oEPA
United States
Environmental Protection
Agency
Off ice of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9475.00-12
TITLE: Closure Requirements
APPROVAL DATE: 02/02/88
%
EFFECTIVE DATE: '02/02/88
ORIGINATING OFFICE: office of solid waste
m FINAL
O DRAFT
STATUS:
I 1 A- Pending OMB approval
[ J B- Pending AA-OSWER approval
{ ] C- For review &/or comment
[ ] D- In development or circulating
REFERENCE (other documents):
headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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United States Environmental Protection Agency
Washington. DC 20460
OSWER Directive Initiation Request
1. Directive Number
9476.00-12
2. Originator Information
Name of Contact Person
Hope Pillsbury
Mail Code
WH-563
Office
OSW
Telephone Code
(202) 475-6725
3. Title
Closure Requirements
4. Summary of Directive (include brief statement of purpose)
The purpose of this policy directive is to interpret certain aspects of the closure
regulations as they apply to tank systems, surface impoundments, and municipal
landfills.
5. Keywords
Closure / Hazardous Waste / Landfill / Permit / Surface Impoundment / Tank System
oa. Does inis Directive supersede rrevious uirective(S)'.
b. Does It Supplement Previous Directive(s)?
XX
No
No
Yes ' What directive (number, title)
Yes What directive (number, title)
7. Draft Level
A - Signed by AA/DAA
B - Signed by Office Director
C - For Review & Comment
D - In Development
8. Document to be distributed to States by Headquarters?
Yes
XX
No
This Request Meets OSWER Directives System Format Standards.
9. Signature of Lead Office Directives Coordinator
VUM&r A ~&tUc^>-, <9&0
10. Name and Title of Approving Official
Marcia Williams, Director, Office of Solid Waste
Date
02/02/88
Date
02/02/88
EPA Form 1315-17 (Rev. 5-87) Previous editions are obsolete.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
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OSWER DIRECTIVE # 9476.00-12
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
FEB 2
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Closure Requirements
FROM: Marcia E. Williams
Director
Office of Solid Wa
TO:
/
e IWH-563)
David A. Wagoner
Director
Waste Management Division
EPA, Region VII
This memorandum is in response to your memorandum of
December 17, 1987, which posed a number of questions related to
implementation of the closure regulations. As you know, we
have discussed the issues over the phone with you several times
since receiving your memo, both in the context of general
policy, and also in the context of applying these policies to
.specific situations. We have responded to each point in turn.
Response to point 1:
Your question concerns the consistency between the new
tank system regulations (51 FR 25422, July 14, 1986), which
include post-closure care, and the closure requirements for
container storage units. Since we have now revised the tank
system standards as of July 14, 1986, we recognize that there
are inconsistencies with the present container standards. We
agree that the container storage requirements in Subpart I of
40 CFR Part 264 and 265 should be revised so that the Agency
will have: a consistent overall policy for closure of storage
and treatment units.
•ts -
viT~ — -•
Response to point 2:
You requested guidance on whether the clean closure policy
for surface impoundments contained in the March 19, 1987
Federal Register notice, can be applied to all hazardous waste
management units in Iowa (which does not have final RCRA
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OSWER DIRECTIVE # 9476.00-12
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authorization). The clean closure policy that was contained in
the March 19, 1987 Federal Register should be applied to
closures by removal of wastes from any RCRA regulated unit.
Regulated units include landfills, surface impoundments, waste
piles, and land treatment units. The regulatory language
governing the level of cleanup described in each of the
following sections, 264.197, 264.228(a), 264.258(a), 265.197,
265.228(a), and 265.258(a), is identical. Since the
consequences of achieving clean closure are the same,
regardless of type of unit, the general policy contained in the
March 19, 1987 FR notice, and the specific details regarding
the setting of cleanup levels in each medium that are contained
in the upcoming "Surface Impoundment Clean Closure Guidance
Manual", should be applied consistently to all units that close
by removal of wastes. Another guidance document, "Clean
Closure of Hazardous Waste Tank Systems and Container Units",
is currently being developed. It is consistent with the manual
for clean closure of surface impoundments; differing only where
necessary because of the unique nature of tank systems and
containers.
As stated in the March 19, 1987 preamble, clean closure
cleanup levels are to be based on Agency-approved health based
limits, rather than background, except where no such
Agency-approved limit exists, and then background may be used
as the basis for setting cleanup levels.
Response to point 3:
As currently envisioned, the proposed changes to the
closure regulations would allow a landfill to defer closure to
manage non-hazardous wastes only if certain demonstrations are
made. Key among these is that managing non-hazardous wastes
will not be incompatible with prior management practices. The
preamble will include a discussion of potential incompatible or
detrimental effects which are to be considered in evaluating a
request to defer closure. For landfills these concerns
include: subsidence, increased leachate formation, cap
settlement and gas production. These potential detrimental
effects could support a finding of incompatibility, which would
be grounds for disapproving a deferred closure request.
This rule change will not affect enforcement actions. The
opportunity to defer closure will be afforded to both permitted
and interim status units. Facilities with units which have
lost interim status can receive an operating permit which
includes the LOIS unit. Waste receipt would not be allowed in
the LOIS unit prior to permit approval.
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OSWER DIRECTIVE # 9476.00-12
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Response to point 4
You have requested guidance on the issue of whether
changes may be made at facilities operating without a permit or
interim status and LOIS (loss of interim status) facilities
under Section 270.72 when necessary to comply with corrective
action and closure plans. This issue was raised in the context
of the rule, proposed on August 14, 1987, 40 CFR Parts 265, 270
and 271 entitled "Changes to Interim Status and Permitted
Facilities for Hazardous Waste Management; Procedures for
Post-Closure Permitting; Proposed Rule". We are currently
considering this issue and will address it in the final rule
scheduled for Summer 1988.
Response to point 5
Your first question, in 5a and b, concerns your
interpretation of 40 CFR Part 261 and the March 19, 1987
Federal Register notice, as they apply to wastes resulting from
closure. Your interpretation is correct. As you stated, a
characteristic waste must be managed under Subtitle C unless
the material no longer exhibits any of the four characteristics
specified in Part 261, Subpart C. It would not be sufficient
to merely demonstrate that the materials no longer exhibit the
one or more characteristics that had originally brought the
waste under Subtitle C regulatory control. A waste that is
listed as hazardous under Part 261, Subpart D, and any waste
residues or contaminated soil or debris that are removed from a
unit during closure operations, are considered to be hazardous,
unless the waste materials have been delisted, in accordance
with Section 261.3.
Your first bullet point within point 5 referred to how
DOD/DLA (Department of Defense/Defense Logistic Agency)
recommends, in their "Conforming Storage. Model RCRA Permit
Application" (which accompanies their model permit), to
determine whether or not decontamination washwater at a site is
hazardous. As mentioned above, the determination should be
based on whether or not the waste exhibits any of the four
characteristics specified in Section 261.20. TOC and TOX are
indicator parameters only. Therefore the DOD/DLA Model Permit
Attachment for Closure is incorrect when it implies that the
concentrations of TOC and TOX define whether or not washwater
is hazardous.
EPA has commented on this closure plan application
extensively. DOD, however, has not responded to all of our
comments on the model permit. Therefore, as we said in the
August 8, 1987 cover memo to the model permit, EPA may request
different or additional information if a permitting authority
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OSWER DIRECTIVE # 9476.00-12
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finds part or all of the model permit application to be
inappropriate. Copies of both the cover memo and EPA's
comments on DLA's conforming model permit application are
attached for your reference. Please note EPA comments
regarding waste analysis and the closure plan. We recommend
that you use the recent draft report, "Clean Closure of
Hazardous Waste Tank Systems and Container Units" instead as a
guide to closure.
Your second bullet point within point 5 asked why, in
certain situations, non-hazardous material must be removed from
a landfill for clean closure, but then could conceivably be
re-deposited legally in a sanitary landfill. We share your
concern that this could be viewed as an inconsistency within
our regulatory program. Two regulatory efforts, however, are
currently underway which should address this potential
problem. You alluded to the first effort, redefining hazardous
waste, in your memo.
As we move more towards concentration-based listings,
inconsistencies may occur less often. You should note,
however, that the basic reason why action levels in the clean
closure situation are not consistent with hazardous waste
identification levels is that action levels in the clean
closure situation are based on the more protective of two
possible scenarios: the direct ingestion of soil and ingestion
of contaminated ground water, assuming no attenuation in the
unsaturated zone or dilution in the ground water. The
delisting levels, on the other hand, are based strictly on
ground water ingestion, and are derived from a generic model
that accounts for vertical and horizontal spreading of
contaminants over a 500 foot distance in the aquifer. This
difference may well remain even if changes are made in how
hazardous wastes are listed. The answer to the problem is to
complete the Subtitle D regulations for municipal landfills and
surface impoundments. The result of these more stringent
regulations should be that if waste is removed from a landfill
for clean closure and re-deposited in a sanitary landfill, that
the new landfill will be more protective of the environment
than the original one.
We hope you will find this memo to be useful to you in
interpreting these issues related to the implementation of
regulations regarding closure. Please contact Hope Pillsbury
of my staff at FTS 475-6725 if you have any questions regarding
this memo.
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OSWER DIRECTIVE # 9476.00-12
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Attachments
cc: Luetta Flournoy, Region VII
Matt Hale, OSW
Margaret Schneider, OSW
Jim Bachmaier, OSW
Chet Oszman, OSW
Bill Kline, OSW
Mike Petruska, OSW
Chris Rhyne, OSW
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
. WASHINGTON. D.C. 20460
AUG 20 '--? OFF.CEOF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: DOD/DLA Conforming Storage Model RCRA Permit
and Model Permit Application
FROM: Marcia Williams, Director M ^JCM^ i^^^
Office of Solid Waste " (
TO: Hazardous Waste Division Directors, Regions I-X
The Office of Solid Waste has'been working with the Defense
Logistics Agency (DLA) to develop a model permit application and
a model RCRA permit for DLA's Defense Reutilization and Marketing
Service (DRMS) storage facilities. This memorandum transmits
the final documents for your use.
A copy of the model application for the DLA conforming storage
facility is being sent to you as a reference guide to the model
RCRA permit. The model application is based on actual submittals
by DRMS to many of the Regions and States. The model application
has been reviewed by the Headquarters Incineration and Storage
Permit Assistance Team (PAT) and a Regional and State Workgroup.
However, this review must be supplemented by a detailed review
at the time the site-specific application is received. Many of
the sections of the application will change when DLA includes
site-specific information (e.g., the facility's contingency plan
or a list of waste to be handled). Also, different or additional
information maybe requested if a permitting authority finds
part, or all, of the model permit to be inappropriate.
The model permit is to be utilized in conjunction with the
model permit application. Spaces are provided for inserting
information and brackets [ ] are placed to designate optional
sections or phrases, as well as notes to the permit writer. All
brackets, inappropriate phrases, and notes should be deleted
by the permit writer.
Although DRMS might not be the owner or operator of solid
waste management units (SWMUs) at each base, their permits must
address corrective action for these SWMUs. To provide an example
of specific conditions relating to corrective action, excerpts
are included in the model permit from a permit prepared by EPA
Region III for the Defense General Supply Center.
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I hope the attached model application and the model RCRA
permit aid you in drafting permits for the DLA conforming storage
facilities. If you have any questions regarding the DLA storage
facilities and the use of these guidances, please contact
Chet Oszman at FTS 382-4499. Also, I want to thank those
Regions and States who participated in the review of the model
application.
Attachments
cc: Hazardous Waste Branch Chiefs, Regions I-X
State Hazardous Waste Agency Contacts
Mary Jane O'Donnell, Region I
Clifford Ng, Region II
Ed Vollberg, Region III
John Humphries, Region III
Kurt Batsel, Region IV
Doug McCurry, Region IV
Gale Hruska, Region V
Steve Rubin, Region VI
Bill Honker, Region VI
Susan Oberdick, Region VII
Nat Muillo, Region VIII
Eric Yunker, Region IX
Janette O'Hara, Region X
Bruce Weddle, OSW (w/o attachments)
Sue Bromm, OSW (w/o attachments)
Suzanne Rudzinski, (w/o attachments)
James Michael, (w/o attachments)
Chet Oszman
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 30460
2 9 !987
C F P : C E OF
SOLID WASTE A-NiD E VI = R.~ EMC
MEMORANDUM
SUBJECT: Regional and State Workgroup Comments on DLA's
Conforming Storage Application
FROM: Arthur Glazer, Chief .
Incineration/Storage PAT Section
TO: Jan Reitman, Chief
• Environmental Policy Office, DLA-W
The Regional and State workgroup has completed its review
of the Defense Logistics Agency (DLA) conforming storage facility
model permit application. A summary of their comments is attached
You will note that the bulk of the Workgroup's comments are
on the waste analysis and process information sections of the
model application. To improve the quality.of the model applica-
tion, you should amend it, responding to all of the Workgroup's
concerns.
A.T. Kearney (our contractor) has been instructed to begin
development of the model permit. However, completion of the
model permit relies on your response to the attached comments..-.
Therefore, we will need to meet with you at your earliest con-
venience .
If you have any questions or would like to discuss the
comments, we can plan a conference call with the participating
workgroup members. In the meantime, please continue to work
directly with Chet Oszman.
Attachments
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cc: Mary Jane O'Donnell, Region I
Clifford Ng, Region II
Ed Vollberg, Region III
John Humphries, Region III
Cindy Clark, Region III
Kurt Batsel, Region IV
Doug McCurry, Region IV
Gale Hruska, Region V
Steve Rubin, Region VI
Bill Honker, Region VI
Susan Oberdick, Region VII
Nat Muillo, Region VIII
Eric Yunker, Region IX
Janette O'Hara, Region X
Raoul Clarke, Florida Dept. of Environmental Regulation
Wladimer Gulevich, Virginia Dept. of Health
Ray Austin, Texas Water Commission
Bruce Weddle, OSW (w/o attachment)
Sue Bromm, OSW (w/6 attachment)
Suzanne Rudzinski, OSW (w/o attachment)
Paul Connors, OSW (w/o attachment)
Chet Oszman, OSW
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DLA CONFORMING STORAGE
REGIONAL and STATE WORKGROUP COMMENTS
IN GENERAL
1. Generally, the model is a significant improvement over past
DOD efforts in this area. The main area needing additional work
is the waste analysis plan.
INTRODUCTION
1. (page 5) Regarding the first sentence of section (a)(l), the;.
permitting authority would need to make a determination during
the review of the site specific information, that there is suf-
ficient evidence that noncompatible hazardous materials/hazardous
waste will be fully isolated from each other.
2. (page 7) Regarding section (d)(l), the design of each storage
room or compartment must be verified during the review of site
specific information. Stating that it is your intent to meet
the regulatory provision is not sufficient to demonstrate "how"
you will meet that provision.
3. (page 10) Regarding section (e), the first two bullets, the
terms "sealed" needs to be described. How are they sealed? •:«'-
SECTION A
1. The actual wastes to be stored must be indicated in the permit
application, along with the precise storage area in which this
waste will be stored. The draft application makes no attempt to
specify storage locations and instead relies upon incompatibility
charts (given at the end of the application) to determine storage
locations. These charts should be used only as guides.
SECTION B
1. (B-2) The topographic map to be used at the site should be at
a scale of 1" = 200 ft (or smaller) with contour intervals of -
two feet and include a site-wide map of greater scale such as a
USGS quadrangle map. A map which shows land use (especially
residential) within 1000 feet of the hazardous waste storage
facility (HWSF) should also be included. Remember, the facility
is defined by the continuous boundary as defined in 40 CFR 260.10.
2. (B-2a(l) and B-2a(2)) Maps: show location of HWSF on map of
the entire military base and show legal boundaries of the base.
3. (B-2a(4)) Show access control on "Map 1" and refer to B-2 of
the application.
4. (B-2a(ll)) List fire equipment that will be available for
use at the facility.
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5. (3-2a{12)&(13)) One topographical map should show 100 year
Eloodplain (if one exists within 1000 feet of the HWSF) and'
drainage and any surface water bodies around the HWSF.
6. (3-4) Tell where off-site wastes come from and what route(s)
they will travel to jet to the HWSF from the port, airport, or
state line. You will need this information for the general
public.
7. (3-4d) Give the expected traffic load as well as the load
bearing capacity of the roads.
8. (Section B) Although not specifically required we suggest:
(1) Each map contains a notation in brackets indicating the map's
date and orientation; (2) the 100-year floodplain be discussed,
whether the HWSF is in it or not; (3) seismic considerations be
provided; and (4) certification of all design drawings, specifica-
tions, and engineering studies by a registered professional
engineer be noted.
SECTION C
1. (p.C-1, 8th line) Regarding the phrase "on-base versus off-
-base", more information on the source of waste should be provided.
If wastes are coming from certain off-site facilities on a regular
basis, their location and mode of transportation should be
described. The permit will require proper manifesting for these
shipments. Also, if shipments originate outside the continental
U.S., this should be described. The information .should indicate
if unexploded ordinance (VXO's) or outdated munitions will be
stored at the facility. Information of this "nature must be
available for the public hearing.
2. (C-l) A detailed physical and chemical analysis of each
hazardous waste must be obtained prior to storage of the waste.
Reliance on generic chemical classification data is not adequate
for this purpose.
Physical analyses and ranges in the concentrations of chemical
constituents need to be provided for both groups of wastes (i.e.,
Groups I and II). With regard to Group I wastes, the information
provided by the container label and the applicant's Figure C-l
(Disposal Turn-In Document for Generators of Hazardous Waste) does
not appear to be adequate. Although the applicant may, indeed,
rely on information provided by the generator, relying on what
appears to be inadequate information is not appropriate for demon-
strating compliance with 40 CFR 270.14(b)(2). A more complete
physical and chemical description of the waste must be provided.
These analyses must provide sufficient information on the wastes'
properties to comply with 40 CFR 264.13(a).
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With regard to the identification of Group I wastes, it
appears that too much reliance has been placed on the information
provided by the generator. It is our opinion that there is no
guarantee that wastes in "original containers" will match the
label shown on the container. This group of wastes should be
tested to assure proper identification.
At a minimum, list what hazardous wastes, if any, will not be
accepted (e.g., dioxins, nerve agents, etc.) and waste properties
which, if exhibited by the waste, would preclude the facility's
acceptance of the waste. Also, it would help to refer to Appen-
dixes C-l and C-2 in this section of the application.
3. (C-2) The waste analysis plan drew alot of comment from the
EPA/State workgroup. Rather than attempt to combine all the
comments, I simply listed them out. It will add greatly to
the readability of the model's waste analysis plan if all the
following are addressed.
** The waste analysis plan must include provisions for repeating
chemical analysis as necessary to ensure that it is accurate and
up to date for waste generated on-site.
** The waste analysis plan must specify procedures which will
be used to inspect and, if necessary, analyze each movement of
hazardous waste received at the facility to ensure it matches
the identity of the waste designated on the accompanying shipping
ticket. Such inspection and/or analysis procedures must include
testing for indicator or fingerprint parameters which will provide
reliable evidence that the waste received is the same as the
waste represented. Also, the waste analysis plan needs to specify:
- the rationale for the selection of the parameters for
which hazardous waste will be analyzed, in order to
show how analysis for these parameters will provide
reliable evidence that the waste received is the same
as the waste represented;
- the test methods which will be used to test for these
parameters; and
- the sampling method which will be used to obtain a
representative sample of the waste to be identified.
The information requirements [under 40 CFR 270.14(b)(3 ) ] spelled
out above apply to deficiencies in the model application with
regard to Group I and II wastes. Group II waste analytical
parameters need to be supplemented and/or the rationale for the
selection of the given parameters (i.e., Table C-l of the model
application) needs to be explained. Of course, each movement or
shipment of hazardous waste received at the facility needs to be
tested at the time of receipt, regardless of the frequency of
such shipments.
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** In regard to the waste analysis plan,, as long as the generator
is required to obtain a detailed chemical analysis, then the
confirmation analysis done at the DOD storage facility should
ensure that the proper waste has been received.
** The identity of wastes -generator both on-site and off-site
must be verified through the waste analysis plan. Since the
DRMO is merely a tenant on the military base, it has very little
(if any) control over how wastes are handled on base, and it
should treat wastes from the host base and from other bases the
same.
** DRMO does not control what happens on base; it is merely a
tenant. We see no basis for treating off-base and on-base wastes
differently under the wasta analysis plan. Quite the contrary,
our experience has been that, perhaps due to the rapid turnover
of military personnel, it is very difficult to ensure proper
waste handling, even on the most environmentally concerned bases.
This Region will require -testing of both on-base and off-base
wastes, as it does for other commercial facilities. The waste
analysis plan for DRMO storage facilities should also address
obtaining the information needed for final disposition of the
waste. For example, wastes that are restricted from landfilling
must be identified. Each of the military sites sending waste to
DRMO will not be keeping abreast of the land disposal restrictions,
waste oil rules, etc., and properly labeling its waste/ therefore,
DRMO should establish procedures for identifying, labeling, and
properly disposing of these wastes.
** In section C-2 (waste analysis plan), on the third line, the
term "indicates" is questioned. (40 CFR 264.13(a)(2) says "may
include data".) This seems to be the arguement for not completing
a detailed chemical and physical analysis of the waste as required
in §264.13(a ) (1) . This analysis must contain all the information
necessary to treat, store, or dispose of the waste.
** Attached to these comments is a "Sample Waste Analysis Plan"
which Region 3 believes a good guide in revising the model.
4. (C-3c) See our comment on the waste analysis plan above.
Also, see the attached "Sample Waste Analysis Plan for guide.
5. (C-3c(D) The parameters and rationale section must include a
list of parameters for which each hazardous waste will be analyzed
and trie rationale for the selection of these parameters.
6. (C-3c(D) In the case of waste not meeting the generators
identification, the waste should be returned to the generator.
7. (C-3c(2)) The test method to be used to analyze each parameter
must be specified.
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8. (Table C-l, p.C-11) The range of values for either acceptance
or rejection for each of the analytical parameters should be
stated with accompanying rationale. Further, color and physical
state should be used. See attached "Waste Analysis Plan" spot
check procedure for example.
9. (C-3c(3)) Sampling methods must also be specified for those
wastes listed in Appendix C-l.
10. (C-3c(4)) Table C-4 should be clarified and expanded. "Shipment
size" evidently refers to the number of 55-gallon drums - - this
should be clarified. Also, give sample frequency for other type.si.;_^
of containers. .. • •
11. (C-3c(4)) Describe the procedure used to determine which drums
in a shipment would be sampled.
12. (C-3c(4)) The first line should read: "Frequency of analysis
by the generator will be 'as follows:". Also, the phrase in
bullet #2, "will be performed at each turn-in" should be changed
to "will be performed prior to turn-in."
=.«^
13. (Bottom of page C-12) What does the footnote "*" reference?
Actually, the SW-846 is in a third edition. GPO#955-001-00000-1,
2/87, available from the Superintendent of Documents, US Govern-
ment Printing Office, Washington, D.C. 20401, (202)783-3228.
If you choose to use the original footnote, you should state
"second Edition, as updated" and we are the "Office of Solid
Waste". Table C-2 should be amended accordingly.
14. (Table C-3) The reference guide for soil and rock-like material
should be ASTM Standard D420-69. Also, remove the phrase "second ^
edition (1982)" from the reference guide for containerized liquid*";;."
waste.
15. (Table C-4) Schedule B - - "Reduced Inspections" for the last
three lines should be change to:
Shipment Size # of samples to be collected
26-50 5
51-90 3
91-150 10
16. (C-3c(5)) Certifications and documentations of quality control
and quality assurance procedures should be maintained in the
"operating record".
17. (C-4) Refer to Appendices D-2 and F-2 and give examples of
how incompatible wastes will be identified upon receipt. Will
different storage areas be designated for different types of
wastes? If so, tell how. If not, tell how the workers will keep
track of where each category of wastes is stored in the HWSF.
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18. (C-4) The permit application seems to ignore that all flam-
mable s are not compatible, just as all acids are not compatible.
Further designation of incompatiblity is necessary. The^appli-
cation should not be written for every hazardous waste. The
applicant should have a log which indicates what hazardous waste
have been stored in the past, and should project as exactly as
possible, what waste will be stored in the future. If the
applicant insists that all waste codes be allowed, then the
design of the storage bays must be sufficient to separate all
incompatible wastes.
19. The Waste Analysis Plan must state what actions will be taken
when a waste differs from its label description, and what will
be done with unknown wastes when they arrive.
SECTION D
1. (D-la) We did not receive enough information on the loading
area sump design to approve it. In general, we find its con-
nection to the storm drainage system worrisome. Also, we have
found that sumps, even when covered by a roof, fill quickly with
rainwater. The procedures for maintaining the sump and keeping
it free of storm water are of great importance and must be docu-
mented clearly and carefully.
2. (D-la(l)) See our comment to "Section A".
3. (D-la(l)) Experience has shown that application of epoxy
coatings to concrete under suboptimal weather conditions has
resulted in peeling of the coating layers. DLA may want to
protect itself from costly repairs by preparing a thorough QA/QC
plan for application of the coatings.
4. (D-la(l)) Referring to "Conforming Storage Facility Standard
Design", 3/86, Section E, Figure 24, it is suggested to (1) add
a six inch floor thickness dimension, (2) correcting the depressed
floor dimension on left side of wall to "Face to Face", not "Face
to Center Line", and (3) changing the depressed floor height
dimension from "6-8 inches" to "varies: 4" minimum".
5. (D-la(l)) Information showing the basic design parameters,
dimensions, and materials of construction of the catch basin
adjoining the load/unload area needs to be provided. The materials
of construction of the catch basin should also include the same
barriers to waste migration that will be provided for the interior
storage area and the load/unload area (i.e., vapor- barrier and
epoxy sealant).
6. (D-la(l)) Within the discussion, epoxy coatings to be applied
on concrete, curbs and partition walls, and the polypropylene
water stops and other joint sealers, must be compatible with the
waste. The specifications for the coatings and joint sealers,
plus, discussion of compatibility with'the waste, must be supplied.
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7. (page D-3) The use of the phrase "perimeter curb" in the third
paragraph does not match the design. Shouldn't the phrase be
"depressed section".
3. (D-la(D) Revise page D-3 to state that the storage area will
be designed to contain the greater of 10 percent of the total
volume of containers or all of the volume of the largest container.
Submit calculations demonstrating the containment system's ability
to hold the required volume. Thus, it can be seen that the
model application needs to be revised in the area referring to.
"...25 percent of the volume of the largest container...".
9. (D-la(2)) With regard to a description of how the design
promotes drainage or how the containers are kept from contact
with standing liquids in the containment system, the model
application does not offer adequate description because of state-
ments such as: "storage aids can be racks, shelves..." and
"shelving. . .can also be installed..." (emphasis added). More
positive statements need to be included, and these statements
must take into account all storage areas.
10. (D-la{3)) Regarding spills, on page D-4, the statement is -•"•.„-.
made that a 4 inch curb will be able to contain .any spiLts:;". TheV
facility is instructed to include site specific calculatians;. ^ '» :
However, if the area contains 55-gallon drums, stacked 4 to a '-'';
pallet, and 3 pallets high, the capacity to hold 10 percent of
the volume may not be met. Also, the phrase "4-inch curbing"
should be changed to "a 4 inch depressed area".
11. (D-la(4)) The PAT's concern about the adequacy of the loading
area sump is well-founded. We did not receive enough information
to calculate run-off into the sump, nor was the volume of the
sump given in the material we reviewed. We would like to see
more detail on the outlet valve to the storm drainage system,
also, the potential for operator error seems quite high, even
with the alarm.
12. (D-la(4)) The application says a "sealed concrete spill con-
tainment area" is provided outside. How will the concrete be
sealed? Specifications? Chemical compatibility? Further, will
the loading/unloading area be swept/or washed after material
has been transferred and prior to reopening the valve in order
to prevent a release to surface water? When the valve is closed,
will it be tagged with a tamper seal to prevent reopening prior
to completion of the .transfer activity?
13. (D-la(5)) Add after the first sentence: "A wash with an
apropriate solvent or detergent will follow to assure decon-
tamination. "
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- a -
14. (D-la(5)) On page 9, there is a list for spill response equip-
ment and personnel protective equipment. The items listed are
not appropriate for all the different chemicals that will be
handled at the facility. For example, many of the chemicals
listed are incompatible with rubber. Also, there is no mention
of pumps being available for collecting spills, yet on page D-5,
the use of a pump is mentioned. THE PERMIT APPLICATION.MUST BE
CONSISTENT.
On page D-5, pumping the spilled liquid is one of the
alternatives to use for clean-up. However, because the contain-
ment area is not sloped, it will be almost impossible to pump any
liquid. For example, from dimensions estimated from the enclosed
drawings, if the containment area is 10 feet by 4 feet, then a
spill Crom one 55 gallon drum will be approximately two inches
in depth. Pumping such a spill would be difficult. It would
facilitate spill clean-ups if the containment area were sloped
to a collection sump.
15. (D-lb(2)) The applicant has misinterpreted the requirement.
The applicant must show that after a spill occurs, the containers
will not be in contact with the spilled material...
16. (D-lc) See our comment #18 in^.Seetiarr.Cr above.•"• Regarding
bullet #2 on page D-6, the site specific information should provide
more detail on how incompatible wastes will be separated. The
"storage plan" in Figure D-2 should be annotated to correspond
to the incompatibility groups (i.e., Group 1-A, Group 1-B, etc.).
The permit reviewer should be shown how the waste will be separ-
ated. For example, how will Group 4-A wastes be prevented from
contacting Group 3-A wastes both of which may be stored in the
"toxic" area. The applicant should beware of the use of a common
sump for incompatible waste.
17. (D-lc) Is it possible to operate the electric roll-up doors
manually? This will be necessary in case of a power outage.
Further, regarding the "storage according to compatibility" and
considering the size of the lists in Appendixes C-l and C-2,
will the storage building be big enough to provide segregated
cells to store separately incompatible wastes.
18. (D-ld) Each DRMO permit application must give specific
(1) procedures for transporting containers (of all types, e.g.,
some may not be moveable by forklift) across the facility,
(2) aisle spacing to be maintained, (3) maximum number of drums
and other containers, and (4) maximum stacking height in each
area in which containers are stored.
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- 9 -
Also, the application should demonstrate that adequate space
and equipment are available for transferring waste from damaged
containers to new ones. This should be done near a well ventilated
area equipped with shower, eye-wash, alarm, sump, and a place to
store new drums/containers. Transferring wastes will present
the Largest potential safety problem of all the HWSF operations,
and it should be addressed in the application.
SECTION F
1. (F-la(2)(b)) With regard to the means used to control entry
pursuant to 40 CFR 264.14(b)(2)(ii), it should be pointed out
that Air Force Base Security Police may not be available for any
DRMS facilities that are physically located off the site of the
Air Force Base. In such cases, the application should provide
site-specific information as to how the owner or operator will
comply with 40 CFR 264.14(b).
2. (F-la(3)) The warning signs referred to in Section F-la(3)") *
of the model application must be posted not only at the entrances
to the active portion of the facility, but also at other locations,
in sufficient numbers to be seen from any approach to the facility,
pursuant to 40 CFR 264.14(c). "":"
3... (F-2) The inspection tables are very good. Our only comments
are that (1) most of the items on Table F-2 should be done daily"
when loading/unloading, and (2) the problem to look for when
inspecting container labels is whether the labels are intact.
4. (Table F-l) The General Inspection Schedule should include
"smoke detectors" and "lighting & power equipment" and "snow &
ice removal from areas traveled by vehicles (applicable in some
States) under the "Safety and Emergency Equipment" headings.
Under the heading "Operating and Structural Equipment",
direct reference should be made to inspect the valve closing
"catch basin" drain system, as well as, the warning siren weekly
or daily if loading/unloading.
5. (Table F-2) Include an inspection of the containment systems
for both the loading/unloading area and the container storage areas
to detect the presence of accumulated liquids in the inspection
schedule. Also, inspection of any piping and associated ancillery
equipment should be performed regularly.
6. (F-2c) Does the inspector have authority to commit government
resources to undertake the necessary remedial action?
7. (F-2d) The inspection log should also note the time of
inspection.
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- 10 -
8. (F-3(a)(3) and others) A contingency plan is not included.
Each facility is to include its own contingency plan. However,
if the building is constructed on a consistent basis, then expect
for a list of emergency coordinators, the plan should be the
same for each site. Remember, the contingency plan must address
whether the drums will be moved prior to initiation of the
clean-up and to where they will be moved.
9. (F-3b) How hard will it be to get a drum from a pallet into a
hand truck?
10. (F-5a) The use of brass instruments is mentioned in handling
ignitable waste. The applicant should be aware that the reaction
of 1,1,1-trichloroethane and brass products produces a neuro-
toxic agent.
11. (F-5b) See our comment #18 in Section C above.
SECTION H
1. (H-l) The model application should demonstrate, pursuant to
40 CFR 264.16(a)(2) that the personnel training program is directed
by a person trained in hazardous waste management procedures.
Perhaps it could be noted in the model application that this
demonstration will be made as part of the site-specific portion
of the application.
SECTION I
1. (I-la) What parameters will be used to properly close the
facilities. What decontamination levels will be used. What
tests will be performed to determine if decontamination has been
achieved. The closure performance standard must match the
requirement of 40 CFR 264.111.
2. (I-ld) Final closure must also be certified by the owner/
operator. In regard to initiating final closure, 40 CFR 264.113
states final closure activities will be initiated upon receipt
of the final volume of hazardous waste. So, the first sentence
of the 3rd paragraph should read: "Upon receipt of the final
volume of hazardous waste, final closure will be initiated (see
Table 1-1 on page 1-3)."
3. (I-le) The procedure given in Section I-le of the model
application to demonstrate removal of all hazardous waste and
residues needs to be supplemented or clarified in the following
area: "...washings and collection of wash residue...will be
performed until an analysis of the wash residue from all affected
surfaces indicates that the level of contamination is within
regulated concentrations." The meaning of "regulated concentra-
tions" is not clear. Such washings should be performed until an
analysis of the wash residue from all affected surfaces indicates
no significant contamination relative to the wash material prior
to being used.
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Furthermore, any contaminated soil or groundwater must be
removed or treated down to the level of background concentration
for each Appendix VIII hazardous constituent which is reasonable
expected to have been present in any of the waste handled at the
facility.
The decontamination procedure for the container storage
area should describe the specific analysis to be conducted for
each type of waste stored. The definition of clean up to
"regulated concentrations" should be provided. Is the loading/
unloading area's "catch basin" included in this section; if
not, is it included elsewhere in the Closure Plan?
4. Per the reference to SE-846 at the bottom of page 1-5, see our
comment #13 in Section C.
5. The last paragraph on page 1-5 (regarding soil sampling) is
meaningless. Soil samples must be taken any time a spill reaches
the ground surrounding the facility, because contamination left
in the soil constitutes i-llegal disposal. I_f further sampling
will be done at closure, the closure plan should give the number
of samples, sample locations and methods, types of analyses, and
detection levels to be achieved. ;;':
'-fc'- •
CORRECTIVE ACTION FOR SOLID WASTE MANAGEMENT UNITS ,,' •,'"
The model application does not instruct the DRMOs that all
solid waste management units at the base must be identified and
appropriate corrective action taken. If an installation assessment
report has been prepared for the base under the Installation
Restoration Program, this report may be useful in satisfying the
Section 3004(u) of RCRA information requirements. (See the
attached "RCRA Facility Assessment Guidance Manual" for further
information.)
APPENDIX C-l
Appendix C-l and C-2 do not include "K" waste. Perhaps "K"
wastes were not included because they are specific to certain
industries, which would not include military installations?
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r
'/ '•'- -
ATTACHMENT i
WAiiTE ANALYSIS PLAN
iSSON CHEMICAL COMPANY
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McKesson Chemical Company
Wastft Ana lysis Plan
A proposed waste stream from a new or existing customer (the generator)
is evaluated for its economic value by McKesson Envirosystems and a
purchase agreement is completed between McKesson Chemical Company and
the customer. A sample is then submittiu by way of McKesson Chemical
to McKesson Envi rosystems for appropriate analyses. The parameters-..:. '
measured vary from waste stream to waste stream; examples of the major
parameters needed by the recycler and the rationale for their selection
t
appear in the appended table.
The results of these analyses are reported on a "Results of Laboratory
Analysis" form, a copy of which follows: a copy of the completed form
is sent to the McKesson Chemical branch prior to the branch's sending
a truck Co bring the drums of spent soKent back to Che branch.
These physical and chemical analyses of each waste stream will be
repeated when:
1. It is necessary to ensure that they are accurate and up-to-date.
2. The branch is notified, or has reason to believe, that the
process of operation generating the hazardous waste has changed.
3- A manifest discrepancy is detected (unless the branch chooses
to return the shipment to the generator).
Ac laast annually, McKesson Chemical Company will either determine the
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McKesson Chemical Company
Waste Analyses Plan
Page 2.
physical and chemical parameters referred to in the appended table
or receive certification front the.gsnerator of each specific waste
that these parameters remain as previously measured. Such certification
will be kept as part of the operating record. (In fact, all shipments
of drums received at McKesson Envirosystems are routinely analyzed in
order that their economic value is known (i.e., to determine how much
credit to issue to the generator)).
Upon receipt of these drums of solvent, the McKesson Chemical branch
has the responsibility of measuring a sufficient number of paramenters
to assure the branch that the customer did indeed send what he had
agreed to. This consideration leads to the selection of "fingerprint"
or spot check parameters, the measurement of which will provide reasonable
assurance to the branch that the drums of spent solvent received from a
generator actually contain what* :he customer agreed to subnit as
established by the analysis by M:Kesson Envirosystems of the corres-
ponding sample. In addition co comparing the information on the manifest
as to number of drums and their contents as defined on the hazardous
waste labels, the following physical data will be determined at the branch
on samples taken from an appropriate number of drums from each waste
stream:
1. Physical state of the spent solvent, including phase separa-
tion and presence of solid material.
2. Color.
3- Spec i f ic grav i ty .
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PARAMETERS MEASURED IN EVALUATION OF SPENT SOLVENT STREAMS
A. By McKesson Łnvirosystems on Pre-shipment Sample
Parameter Test MetSac-d
Assay
Specific Gravi ty
Water
Flash Point
PH
Gas Chroma tagraph
(SW-8^6, Section 8)
Hydrometer and glass
cy1inder
(ASTM D2I1I-7D
T11 r i me t r i c
(Kar! rischer)
Closed Cup ASTM-0-3278
(SW-846 2.1.1.)
Electrometrical1y
(SW-8A6 2.1.2)
Purpose
To confirm identity, amount of
recoverable component(s), and
major contaminants, if any.
Useful in product identity;
permits conversation of volume
to weight.
Possible contamination.
To confirm identity of DOOl
wastes.
To determine danger of corrosion
from D002 wastes.
3. By McKesson Branch on Actual Shipment
Parameter
Speci r ic Gravi ty
*
Appearance
Test Method
Hydrometer
(AST, -)2111-71)
Visual examination of
sample for color,
clarity, phase
separation
Purpose
To conpare with pre-shipment
sample.
To compare with pre-shipment
sample.
The gas chromatagraph assay will discern all organic compounds which exist in
the waste at concentration exceeding 0.10? by weight, although routine
identification for purposes of recycling are usually limited to concentrations
of 10% or higher.
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McKesson Chemical Company
Waste Analysis Plan
Page 3.
The method of sampling the drums is described in the appended "Scandfl/rd
Procedure for'Samp I ing Waste *Conta i'ners".
For eacr. •.-.•2see stream received from each generator, ten percent of the
number of drums will be sampled, rounded off to the next highest whole
number. Each separate sample will be analysed for the "fingerprint"
parameters — physical state, color and specific gravity.
The methods of analysis for the "fingerprint" parameters are described
below:
1. Physical state, phase separation and presence of solid
material will be determined by observation.
2. Specific gravity will be determined by ASTM Method 02111-71
(reapproved 1978). However, if the specific gravity of
Che wa. te is less Ckan 0.9 (at 25°C)., an appropriate ASTM
standard method using hydrometers will be used.
3. The determination of color (or hue) of the waste, as received,
wiM be made by placing a sample into a glass test tube and
comparing the color to a group of knowncolors. The six e<» . 116)
possible color choices are colorless, white, brown, black,
yellow, yellow-green, green, blue-green, blue, blue-violet,
violet, red-violet, red, red-orange, orange, and orange-yellow.
Lighter ir.ensities of a color (equivalent to mixtures of the
color with white) are considered for these purposes to be the
named color.
The results of the measurements of the "fingerprint" parameters wi1i be
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McKesson Chemical Company
Waste Analysis Plan
Page k.
compared to the values obtained*^ the jnitial McKesson analysis. If any
sample fails any of the spot check criteria, all containers of that waste
must be returned to the generator except those containers that pass all of
the "fingerprint" criteria.
The criteria for the color spot check are that for a waste that should be
colorless, wh;:^, brown, or black, the waste must be that color to pass the
test. If a waste should be any of the other twelve named colors, the spot
check sample n.ust be the original color or no more than one color removed
from the original color when using a color wheel (e.g. Grumbacher Cc'-""
Compass) to pass the test.
The criteria for specific gravity is that the measured specific cravity
at 25°C must ts within 0.10 of the originally determined specific gravicy
•v
to pass the ttst.
All these data and observations will be recorded at the branch and maintained
as part of tne branch's operating record.
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ks»»ww»f»«^ —
177 Wet 8«fry S« 200 Commerce 9ui«Mig. ft *ftyne IN 46802 T* 219 4^41940
'SPENT'SOLVEN'i- STREAM — RESULTS OP LABORATORY ANALYSIS
P] 633 East 138 TH St ri
*— ' P 0 *-*
"I Stata Hgh
P 0 Box 406 — P 0 Box 100
New Castle. KY 40050 Doltoir, II 60419
» 51. Highway 2
P 0 Box 1028
Kanati. PR 00701
D
Q
Part A. Spent Stream Identification
Customer Name ___________________
A Location
Sample Oatei
Spent Stream Name
4 Jlis'e Informationi
- In Bulk
- In Drums Est. Volume-
Fart B- Basic Required Laboratory Analysis - RCRA (Federal) and Hazardous
Waste Regulations (State)
Concentration of Components, Organic Analysis by Gas Chromatographyt
CflMPdN EUT
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STANDARD PROCEDURE
• For
SAMPLING WASTE CONTAINERS
- •»* TTT
Uniform Requirements for Sample Taking
Personnel Safety Precautions
Prior to opening the container for sample withdrawal, the employee
who is to do the sampling must be wearing his hardhat, his safety
glasses, and his solvent*impervious gloves.
The equipment required in order to obtain a sample consists of:
• A Coliwasa type sampling tube.
- A clean, dry glass sample bottle.
- A screw-cap for*the sample bottle which is fitted with a poly-
ethylene poly-cone seal.
- A label containing the following information:
- The manifest number corresponding to the waste shipment.
- The name of the waste being sampled.
^-The date on which th* sample is taken.
- The name of the employee withdrawing the sample.
CAUTION: Always leave about one-inch of free space in the sampls
bottle before it is closed. Never fill the sample bottler to the
brim. Quite frequently the sample is withdrawn at a temperature
which is less than the temperature in which the sample will be
stored prior to analysis. As the temperature increases, the liqui
expands. If the sample bottle is completely filled,, the expanding
liquid has no ^Jace to go and it will shatter the bottle.
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Standard Procedure for Sampling Waste Containers
Page Two
Sampling Procedure for Drums
. *•* f
1. Sampling is done through the bung on the drum. When removing
the bun? closure of the drum, first loosen it slightly without
completely removing the bung in order to relieve any internal
pressure which may have been built up because of change in
temperature.
2. After you are sure that there is no pressure in the drum, remov
the bung closure completely.
3. Open the bottom valve of the Coliwasa type sampler completely.
4. Lower the sampler slowly into the drum until the bottom of the
sampler reaches the 'bottom of the' rf-'-um.
5. Close the bottom valve of the Coliwasa type sampler completel
6. Withdraw the sampler from the container.
7. Transfer the content of the sampler to the sample bottle.
8. Screw the cap tightly onto the bottle.
9. Affix the appropriate label to the bottle.
10. Wipe any spillage from the outside of the bottle.
11. Clean the Coliwasa sampler prior to using it on the next drum.
12. Inspect the gasket on the drum closure to make sure it is in
good condition.
Disposition of the Sample
After the samples have been taken, the sampling containers closed, th
labels affixed, and the sample containers wiped off, take the samples
to the laboratory and turn them ov«»r to the chemist for analysis.
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P«SJCjn*tJon: 0 211?*-71 CFtapprove-d 1978)
Standard Test Methods for
SPECIFIC GRAVITY OF HALOGENATED
ORGANIC SOLVENTS AND
THEIR ADMIXTURES'
Tk» •amUra' » nmit* uadar tfct fli** dnifiuiio* D 2111: tfea aunbar invnadmrty foUovutf ib* dnif n*uoa tsdoia law
yaar of an|nu/ «dopim< ar. »Utt cu* of imaMM. UM vtarof Uw rwnie*. Aaunaar w parent Ann in4 a> napotwal.
TV*
•f Ortrm* m»4 t~
1. Scop*
I.I TheM methods cover the determination
of the specific gritty of halofenated organic
solvents and solvent admutures. Thc> •*•*"«
suitable apparatus and procedures and furnish
details under!) in| the interpretation of test
data and the selection of numeric*' limits for
agreement among interested persons and
agencies.
i.2 Four methods are covered av toila^K
1.2.1 Htihod A. ipecific fravny trj mwns
of a vpecinc f ravit) balance.
1.2.2 Mtthod B. specific |ravu>_b) means
of a h\drometer.
I^.J Mtttiod C. specific |ravit> by means
of a p>cnometer.
1.2.4 Mtiiiod D. specific |ravit> b> meant
of a vacuum pjcnometer.
Norr I — In referee problems. Methods A. C. or
0 ma> be u*ed.
2.1 sptcific /roct/i— the ratio of the weifhi
ia air of a given volume of the material' at a
stated temperature to the weight in air of an
equal volume of distilled water at a stated tem-
perature. It shall be stated thus:
2.1.1 When the icmperatures of the mate-
rial and of the water are the same:
Specific |ravti> if* C ----
• here z <• temperature of the maurial and
the water.
2.1.2 When the temperature of (he material
and of the «aier are not the same:
Specific fri*u\ //i C . -
• here:
* • temperature of (he material, and
r • temperature of the water.
2.1.J ipreific gretitv. ebsaimt—iht ratio of
the weight referred to »>ojum of a given vol-
ume of the material at a stated temperature to
the weight referred to vacuum of an equal vot-
ume of gas*frc» distilled water (Note 2) at a
stated temperature. It shall be stated as in 2.1.
NIITI J— G*-(tn ditnllrt »atcr n ditnllcd wa.
ter thai ha» been boiled to eliminate du*oUed
3. Trti Trmperaiures
3.1 Matenal specifications often specify dif-
ferent temperatures at which specific gravity
shall be measured:
SovnAc irj»u» 15/4 C .
Sptk-inc •'»"«» 20/70 C
Sonaoc |fa*M» 2)/^ C
For purpoxs of unit), the test temperature
used throughout shall be 23/23 C.
3.2 For some of (he liquids, an agreement
ma> be reached as to the coefficient of expan-
sion of the product. In such cases, the specific
gravity may be changed from one temperature
basis to another as described in Section 14.
of ASTM
13.
U :ill M
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