laboratory promptly to provide ample time
for analyses to be conducted within the holding times specified in Table 2. Prior to shipment,
all samples will be carefully placed in an ice chest with frozen refrigerant packs to keep
samples cool.
3.7 Sample Labels
Each sample container must have a sample label affixed to the outside of the container in an
obvious location. The label should specify: container number (or lot number), sample
identification number, name of collector, location sampled, date and time sampled,
preservatives used, and parameters to be analyzed. All information must be recorded on the
sample label with water-resistant ink.
3.8 Sample Seals
Samples shipped from the facility to the laboratory by a commercial courier must be
transported in a refrigerated shipping container sealed with tamper evident tape or a tamper
evident seal. Each seal must have a unique number. In the event samples are received with
broken seals, or the chain-of-custody seal is broken, the well(s) or leachate collection
component(s) in question must be resampled.
3.9 Field Logs
An example of a field log sheet is provided in Figure 11. The sampler must complete a field log
form for each sample location noting the following information:
* Sample location.
* Sample identification number.
* Sample source: monitoring well, leachate standpipe, stream, etc.
* Sample type and collection equipment: grab sample, composite sample,
bailer, pump, etc.
* Evacuation date and time, if applicable.
* Purge rate and volume purged (note will be made if purged to dry), if
applicable.
* Personnel present at time of evacuation, if applicable.
* Depth to bottom, depth to water, and casing volume, if applicable.
* Water level after purge, if applicable.
* Casing inside diameter and type, if applicable.
* Weather conditions at time of purge, if applicable.
* Comments and observations at time of purge, if applicable.
* Date and time of sample withdrawal, if applicable.
* Sample appearance: color, turbidity, odor, sediments, etc, if applicable.
* Depth to water at time of sample withdrawal, if applicable.
* Estimate rate of recharge, if applicable.
* Weather conditions at time of sample withdrawal.
42
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* Field analyses: temperature, pH, specific conductance.
* Container number of each aliquot collected.
* Container size, type, and preservative used in each sample aliquot.
* Parameters (analytes from each sample aliquot).
* Comments and observations at time of sample withdrawal.
* Signature and date of samples upon field log completion.
All field log entries should be made in ink. If an error is made in the field log, corrections
should be made by crossing a single line through the error, initialing, and entering the correct
information. The erroneous information should remain legible.
3.10 Chain-of-Custodv-Record
Each sample set for a sample location may consist of several individually numbered containers.
Each sample container must be logged onto the chain-of-custody form (Figure 12) prior to
placement in ice chests for shipment to the analytical laboratory.
The following information must be recorded on the chain-of-custody form:
* Sample source: monitoring well, leachate standpipe, stream, etc.
* Collector's name.
* Purpose of sample collection.
* Dates of sample collection.
* Sample identification numbers.
* Sample location.
* Container number of each sample aliquot.
* Container size, type, and preservatives used in each sample aliquot.
* Constituents or parameters (analytes from each sample aliquot).
* Rush analyses requested, if applicable.
* Special handling instructions.
* Destination of samples, if applicable.
* Name, date, time and signatures of each individual possessing the samples.
* Shipping container seal number and condition (used only if transported by commercial
courier).
The chain-of-custody form must be signed by each individual responsible for handling the
sample containers and must accompany the samples until they are received by the outside
laboratory.
Custody of the samples is defined as actual physical possession, in view after physical
possession, or locked and/or sealed in a tamper resistant container after physical possession.
At the time of custody transfer, the individual relinquishing the samples shall observe as the
transferee inspects the samples for integrity and number, dates, and signs the chain-of-custody
form. A signed original copy of the chain-of-custody form must be returned to the facility once
the samples have been received by the laboratory.
43
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FIGURE 11/EXAMPLE FIELD LOG SHEET
Sample ' Monitor Wells'
SmaOK Underdrain;
Sample Crab'
Type/ RaiW;
EcluiP- Split Spoon:
ment
Evacuation:
Date- /
T?_ J Tl
Purged To Dry- ~ ves/no
Comments:
Sampling:
r»afe- /
Sample Appearance :
Comments:
Field Log Page#
Lah*
I^»b#
I rearhate Stand pipe* I ,eak Detection'
Stream: Pond: Other
— Comoosite* FHnnintr Rnttln In ^fnnHinfr/PloTArina Wai
Electric Pump; Vonhiri Piirpp- Dipping;
Other:
Depth To Bottom: '-
gm Depth To Water: '•
pal Height Of Water Column!
Water Level After Purge:
, , Casing I.D. & Type: in.
/ .Personnel Present:
Depth To Wafer-
Weather Conditions;
:er
ft
ft
ft
gal
ft
ft
TEMPERATURE
(0
pH
.TC
_TC
TC
CONDUCTIVITY
(Umhos/cm)
TC
TC
.TC
TC
CONTAINER
NUMBER
SIZE
(ml)
TYPE
Pl/gl
PRES.
PARAMETERS/COMMENT
SIGNATURE:
DATE / /
44
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FIGURE 12/EXAMPtE CHAIN-OF-CUSTODY FORM
Sample
Identification:
Sample Source:
Collector:
Purpose: —
Dates Collected:
Sample
I.D.
Sample
Point
1
Container
Number
Size
(ml)
Type
(pl/gD
Pres.
Parameters/Comments
Rush
Special Handling Instructions:
Destination:
Shuttle 1.
Chronology:
2.
3.
Company:
Address:
Prepared By:
Signature:
Transported By:
Signature:
Received By:
Signature:
Ann:
Phone No.: ( )
P.O. No.
Date: / /
Seal No.
Date: / /
Company:
Date: / /
._ Comments:
I
Time: :
Intact
Time: :
Time: :
-------
4. Analytical Procedures
Sample analyses must be performed using only EPA-recognized laboratory procedures. Table 3
indicates the test methods and detection limits to be used in the analyses of samples collected at
the TSCA landfill facilities. Detection limits for specific volatile organic compounds are
compiled in Table 4.
5. Field and Laboratory Quality Assurance/Quality Control
One of the fundamental responsibilities of the TSCA landfill facilities is the establishment of
continuing programs to ensure the reliability and validity of field and analytical laboratory data
gathered as part of the overall monitoring program.
The facility's Operation Plan must explicitly describe the QA/QC program that is to be used in
the field and laboratory. Most facilities use commercial laboratories to conduct analyses of
ground water samples. In these cases, it is the facility's responsibility to ensure that the
laboratory of choice is utilizing a proper QA/QC program. The QA/QC program described in the
Operation Plan must be the one used by the laboratory that is analyzing samples for the
owner/operator.
5.1 Field QA/QC Program
The Operation Plan should provide for the routine collection and analysis of two types of QC
blanks: trip blanks and equipment or field blanks. Trip blanks are used to determine if
contamination is introduced from the sample containers. They are prepared by the analytical
laboratory and consist of a series of laboratory cleaned sample containers filled with laboratory
demonstrated contaminant-free water. Equipment or field blanks are used to determine if
contamination is introduced by the sample collection equipment. They are prepared by passing
deionized water through clean sampling equipment (bailers, pumps, etc.) prior to transfer to
sample containers using the normal handling procedures (filtering, preservation, etc.). Field
blanks must be analyzed for the same parameters as the other samples collected through the
same devices. This allows the source of any contaminants detected in the field blank to be
identified and corrected. Locations sampled with the same equipment as a field blank showing
contamination may require resampling.
Some Operation Plans may include provisions for taking blind duplicate samples as a check on
the precision of the analyses. In this case, a duplicate sample should be taken periodically and
collected in the identical manner as routine monitoring samples. The sample labels and
chain-of-custody forms should not indicate where the duplicate sample was collected. The
actual identity of the blind duplicates must be recorded only on field log sheets. The duplicate
sample is to be analyzed for the same parameters as the regular samples and the analytical
results are to be compared with those from the original sample. Discrepancies in the
concentration of contaminants detected in either sample should then be explained if in excess of
the error limits of the analytical procedures used.
46
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TABLES
ANALYTICAL TEST METHODS
Method
Detection
Constituent
Sodium
Potassium
Calcium
Magnesium
Iron
Manganese
Chloride
Sulfate
Bicarbonate
Fluoride
Semivolatile
Organic Compounds
Cyanide
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Test Method
D-1428(a)
D-1428(a)
7140(b)
7450(b)
7380(b)
7480(b)
9252(b)
9038(b)
406(c)
300.00(6)
8250(b)
335.3(6)
7060(b)
7080(b)
7130(b)
7190(b)
7420(b)
7470(b)
7740(b)
Limit (mg/L)
0.05
0.05
0.001
0.01
0.05
0.015
1.0
1.0
1.0
0.1
0.010
0.005
0.001
0.1
0.005
0.05
0.1
0.0002
0.002
47
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TABLE 3 (continued)
Test Method
7760(b)
(f)
9066(b)
9060(b)
9020(b)
5030 + 8240(b)
3510 + 8080(b)
Method
Detection
Limit (mg/L)
0.01
None Given
0.005
1.0
0.002
Constituent
Silver
Strontium
Phenol
Total Organic
Carbon (TOC)
Total Organic
Halides (TOX)*
Volatile Organic
Compounds (VOA)**
Pesticides and 3510 + 8080(b) 0.0002
Polychlorinated
Biphenyls (PCB)*
Notes:
(a) ASTM (1979) Water and Environmental Technology, Vol. 11.02.
(b) U.S. EPA (1986b) Test Methods for evaluating Solid Waste, Physical/
Chemical Methods, SW-846, third edition.
(c) AWWA (1985) Standard Methods for the Analysis of Water and
Wastewater, 16th edition.
(d) Detection limits for volatile organic compounds are described in Table A-4.
(e) Methods of Chemical Analysis of Water and Wastes, EPA-600/4-79-
020. March 1983.
(f) Handbook of Radiochemical Analytical Methods, EPA-680/4-75-001.1975.
Analyses sometimes required under special permit conditions.
Analyses specifically required under TSCA, 40 CFR 761.75(b)(6)(iii).
References:
1. U.S. EPA (1986a) RCRA Groundwater Monitoring Technical Enforcement Guidance
Document, OSWER-9950.1.
2. U.S. EPA (1986b) Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods, SW-846, third edition.
48
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TABLE 4
VOLATILE ORGANICCOMPOUNDS
PRACTICAL QUANTITATION LIMITS
Practical
Quantitation
Volatile Organic Compound Limit fug/L)
Acrolein 5
Acrylonitrile 5
Benzene 5
bis (Chloromethyl) ether 10
Bromoform 5
Carbon tetrachloride 5
Chlorobenzene 5
Chlorodibromomethane 5
Chloroethane 10
2-chloroethylvinyl ether 10
Chloroform 5
Dichlorobromomethane 5
Dichlorodifluoromethane 5
1,1 -dichloroethane 5
1,2-dichloroethane 5
1,1-dichlorethylene 5
1,2-dichloropropane 5
cis-1,3-dichloropropylene 5
Ethylbenzene 5
Methyl bromide 10
Methyl chloride 10
Methylene chloride 5
1,1,2,2-tetrachloroethane 5
Tetrachloroethylene 5
Toluene 5
1,2-trans-dichloroethylene 5
1,1,1-trichloroethane 5
1,1,2-trichloroethane 5
Trichloroethylene 5
Trichlorofluoromethane 5
Vinyl chloride 1
Methyl ethyl ketone 100
2-Hexanone 50
Acetone 100
Notes:
1. Practical Quantitation Limits are from Federal Register, July 9, 1987, for method
8240.
2. Actual GC/MS method detection limits may vary because of analytical interference and
dilution effects. PQLs are provided as an example of typical detection limits.
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Evacuation and sampling equipment must be handled in a manner to prevent contamination from
outside sources. Surfaces that come into contact with samples must be thoroughly cleaned with
deionized water, handled with disposable PVC or latex gloves and capped or stored in plastic
until use.
5.2 Laboratory QA/QC Program
The Operation Plan should also provide for the use of standards, laboratory blanks, duplicates
and spiked samples for calibration and identification of potential matrix interferences. The
facility should use adequate statistical procedures to monitor and document performance and
implement an effective program to resolve testing problems. Data from QC samples (e.g.,
blanks, spiked samples) should be used as a measure of performance or as an indicator of
potential sources of cross-contamination but should not be used to alter or correct analytical
data. These data should always be submitted to the Agency along with the monitoring sample
results.
6. Data Analysis and Interpretation
Once samples have been collected and analyzed at the laboratory, the data produced must be
interpreted in order to determine whether or not the facility has had a significant negative
effect on ground water or surface water due to a release of contamination. This determination is
based upon the results of a statistical test involving a comparison of background chemical data to
that obtained from appropriately associated downgradient ground water monitoring well
sampling and surface water sampling.
Although TSCA regulations do specifically require that background contaminant levels be
established by sampling and analysis of ground and surface water prior to commencing
operations, no guidance is provided regarding how this data is to be collected and how
contaminant detection and assessment are to be done. The following discussion of data
interpretation techniques, with respect to contaminant detection and assessment, is therefore
largely based upon applicable RCRA 40 CFR Part 264-265 regulations and guidance.
Therefore, the following should only be taken as a strong recommendation, one that would not be
enforceable under TSCA unless specifically included as a permit condition or in an Operations
Plan.
6.1 Establishment of Background Conditions
The first step in the procedure used to evaluate possible releases of contamination from a TSCA
landfill facility is the establishment of background conditions. In concept, background
conditions are thought to represent the pristine or natural chemical conditions of ground or
surface water that exist or existed at the time the facility commenced its disposal operations. As
such, background sampling locations must be upgradient from the facility with respect to
ground and surface water flow directions and must be far enough removed from the facility that
any potential influences from the site are avoided. It is possible that some background
monitoring wells may later be found to be downgradient as a result of an incorrect assessment of
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ground water flow direction, site-related contamination, contamination unrelated to the facility
or a change in ground water flow direction due to site dewatering or other activities. Because of
these possible difficulties, it is recommended that background conditions be assessed on a
year-by-year basis. In addition, it is preferable to employ more than one background ground
and surface water sampling location in order to understand possible spatial variability of
background concentration levels in the vicinity of the site.
Background ground water and surface water quality should be established based upon data
obtained from quarterly sampling of upgradient wells and surface water locations for one year.
Four replicate measurements should be obtained from each well or surface water location
during each sampling event. The background mean and variance values determined for each
parameter of interest (PCBs, pH, specific conductance, chlorinated organics (TOX), others)
should then be calculated from the data sets utilizing procedures outlined under Cochran's
Approximation to the Behrens-Fisher (CABF) Students' T-test (see 40 CFR Part 264, Appendix
IV). These summary statistics (mean, variance), which describe the background
concentrations, form the basis against which all subsequent upgradient and downgradient
concentrations are compared. Note: For sites in which all background values are nondetectable
(i.e., less than the parameter detection limit), background levels should be set at 1/2 the
method detection limit. (Of those parameters listed above, this applies only to PCBs and TOX.)
6.2 Statistical Analysis of Monitoring Data
After the first year in which background concentrations are established, ground water and
surface water monitoring data are compared with their respective background values to
determine if there is an indication that a release of contamination has occurred. Once again, the
CABF Students' T-test is recommended to make this comparison. A statistically significant
increase in the mean concentration of any parameter of interest above that found in the
background suggests that contamination may have taken place. Note: In the case of pH, the
T-test is conducted to detect either an increase or decrease (a significant change).
All of the upgradient and downgradient wells and surface water locations must be sampled each
year after the first year. The parameters of interest must again be measured by performing at
least four replicate analyses from each sample in the monitoring network at least
semi-annually. The data obtained here must then be used to compute mean and variance values
for each parameter from each well or sampling station (surface water) utilizing the same
methodology used to define the background means and variances.
If the increase between the mean of the parameter measured at each well or surface water
sampling location and the respective background value for the parameter is significant at the
0.05 level (95% confidence limit), using the CABF Students' T-test, a suggestion that the
facility may be affecting water quality is indicated. It is then the facility owner's responsibility
to resample the wells or surface water stations where a significant increase has been detected.
These samples should be split in two and analyzed to determine by reapplying the T-test
whether the indicated increase was the result of laboratory error or actual contamination. If a
significant increase is confirmed by the additional analyses, the facility must take steps to begin
the detailed assessment of the nature and extent of the ground water or surface water
contamination.
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6.3 Assessment of Contamination Extent
Once the facility has detected a contaminant release as a result of the above-outlined or other
monitoring efforts, a more aggressive program of ground or surface water assessment
monitoring must be undertaken in order to determine the extent of contamination that is related
to the facility and its operations. Generally speaking, the owners of the facility must determine
the vertical and horizontal profiles of all hazardous or toxic constituents present in the
contaminant plume that has been found to be escaping from the landfill area(s). In addition, the
rate and extent of contaminant migration must also be established. The goal of an assessment
monitoring program is to provide sufficient information to form the basis for plans to
remediate the affected ground and/or surface water.
Contaminant assessment monitoring involves a more intensive and specifically-focused
investigation of ground water and/or surface water quality; an investigation aimed at the
immediate vicinity of the area(s) in which contamination has been proven to exist. This
investigation generally consists of a more detailed characterization of the geohydrologic setting
of the site and the chemistry of the affected waters. Geophysical surveys may be employed in
attempts to define the extent of a contaminant plume. Installation of a more extensive, denser
network of ground water monitoring wells and well nests or clusters is often necessary along
with increased sampling frequencies. Mathematical modeling of contaminant movement may
also be used to estimate the migration rates and expected concentrations of the particular
constituents of interest. This can then be compared with the actual ground water data from
wells to fine tune the model to provide an accurate three-dimensional picture of contaminant
migration within the affected aquifers or surface water bodies.
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CHAPTER III
REGULATIONS AND PERMITTING
A. TSCA OVERVIEW
1. Introduction
The Toxic Substances Control Act (TSCA) was enacted by Congress in 1976 to identify and
control chemicals which posed an unreasonable risk of injury to health or the environment.
Under Section 2 of TSCA, Congress delegated the authority to control the chemical substances
whose manufacture, processing, distribution in commerce, use or disposal presented such
risks, to the Administrator of EPA. Within EPA, the Office of Toxic Substances is responsible
for enforcement of the Act.
2. TSCA Synopsis
A review of the entire Act is recommended to provide the inspector with an understanding of
EPA's authority with regard to chemical substances, specifically PCBs, which may be considered
harmful. Several sections of the Act are summarized below.
Section 6(e) of TSCA specifically required the EPA to establish rules to: (1) prescribe the
methods for the disposal of PCBs; (2) require PCBs to be marked with adequate warnings; and
(3) unless granted an exemption, prohibit the manufacture, processing, or distribution of
PCBs, and the non-totally enclosed use of PCBs. These rules, as compiled in 40 CFR Part 761,
were established and became effective in 1978 and 1979. This Section also allowed the EPA to
regulate other chemicals if they were determined to be harmful.
Under Section 11, representatives of EPA may inspect an establishment, facility, or other
premises or conveyance for the purpose of administering the Act. The inspection, however, may
only be made upon the presentation of appropriate credentials and a written notice to the owner,
operator or agent in charge of the premises or conveyance being inspected. It should be
conducted at reasonable times, within reasonable limits, and in a reasonable manner, and can
extend to records, files, papers, processes, controls, and facilities.
Section 15 of TSCA states that, among other things, it is unlawful for any person to fail or
refuse to comply with any requirements under Section 6, or to deny entry for inspection as
required by Section 11.
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CHAPTER III
B. TSCA LANDFILL REGULATIONS - PCB CONTROL
1. Introduction
The remainder of this chapter deals with the regulations and permitting activities effecting
chemical waste landfills which accept wastes whose disposal is governed by TSCA. As of the
penning of this manual, the only chemical whose disposal is regulated by TSCA is PCBs. Prior to
the acceptance of PCBs, a chemical waste landfill must be approved by the Regional
Administrator for the Region in which the landfill is located. The approval, in the form of a
written permit, establishes enforceable operating conditions. The landfills discussed
throughout the remainder of this manual will be those permitted to accept PCBs (TSCA
landfills).
In addition to the PCB disposal, storage, marking and recordkeeping regulations listed under 40
CFR Part 761, the inspector should have a thorough understanding of the operating permit for
the TSCA landfill prior to its inspection. It is also recommended that the inspector become
familiar with the chemical waste landfill requirements under the Resource Conservation and
Recovery Act (RCRA) as listed in 40 CFR Part 264 Subpart N, as well as any other Federal,
State, or local permits or approvals for a particular landfill. The requirements for RCRA
landfills are in many instances more detailed and stringent and may be incorporated into landfill
permits written under TSCA.
2. Landfill Regulations (40 CFR Part 761.75)
The minimum technical requirements for TSCA landfills fall into three major topics: (1) land-
fill siting; (2) monitoring wells; and (3) landfill design.
Landfill Siting
Soils. The landfill must be located at a site underlain by thick, relatively impermeable
soil formations or by soils having a high clay and silt content with: (1) an in-place soil
thickness (4 feet) or compacted soil liner thickness (3 feet); (2) a permeability equal
to or less than 1 x 10-7 cm/sec; (3) greater than 30% soil passing No. 200 Seive; (4)
a liquid limit greater than 30; and (5) a plasticity index greater than 15.
Hydrologic Conditions. The bottom of the landfill liner or natural inplace soil barrier
must be at least 50 feet from the historic high water table. In addition, the site should
avoid floodplains, shorelands and ground water recharge areas and should not have a
hydraulic connection between it and surface water.
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Flood Protection. A surface water diversion dike, with a minimum height equal ;to two
feet above the 100-year floodwater elevation, must be provided around the perimeter of
a landfill which is located below the 100-year floodwater elevation. If the site is above
the elevation, structures capable of diverting the surface water runoff from a 24-hour,
25-year storm are required.
Topography. The landfill site must be located in an area of low to moderate relief to
minimize erosion and to help prevent landslides or slumping.
Monitoring Systems
Water Monitoring Systems. Ground and surface water from the disposal site must be
sampled prior to commencing operation. In addition, surface watercourses designated by
the EPA must be sampled at least monthly when the landfill is being used for disposal
operations, or at least every six months after final closure of the disposal area.
At least three ground water monitoring wells are required. They must be equally spaced
on a line through the center of the disposal area and extend from the highest to the lowest
water table elevation on the property. Each monitoring well must also be cased, have a
removeable cap, and have its annular space between the monitor zone and the surface
backfilled with Portland cement or its equivalent.
The frequency at which the facility must sample the wells is specified in the permit.
Prior to obtaining a sample for analysis, the well's initial volume of liquid must be
removed. The liquid purged from the well prior to sampling must be recycled to the
landfill or treated to meet applicable State or Federal standards.
All water samples, including those from the leachate collection system, must be analyzed
for PCBs, pH, specific conductance, and chlorinated organics.
Landfill Design
Synthetic Membrane Liners. If required by the EPA, a synthetic liner can be used to
provide a minimum total permeability equivalent to 1 x 10-7 cm/sec. The liner must be
compatible with PCBs and have a minimum thickness of 30 mils.
Leachate Collection. Depending on the site's geologic setting and the waste type(s) to be
disposed, a simple, compound, or suction lysimeter system should be used to collect
leachate. The leachate collection monitoring system shall be installed above the landfill
and must be monitored monthly for the quantity and physiochemical characteristics of
the leachate produced. The leachate must be treated for discharge or disposed of in
accordance with the State or Federal permits or regulations.
Supporting Facilities. The site must be bounded by a 6 foot woven fence, wall or similar
device to prevent unauthorized persons or animals from entering.
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The types of waste and the handling of the wastes to be disposed of in a TSCA landfiH are
regulated as follows:
* PCBs and PCB items must be placed in the landfill in a manner that will prevent
damage to the containers or articles.
* Incompatible wastes must be segregated from PCB wastes at all times.
* Liquid wastes must not contain over 500 ppm PCBs, and PCBs must not migrate
from the site.
* Bulk liquids containing less than 500 ppm PCBs must be pretreated and/or
.stabilized into a non-flowing consistency prior to disposal.
* Ignitable wastes must not be disposed of in TSCA landfills.
* Containers of liquid PCBs (50 - 500 ppm) must be surrounded by an amount of
inert sorbent material capable of absorbing all of the liquid contents of the
container.
Prior to the disposal of PCBs, an Operation Plan must be submitted as part of the TSCA permit
application process. This plan governs day-to-day procedures and must include detailed
explanations of the procedures to be used for recordkeeping, surface water handling,
excavation/backfilling, vehicle movement/roadway use, leachate collection systems, sampling
and monitoring procedures, emergency contingency plans, site security and liquid waste
disposal limitations. Provisions must be made to assure that containers are not damaged during
disposal and that incompatible wastes, such as organic solvents, are segregated from PCB wastes
in the landfill. Ignitable wastes are prohibited from disposal in TSCA landfills.
During the operation of the landfill, records must be maintained for all PCB disposals and must
include information on the PCB concentration in liquid waste and three dimensional burial
coordinates for all PCBs and PCB items placed in the landfill.
3. Related Disposal Regulations (40 CFR Part 761.60)
The following wastes are approved for disposal in TSCA landfills:
* Liquids containing PCBs at concentrations of 50 ppm or greater, but less than 500
ppm, provided information is available to show that the liquid does not exceed 500
ppm PCBs and is not an ignitable waste.
Non-liquid PCBs in the form of contaminated soil, rags, or other debris.
* Dredged materials and municipal sewage treatment sludges containing PCBs.
* PCB transformers, provided that they are first drained of all free-flowing liquid,
filled with a solvent, allowed to stand for 18 hours and then drained thoroughly.
* Capacitors containing less than 500 ppm PCBs.
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* PCB articles other than PCB transformers, provided all free-flowing liquids have
been drained.
* PCB containers which have not been decontaminated, provided they are first drained.
* PCB small capacitors, provided they are placed in appropriate containers.
The following wastes cannot be disposed of in TSCA landfills:
* Liquid PCBs at concentrations of 500 ppm or greater.
* PCB large high or low voltage capacitors.
* Industrial sludges or slurries containing 500 ppm or greater PCBs.
An additional requirement of notification is specified within the PCB disposal regulations. Each
operator of a TSCA landfill must give written notice to the appropriate State and local
government at least 30 days before a facility is first used for the disposal of PCBs. If requested,
an annual notice of the quantities and types of PCBs disposed must also be submitted no more
than 30 days after the end of the year covered.
4. Related Storage Regulations (40 CFR Part 761.651
Long-term storage areas used in TSCA landfills to store PCBs and PCB items must meet the
following requirements:
* Adequate roof and walls.
* A floor and continuous curbing with a minimum 6-inch high curb, both of which
must be constructed of smooth and impervious materials.
* A containment volume equal to at least two times the internal volume of the largest
PCB article or PCB container, or 25 percent of the total internal volume of all PCB
articles or PCB containers in the storage area, whichever is greater.
* No drains, valves, expansion joints, sewer lines or other openings within the diked
area.
* Not located at a site below the 100-year flood water elevation.
In addition, non-leaking, undrained, and undamaged PCB large high voltage capacitors and PCB
contaminated electrical equipment may be stored on pallets next to a long-term PCB storage
area. However, the storage area must have immediately available unfilled storage space equal to
10 percent of the volume of capacitors and equipment stored outside the facility, and must be
checked for leaks weekly.
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A temporary storage area, which does not meet the requirements of a long term storage area, can
be used to store the following PCB articles and PCB containers for up to 30 days from the time
the generator designated the article or container in storage for disposal, provided that a notation
is attached to the PCB article or container indicating the date the PCB article or container was
removed from service:
* Non-leaking PCB articles and PCB equipment.
* Leaking PCB articles and PCB equipment, provided they are placed in a non-leaking
PCB container with sufficient sorbent material to absorb any liquid PCBs remaining
in the PCB items.
* .PCB containers containing non-liquid PCBs.
* PCB containers containing liquid PCBs at concentrations between 50 and 500 ppm,
provided a Spill Prevention, Control and Countermeasures (SPCC) Plan has been
prepared, and each container bears a notation that indicates that the liquid in the
drum does not exceed 500 ppm PCBs.
Both types of storage areas used for the storage of PCBs and PCB items must be marked with the
mark ML, as illustrated in 40 CFR Part 761.45.
All PCB articles and PCB containers in storage for disposal must comply with the following
regulations:
Must be checked for leaks at least once every 30 days.
Must be dated when they are placed in storage.
* The storage of the articles and containers must be arranged so they can be located by
the date they entered storage.
* If any PCB articles or containers are discovered to be leaking, the article, container
and their contents must be transferred to a nonleaking container.
* Any spilled or leaked material must be cleaned up immediately.
Any container used for the storage of liquid PCBs must meet the following Shipping Container
Specifications of the Department of Transportation (DOT):
* Specification 5 (steel drums without removable heads).
* Specification 5B (steel drums without removable heads).
* Specification 6D overpack (cylindrical steel overpack) with Specifications 2S or
2SL (polyethylene containers).
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* Containers designed, constructed, and operated in compliance with Occupational
Safety and Health Standards 29 CFR Part 1910.106, provided an SPCC Plan has
been implemented.
For PCB non-liquids, the following containers, which meet the DOT specifications, can be used:
* Specification 5 and SB (both steel drums with removable heads).
* Specification 17C (steel drums). .......
* Other containers larger than those above, provided they are designed and
constructed in a manner that provides as much protection as the DOT
containers.
Moveable equipment used for handling PCBs and PCB items within the storage area must be
decontaminated prior to removal from the area if it has come in direct contact with PCBs.
5. Related Marking Regulations (40 CFR Part 761.40)
Each of the following items observed at a TSCA landfill must be marked with the mark ML or, if
allowable, the mark Ms, as illustrated in 40 CFR Part 761.45:
PCB containers.
* PCB transformers.
PCB large high and low voltage capacitors.
* PCB article containers containing PCB transformers, or PCB large high or low
voltage capacitors.
* Equipment containing a PCB transformer or PCB large high voltage capacitor.
* Electric motors, hydraulic systems and heat transfer systems which contain >50
ppm PCBs.
* Storage areas used to store PCBs and PCB items for disposal.
* Transport vehicles, on each end and side, if they are loaded with PCB containers that.
contain more than 99.4 Ibs. of PCBs in the liquid phase, or with one or more PCB
transformers.
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6. Related Recordkeeoinq Regulations (40 CFR Part 761.180)
The owner or operator of a TSCA landfill must prepare and maintain an annual document which
tracks the PCBs and PCB items handled at the facility. The document should be maintained for
each year beginning with July through December, 1978, and must be prepared by July 1 of
each succeeding year. The following information must be included in these documents for the
previous calendar year:
* The date when PCBs and PCB items were received for storage or disposal at the
landfill, or transferred to another disposal or storage facility.
* The identification of the specific types of PCBs and PCB items that were stored or
disposed.
* The identification of the facility and the owner or operator of the facility from whom
the PCBs were received, and the identification of the facility to which PCBs and PCB
items were transferred.
* A summary of the total weight in kilograms of PCBs and PCB articles in containers
and PCBs in PCB transformers received and/or transferred to other facilities
during the calendar year, or retained at the facility at the end of the calendar year.
* The total number of PCB articles or PCB equipment not in PCB containers received
or transferred to other storage or disposal facilities during the calendar year, or
retained at the facility at the end of the calendar year.
* Records of any water analysis required from ground water and surface water
sampling.
* Operation records, including burial coordinates for PCBs and PCB items disposed.
In addition to the annual recordkeeping requirements mentioned above, owners or operators
must also maintain the following data:
* Any and all documents, correspondences, and data between the owner or operator of
the facility and any State or local government agency that pertains to the storage or
disposal of PCBs and PCB items at the facility.
* Any application and related correspondence sent by the owner or operator of the
facility to any local, State, or Federal authorities in regard to waste water discharge
permits, solid waste permits, building permits, or other permits or authorizations.
All of the above-mentioned records and documents are required to be maintained at least 20
years after the landfill is no longer used for the disposal of PCBs and PCB items. If the facility
ceases to be used for PCB storage or disposal, the owner or operator must notify the EPA within
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60 days. The notice should also specify where the documents are located.
If a TSCA landfill has PCBs and/or PCB items in service or projected for disposal, the owner or
operator must maintain records on the disposition of the PCBs if they are using or storing at one
time at least 45 kilograms of PCBs contained in PCB containers, or one or more PCB
transformers, or 50 or more PCB large high or low voltage capacitors. The records should have
been initiated, if applicable, beginning July through December 1978, and should be prepared
by July 1 covering each previous calendar year. These documents and records must be
maintained for five years after the facility ceases using or storing PCBs and PCB items, in the
aforementioned quantities, and should include the following information:
* The dates when PCBs and PCB items were removed from service, were placed in storage for
disposal, and were placed into transport for disposal, and the quantities associated with each
change using: (1) the total weight in kilograms of PCBs and PCB items in containers including
the identification of the container contents, (2) the total number of PCB transformers and the
total weight in kilograms of PCBs contained in the transformers, and (3) the total number of
PCB large high or low voltage capacitors.
* For PCBs and PCB items removed from service, the location of the initial disposal or storage
facility, and the name of the owner or operator of the facility.
* PCBs and PCB items remaining in service at the end of the calendar year using: (1) the total
weight in kilograms of any PCBs and PCB items in PCB containers, including the identification
of the container contents, (2) the total number of PCB transformers, and the total weight in
kilograms of any PCBs contained therein; and (3) the total number of PCB large high or low
voltage capacitors.
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CHAPTER III
C. PERMITTING
1. Application Process
Prior to disposal of PCBs or PCB items in a TSCA landfill, the owner must receive written
approval from the Regional Administrator for the Region in which the landfill is located. This
approval must be obtained through the owner's submittal of an initial report containing the
landfill location; a detailed description of the landfill; plans and design drawings; an engineering
report describing the landfill's compliance with the technical requirements outlined in the
regulations; the sampling and monitoring equipment and facilities available; the expected PCB
waste volume; a general description of wastes other than PCBs (if any) also to be disposed of in
the landfill; a detailed landfill Operations Plan (as outlined above); any applicable local, State
or Federal permits or approvals; and any schedules or plans for complying with the approval
requirements of the regulations.
2. Approvals
In general, the Regional Administrator may not approve a chemical waste landfill unless he finds
that the facility meets all of the regulatory requirements under TSCA. The Regional
Administrator can waive one or more of the technical requirements, if, in his opinion, the
owner of the facility submits sufficient evidence indicating that landfill operation will not
present an unreasonable risk of injury to health or the environment from PCBs. Any such
waiver is stated in writing and included as part of the approval. For example, the rule
requiring that the base of the landfill be 50 feet above the ground water table is invariably
waived for landfills in the Great Lakes Region (EPA Region V) because of the typically shallow
depth of ground water and the relative impermeability of the clay-rich glacial soils that occur
in the area. Soil liquid limit and plasticity index requirements are also commonly waived.
As compensation for such a waiver, the Regional Administrator has the authority to impose
additional technical requirements or provisions that are deemed necessary. Examples of such
compensatory requirements imposed under this omnibus provision are: RCRA-style double
leachate collection/double soil liners; increased soil liner and synthetic liner thicknesses;
RCRA-style landfill caps; submittal of closure plans; extensive monitoring programs; and
financial assurance. Such compensatory requirements can and often do exceed the minimum
technical standards outlined under TSCA or RCRA.
Generally, the TSCA landfill regulations form a framework for permitting purposes with waiver
and omnibus provisions giving EPA authority to impose necessary requirements and permit
conditions. Approvals issued under TSCA are, therefore, specifically tailored to each facility on
a case-by-case basis with enforceable operating or other conditions being imposed where
appropriate. This allows EPA to maintain tight control over landfill design, construction,
operations and monitoring to assure that public health and the environment are protected.
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CHAPTER IV
TSCA LANDFILL INSPECTION
A. INTRODUCTION
An on-site inspection of a TSCA landfill is necessary to insure that the landfill is in compliance
with the Act and any regulations, permits or enforcement actions issued under it. The
inspections serve as a mechanism for the detection and verification of potential violations and
the observation and evaluation of operating practices by providing EPA an opportunity to
compare actual operations with those allowed in the operating permit and the PCB Regulations.
As a result of information gathered during an inspection, EPA can take the following enforcement
actions: (1) issue a notice of noncompliance; (2) assess a civil administrative penalty; (3)
institute a civil court action; (4) institute a criminal court investigation; or (5) revoke an
operating permit written under TSCA.
The EPA was granted the authority to conduct inspections under Section 11 of TSCA. Under this
Section, a duly designated representative of the EPA, identified by appropriate credentials, may
inspect the records, files, papers, controls, and facilities of a TSCA landfill, provided the
inspection is conducted at reasonable times, within reasonable limits, and in a reasonable
manner.
The inspector's role in this process is to use the time at the site to assess the performance of the
landfill and provide evidence supportive of violations in the form of samples or documentation,
all of which may be used in future enforcement actions. It is also the inspector's responsibility
to conduct the inspection in a technically and legally correct manner to insure the accuracy and
quality of the evidence gathered.
Advance preparation for a TSCA landfill inspection is necessary to insure that the inspection is
focused and conducted efficiently. There are many steps which should be taken as part of a
proper preparation for a TSCA landfill inspection. To begin with, the objective and goals of the
inspection should be established and prioritized to insure that the review and inspection are
conducted efficiently and thoroughly. Next, the inspector should review the landfill's TSCA
permit as well as any previous inspection reports or reports of violation for the facility. An
inspection checklist should then be formulated outlining the inspection and particular
parameters and activities to be observed; and finally, as with any other inspection, the proper
documents, safety equipment, and sampling equipment shall be prepared.
Each of the steps for preparing for a TSCA landfill inspection will be covered in more detail in
the following sections of the manual. Some of them may vary from State or Regional policies
currently being practiced. At this point, it should be emphasized that the material presented
regarding advance preparation and the actual inspection and follow-up are offered as general
guidelines, which should be considered in light of State and Regional needs as well as individual
inspection goals.
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CHAPTER IV
B. PREPARATION FOR A TSCA LANDFILL INSPECTION
Much of the preparation for the inspector involves the review of the facility's operating permit,
previous inspection reports, and follow-up enforcement actions, if applicable, and formulation
of an inspection checklist. The inspector should be familiar with the up-to-date PCB
Regulations applicable to TSCA landfills. These were covered in Chapter III (above), and should
be reviewed as necessary. During the preparation, the inspector should keep in mind the
objectives and goals for the inspection and adjust his/her review accordingly. For instance, is
the landfill to be inspected because of a complaint, as part of an enforcement action, or is it a
routine inspection? This information may facilitate the preparation by allowing the inspector
to concentrate his/her efforts on special issues, effectively using time in the office and at the
site. The inspector, however, should have an understanding of all the permit and regulatory
requirements the landfill must meet, so that noncompliances will not be missed due to
unfamiliarity with the requirements.
1. Review of the Permit (Conditions. Waivers)
Comparing the permit conditions and the regulatory requirements to current and past operating
practices and parameters is an important part of a TSCA landfill inspection. The inspection of a
landfill's current operations is done by on-site observations and sampling, while that of past
operations is dependant on a review of the facility's records. A major part of the preparation
for the inspection is a review of the operating TSCA permit for the facility as well as the
application material which includes the landfill Operations Plan. The review of this material
should be conducted to provide the inspector with:
* General background information.
* The operating conditions which can be inspected.
* The technical operating requirements.
* Any recordkeeping requirements in addition to those in 40 CFR Part 761.
While reviewing the general background information, the inspector should note when the
landfill was established and permitted, its size, location and owners, the general site plans,
design drawings and the layout of the landfill, monitoring systems, as well as a description of
waste materials other than PCBs disposed of in the landfill. Most of this information is
contained in the application material submitted to the EPA's Regional office for approval. The
application material can be a valuable tool in the preparation for an inspection. This
information provides the inspector with an overview of the landfill, allowing him/her to
determine what to inspect on site, so an initial order of approach for the inspection can be
planned, as well as providing him/her with background information that will not have to be
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covered during the actual inspection.
The landfill Operations Plan, which must be submitted as part of the application material,
contains information on how the landfill conducts its day-to-day operations. The Operations
Plan must be approved prior to the acceptance of PCB waste, and once approved, becomes part of
the enforceable requirements for the landfill. The information required to be maintained in the
Operations Plan is discussed in Chapter III above. This plan is one of the most important
documents to be reviewed and understood. The procedures mentioned in the plan must be
followed by the facility, and the inspector should be aware of them to insure that facility
personnel are following the proper procedures for sampling, monitoring, waste handling and
maintenance. In addition, any other construction plans or technical drawings submitted by the
facility as part of its TSCA application should be reviewed to verify the existence of the proper
certifications, if required, and to determine if there are significant departures from these
documents.
The conditions of approval in the TSCA permit must also be reviewed to determine the
site-specific requirements the landfill must meet. Special attention should be paid to those
which can be observed while at the site such as: the verification of monitoring locations;
sample, waste, leachate and ground water handling; and any newly added amendments to the
permit which may not have been previously inspected. These observable conditions should be
noted during the review for later incorporation into an inspection checklist.
In addition to the recordkeeping requirements in 40 CFR Part 761.180, a landfill may be
required to maintain records under conditions of the permit. Some TSCA landfill permits
require the submittal of an annual report to the Region in which the landfill operates. This
report may contain annual analytical data from ground and surface water monitoring and the
leachate collection system, volumes of leachate collected, the types and quantities of PCBs
accepted and disposed and may contain water table maps, etc. If this report is required to be
submitted, it should be reviewed prior to the inspection to: (1) determine compliance with the
permit; (2) provide the inspector with an idea of the wastes collected and disposed and the
volumes of leachate collected; and (3) give the inspector a feel for the tracking records
maintained by the facility. Other permit conditions may require records to be maintained
regarding monitoring frequency and waste handling. Again, as with the other parts of the permit
review, the observable records should be targeted for inspection.
2. Meeting With the Permit Writer
The permit writer can be a valuable source of information for the inspector. They have spent
many hours reviewing the application material for the landfill and should be able to provide the
inspector with a physical description of the facility and its equipment, and offer guidance as to
what the inspector should look for. The permit writer is also the best source of information
regarding clarification of possible confusion related to imposed approval conditions, their
background, and the granting of any waivers. In addition to the permit writer, Federal or State
agency officials involved in previous inspections of the site may have information pertinent to a
new inspection. The inspector should contact these individuals and the permit writer prior to
the inspection.
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3. Review of Previous Inspection Reports/Reports of Violations
Another important aspect of the preparation is a review of the previous inspection reports and,
if applicable, past enforcement actions related to the facility. This step should not be
overlooked. Not only will it provide more information concerning the background of the
facility, it.also provides the inspector with the compliance history of the landfill and a
description of the actual on-site practices. Some of the specific information which should be
covered and noted during the review are:
* Responsible parties and participants.
* Site-specific background information.
* Daily operational practices.
* Records and documents maintained.
* Past violations.
The name, title, phone number, and locations of responsible parties and past inspection
participants should be noted. This information will be useful for making arrangements for the
inspection or, if the inspection is to be unannounced, for gaining entry at the site.
General site information such as the landfill's size, location, layout, and equipment should also
be noted. This information may fill in any gaps in the permit application materials and/or
reveal any variances from the operation practices outlined in application material or from the
site-specific conditions of approval.
The description of the daily operations contained in the previous reports will indicate what
wastes are accepted by the facility, how they are managed from receipt to disposal, as well as
the facility's monitoring and sampling practices. It may also describe how the receiving and
storage facilities and roadways are maintained. If an on-site laboratory is being used, the
report may describe the analytical practices followed by landfill personnel. Particular
attention should be given to observations of activities which violate the TSCA regulations or
permit conditions. These are clearly areas to be reinspected.
Any enforcement actions and related documents resulting from previous inspections should also
be reviewed. This review provides the information on past practices which resulted in
violations, enabling the inspector to focus on specific topics which should be rechecked to verify
that the facility corrected the areas of noncompliance. For example, does a particular operation
of the facility continually result in an enforcement action, or are wastes being repeatedly
mismanaged at various stages of the disposal process? The effort a facility makes to maintain
compliance may also be determined by a reveiw of these documents.
Since there are no specific format requirements for the records to be maintained by the facility,
they can often be very detailed and confusing and may require an explanation by a representative
of the facility. If these records are available as an attachment to the inspection report, or as a
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submittal to an enforcement action, they should be reviewed and understood prior to the
inspection. The inspector may contact the facility for a description or clarification of the data
recorded. During the review of these documents, the inspector should note the title of the
forms, the types of data recorded and how it is recorded. If the forms are understood prior to
the inspection, the time spent at the landfill may be used more effectively.
While conducting the review of the landfill's TSCA permit, inspection reports and enforcement
actions, the inspector should prepare a summary sheet which contains the reviewed information
which relates to the overall understanding of the landfill: Information on background,
operations and the areas of concern pertinent to the inspection (such as conditional
requirements, past violations and recordkeeping practices) should be recorded. This sheet will
subsequently be used to construct an inspection checklist.
4. Formulation and/or Review of inspection Checklist
The formulation of a checklist can be a useful practice in the preparation of a landfill
inspection. It serves as a guideline for the entire inspection process by providing an internal
check of preinspection activities and a detailed list of information to be covered while on site.
Most importantly, it outlines steps of the inspection, in sequence, and if followed, adds a
measure of insurance that specific areas of the inspection will not be overlooked. If prepared
and used properly, it can effectively assist the inspector in conducting a thorough and efficient
inspection.
The information which should be included on the checklist includes;
* Special topics related to facility background and operations to be covered during
the opening conference and subsequent interviews.
* The types of records required to be maintained by the facility for regulatory
purposes.
* The procedure or schedule to be followed during the inspection, including the
areas of particular interest.
The inspector must first determine what the site-specific goals of the inspection are and the
order in which they are to be achieved. Then, using the summary sheets and other information
accumulated from the previous review stages, develop a fact sheet containing all information
relevant to the inspection. The inspector may include general descriptive information as well as
more specific information on monitoring practices, operations, waste handling, and
recordkeeping. The checklist will take on the appearance of a questionnaire with "yes" or "no"
answers or with blanks to be filled in during the inspection. The questions which are to be
answered "yes" or "no" should relate to the observation of operations and practices and if
certain records are maintained, and should be phrased so a "yes" answer indicates compliance
with the regulations and permit conditions. The questions with blanks should apply to readings
on monitors or records where the actual value observed is entered in the blank. A "comment"
section may be included if the inspector feels that particular questions may require further
explanation. Since the checklist may be used in an enforcement action, care must be taken with
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the phrasing of the questions to avoid any ambiguities. It is suggested to keep the checklist as
simple and straightforward as possible. While preparing the checklist, the inspector should
take into account his or her experience and the complexity and purpose of the inspection. For
instance, if the inspector has conducted frequent landfill inspections and/or is familiar with
their operations, a simpler version or none at all may be necessary. Finally, as with the
previous stages of the preparation, the time spent on the formulation of a checklist should be
limited and unnecessary information should be avoided.
By using a checklist, the inspector can help assure that the inspection is conducted in an
organized and efficient manner and that the original goals of the inspection will be met. The
checklist, however, is only a tool designed to be used on site as a supplement to the notes
normally taken during an inspection. In other words, the inspector should not be limited simply
to completion of the checklist and should not feel bound to strictly adhere to its format and
questions. Rather, the checklist can simplify and eliminate various aspects of the note taking
process; if other areas of concern arise during the inspection, the inspector should be sure to
pursue these in more detail as necessary.
State and Regional policies regarding the use of checklists should be followed. Also, if a
preferred checklist has been prepared, the inspector should continue to use it. An example of an
inspection checklist is included at the end of this section.
Since landfills vary from site to site, there will not be a specific checklist which can apply to
each landfill inspection. The inspector should compare any existing checklist with the one
included in this manual and make any appropriate changes.
5. Safety and Field Equipment Preparation
The preparation of inspection documents and gathering of safety and field equipment are the final
activities to be undertaken prior to the inspection. The documents and equipment required for
the inspection are similar to those for any TSCA inspection with a few exceptions.
Several documents and items to be prepared, brought on site and presented as required or
necessary include:
* Credentials
* Notice of Inspection
* TSCA Inspection Confidentiality Notice
* Receipt for Samples and Documents
* Declaration of Confidential Business Information
* TSCA Landfill Inspection Checklist
* PCS Regulations, 40 CFR Part 761
* TSCA Landfill Permit (site-specific)
* Outreach Materials
* Notebook
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In order to effectively use the time at the facility, the inspector should complete the documents
with as much information as possible prior to the inspection.
Most of the equipment required for the inspection falls into two categories: that for safety; and
that for sampling. The safety equipment to be assembled and used during the inspection include:
* Hard hat
* Safety glasses or goggles
* Rubber soled, metal-toed shoes
* Coveralls
* Liquid-proof gloves
* Disposable plastic shoe covers
* Respiratory protection devices, depending on the scope of the inspection
* Tyvek suit, depending on the scope of the inspection
The inspector should be familiar with the proper use of the safety equipment and should have a
complete understanding of all health and safety practices to be followed during the inspection.
The facility's own safety policies must be followed on site and should be discussed prior to, or at
the beginning of the inspection.
The areas of greatest health and safety concern while at a landfill are the actual wastes
themselves and equipment. Extra caution should be taken around containers which appear to be
leaking, bulging or are stacked improperly, and those having unknown contents. Also, the
inspector should always be aware of equipment which is moving or has moving parts.
Knowledgeable factiliy representatives should accompany the inspector to answer questions and
to provide extra safety-related guidance. The inspector should never voyage into unknown areas
or near unknown wastes if not properly prepared.
The media which may be sampled during the inspection include: oil, water, soil, sediment, solid
surfaces and biological items. The inspector should be prepared to sample any of these and,
therefore, should have the proper equipment available. The proper equipment will include:
* Sample bottles and containers
* Liquid waste samplers (e.g., glass rods and aspirator)
* Scoop sampler (e.g., shovel)
* Core sampler
* Surface samplers (e.g., wipes and templates)
* Hexane
* Sediment sampler
* Towels and bags
* Tags and seals
* Tape measure or ruler
The types of samples that are typically taken as part of landfill monitoring activities and which
may also be split in some cases with TSCA inspectors are covered in the next section. Guidance
for surface sampling techniques (wipe sampling, soil sampling) are provided in volumes One
and Two of the TSCA Inspection Manual. Proper and consistent sampling techniques are crucial
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to insure the validity of sample analyses which may be used as evidence in subsequent
enforcement actions.
Advance planning regarding the location and shipping restrictions of a particular air carrier for
some samples may apply if air travel is required.
In addition, to the items listed above, a camera, flashlight and other equipment may be
appropriate for use during the inspection. All of the equipment to be used on site should be in
proper working condition and should be properly decontaminated. The choice of documents
andequipment to bring to the inspection will be made in light of the goals of the inspection and
the availability of the equipment.
6. Making Inspection Arrangements
The final stage of preparation for a TSCA landfill inspection involves making the necessary
arrangements. Three considerations apply during this stage: (1) coordination of the inspection
with other Federal, State or local agencies; (2) the procurement of a warrant; and (3)
notification of the facility.
Prior to the inspection, other Federal, State or local agencies having approval or regulatory
authority over the landfill should be contacted. The reasons for this are: (1) they may have
planned or ongoing actions with the landfill that the inspector should be aware of; (2) a joint
inspection may be scheduled; (3) they may have additional information that may be useful; (4)
scheduling interferences can be avoided; and (5) the inspector may be able to provide them with
information concerning the site.
If the inspection is to be conducted to support an enforcement action, the compliance officer and
attorneys involved with the case should be consulted. They will be able to identify specific areas
or operations of the landfill which should be inspected.
Another consideration which may be made prior to an inspection concerns the acquisition of a
warrant. A warrant is a judicial approval for designated officers to inspect a specific location
or function. It is normally used to gain entry when entry is denied or consent to conduct an
inspection is withdrawn. One can be obtained prior to an inspection if there is sufficient reason
to believe there will be a denial of entry or withdrawal of consent to inspect. If a warrant is
deemed necessary, the Office of Regional Counsel should be contacted. Additional procedures
pertaining to the procurement and use of a warrant are included in the TSCA Inspection Manual.
Depending on the purpose of the inspection, State or Regional policies, suspicion of
noncompliances and the planned duration of the inspection, the inspector may wish to notify the
landfill of the inspection. If the inspection requires examination of a large volume of records,
certain personnel to be available, or expensive sampling, it may be more convenient to
prearrange the inspection with the facility. However, if the actual operations and practices of
the facility are to be observed, an unannounced inspection may be necessary. They are
particularly effective if an act of noncompliance is suspected. An annual notification, without
specifying dates, of EPA's authority to conduct TSCA inspections can be an effective way to avoid
admittance problems when unannounced inspections are to be conducted.
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CHAPTER IV
C. THE INSPECTION
1. Entry
After preparations and arrangements have been completed and made, the on-site inspection can
be conducted. The first step is to gain entry to the site. Under TSCA, Section 11, a
representative of EPA may inspect a facility upon presentation of proper credentials and a
written notice of inspection. The credentials and notice must be presented to the owner or
operator in:charge of the facility. The inspector, however, must have consent by the owner,
agent-in-charge or other authorized official before proceeding with the inspection.
The owner or agent-in-charge can deny access to the facility, records, files, etc. When this
occurs, the inspector should question and document the basis for denial, and discuss this basis
with the facility in an attempt to have denial removed. If a resolution cannot be reached, the
inspector may suggest that the party contact their attorneys for clarification of EPA's authority
under TSCA. If all attempts to acquire consent have failed, the inspector should withdraw from
the site, but not before recording the names of the officials involved and any observations made
while on site, particularly those which may suggest noncompliances.
After leaving the site, the inspector should contact his or her supervisor or the Office of
Regional Counsel to begin the process of obtaining a warrant.
The consent to inspect may also be withdrawn at any time during the course of the inspection.
This action constitutes a denial of inspection and a warrant may be necessary to complete the
inspection. Some typical but non-valid reasons for denial:
* Refusal to allow photographs to be taken.
* A temporary shutdown or strike.
* Refusal of the inspector to sign a waiver.
* Too busy to accommodate the inspector.
If the facility personnel use any of these excuses, the inspector should inform them that their
action constitutes an act of denial, and then follow the procedures outlined above which describe
the proper responses when confronted with denial.
2. Opening Conference
After the inspector has found the person with whom the inspection will be conducted and has
presented his or her credentials and the Notice of Inspection, an opening conference may be held.
During this conference, and after the presentation and explanation of the TSCA Inspection
Confidentiality Notice, the purpose and objectives of the inspection should be explained.
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For example, is the inspection the result of a complaint, a reported violation, or is it a routine
compliance inspection? Will it consist of a review of the facility's records and/or operations
and will samples or photographs be required?
The inspector should then provide a brief rundown of the predetermined plans or schedules for
the inspection. At this time, arrangements can be made to schedule meetings with various
landfill personnel, to have records made available for review and areas accessible for
observation. The time and participants of the closing conference should also be discussed.
Most of the time spent on the opening conferences should involve discussions concerning the
facility, its background and operations, as well as any new policies, regulations, or conditions
related to the landfill. Specific information that the inspector should discuss and/or document
includes: .•
* Names and addresses of inspection participants.
* Facility owners and parent companies.
* Background and history of the site.
* Operating requirements and practices.
* Recordkeeping requirements and records maintained.
* Health and safety reports (e.g., injury or spill occurrences).
* Wastes accepted and disposed (types and volumes).
* Monitoring requirements and practices.
* Sampling procedures.
* Facility maintenance.
Inconsistencies between information presented during the opening conference, and that reviewed
prior to the inspection should be pursued. The opening conference should also be documented in
the field notes. An inspection checklist may be used to record specific information.
The inspector can forego the opening conference and proceed directly to a specific area or
operation of the landfill if he or she feels that a possible noncompliance exists.
3. Scope of Inspection
In some cases, particularly where older, larger facilities having a pre-TSCA history are
concerned, contaminant assessment efforts may be ongoing while newer landfill cells are being
used, planned, and constructed. In such an instance, a TSCA inspector could, depending on the
scope of the inspection, be called upon to inspect and evaluate a facility's contaminant
assessment effort, routine monitoring efforts and procedures, various phases of landfill
construction, operations/disposal practices, or closure/post-closure care/conditions. It is not
possible for an inspector to evaluate all of these aspects of landfill operations during a single
one-day visit. It is therefore important for the inspector of these types of facilities to focus on
one major topic of interest or schedule either a longer, more extensive inspection visit or a
series of one-day inspections. Some facilities are scheduled for routine recordkeeping, storage
and disposal inspections on a regular basis (quarterly, biannual) and are also subjected to
non-routine technical inspections on an as-needed basis (if permit violations are suspected or
operation problems arise). With these considerations in mind, it is vital that the TSCA landfill
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inspector carefully plan the scope of his or her inspection so that its objectives can .be
efficiently and reasonably met within any scheduling or time frame limitations.
The TSCA landfill inspector must also keep in mind the facility's responsibility to comply not
only with the PCB landfill regulations, as compiled in 40 CFR 761.75, but also with the letter
of their submitted application materials, including the Operations Plan, monitoring plans,
sampling and analysis plan, and landfill design/construction methodologies. Any deviation from
the procedures outlined in these plans or submitted drawings (governing construction) without
prior written notice to TSCA constitutes a permit violation, and may subject the facility to an
enforcement action. In addition, all site-specific permit conditions are enforceable and should
be checked for facility compliance during an inspection. Therefore, the inspector may also need
to prepare, in addition to a generic regulations-based checklist (see end of section), an
Operations Plan, permit conditions, monitoring or construction/design checklist that is tailored
specifically to the facility to be inspected.
The following discussion pertains to items which are not directly addressed under the TSCA
regulations but are believed to be appropriate for inspection at any TSCA landfill facility.
3.1 Monitoring System Integrity
3.1.1 Ground Water Monitoring Wells
It is important for an inspector of TSCA landfill cells to inspect the monitoring well array at the
facility to assess well integrity. Several components of each well should be inspected as follows:
* Stainless steel, teflon, or PVC monitor well casings (well pipes) should be
checked visually for evidence of excessive rusting, cracking, or other damage.
Any damaged wells must be replaced.
* The surface grouting and concrete pads that are required to be placed at the
surface surrounding the well casing should be checked for cracking or other
evidence of frost-heave or freeze-thaw damage. Any damaged concrete pads must
be replaced.
* Wells containing water with very high pH readings (> 10) were probably grout
contaminated due to improper installation and should be evaluated and replaced as
necessary.
The protective pipes emplaced over the top of the well casing and their locking
caps should be checked for damage and evidence of frost-heave (where
appropriate).
* Inspectors who may be in a position to supervise or inspect monitor well
installation and development should verify that the proper techniques and
procedures (outlined in Chapter II or presented in the facility's Operations Plan)
are being followed.
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3.1.2 Leachate Collection Systems
The structural integrity of leachate collection systems can not normally be directly determined
by an inspector of an operating landfill since most of the components that make up these systems
are installed below grade. Those components of leachate collection systems which do reach the
ground surface can and should be inspected as follows:
* Large diameter concrete leachate standpipes can be inspected for evidence of
cracking, degradation, or other damage during the period in which disposal
activities are ongoing in a cell. After capping, the standpipes are no longer
accessible for inspection.
* Lateral leachate discharge pipes (6" or 10" steel or PVC) which are associated
with primary standpipes, secondary leachate drainfields, or underdrain/leak
detection system discharge should all be inspected for evidence of cracking,
heaving, or other damage (perhaps due to vehicle accidents).
The inspector may be interested in observing leachate volume measurement or
the procedure employed for leachate treatment (if any).
3.2 Landfill Cell Integrity
Maintaining the structural integrity of the landfill cell as a whole is critical to protect human
health and the environment from the potential negative impact of an escape of contamination to
surface or ground water. Therefore, an inspector should be prepared to evaluate the following
landfill features:
3.2.1 Landfill Cap
A landfill cover or cap should be inspected to assure that the waste contents of the cell are
prevented from having excessive contact with percolating surface infiltration or runoff. This
reduces the potential for leachate production and treatment problems, and prevents releases of
ground and/or surface water contamination. The landfill cap should be free of any evidence of
excessive erosion or gullying due to inadequate runoff control, anomalous amounts of rainfall,
or an inadequate soil or vegetative cover layer.
3.2.2 Landfill Walls and Berms
The inner and outer landfill walls and subcell divider berms should be inspected when possible
to assure that excessive erosion, slope failure (slumping), or ground water or leachate
discharge have not taken place at the cell. The inner walls and divider berms can only be
inspected during the construction or active phases of cell operation.
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4. Receiving Area
Two areas of a TSCA landfill which should be inspected are the shipping and receiving areas for
the wastes to be disposed. Large volumes of waste pass through these areas and proper handling
is important to reduce the risk of exposure to the environment. The inspector should know the
regulatory and conditional requirements that these areas must meet. Although they may be
included on the inspection checklist, the following questions provide examples of what should be
observed and documented:
Access Roads
How are they maintained?
Is there enough room to accommodate all vehicles?
Are there signs of damage or deterioration?
What are the facility's restoration policies?
How many vehicles currently occupy the roads?
How much dust is raised by the vehicles?
Do the roads show signs of spills or accidents?
Equipment
What are the decontamination procedures used for equipment and vehicles?
Is the equipment being overloaded with waste?
Are there signs of leaks or damage to the containers handled by the equipment?
Is the equipment marked with the mark ML?
Waste Handling
How are the wastes handled in the shipping and receiving areas?
Are the wastes piled or stacked?
Are PCB wastes segregated from other wastes? If so, how?
Do some of the containers appear to be damaged due to the waste handling process?
Are there any spills or leaks in these areas?
Are the wastes stored temporarily?
Are the PCB containers or articles marked with the mark ML?
Waste Analysis
Where, when, how and how often are the wastes sampled?
Are the procedures and techniques used to sample the wastes satisfactory?
What types of sampling equipment are used?
Is there sufficient protection against contamination?
How are the samples tracked?
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Temporary Storage
Is there an area used for off-loading or temporary storage?
If so, does the area have containment or diking?
What is the containment volume?
Is the area marked with the mark ML?
Are there signs of spills or leaks in the area?
How long do the wastes remain in this area?
Records
What types of records are maintained relating to shipping and receiving?
How are the wastes tracked?
What do the records contain?
Who maintains the various records?
Where are they maintained?
During the walk-through of these areas, the inspector should take detailed notes of observations
and responses to questions. If stains or unmarked wastes, or containers being improperly
stored are observed, samples or photographs should be taken as necessary to support claims of
noncompliance. If other observations or responses indicate a potential noncompliance, they
should be pursued and the inspector should not limit him or herself to the checklist or questions
above.
5. Storage Area
The area used to store the wastes, including PCBs and PCB items, prior to disposal should also be
inspected to insure that the wastes are managed properly. The inspector should be familiar with
the storage requirements in the PCB regulations, and any applicable conditions in the TSCA
permit. The following questions provide an inspector with general guidelines regarding the
types of observations to be made. Any observed potential noncompliances should be followed up
and documented in detail.
General Storage Area
Is the storage area maintained as a temporary (30 day maximum) or a permanent
storage area?
Does the area have sufficient diking? What is its containment volume?
Are there any drains, sewers or expansion joints within the containment area?
Does the storage area have adequate roof and walls?
Is there an indication that the roof or walls leak?
Is the storage area marked with the mark ML?
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Containers
What types of containers are being used to store PCBs and PCB items?
What condition are they in? Are they damaged or leaking?
Are the containers marked with the mark ML or dated with the date they were placed in
storage?
Do the containers indicate the concentration of PCBs within them?
Waste and Storage Area Handling
Are the containers arranged in the storage area by dates?
Are the containers stored within the diked and enclosed area?
Are .inspection records maintained?
Is an SPCC plan required? If so, is one maintained?
Do any of the containers appear to be leaking?
Records
Are waste blending or batching records maintained?
How are the wastes tracked through the storage area?
Who maintains the records, and where are they maintained?
Detailed notes, samples and/or photographs should be used to document and substantiate any
observations made while inspecting the storage area(s).
6. Laboratory
A TSCA landfill may use an on-site laboratory to analyze wastes, leachate, and ground water.
The laboratory may not have to be certified, but the analytical procedures used must meet EPA
standards and should be documented by the inspector. Since some inspectors have limited
chemical backgrounds, a thorough inspection of the laboratory will require the presence of a
chemist or other specialist, however, an inspector may uncover inconsistencies through on-site
observations. Based upon these observations, a chemist or specialist within the State or
Regional office may be able to make a determination regarding possible problems with
laboratory's quality assurance/quality control and analytical procedures. With this in mind,
the following presents some general guidelines on the topics that should be reviewed during an
inspection of an on-site laboratory:
Handling of Samples
How are samples preserved, stored and prepared?
Are the containers marked?
After the samples are analyzed, what is done with them?
What steps are taken to avoid cross contamination of samples?
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Laboratory Equipment
What types of equipment are used to analyze the samples?
How and when are they calibrated?
Are spiked samples, lab blanks or controls run? If so what are the results?
How are the containers and equipment decontaminated?
Are there signs of spills in the laboratory?
Analysis
What are the procedures used to analyze the various samples?
What EPA standards are followed?
Is there a QA/QC plan for the laboratory?
What calculations are done during the analysis?
Records
What types of records of the analysis are maintained?
How are the samples logged and tracked through the laboratory?
Who is responsible for the maintenance of the records?
While in the laboratory, the inspector may want to obtain a split sample of waste or leachate or
ground water that has been, or is in the process of being analyzed. The analysis of such a sample
provides a check on the accuracy of the facility's equipment and practices. A copy of the QA/QC
plan should be requested, and an actual analysis of a sample should be observed and documented,
time permitting. Once in the office, the inspector should discuss the QA/QC plan and his or her
observations with appropriate and qualified laboratory personnel. Their comments may be
included in the inspection report.
7. Recordkeepinq
The PCB Regulations and TSCA permits require owners or operators of TSCA landfills to
establish and maintain various records. One important element of a landfill inspection consists
of a review of these records. The records required to be maintained include annual PCB reports,
operational records, waste, water and leachate analysis, and correspondence between the facility
and environmental authorities. Several specific recordkeeping requirements which are
discussed in some detail in Chapter III will also be covered in this section.
Some considerations to be made for an effective review of a landfill's records are similar for
each type of record maintained, however, the approach will vary widely between on-site and
in-office reviews. When reviewing records at the site, the time available, the volume of
records and clarity or conciseness of the records must be taken into account. There are also
several options for review. The inspector can review records on or related to questionable
periods or periods in which violations are known to have occurred. Alternatively, time periods
can be randomly selected for review. Another option is to select specific waste streams and
track them through the entire disposal process. The records should be reviewed for overall
completeness, discrepancies, deficiencies, accuracy and compliance. The types of information to
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be noted should include:
* The title of the documents reviewed.
* Information maintained on the documents.
* Periods or dates of information reviewed.
* Specific information reviewed, including values.
* Preparers of the records.
* Location where the records are maintained.
* The origin of the data recorded.
The inspection checklist may be used to list values for the data observed while on-site. It is
most effectively used when the records' formats are known in advance and specific dates and data
are slated.for review. If there is not enough time during the inspection, or if potential
noncompliances are found, the inspector should request copies of the records for specifically
defined periods. The records can be received during the inspection or submitted to the inspector
afterwards. When copies are made at the site, the inspector should number or identify them. If
the information is stored on a computer, arrangements should be made to obtain a "hard copy."
While at the office, the inspector should review the documents in their entirety, noting the same
information as indicated above.
The remainder of this Section is devoted to an explanation of the types of records that the facility
is required to maintain and what should be inspected.
7.1 Annual Reports
Annual reports which track the PCBs and PCB items handled at the facility each calendar year
must be maintained. The reports have been required to be completed by July 1 of each year
since 1979. Specifics regarding the information to be recorded are covered in Chapter III and
40 CFR Part 761.180(b), (d), and (f). In general, the records should include the identification
of PCB wastes; their generators and their disposal sites; dates PCB wastes were received,
disposed of or transferred off site; and summaries of the total weight in kilograms of each type
of PCB waste received, disposed of or transferred off site during the calendar year. In addition,
records of any required water analyses, waste burial coordinates and correspondence between
the facility and environmental agencies must be maintained. The records mentioned above must
be maintained for 20 years after the facility has ceased accepting PCB wastes for disposal.
Additional records must be maintained if the facility owns or operates in service PCBs or PCB
items or PCBs/PCB items projected for disposal, as indicated in 40 CFR Part 761.180(a).
In addition to the review considerations described in the beginning of this Section, the inspector
should also review the material/reports to ensure that the following requirements are met:
* All applicable years were represented.
* The reports were prepared by July 1 of each following year.
* The PCB wastes were described satisfactorily.
* Were the PCBs or PCB items in storage for more than one year?
* The year to year value changes should equate.
* The analysis dates must meet monitoring frequency requirements.
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* Burial coordinates must be maintained.
* The PCBs must be segregated from other wastes.
7.2 Operations Plan Conformance
The Operations Plan must include among other things, detailed explanations of the procedures to
be used for recordkeeping, sampling and monitoring, water and leachate handling, waste
sampling and segregation, and maintenance (see 40 CFR Part 761.75(b)(8)(ii)). This plan
should be located in the Regional TSCA Office and should be reviewed by the inspector to
determine which records the facility must maintain with respect to the TSCA approval. The
self-proposed recordkeeping practices explained in the Operations Plan are part of the
requirements the facility must meet to maintain compliance status. The records that are often
described in the Operation Plan may be in the form of spreadsheets, sampling and inspection
logs, and other operations/tracking documents. Review procedures similar to those previously
described should be followed and documented when inspecting these records. The inspector
should review these records for completeness, consistency, and compliance.
7.3 Permit-Specific Requirements
Additional recordkeeping requirements are often specified as direct or indirect conditions in the
TSCA permit or approval. Most of these deal with the analysis of liquid samples collected from
the landfill's ground water, surface water and leachate monitoring systems. The frequency in
which sampling is to be conducted is typically specified in the conditions of the permit. Leachate
handling procedures and volume requirements are also commonly included as permit conditions.
Because the format is not specified, these records can be maintained in various forms (e.g.,
charts, tables, graphs, etc.) The first step in a review is to understand the data recording
method. Because most of the records are required to be submitted to the Regional Office, the
reporting format used can usually be determined through a review of the documents already in
EPA's possession. Some specific items that should be checked may include:
* Were sampling dates in compliance with the sampling frequency requirements?
* Were the volumes of leachate recorded? If so, were they recorded at the specified
frequencies?
* Were all analysis parameters performed? (Normally, these include pH, PCBs,
chlorinated organics, and specific conductance.)
* Were records for each monitoring system maintained?
* Were accurate values included in the reports? (This will involve a review of raw
data while at the facility.)
If, after the review of the records, it is determined that one of the above questions could be
answered "no", the facility would appear to have insufficient records. In such a case, the
specific deficiencies should be explained in the inspection report, as would deficiencies observed
during the review of any other facility records.
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. 8. Active Versus Closed Landfill Inspection
The inspection of a TSCA landfill which has entered the closure/post-closure phase of its
history is a much simpler process than that which is appropriate for a currently active facility.
The only issues of concern in the case of a closed facility are those related to its overall
integrity and its recordkeeping, sampling and analysis and monitoring practices. Inspection of
receiving and storage areas and observation of construction or other landfill operations
practices is not possible for closed facilities.
Currently active facilities should be inspected not only for recordkeeping, storage and disposal,
sampling, analysis and monitoring practices but also for compliance with any stipulations or
specific requirements which may have been set down as conditions in the permit, construction
methods as shown in the submitted designs and plans or as procedures to be followed in
accordance with the Operation Plan.
8.1 Conformance with Permit Conditions
Most TSCA landfill permits do not limit the operating requirements simply to the records and
systems that have been discussed above. It is therefore also important to inspect and evaluate
the facility with respect to its conformance with some functions and requirements that are
specified in permit conditions. Examples of some typical conditions include those related to
leachate collection system monitoring; notification; health and safety; financial assurance and
closure and post-closure plans. The conditions which are inspectable should be targeted during
the review of the permit, and incorporated into the site-specific checklist, if used. Examples of
items to consider while evaluating the following commonly included permit conditions are listed
below:
Hydraulic Head Monitoring
Recording of periodic water level measurements in ground water monitoring wells may
be required as well as the compilation of potentiometric surface maps. Determination of
the ground water flow direction may also be specified.
Leachate Collection System Monitoring and Fluid Characterization
Analysis of fluids gathered by the leachate collection system may have to be undertaken
and leachate generation (volume) figures may have to be recorded according to an
established frequency. Requirements pertaining to the handling, storage and disposal of
leachate may also appear as specific conditions in some TSCA permits.
RCRA Coordination and Financial Assurance
Some landfills may be required to comply with all or certain provisions of the RCRA
closure requirements; financial assurance for maintenance, monitoring and remediation
may have to be secured, usually through requirements outlined under RCRA.
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Notification. {Health, and Safety
The permit may contain conditions which require the landfill to notify the Regional
Administrator if sample analysis indicates over 1 ppb PBCs; or if there has been an
accident or a lost-time personnel injury.
The inspector is likely to encounter more site-specific permit conditions than those mentioned
above and throughout this manual. Standard inspection procedures, however, should be followed.
Appropriate questions should be posed and responses documented, samples and photographs of
potential violations should be taken, and records should be completely reviewed.
8.2 Conformance with Construction Specifications
Although a TSCA landfill inspector is not normally equipped to make an inspection of landfill
construction techniques without some aid from a technical assistant, an opportunity may arise
for an inspector to observe the installation of compacted soil liners, primary or secondary
leachate collection systems, standpipes, synthetic liners or landfill cap systems. Where
possible and practicable the observed techniques or construction practices should be checked and
should conform to those outlined in the construction specifications or technical drawings/plans
submitted by the facility as part of its TSCA application.
An inspection of aspects of landfill construction is generally not done unless the inspector is
technically equipped for the task and the inspection is a comprehensive one covering a
wide-variety of landfill practices and operations.
8.3 Conformance with the Operations Plan
As indicated above, the procedures and practices covered by a facility's approved Operations
Plan, are enforceable and therefore inspectable. The inspector should make an assurance that
the facility is following the plan by evaluating conformance with all procedure/protocols
detailed under the following Operations Plan sub-topics:
* Surface water handling
* Excavation and backfilling
* Waste segregation burial coordinates
* Vehicle and equipment movement (roadway use)
* Leachate collection systems
* Sampling and monitoring procedures
* Monitoring wells
* Environmental emergency contingency plans
Site security
Liquid waste disposal practices
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9. Sampling
On some occasions, a TSCA inspector may be called upon to observe or participate in water,
leachate or other sampling procedures at a facility. It is the inspector's responsibility in such a
case to determine if the sampling is done in accordance with protocols outlined in this manual,
in the facility Operations Plan, or in the TSCA Inspection Manual (for wipe sampling/soil
sampling).
9.1 Observation/Supervision
Procedures employed in ground water, surface water, and leachate sampling should be evaluated
by an inspector to determine whether or not the facility complies with its own self-imposed,
TSCA-approved Operations Plan. In cases where an older Operations Plan is in force at a
facility, the procedures given in this manual can be used as general guidance. The inspector
should determine the facility's compliance with the following requirements:
Presampling water level measurement
Proper presampling purging or evaluation, if necessary
* Proper decontamination/dedication of sampling equipment
* Proper sample collection procedure and sequence
* Field analysis performance
* Use of the appropriate sample containers/preservation methods
* Proper packing for transport
* Proper sample labeling and logging procedures
* Maintenance of chain-of-custody logs
* Collection of QA/QC samples
9.2 Split Sampling
In some instances, the TSCA inspectors may want to take a set of split samples in order to
compare the results obtained by the Regional EPA laboratory to those returned by the
commercial laboratory employed by the facility. In such a case, the inspector will need to
assemble the necessary sample containers, labels, preservatives, coolers, log sheets,
chain-of-custody forms, etc., prior to the inspection.
All other procedures, as outlined above, should be followed identically for both sets of samples.
Holding times, detection limits, and analytical methods must be the same. If an entire suite of
parameters are to be analyzed it should be kept in mind that the two splits taken for analyses of
a particular class or type of parameter (PCBs, for example) should be obtained sequentially. It
is not good practice to take a complete suite of samples from a well before taking the second suite
(the split) because of the tendency of some parameters (VOCs) to volatilize.
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10. Closing Conference
After the inspector is satisfied that the facility's procedures and records have been reviewed and
documented, and that the objectives of the inspection have been met, a closing conference should
be held with the appropriate landfill personnel. The conference is an opportunity to obtain
answers to outstanding questions, or to obtain additional explanations of the landfill's practices.
Also, the inspector could take this time to answer the facility's questions pertaining to his or
her area of responsibility regarding the inspection or related EPA or industrial topics. In
addition, any claim of Confidential Business Information should be organized and clarified.
The preliminary results of the inspection can be discussed. The facility representatives should
be informed of any potential problem areas observed during the inspection, however, the
inspector should inform them that final conclusions of compliance can not be made until the
inspection information has undergone official review. All of the possible results of a TSCA
landfill inspection should be briefly explained, but no indication of which will apply should be
given.
After these issues have been discussed, a receipt should be issued for the samples and documents
acquired during the inspection, carefully logging each sample and/or document received.
11. The Inspection Report
The inspection report serves as a summary of the evidence gathered during the review, on-site
inspection and follow-up activities. Its main objective is to collect and organize the evidence
into a usable package. The foundation of subsequent enforcement actions will depend on the
information contained in the report. Therefore, it should be presented as a concise, factual
summary of the observations and be organized in a logical manner. The evidence contained in the
report should be supported by specific references where appropriate.
The first step in writing the inspection report is to review all of the gathered information. This
will include inspection notes, checklists, sample results, photographs, records,
correspondences and records of telephone conversations. The information should then be
organized. The guidelines at the end of this Section should assist in the organization of the
information. Finally, the narrative should be written, with particular detail given to the facts
relating to potential noncompliances.
This report should, for the most part, be written to follow the sequence of events as observed
before, during and after the inspection. A general list of topics that should be addressed in the
report is given below.
General Information
The purpose and objectives of the inspection should be explained, and the names and
titles of all the inspection participants should be listed.
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Background of the Facility
A general description of the facility's size, parent company (if any), operations and
siting characteristics should be given. A brief history of the landfill's compliance status
and results of previous inspections should also be included.
Opening Conference
The inspection report should document the presentation of the inspector's credentials,
the Notice of Inspection and the TSCA Inspection Confidentiality Notice. This section can
also be used to describe any difficulties encountered while attempting to gain entry, or
any other observations made at the beginning of the inspection.
Landfill Operations
Most of the information concerning the inspection will be contained in this section. It
can be simplified by breaking it down into subsections for each operation of the landfill
(e.g., leachate collection; water monitoring; shipping; receiving and storage; disposal
operations; maintenance; laboratory practices). Within each subsection, the report
should contain information regarding system(s) operating status. Were samples,
photographs and/or records taken? If so, what were the results or what did they show?
The regulatory or conditional requirements may also be mentioned if a particular
operation did not appear to be in compliance. Also, as mentioned before, references
should be made to the supportive information and it's location.
Recordkeeping
A general description of the records maintained for regulatory purposes should be given.
The description should include the particular record's title, preparer, location and the
information contained in it. The results of the records reviewed and any apparent
noncompliances should be detailed.
Samples and Photographs
The purpose for taking a sample or photograph should be explained, along with a
summary of the analytical results, the sample identification numbers, sample locations
and media. If special considerations were taken while collecting samples, they should
also be explained. If a split sample was provided for the facility, this should be indicated
and the chain of custody mentioned. Some of this information may be available in the
sample forms which can be included as attachments to the report. For photographs, the
specific contents and other pertinent information should be explained.
Closing Conference
The results and possible outcomes of the inspection as summarized during the closing
conference should be outlined. Also, the issuance of a receipt for samples and documents
should be documented.
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Attachments
Attachments to the report provide the supportive evidence of apparent noncompliances.
At a minimum, the following should be included as report attachments: inspection
documents; sample analysis reports; checklists; chain-of-custody forms; landfill
records; photographs; and documented telephone conversations.
12. TSCA inspection Checklist
The following pages contain a suggested format for a TSCA landfill inspection checklist.
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TSCA LANDFILL INSPECTION CHECKLIST (A Suggested Format)
Date
Facility Name
Facility Address
Participants
A. Background
1. Years in operation? ;
2. Parent company?
3. Have there been any transfers of ownership? Yes No
If yes, was the Regional Administrator
notified 30 days in advance? Yes No
4. Types of wastes accepted? a.
b.
c.
d.
B. Approval
1. If the landfill is multi-celled, have
PCBs and/or PCB items been disposed of
in the proper cells Yes No
2. Are there any waivers in the TSCA permit?
(If yes, the waivers may be incorporated in
the checklist in the appropriate sections.) Yes No
C Siting and General Design
1. If surface water diversion dykes are required,
(a) are they currently provided around the
perimeter of the landfill, and/or (b) is their
minimum height equal to two feet above the
100-year floodwater elevation? a. Yes No
b. Yes No
2. If surface water diversion structures are
required, do they appear to be properly
maintained? Yes No
3. Has a 6 foot woven mesh fence, wall or similar
device been placed around the site? Yes No
4. Are measures taken to prevent PCBs from
migrating from the landfill? Yes No
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CHECKLIST (continued!
D. Operation Monitoring Systems
1. Are the designated surface watercourses sampled
at the permit-specified frequency? Yes No
2. Are all of the monitoring wells cased? Yes No
3. Has the backfilling and plugging of the
annular spaces between the monitoring zone
and the surface prevented the percolation of
surface water into the well bore? Yes _No
4. Do all of the well openings have removable caps? Yes No
5. Are all of the samples analyzed for PCBs, pH,
specific conductance and chlorinated organics? Yes No
E. Leachate Collection
1. Are the leachate collection systems monitored
at the permit-specified frequency for quantity
and physiochemical characteristics of the
leachate produced? Yes No
2. Is the leachate treated or discharged in
accordance with a State or Federal permit? Yes No
If no, is it disposed of by another State or
Federally approved method? Yes No
3. Is the aqueous phase of the leachate collected
analyzed for PCBs, pH, specific conductance and
chlorinated organics? Yes No
F. Recordkeeping
1. Does the owner/operator maintain records at the
facility? Yes No
If yes, are records maintained for the following?
a Water analysis from ground and surface water
sampling? Yes No
b. Three dimensional burial coordinates for PCBs
and PCB items? Yes No
c. Liquid waste PCB concentrations Yes No
d Annual PCB documents for disposal and storage
facilities (40 CFR Part 761.180(b)) Yes No
If yes, are all years represented when PCBs
were accepted for storage and/or disposal? Yes No
e. Annual PCB documents for owners of PCBs or PCB
items in service or projected for disposal? Yes No
If no, was this type of annual PCB document
required? Yes No
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CHECKLIST /continued)
2. Have any annual PCB reports as specified in
the permit been submitted to the Regional
Administrator? Yes No
(Although not detailed on the checklist, the annual PCB documents and reports should be
reviewed to ensure compliance with 40 CFR Part 761.180 and the landfill's TSCA
approval.)
G Receiving
1. Are 'access roads (a) to and (b) within the
landfill adequately maintained? a. Yes No
b. Yes No
2. Are there any vehicles owned or operated
by the landfill at the site which are loaded
with (a) PCB containers containing more than
45 kg of liquid PCBs or (b) one or more PCB
transformers? a. Yes No
b. Yes No
If yes to either (a) or (b) in 2, are the
vehicles marked with the mark ML on all four
sides? Yes No
3. Are the PCBs and PCB items segregated from wastes
not chemically compatible with the PCBs through
the receiving and storage process? Yes No
4. Are there procedures to determine that liquid PCBs
designated for disposal at the landfill do not
contain over 500 ppm PCBs? Yes N
5. Within the receiving process, is there a storage
area for PCB wastes? Yes No
If yes, is the storage area marked with the
mark ML? Yes No
6. Are there signs of spills or leaks in the
receiving area? Yes No
H. Storage
(Since storage areas at disposal facilities are likely to encounter PCB wastes which have
been removed from service for over 30 days, the questions in this section will apply to the
permanent storage area.)
1. Does the storage area have a roof and walls? Yes No
2. Is there an indication that the roof or walls
leak? Yes No
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CHECKLIST (Continued)
3. Is the storage area diked? Yes No
If yes, are the following conditions met? Yes No
a Does it have continuous curbing with a
.minimum 6 inch high curb? Yes No
b. Does it have 2 times the internal volume of
the largest PCB article or container stored
therein? Yes No
c. Does it have a volume equal to 25% of all
PCB articles or PCB containers stored
therein? Yes No
d. Is it constructed of a smooth and impervious
material? Yes No
4. Can spilled liquids flow from the area through
any openings? Yes No
5. Is the storage area marked with the mark ML?
6. Do all of the containers used to store PCBs and
PCB items meet the Shipping Container Specifica-
tions of the Department of Transportation (5, 5B,
6D with 2S or 2SL or 17E for liquids; and 5, 5B,
17C for containers equivalent to the DOT
containers for non-liquids)? Yes No
7. Are all of the PCB containers (a) marked
with the mark ML and (b) dated with
the date they were placed in storage? a. Yes No
b. Yes No
8. Do the PCB containers indicate the concentration
of PCBs within them? Yes No
9. Are all of the PCB containers in good condition Yes No
(ie. not leaking, rusted, or damaged)? Yes No
10. Are the PCB containers arranged in the storage
area by dates placed in storage? Yes No
11. Does the storage area have containers for
liquid PCBs larger than the DOT containers? Yes No
If yes, has a Spill Prevention Control and
Countermeasure (SPCC) Plan been prepared? Yes No
Laboratory
1. Are the PCB containers in the laboratory area
marked with the mark ML? Yes No
2. Are spiked samples or controls run to check the
accuracy of the analytical equipment? Yes No
3. Are the analytical guidelines contained in the
operation or QA/QC plan? Yes No
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CHECKLIST (continued)
J. Disposal
1. Has the restriction against the disposal of
ignitable wastes in the landfill been followed? Yes No
2. Are the PCB wastes segregated from wastes not
chemically compatible with the PCBs during
placement into the landfill? Yes No
3. Are PCB containers with liquid PCBs at concen-
trations between 50 and 500 ppm surrounded
inert sorbent material capable of absorbing all of
the liquid contents? Yes No
4. Are bulk liquids containing less than 500 ppm
PCBs pretreated and/or stabilized into a non-
flowing consistency prior to disposal? Yes No
5. Are measures being taken to suppress dust
during disposal? Yes No
6. Is the equipment decontaminated prior to
leaving the disposal site? Yes No
K. Comments
(Some questions which have negative responses may require additional
explanations to determine compliance.)
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CHAPTER V
FOLLOW-UP AND SPECIAL ISSUES
A. FOLLOW-UP TO THE INSPECTION
After the inspection, the inspector should be prepared to discuss his or her observations with
supervisors, case development officers, permit writers and other State or Regional personnel.
The inspector's assistance may be required for the development of any potential enforcement
action if education or clarification of the landfill's operations is necessary. In addition, the
permit writer should be consulted to discuss the permit conditions as related to observations
made during the inspection concerning potential violations or new equipment or practices. If
potential violations governed by another State or Regional agency were observed, that agency
should be notified.
The discussions mentioned above should be conducted as soon as possible after the inspection.
This will reduce the possibility that information will be forgotten or become distorted. Since
the inspector may have to discuss the landfill several months after the inspection, the
organization of his or her reports, notes and thoughts becomes an important aspect of the
post-inspection activities.
B. SPECIAL ISSUES
There are several issues that the inspector should be prepared for or aware of and which may be
encountered during and after the inspection and reporting process. First, a chain-of-custody
should be initiated for each sample that has been taken. A "chain-of-custody" is a written
record (usually a form) which traces the possession of samples from the moment of collection
through their possible use as evidence in an enforcement action. It serves to protect the
integrity of each sample collected.
Confidential Business Information (CBI) may be encountered at any stage of the inspection
process. The inspector should be cleared for access to such information by the Agency and
understand and observe the proper procedures for handling CBI material. The Document Control
Officer for each Region has the CBI material within his or her possession and should be referred
to gain access to the material for Agency review or to determine what has been claimed by the
landfill facility as CBI.
Finally, as part of the enforcement process, an inspector may be required to testify in court. If
this occurs, the inspector should be able to relate the facts of the inspection in a objective and
professional manner.
More information on the issues mentioned above is contained in the TSCA Inspection Manual and
will not be repeated here. The inspector is encouraged to review the material included in that
manual for the specific details concerning each issue.
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CHAPTER VI
REFERENCES
American Society for Testing and Materials, Annual Book of ASTM Standards, Method D-1586-
Standard Method For Penetration Test and Split-Barrel Sampling of Soils, Vol. 04.08
(Construction), 1988, p. 216-220.
American Society for Testing and Materials, Annual Book of ASTM Standards, Method D-2488 -
Standard Practice for Description and Identification of Soils (Visual-Manual
Procedure), Vol. 04.08 (Construction), 1988, P. 293-302.
American Society for Testing and Materials, Annual Book of ASTM Standards, Vol. 11.02 (Water
and Environmental Technology), 1979.
American Waste Water Association, Standard Method for Analysis of Water and Waste Water,
1985, 16th Edition.
Hakonson, Biotic Barriers in Landfill Cover Technology, 1986.
National Sanitation Foundation, National Foundation Standard No. 54, 1985.
U.S. EPA, Handbook of Radiochemical Analytical Methods, 1975, EPA-600/4-75-001.
U.S. EPA, Methods of Chemical Analysis of Water and Wastes, 1983, EPA-600/4-79-020.
U.S. EPA, RCRA Ground Water Monitoring Technical Enforcement Guidance Document, 1986a,
OWSER-9950.1.
U.S. EPA, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846,
1986b, 3rd Edition.
U.S. EPA, Minimum Technology Guidance on Final Covers for Landfills and Surface
Impoundments, 1987.
U.S. EPA, Toxic Substances Control Act Inspection Manual, Vol. 1: TSCA Base Manual,
January 1980.
U.S. EPA, Toxic Substances Control Act Inspection Manual, Volume 2: PCB Manual, March
1981.
U.S. EPA, Policy for Managing Leachate at PCB Landfills, January 16, 1987.
U.S. EPA, Toxic Substances Control Act Inspection Manual; TSCA Inspection Manual, August
1989 (Update of January 1980 manual).
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