Environmental Protection
OHic« o<
Solid W«»te «nd
&EPA
DIRECTIVE NUMBER: 9480.00-13
TITLE: Supplementary Guidaoce on Determining Liner/Leachate
Collection System Compatibility
APPROVAL DATE: 8/7/86
EFFECTIVE DATE: 8/7/86
ORIGINATING OFFICE: OSW
QD FINAL
D DRAFT
STATUS:
[ I
[ ]
f J
A- Pending OMB approval
B- Pending AA-OSWER approval
t j C- For review &/or comment
[ ] D- In development or circulating
REFERENCE (other document*): headquarters
n.Q i/i/P/? n Q WPB n ^ \I\ICD
'E DIRECTIVE DIRECTIVE D
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AEPA
. . . .
Wasnmgton. uC 20460 -
OSWER Directive Initiation Reauest
u,l, ,:..e .•,„/'.;
9480.0013
Ofginator Informat'On
Name of Contact Person
Chris W. Rhyne
Mail Code -
WH-
Branch
Teleonone Numoer
382-4695
Lead Office
D OERR
00 OSW
D OUST
D OWPE
LJ AA-OSWER
Approved for Review
Signature ol Office Director
Date
Title
Supplementary Guidance on Determining Liner/Leachate
Collection System Compatibility
Summary of Directive . . . i j T i ""
This memorandum addresses several questions regarding the owner's and operator s
responsibility to demonstrate the chemical resistance of liner and leachate
collection and removal system components to the waste or leachate to which they
are exposed. Outlined is the Agency's current position on High Density Polyethylene
testing of liner and leachate collection system components (other than the liner),
environmental stress cracking, and changing leachate during the liner immersion
test (Method 9090).
Key Words:
Policy Directive
Type of Directive (Manual. Policy Directive. Announcement, etc.I
' Status
\ D Draft
\ 0 Final
i D New
I I _ I Revision
)X| No Does U Supplement Previous Directive^!? [ \ Yes fc"
Ooesin.s Directive Supersede Previous Directive!*;? | | Yes"
f "Yes" to Either Question. What Directive (number, title)
NO
Review Plan
d AA-OSWER D OUST
D OERR D OWP6
D OSW . D Regions
D OECM
D OGC
D OPPE
Other {Specify! ORD
This Bequest Meets OSWER Directives System Format
Iture of Lead Office Directives Officer
: Date
Signature of OSWER Directives Officer
Date
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tftfttti
9480V00=1 3
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460 *
AUG -7 1986
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Supplementary Guidance on Determining Liner/
Leachate Collection System Compatibility
FROM: Bruce R. Weddle, Director1
Permits and State Programs Division
TO: Hazardous Waste Management Division Directors
Regions I-X
A number of questions have arisen regarding the owners' and
operators' responsibility to demonstrate the chemical resistance
of liner and leachate collection and removal system components
to the waste or leachate to which they are exposed (see especially
40 CFR 264.301, 264.251, and 264.221). This memorandum answers
some of these questions and further clarifies existing guidance
(See especially the draft Minimum Technology Guidance on Double
Liner Systems for Landfills and Surface Impoundments - Design,
Construction, and Operation, May 1985. )
Is HOPE* a universal material for liner and leachate collection
system components that needs no additional waste/leachate
immersion testing?
No. HOPE is a relatively inert synthetic material that can
chemically withstand a wide variety of substances; however,
there are chemicals that can seriously affect the performance of
HOPE (e.g., .many aromatic and halogenated hydrocarbon compounds).
Many of these chemicals are found in measurable concentrations
in leachates generated at hazardous waste facilities.
HOPE (High Density Polyethylene) is one type of polyethylene
liner material. Polyethylene materials are the most popular
synthetic liner material being proposed for new units.
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OSWER POLICY _pi.»i'-u«t .m
-2- '9'48 0*00-1 3
Long-term immersion test results from low level exposure to
chemicals of concern showed measurable deterioration of HOPE
properties. Therefore, low concentrations of chemicals of
concern must be tested for liner compatibility if they will be
present in the waste.
EPA has been asked by the Institute of Chemical Waste
Management (ICWM) to consider approving HDPE liners as being
chemically resistant to certain classes of wastes without
chemical resistance testing. EPA is investigating this
possibility by reviewing the available data and by discussing
this issue with technical experts in the polymer chemistry
field. At this time we have not completed our review of the
technical issues or received enough data to grant blanket
approvals for HDPE. In addition, preliminary conclusions
from an EPA meeting with polymer chemistry experts indicate
that in the case of a typical land disposal unit, they do not
have the ability at this time to establish classes of chemicals
that specific flexible membrane liner materials are universally
chemically resistant to, primarily because of the complexity
of the wastes, liner stresses posed by the typical land disposal
environment (e.g., temperature ranges and differential loading),
and variations in liner properties [See also response to next
question].
Therefore, in general, EPA is unable at this time to approve
HDPE (or any other liner material) for use at any hazardous waste
unit without unit-specific verification of chemical resistance
based on the specific liner material and waste for that unit.
(Method 9090 or equivalent).
Does the generic term HDPE imply that all HDPE's are alike?
No. Polyethylene plastics, as defined by ASTM D 1248
(Polyethylene Plastics Molding and Extrusion Materials), are
plastics or resins prepared by the polymerization of no less
than 85% ethylene and no less than 95% of total olefins, by
weight. Within this category HDPE is defined as having a density
of greater than 0.940g/cm->. This higher density is an indication
of increased crystallinity that, with all other things being
equal, produces a material that is harder, stiffer, more chemical
and heat res-istant, and stronger than less crystalline material.
As density increases, the properties of elongation, resistance
to environmental stress cracking, impact strength and permeability
decrease. In addition, comonomers are added during resin manufacture
that affect the degree of crystallinity and other material properties
(depending on the processing technique and the type and amount
of coraonomer). Process type and process additives, such as
carbon black, thermal/ultraviolet stabilizers and antiblocks,
will also affect material properties.
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OSWER POLICY
When the sheet: extruder gets the resin he will, in turn,
extrude the material into a sheet using his own proprietary
additives. The physical and chemical properties of the finished
product will again be affected by the additives and type of
extrusion process. (Even the handling of the material immediately
after extrusion can affect material properties.)
As can be seen from the above description, individual
HOPE liner properties can vary, depending on chemical com-
position and a number of processing factors.
EPA also notes that the ASTM designation for HDPE is not
as meaningful as when originally proposed. Advances in resin
manufacturing (such as the addition of new comonoraers) have
blurred the characteristic distinction between high density
and medium density and even low density polyethylenes.'
Materials are being marketed that are technically medium
density polyethylenes, but are labelled high density poly-
ethylene, and, in fact, may exhibit some of the physical
characteristics of high density polyethylene. Therefore,
the density of the polyethylene is not necessarily as key to
overall chemical performance as it once was. Since the
designation HDPE is no longer as relevant as when first
published by ASTM, EPA prefers to designate the various
polyethylenes as "polyethylene" and distinquish one from
another by their other properties, including resistance to
environmental stress cracking, chemical resistance, yield
strength, impact strength, seamability, etc. Density is but
one of the factors affecting overall field performance.
For these reasons EPA is continuing to insist that
owners and operators verify liner/leachate compatibility on
the specific waste and liner material that will be used in
each disposal unit. Verifying the compatibility of waste/
leachate with a particular polyethylene does not guarantee
in itself compatibility with other polyethylenes.
Therefore, permit writers should require owners and
operators to demonstrate the chemical resistance (immersion
testing) of the specific liner material(s) they expect to
use in the actual construction. When the owner or operator
has already performed the -immersion test, and proposes to
install a different manufacturer's polyethylene or a different
"batch" or formulation of polyethylene, he must demonstrate
that the alternate polyethylene is compatible by either
running Method 9090 (or equivalent) on the material selected
for installation or demonstrate material equivalence through
a "fingerprinting" process (see attachment).
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9480^00*1 3
The attached guidance for "fingerprinting" is very general
If the owner or operator selects this option, agreeing on the
nature of the testing program and interpreting test results
will present difficulties. The effect of a change in any given
"fingerprinting" characteristic (e.g. , percent ash) is poorly
understood.
What other liper and leachate collection system components
are required by current regulations to be compatible with
wastes?
Landfill design and operating requirements state that the
leachate collection and removal system, as well as the liner,
must be constructed of materials that are chemically resistant
to the waste managed at the landfill and the leachate 'expected
to be generated (§264. 301 (a) (2) ). Landfill, waste pile, and
surface impoundment design and operating requirements also
state that liners and leachate collection systems must protect
human health and the environment. It is, therefore, incumbent
upon owners and operators to assure EPA that each component of
the liner(s) and leachate collection system(s) is compatible
with the leachate or waste to which it is subjected. Suggested
general procedures for various components are as follows;
1 . Piping - Piping should be prepared for strength
testing per ASTM D 2412 or equivalent. At least
one prepared sample should be subjected to the
same immersion test as performed on the liner
material (e.g., the immersion test outlined in
Method 9090). After the immersion test, the pipe
sample should be dried (per Method 9090) and
subjected to a strength test (see especially ASTM
D 2412 paragraphs 6-9). Testing of a control
specimen (a sample not subjected to the immersion
test) should be performed. A report should be
prepared similar to that outlined in ASTM D 2412
paragraph 11 (including 11.1.7 and 11.1.9) comparing
the test results of the immersed and control
samples.
2. Geotextiles - Geotextiles can be used to perform
any of three major functions in the land disposal
unit: 1) protection of the flexible membrane
liner, 2) use as filtering media, or 3) use in
the transmission of liquid (water or leachate).
Testing procedures for a given geotextile depend
on its function. When the geotextile is used
either as a filter or as a protective media for
the flexible membrane liner, immersion testing
like that for flexible membrane liners should be
performed. After drying the immersed specimen(s) ,
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QSWEfl POLICY DIRECTIVE
-5- 9^80.00*1 $
both the immersed specimen(s) and identical control
specimen(s) should be subjected to the ASTM D
1682 Grab Strength Test and the ASTM D 751 Puncture
Strength Test to determine if a significant loss
of strength has occurred.
Synthetic fabrics used for drainage, such
as nets, should also be immersed in the expected
waste/leachate. Following immersion, both a
control specimen and the immersed specimen should
be tested for in plane transraissivity. At this
time no ASTM method exists to evaluate in-plane
transraissivity; however, the Federal Highway
Administration's Geotextile Engineering Manual
references a technique by Koerner and Bove.l "
This method (or another method to determine
in-plane transmissivity) can be used to compare the
in-plane transmissivity of the immersed specimen to a
control specimen.
Two specific recommendations need to be made
to implement the test.
(1) The final pressure exerted on the geotextile
should be at least 1.5 times the maximum expected
pressure to be experienced during the active
life and post-closure period of the unit.
(2) The geotextile should be placed in the
apparatus under expected field conditions;
i.e., both sides of the geotextile should be
placed against the materials experienced in
the field (e.g., soil, sand/gravel, flexible
membrane liner, or other geotextile).
Earthen Materials - When rock or gravel are used in
the leachate collection system, the owner or operator
should verify that the mineral content of the rock is
compatible with the waste/leachate mixture. The
owner or operator will need to demonstrate that the
rock will not be dissolved or form a precipitant that
would clog the leachate collection system.
1. Koerner, R.M. and Bove, J.A., "In-Plane Hydraulic
Properties of Geotextiles," Geotextile Testing Journal,
GTJODJ, Vol. 6, No. 4, Dec. 1983, pp. 190-195.
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-6- 9'48-C v 00-1 3
For soil used as a liner or a component of a liner
the material should be subjected to EPA Method 9100,
using the expected leachate to determine its effect
on the hydraulic conductivity of the compacted low
permeability soil. The owner or operator may use the
fixed-wall or triaxial test. (Note: Method 9100 is
currently under revision.)
Should environmental stress cracking be considered
as a modification to Method 9090?
Although environmental stress cracking (ESC)
is not currently included in Method 9090, recently
reviewed data and discussions with technical
experts, including polymer manufacturers, ha\re
reemphasized the need to require an ESC test for
crystalline and seraicrystalline polymeric membrane
liners. We are currently making revisions to Method
9090 that will outline available that ESC testing
be methods.
Until specific test procedures for ESC can be
developed that represent land disposal facility
conditions, we suggest that permit writers discuss
the need for ESC data on these materials and suggest
that the owner or operator conduct ESC testing.
The type of test and initial interpretation of
the data would be the responsibility of the
applicant.
Should the leachate be changed during the immersion
test?
Some of the constituents of greatest concern
in the chemical resistance immersion test are those
that are volatile or that enter into the material
being tested. The owner or operator must assure that
the chemical composition of the leachate remains
relatively constant during the test to provide a
representative atmosphere for samples being immersed.
The owner or operator must attempt to seal the
immersion vessel as tightly as possible to prevent
loss of volatiles. In addition, the concentration
of chemicals in the leachate that are suspected to
affect the samples (such as aliphatic and halogenated
hydrocarbons) must be determined prior to immersion
testing, and should be checked when samples are
removed at the first 30-day testing period (for
Method 9090). If the composition of the leachate
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OSWER peuey m^m we.
9480.00--1 3
-7-
has changed significantly, the owner or operator
should change the leachate in the immersion vessels
and continue to change the leachate on a frequent
basis (frequency to be negotiated with the permit
writer) to assure that the liner samples are experi-
encing exposure conditions similar to those in
the field.
Attachment
cc: RCRA Branch Chiefs, Regions I-X
RCRA Permits Section Chiefs, Regions I-X
Paul Ingrisano, Region II
Frank Langone, Region II
Greg Uetrecht, Region VI
Harvey King, State of New York, DEC
Bob Tonetti
Ken Shuster
Terry Grogan
Les Otte
Robert Landreth
Chris Rhyne
Peter Guerrero
Ana Aviles
Agnes Ortiz
Dave Friedman
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ANALYSIS AND FINGERPRINTING OF UNEXPOSED AND EXPOSED
POLYMERIC MEMBRANE LINERS
Henry E. Haxo, Jr.
Matrecon, Inc.
Oakland, California 94623
ABSTRACT
A plan is presented for analyzing polymeric mer,,brane liners for waste storage and
disposal impoundments before and after laboratory or ^ilot-scale exposure and field ser-
vice. These analyses can be used to fingerprint a material and to follow the changes
that take place in a polymeric membrane liner during exposure to'waste. They can also be
used to determine components of a waste liquid that are absorbed and are aggressive to
polymeric liners.
This analysis plan includes determination of.volatiles, extractables, specific
gravity, ash and crystallinity of polymeric liners. The plan also includes gas chroma-
tography and infrared analysis of the extractables (and possibly of the organic volatiles)
and thermogravimetric analysis of the liner. Also suggested is the use of pyrolysls gas
chromatography, which can be performed directly on unexposed and exposed liner materials.
Typical analytical results for unexposed and exposed liners are presented.
INTRODUCTION
Because of the wide range of composi-
tions and constructions of flexible poly-
meric membrane liners that are currently
available and being developed for lining
waste impoundments, analysis and finger-
printing of the membranes is needed for a
number of purposes. For example, a liner
manufacturer needs to test his sheeting as
new polymers are used and as new compounds
and constructions are developed. He also
needs tests to control the composition of
the liner being manufactured.
The analysis of a polymeric membrane
liner at the time of placement can be used
for three purposes: first, as a means of
characterizing and identifying the specific
sheeting; second, as a baseline for moni-
toring the effects of exposure on the liner;
and third, to assess the aggresive ingredi-
ents in the waste liquid to determine
chemical compatibility.
During exposure • to waste liquids,
polymeric liners may change in composi-
tion in various ways that may affect their
performance and result in actual failures.
Polymeric materials may absorb water,
organic solvents and chemicals, organo-
metallic materials, and possibly some Inor-
ganics if the liners become highly swollen.
On the other hand, the extractable materials
in the original liner compound may be
leacneu out and result in stiffening and
even brittleness on the part of the liner
membrane. The solid constituents of a
polymeric compound (which Include carbon
black, inorganic fillers, and some of the
curing agents) will be retained in the liner
compound, as will the polymer of which the
liner is made (particularly If the polymer
is crosslinked). If organic materials are
similar to the liner in solubility and
hydrogen bonding characteristics, the liner
may swell excessively. Some thermoplastic
157
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lining materials may even dissolve, when in
contact with some solvents.
The objective of this paper is to
present an analytical methodology that can
be used to fingerprint and identify liner
materials and to give a baseline for
assessing the changes in composition of
these materials when they are under test or
in service. Also presented are the analy-
tical procedures for testing exposed liner
materials to determine these changes. Data
on representative liner materials, before
and after waste exposure, are presented.
POLYMERS USED IN MEMBRANE LINER MANUFACTURE
Polymers used in the manufacture of
lining materials include rubbers and
plastics differing in polarity, chemical
resistance, basic composition, etc.,
and can be classified into four types:
- Rubbers (elastomers) that are gen-
erally crosslinked (vulcanized),
- Plastics that a'-e generally unvul-
canized (such as PVC),
- Plastics that have a Relatively
hign crystalline content (such as
the polyolefins), and
- Thermoplastic elastomers that do not
reed to be vulcanized.
Table 1 lists the various types of
polymers that are used and indicates whether
they are used in vulcanized or nonvulcanized
form and whether they are reinforced with
fabric. The polymeric materials most fre-
quently used in liners are polyvinyl chlo-
ride (PVC), chlorosulfonated polyethylene
(CSPE), chlorinated polyethylene (CPE),
butyl rubber (IIR), -.ethylene propylene
rubber (EPDM), neoprene (CR^-, and high-den-
sity polyethylene (HOPE). The thickness of
polymeric membranes for liners ranges from
20 to 120 mils, with most in the 20 to 60-
mi 1 range.
TABLE 1.POLYMERIC MATERIALS USED IN LINERS
Polymer
Butyl rubber
Chlorinated polyethylene
Chlorosulfonated polyethylene
Elasticized polyolefin
Use
Thermo-
plastic
No
Yes
Yes
Yes
in liners
Vulcanized
Yes
Yes
Yes
No
Fabric
reinforcement
With
Yes
Yes
Yes
No
W/0
Yes
Yes
Yes
Yes
(partially crystalline)
Elasticized polyvinyl chloride Yes
Epichlorohydrin rubber Yes
Ethylene propylene rubber Yes
Neoprene (chloroprene rubber) No
Nitrile rubber Yes
Polyethylene (partially crystal-
line) Yes
Polyvinyl chloride Yes
No
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
158
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Most polymeric lining materials are
based on single polymers, but blends of two
or more polymers (e.g., plastic-rubber
alloys) are being developed and used in
liners. Consequently, it is difficult to
make generic classifications based on
individual polymers in the liners, even
though one polymer may predominate. Blend-
ing of polymers introduces tne long-range
possibility of the need for performance
specifications, but long-term liner per-
formance in the field cannot presently be
completely defined by current laboratory
tests.
The basic compositions of the different
types of compounds are shown in Table 2.
The crosslinked rubber compositions are
usually the most complex because they con-
tain a crosslinking system that requires
more ingredients (e.g., the sulfur system).
Thermoplastics, except for CSPE compounds,
contain no curatives. Although supplied as
thermoplastic membranes, CSPE liners con-
tain inorganic crosslinking chemicals that
allow the compound to crosslink slowly over
time during service. Crystalline materials
have the simplest composition and generally
consist of polymer, a small amount of carbon
black for ultra-violet protection, and
antidegradants.
Of the various'liner components (except
for the polymer), the following are poten-
tial extractables:
- Small amounts in the original polymer
(i.e., .stabilizers and antidegrad-
ants)
- Oils and plasticizers
- Antidegradants added to the compound.
- Organic constituents of the sulfur
crosslinking system (e.g., vulcaniza-
tion accelerators and activators).
These ingredients are extracted in the de-
termination of extractables.
Most of the polymeric membrane liners
currently manufactured are based on unvul-
canized or uncrosslirvked compounds and thus
are thermoplastic. Even T-f the polymer in
the vulcanized form is more chemically
resistant (such as CPE and CSPE), it is
generally supplied unvulcanized because it
is easier to obtain reliable seams and to
make repairs in the field. Thermoplastic
polymers can be heat-sealed or seamed with
a solvent or bodied solvent (a solvent con-
taining dissolved polymer to increase the
viscosity and reduce the rate of evapora-
tion). Crystalline sheetings, which are
also thermoplastic, are seamed by thermal
welding or fusion methods. Information on
individual polymers and liners is presented
in the EPA Technical Resource Document on
liners (Matrecon, 1982).
TABLE 2.BASIC COMPOSITIONS OF POLYMERIC MEMBRANE LINER COMPOUNDS
Type of polymeric compound
Component
Crosslinked Thermoplastic Crystalline
Polymer or blends (alloys)
Oil or plasticizer
Fillers:
Carbon black
Inorganics
Antidegradants
Crosslinking system:
Inorganic system
Sulfur system
100
5-40
5-40
5-40
1-2
5-9
5-9
100
5-40
5-40
5-40
1-2
(*)
100
0-10
2-5
1
*An inorganic curing system that crosslinks over time is Incorporated
in CSPE liner compounds.
159
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ANALYSIS AND FINGERPRINTING OF UNEXPOSED
POLYMERIC LINING MATERIALS
Analyses of liners run before and after
exposure to different environments include:
- Volatlles
- Ash
- Extractables
- Gas chromatography
- Thermogravimetric analysis
- Differential scanning calorimetry
if Hner material is crystalline
- Specific gravity
The following subsections describe the
tests performed on unexposed polymeric
linings.
Volatiles
The volatile fraction is represented by
the weight lost by an unexposed specimen of
the liner on heating in a circulating air
oven at 105°C for 2 hr. Polymeric compo-
sitions generally contain a small amount of
volatiles (<1.0%), usually moisture. The
recommended specimen is a disk cut from the
membrane.
The volatiles test can also be used to
determine the direction of the grain that
has been introduced in the membrane during
manufacture. By identifying the orientation
of the 2-in. disk specimen with respect to
the sheeting at the time the specimen was
died out, the grain direction can be iden-
tified. The grain direction must be known
so that tensile and tear properties can be
determined in machine (grain) and transverse
directions. Upon heating in the oven at
105°C, sheeting with a grain will shrink
more in the grain direction than in the
transverse direction (Figure 1).
Volatiles need to be removed before
determining ash, extractables, and spec-
ific gravity. Ash and extractables are
reported on a dry basis (db). Volatiles
contents of representative membrane liners
are presented in Table 3. Monomeric plas-
ticizers that are generally used in PVC
compositions have a limited volatility and
can slowly volatilize at 105°C. Thus the
air oven test must be limited to 2 hr.
As received
After air oven heating
2hr. at 105°C
Figure 1.Machine direction determinations.
A standard test for the volatility of
plasticizers in PVC compounds is performed
in accordance with ASTM D1203. In this
test, activated charcoal is used to absorb
volatilized plasticizer.
Ash
The ash content of a liner material is
the inorganic fraction that remains after a
devolatiiized sample is thoroughly burned at
550°±2bJC. The ash consists of (1) the
inorganic materials that have been used as
fillers and curatives in the polymeric
coating compound, and (2) ash residues in
tne polymer. Different liner manufacturers
formulate their compounds differently, and
determining the ash content can be a way to
"fingerprint" a polymeric liner compound.
The residue obtained by ashinq can be
retained for other analyses (such as metals
content) needed for further identification
and for providing a reference point to
determine trace metals that may have been
absorbed by the liner. The test method
160
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described in ASTM 0297, Section 34, is
generally followed in performing this
analysis. Ash contents of representative
membrane liners are presented in Table 3.
Extractables
The extractable content of a polymeric
sheeting is the fraction of the compound
that can be extracted from a devolati 1 ized
sample of the liner with a solvent that
neither decomposes nor dissolves the poly-
mer. Extractables consist of plasticizers,
oils, or other solvent-soluble constituents
that impart or help maintain specific
properties such as flexibility and proces-
sability. A measurement of extractable
content and an analytical study of the
extract can be used as part of the finger-
printing of a sheeting.
During exposure to a waste, the ex-
tractable constituents in a liner may be
removeu and resu]t in property changes. At
the same time during exposure, the liner
might absorb nonvolatiIizable constituents
from a waste. Measuring the extractable
content of unexposed lining materials is
therefore useful for monitoring the effects
of exposure. The extract and the extracted
liner obtained by this procedure can be used
for further analytical testing (e.g., gas
chromatography, infrared spectroscopy, ash,
tnermogravimetry, etc.) and fingerprinting
of the liner.
The procedure for extraction generally
follows ASTM 03421, "Extraction and Analysis
of Plasticizer Mixtures from Vinyl Chloride
Plastics". Also see ASTM D297, "Rubber
Products-Chemical Analysis", paragraphs
16-18.
Because of the wide differences among
the polymers used in liner manufacture, a
variety of extracting media must be used.
TABLE 3. ANALYSIS OF UNEXPOSED POLrMERIC MEMBRANE LINERS*.*
Base polymer,
Polymer specific gravity
Butyl rubber
Chlorinated polyetnylene
Chlorosulfonated poly-
ethylene
Elasticized polyolefin
Epichloronydrin rubber
Etnylene propylene rubber
Neoprene
Polybutylene
Polyester elastomer
Polyethylene (low density)
Polyethylene (nigh density)
Polyethylene (high density)
al loy
Polyvinyl chloride
0.92
1.16-1.26
1.11
0.92
1.27-1.36
0.86
1.25
0.91
1.17-1.25
0.92
0.96
0.95
1.40
Compound
Specific
gravity •
1.206
1.176
1.360
1.362
1.377
1.433
1.343
0.938
1.490
1.173
1.122
1.199
1.503
1.480
1.390
0.915
1.236
0.921
0.961
0.949
1.275
1.264
1.231
1.280
1.308
Volatiles,
X
0.45
0.46
0.10
0.00
0.05
0.84
0.51
0.15
0.63
0.38
0.50
0.31
0.76
0.19
0.37
0.12
0.26
0.18
0.12
0.11
0.11
0.09
0.05
0.31
0.03
Extractables
X
10.96
11.79
7.47
9.13
1.49
3.77
5.50
7.27
23.41
31.77
18.16
10.15
13.43
21.46
...
2.74
2.07
0.49
2.09
33.90
37.25
38.91
35.86
25.17
. Asn,
I
5.25
4.28
14.40
12.56
17.37
33.95
3.28
0.90
4.49
6.78
5.42
0.32
12.98
13.43
4.67
0.08
0.38
0.13
0.46
0.32
6.20
5.81
3.6S
6.94
5.67
•Source of some of the data
^Multiple figures represent
: Haxo et a). (1982).
materials from different manufacturers.
161
-------
Table 4 lists the recommended solvents for
extraction of membrane liners of each
polymer type.
Typical values for the extractables in
polymeric membranes are given in Table 3.
Gas Chromatography
Gas Chromatography can be used to find
the level of the plasticizer (e.g., diethyl-
hexyl phthalate (DEHP), a dioctyl phthalate)
compounded into a PVC liner material. Fig-
ure 2, shows the quantification of DEHP in
the solvent extract of a PVC liner material.
The weight percent of the DEHP in the liner
can then be calculated, assuming the extrac-
tion to be 100% efficient. A typical
procedure is summarized below.
A weighed sample of liner is extracted
with an appropriate solvent. The extract is
evaporated to dryness over a steam bath.
The dry residue is redissolved irr solvent
and brought to an accurately known volume.
Following the development of appropriate
chromatographic conditions, injection of
this solution into the instrument will
separate it Into chemically pure components
characterized by different retention times.
An injection of a DEHP standard solution
will identify the retention time of the DEHP
component. Comparison of the peak height
I 0.4
>-
I
0.2
O Standards
+ Sample
0123456789 10 11
PEAK HEIGHT IN CM
Figure 2.Gas chromatograph determination
of the di ethyl he'x'yl phthalate
content in an extract of a PVC
membrane. Column: 6'xl/8" 3% 0V
101 on Chromosorb WHP. Tempera-
ture: 200°-3QO°C at 8°C/min. He
carrier gas: at 30cc/min.
(area) data obtained from the injection of
equal volumes of the extract solution and
from quantitatively prepared standard
solutions allows the interpolation of the
DEHP concentration in the extract solution
(Figure 2).
TABLE 4. SOLVENTS FOR EXTRACTION OF HULYintRIC MEMBRANES*
Polymer type
Extraction solvent
Butyl rubber (IIR)
Chlorinated polyethylene (CPE)
Chlorosulfonated polyethylene (CSPE)
Elasticized polyolefin
Epichlorhydrin rubber (CO and ECO)
Ethylene propylene rubber (EPDM)
Neoprene
Nitrile rubber (vulcanized)
Nitrile-modified polyvinyl chloride
Polyester elastomer
High-density polyethylene (HOPE)
Polyvinyl chloride (PVC)
Thermoplastic olefinic elastomer
Methyl ethyl ketone
n-Heptane
Acetone
Methyl ethyl ketone
Methyl ethyl ketone or acetone
Methyl ethyl ketone
Acetone
Acetone
2:1 blend of carbon tetrachlo-
ride and methyl alcohol
Methyl ethyl ketone
Methyl ethyl ketone
2:1 blend of carbon tetrachlo-
ride and methyl alcohol
Methyl ethyl ketone
*Because lining materials can be sheetings based on polymeric aloys mar-
keted under a trade name or under the name of only one of polymers, this
list can only be taken as a guideline for choosing a suitable solvent for
determining the extractables. Once a suitable solvent has been found, it
is important that the same solvent be used for determining the extract-
ables across the range of exposure periods.
162
-------
Pyrolysis gas chromatography
Pyrolysis gas chromatography is an
alternative method for measuring a plas-
ticizer in liner materials. In this tech-
nique, a small, weighed sample of liner is
heated very rapidly to a temperature suf-
ficient to volatilize all of its organic
components. The plasticizer and other
lower-molecular weight organics will be
driven off as chemically unchanged vapors.
The polymer will undergo pyrolysis, or high
temperature decomposition, and will vola-
tilize as lower-molecular-weight organic
compounds. The resulting volatiles may be
separated and quantified by gas chroma-
tography as previously described, and the
plasticizer content of the liner may be
calculated.
This method has the strong advantage of
not requiring extraction of the liner
sample, but it may not be as reliable a
means of quantification because of the very
small sample size and the large number of
components that must be separated by the gas
chromatograph.
Thermogravimetric analysis (TGA)
TGA is a thermal technique for asses-
sing the composition of a material by its
loss in weight on heating at a controlled
rate in an inert or oxidizing atmosphere.
For example, when a material is heated in an
inert atmosphere from room temperature to
600°C at a controlled rate, it will vola-
tilize at different temperatures until only
carbon, char and ash remain. The intro-
duction of oxygen into the system will burn
off the char and carbon black. Thus from
the weight-time curve which can be related
to weight and temperature, the amounts of
volatiles, plasticizer, polymer, carbon
black, and ash can be calculated. In some
cases, thermogravimetric analysis can
replace measurements of the volatiles, ash,
and extractables contents discussed above.
The TGA curve and the derivative of the TGA
curve can thus be used as part of a finger-
print of a polymeric composition. This
technique 1s described by Reich and Levi
(1971).
A Perkin-Elmer TGS-2 thermogravi-
metric system, consisting of an analyzer
unit, balance control unit, heater control
unit, and first derivative computer, is used
in our laboratory. Temperature control is
supplied by the temperature controller on
the Perkin-Elmer DSC-2 (Differential Scan-
ning Calorimeter). A double side-arm fur-
nace tube was used to allow rapid changing
of the atmosphere from inert (N2) to oxi-
dative (N2/02 mixture). For the oxida-
tive atmosphere, N2 purge is maintained
through the analyzer unit head, and 02
is introduced at the upper side arm where
it mixes with the N2 to burn the carbon
black and any carbonaceous residue that
forms during the pyrolysis of the polymer.
Use of the double side-arm furnace tube
shortens the turnaround time because it
eliminates the need to flush the analyzer
head completely to remove 0? between runs,
as would be necessary if &2 were intro-
duced through the head. A dual pen recorder
Perkin-Elmer Model 56 allows a simultaneous
display of thermocouple temperature in the
furnace and the change in weight of the
specimen or the first derivative of the
change in weight.
An example of the TGA procedure for the
analysis of a polymeric liner is described
below.
A 5-mg specimen of the liner was placed
in the balance pan and weighed in a nitrogen
flow of 40 cc/min. The instrument was
adjusted to give a 100% full-scale deflec-
tion for the weight of the sample, so the
percent of weight change can be read
directly from the chart.
The specimen was heated to 110°C and
held there for 5 min to determine whether
measurable volatiles were present; it was
then heated from 110° to 650°C at a rate of
20°C/min in a nitrogen atmosphere. The
specimen was held at 650°C until no more
weight loss occurred, usually 2 to 3 min,
after which it was cooled to 500°C and Q£
was introduced at a rate of 10 cc/min with
an N2 flow rate of 30 cc/m1n.
Typical thermograms for HOPE and EPDM
appear in Figures 3 and 4, respectively.
Analyses of a variety of polymeric membrane
liners are presented in Table 5.
Differential Scanning Calorimetry (DSC)
DSC is a thermal technique for measur-
ing the melting point and the amount
of crystallinity in partially crystalline
polymers such as the polyolefins polyethy-
lene, polypropylene, and polybutylene.
This technique measures the heat of fu-
sion of a crystalline structure; it can
also give an indication of the modification
of crystalline sheeting with other polymers
163
-------
12 16 20 24 28 32 36 40
TIME. MINUTES
Figure 3.TGA of an unexposed black HOPE liner. The plots of sample weight and temperature
as a function of time are shown. Under an N2 atmosphere, the black HOPE sample
lost approximately 95.5% of its mass as hydrocarbons were evolved. The carbon
black added as an ultraviolet light absorber remained as a carbonaceous residue
and was not volatilized until it was oxidized when oxygen was allowed into the
system.
llftJU
900
900
700
°. 600
UJ
3
K
< 500
or
UJ
^
£
lu 400
K
300
200
100
0
^"^^^
,- COMPOSITION FROM TGA.
Volatilei 0
Oil 33.0
Polymer 3 1 .0
Carbon Black 31.0
Ash 5.0
Total 100.0
\ 3
\
\
\
'
3\0it
^\
j-A /"
% Original Wei^it of Specimen — H /
\X
/i
' '
/'
k X
\ /
^
> \ 31% Polymer
.' 1
s \
~ s \
/ \
S
Temperature — _ _ *
/
S
S
^_ _f* ^
i i i i i i i i t i
'
3
.
. l«
*^*
1 f 1
I
-
-
,-\
\
\
\
\
\
\
\
\
\
\
\
\
N
% Carbon Black
-
f 5
-------
TABLE 5.THERMOGRAVIMETRIC ANALYSIS OF POLYMERIC MEMBRANE LINERS
Volatiles, Polymer, uiI or plas- Carbon Ash,
Polymer type % % ticizer, % black, % %
Butyl rubber
Chlorinated
polyethylene
Chlorosulfonated
polyethylene
Elasticized
polyolefin
Epichlorhydrin
rubber
Ethylene propylene
rubber
Neoprene
Polyethylene (high
0
0
0
0.4
1.0
0.9
0.1
0.1
0.2
1.0
0
45.0
72.2
71.3
53.9
49.3
47.7
58.1
93.1
49.3
30.8
33.5
42.3
44.0
12.2
7.6
9.1
13.9
1.5
3.2
5.5
1.7
8.2
32.9
23.2
10.7
10.7
37.1
5.3
6.5
21.0
45.6
45.2
9.8
4.0
37.7
30.9
35.5
34.9
33.8
5.7
14.9
13.1
10.8
2.6
3.0
26.5
1.2
4.8
5.3
7.6
11.1
11.5
density)
Polyvinyl chloride
0
0
0
0
0
0
97.9
95.6
97.0
48.7
46.0
51.0
U
0
0
38.2
42.1
35.0
2.1
4.2
1.8
6.2
7.8
7.0
• • •
0.2
1.2
6.9
4.1
7.0
by alloying. Thus this type of analysis can
be used as a means of fingerprinting crys-
talline polymeric liner materials (partic-
ularly high-density polyethylene) and
assessing the effects of aging and exposure
to wastes. This technique is described by
Boyer (1977) and Ke (1966).
The differential scanning calorimeter
used in this work was the Perkin-Elmer
Model DSC-2C, equipped with an Intracooler I
subambient temperature accessory to provide
an operating temperature range of -40 to
725°C.
The equipment is used to characterize
the thermal transitions of materials
such as melting, boiling, and changes in
crystal structure. A sample and reference
cell are provided. A weighed sample is
placed in the sample holder; the reference
cell is generally run empty to provide an
absence of thermal transitions. The two
cells are simultaneously heated or cooled so
that the average cell temperature follows a
preset program. When the sample undergoes
a thermal transition, an endotherraic or
exothermic reaction will occur. The
change in power required to maintain the
sample cell at the same temperature as the
reference cell 1s recorded as a deflection
of the recorder pen. The recorder plots the
temperature (°C) versus the differential
energy flow (meal/sec) required to maintain
the sample cell temperature. An endothermic
transition such as melting 1s shown as a
positive peak; an exothermic reaction such
as crystallization 1s shown as a negative
peak. The magnitudes of these peaks and the
temperatures at which they occur are charac-
teristic of the material analyzed.
An example of the use of the DSC to
determine the polyethylene crystal Unity 1n
an HOPE Uner 1s shown 1n Figure 5.
163
-------
2
<
-------
2 —> ~
PLASTICIZER
FILLER
POLYMER
XL OR TP
ORIGINAL
LINER
T
•s
. WASTE . .
. ' LIQUID
PLASTICIZER
FILLER
POLYMER
I
EXPOSED
LINER
i, WEIGHT INCREASE
• A'ASTE •
' LIQUID .
PLASTICIZER
FILLER
POLYMER
VOLATILES
REMOVED
_ VOLATILES
\
i
PLASTICIZER
FILLER
POLYMER
VOLATILES
AND
EXTRACTABLES
<, VOLATILES \EXTRACTABLE
• Momure • Nonvolatile organic
• Organics
EXTRACTABLES
Figure 6.Schematic presentation of changes in composition of a polymeric liner compound on
exposure to a waste liquid, on removal of volatiles,. and on extraction with
an appropriate solvent.
H20 * volatile orgamcs
Plasticizer
Polymer
Carbon black
Ash
TGA " Ihermogravimetric analysis
GC - gw chromitograpny
IR - infrared soeclroscopv
AAS * atomic absorption spectroscopy
CHONS * Carbon. hydrog«n, nitrogen, oxygen, and suMur determination
Figure 7.Plan for the analysis of exposed polymeric lining materials.
167
-------
Volatiles
The initial analytical test generally
performed is a determination of the vola-
tiles content, which gives an indication of
the amount of wast* liquid that has been ab-
sorbed by the Hner. As an approximation,
the weight Increase can be calculated by
dividing the percent of volatiles by the
percent of nonvolatiles. For example, if
the volatiles are 15%, and the nonvolatiles
are 85%, the percent Increase in weight
based on the original Hner would be 17.6%.
Inasmuch as the volatiles contain
both water and organic components, it
1s desirable to separate these two. A
study was made to dehydrate the speci-
mens of the exposed Hner to remove the
water. A series of desiccants was stud-
led at room temperature and 50°C. Four
days of exposure of the exposed liner at
50°C in a small Individual desiccator
containing calcium chloride removed the
moisture from the 2-1n. disk specimen
without removing organic constituents.
After removal of the water, a 2-hr heating
of the specimen 1n a circulat-ing air oven
removed the remaining organic volatiles.
Collection of the organic volatiles and
determination of composition by gas
chromatography would be desirable but
has not been attempted to date. The
water and the organic volatiles equal
the volatiles obtained in bypassing the
desiccator exposure. Such a bypass removes
the moisture by exposure at room temperature
for 1 week 1n moving air followed by heating
in a circulating air oven for 20 hr at 50°C
and 2 hr at 105°C. We have found, however,
that the highly swollen CPE liner may take
up to 6 days at 50°C to come to constant
weight. The time required to remove
volatiles depends on the thickness and
permeability of the liner and the care taken
to avoid the "skin" that forms on the
surface of the specimen when using too high
an initial temperature to devolatilize.
After the volatiles are removed, the
exposed materials can be subjected to
the other tests, Including specific gravity,
extractables, ashing, etc.
Total volatiles can also be determined
through the use of TGA which is discussed
below.
Extractables
Extractables of exposed materials
will probably differ from the original
values because of the loss to the waste
liquid and absorption of nonvolatile
organics (e.g., oils). After the vol-
atiles have been removed from the liner,
the extractables are determined by the same
method used on the unexposed liner materi-
als. Examples of extractable contents after
exposure are given in Table 6. If the liner
has been in contact with wastes containing
nonvolatile constituents, the extractables
recovered may be greater than the original
values. Analysis of the extractables by gas
chromatography and infrared analysis may
give an indication of the nonvolatile
organics that were absorbed. The analysis of
the extractables will give an indication of
the constituents of the waste that are
aggressive to the liner, as they are the
constituents that have been absorbed. They
may show up in minor amounts in a waste
analysis, but because of their chemical
characteristics such as solubility parame-
ters and hydrogen bonding, they may be
scavenged by the polymeric liner.
Ash
Thp ash content of an exposed membrane
liner is determined after the volatiles have
been removed from the specimen. As in the
case of the unexposed membrane, the exposed
liner is ashed in a muffle furnace at
550°C. The ash value usually differs from
that of the unexposed material, depending on
how many nonvolatile organics were lost or
gained during the exposure period. If plas-
ticizer is lost, the value will increase
because of the nonash content of the plasti-
cizer. Also, if any organic metal compounds
are absorbed by the liner, they will show as
an increased ash content. A comparison of
the elemental analysis of the ash with that
of the original liner will determine whether
any absorption of metal species occurred
during the exposure. No such absorption has
been observed, but metal organics might be
absorbed by a liner. In general, the in-
organics that make up the ash are retained
in the liner and maintain a constant ratio
with respect to the polymer content, as
polymer is generally not dissolved by the
waste liquid.
Thermogravimetric analysis
The TGA analysis can be used to give a
quick analysis of the composition of an
exposed polymeric membrane liner. The test
is run similarly to that of the unexposed
material, except that care must be taken in
handling the small specimens of exposed
168
-------
TABLE 6.EXTRACTABLES OF DIFFERENT POLYMERIC MEMBRANE LINERS
BEFORE AND AFTER VARIOUS EXPOSURES
Polymer
Butyl rubber
Unexposed
11.79
Type of exposure
by waste
Aromatic oil
Spent caustic
Oil 104
Extractables
after exposure
27.23
10.87
40.34
Chlorinated
polyetnylene 9.13
Chlorosulfonated
polyethylene 4.08
Elasticized
polyolefin 5.50
Ethylene prop-
ylene rubber 23.64
Neoprene 21.46
Polyvinyl
chloride 33.90
Oil 104
Roof exposure
Aromatic oil
Oil 104
Slop water
Oil 104
Aromatic oil
Slop water
Aromatic oil
Oil 104
Spent caustic
Aromatic oil
Oil 104
Slop water
Aromatic oil
Roof exposure
Pesticide
Oil 104
17.00
5.99
59.81
15.92
3.70
20.74
23.37
2.96
38.35
43.45
22.89
58.47
23.85
17.63
40.55
26.27
35.38
17.95
liners that contain the volatiles. These
volatiles can be easily lost. Figure 8 is a
thermogram of an exposed PVC membrane liner
that had absorbed more than 7% of the waste
liquid, which was predominantly water. The
results are shown on the figure, but the
losses show the effect of the char formation
of the PVC when It is heated in a nitrogen
atmosphere. Chlorinated polymers lose HC1
and leave a char for which correction must
be made in the calculations of the polymer
content. These calculations have been made
on the figure, and the results compare fa-
vorably with those obtained by direct analy-
sis of the volatiles, extractables, and ash.
Specific gravity
The specific gravity of exposed mem-
brane liners is also determined after the
membrane specimen has been thoroughly de-
volatilized. Three steps must be taken to
avoid the formation of bubbles 1n the Uner
mass during a direct devolatilizlng process
(which would affect the specific gravity
results). First, the specimens must be
allowed to "dry" at room temperature 1n an
air stream in a hood until constant weight
is achieved, which could take several days.
Second, they must be placed in an oven at
70°C for 16 hr; and third, they must be
heated at 105°C for 2 hr.
The specific gravity of an exposed
membrane can differ from that before ex-
posure, depending on how much of the origi-
nal extractable material was lost and how
much material from the waste was absorbed
during exposure. The procedure followed was
ASTM D297 using the hydrostatic method.
169
-------
iooo
100
60 80
TIME. MINUTES
100
120
140
160
Figure 8. TGA of an exposed polymeric PVC liner.
Weight loss A
Weight loss B
Weight loss C
Weight loss D
Residue weight E
7.0% volatiles = moisture + possible organics.
60.2% = plasticizer + HC1 from the polymer (PVC).
16.0% = residual polymer.
10.0% = carbonaceous polymer residue + carbon black,
6.8% = ash.
Composition of the exposed liner as received calculated from above data.
Values by direct analysis are shown in parentheses.
Volatiles 7.0% (7.9)a
Polymer (PVC) 44.7%
Plasticizer 34.1% (32.2% as extractables)3
Carbon black 7.4%
Ash 6.8% (6.4)a
aBy direct analysis.
SUMMARY AND CONCLUSIONS
A protocol is presented for the analysis
of polymeric membrane lining materials
before and after exposure to waste liquid.
The results of the analysis can be used
as a fingerprint of the unexposed liner and
as a baseline for assessing the changes that
occurred during exposure to a waste liquid.
The analysis of an exposed liner
furnishes information regarding the change
in the composition of the membrane and the
chemical materials that are actually absorb-
ed during exposure. This latter information
indicates the constituents of the waste that
are aggressive to the lining material.
Thermal analysis and gas chromatography
are particularly useful in the analysis
and fingerprinting of polymeric membranes.
The use of gas chromatography coupled
with mass spectroscopy needs to be investi-
gated to determine the specific chemicals
that are absorbed by a polymeric liner.
The use of this analysis may lead to
techniques which will better predict the
service life of a flexible membrane liner.
ACKNOWLEDGEMENTS
Tho work reported in this paper was
performed under Contracts 68-03-2134
("Evaluation of Liner Materials Exposed to
Leachate"), 68-03-2173 ("Evaluation of Liner
Materials Exposed to Hazardous and Toxic
Wastes"), and 68-03-2969 ("Long-term Testing
of Liner Materials") with the Municipal En-
vironmental Research Laboratory of the U. S.
Environmental Protection Agency, Cincinnati,
Ohio.
170
-------
The author wishes to thank Robert E.
Landreth, Project Officer, for his support
and guidance in these projects.
REFERENCES
ASTM Standards, American Society for Testing
and Materials, Philadelphia, PA.
D297-81, Rubber Products - Chemical
Analyses: Section 15, Density (Hydro-
static Method); Section 34, Fillers,
Referee Ash Method
D792-66, Specific Gravity and Density of
Plastics by Displacement; Method A-l
for Testing Solid Plastics in Water,
Sections 6-12.
D1203-67, Volatile Loss from Plastics
Using Activated Carbon Methods.
D3421-75, Extraction and Analysis of
Plasticizers from Vinyl Chloride
Plastics
Boyer, R. F. 1977. Transitions and Relaxa-
tions. In: Encycl. Polymer. Sci.
Technol. Supplement, Vol. 2. pp
745-839.
Haxo, H. E. 1983. Liner Materials Exposed
to Hazardous and Toxic Wastes. Final
Report. Contract 68-02-2173. U. S.
Environmental Protection Agency,
Cincinnati, OH. In preparation.
Haxo, H. E., R. M. White, P. D. Haxo, and M.
H. Fong. 1982. Liner Materials
Exposed to Municipal Solid Waste
Leachate. Final Report. Contract
68-03-2134. U. S. Environmental
Protection Agency, Cincinnati, OH. In
press.
Ke, B. 1971. Differential Thermal Analy-
sis. In: Encycl. Polymer. Sci.
Technol. Vol 5, pp 37-65.
Matrecon, Inc. 1982... Lining of Waste
Impoundment and Disposal Facilities.
SW-870, Second Edition. U.S. Environ-
mental Protection Agency, Washington,
DC. In press.
Reich, L., and D. W. Levi. 1971. Thermo-
gravimetric Analysis. In: Encycl.
Polymer Sci. Technol. Vol 14. pp
Ir41.
171
-------
- 5 -
Figure 1. Outline of EIR Review Process
| Appl leant subm.11=3 SIR|
Public
submissions
V
To ATSDR and
forwarded
to EPA/State
(1)
EPA/State does initial screen
Completeness review of EIR
based on Permit Applicants'
Guidance Manual
(coordinated with Part B review)
incomplete
revision
Additional data
froro applicant
complete
Technical review of EIR
to address steps 2 through 6
(using other data as needed)
Gather further
data/ using
permit process,
3004(u) RFA,
enforcement
orders, etc.
unknown
new data.
[2]
Is there evidence
of significant
prior or
continuing
release?
Gather further
data, using
permit process,
3004(u) RFI,
enforcement
orders, etc.
Use of ORD,
ATSDR, or PAT
for technical
assistance
unknown
new
\/
[5]
Could future
release result
in significant
public exposure?
yes
V
[3]
Is there known or
suspected exposure to
the public at
significant levels?
no
Usual
permitting
process
yes
[6]
Consider permit
conditions to
mitigate potential
exposure
(or permit denial)
Consider
corrective action
as needed
yes
A
V
Consider interim
remedial action and
public involvement
as needed
Consider Health
Assessment by ATSDR,
with HO (OSWER)
concurrence
-------
- 6 -
This Guidance is organized according to the steps in Figure 1.
A checklist and'-tables are presented in this Guidance to assist in
summarizing the results of the EIR review. These checklists and
tables are provided as examples only. The Regions are welcome to
revise the format and content of these documents in order to conform
to Regional priorities and methods. Attachments at the end of the
Guidance include a completeness checklist (Attachment II), and
the types of health evaluations ATSDR may perform when requested
(Attachment.Ill).
E. Relationship to Existing RCRA Programs
This Guidance describes the overall §3019 review process, and
how this review should be integrated into existing RCRA activities.
RCRA programs are already in place to identify, investigate, and
clean up prior/continuing releases to ground water (Subpart F
regulations) and other pathways (RFA/RFI process). Therefore,
the two primary goals in implementing §3019 are to: (1) identify
human exposures to past releases that may require ATSDR involvement;
and, (2) to identify potential exposures from future releases that
may be mitigated by specific permit conditions.
The RFA/RFI and permitting programs should provide the infor-
mation needed to determine if a release has occurred and if human
exposure is likely. These activities should also generate most of
the documentation the EIR reviewer needs for the §3019 review
process. The EIR reviewer is required to prepare a separate report
for §3019 when the Regional Administrator (or his designee) believes
that a site is a candidate for referral to ATSDR for a health
assessment. This requires the submittal of a summary report to
EPA Headquarters for concurrence prior to referral to ATSDR (see
Section III.C.2). The EIR reviewer should also produce a brief
memorandum for the administrative record at other important
decision points, i.e., the results of the completeness check/initial
screen (Step 1), and the examination of potential exposures to
future releases (Step 5). In addition, the reviewer should write
a short memorandum for the record documenting a decision not to
refer a site to ATSDRj "and summarizing why the site does not meet
the necessary criterii^for referral (see Section III.B.I).
Documentation of these-decisions may be more important for sites
where public concerns exist.
The prevention of releases and subsequent human exposure
should already be ah-integral part of the permitting process.
However, Step 5 of thei-.EIR review process provides the permit
writer with the opportunity to identify sites that require
special permit conditions to mitigate possible risks from
future releases. Section III.D provides a qualitative approach
that may be used in completing Step 5.
The exposure information review process outlined in Figure 1
illustrates the need to integrate this review with ongoing and
planned permitting and enforcement activities. Which of the
Steps are completed prior to permit issuance depends, to some
extent, on Regional priorities for a particular site. Normally,
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Steps 1, 2, 5, and 6 will be completed at most sites prior to
issuing the permit. In addition, the permit writer should make
at least an initial decision whether the potential for significant
public exposure (Step 3) warrants action via enforcement orders
(e.g., 3008(h)) before permitting. Recommendations on the
appropriate use of the investigation/corrective measure authorities
for the EIR review are described in Section III.B.
F. State Roles in EIR Reviews
States with final authorization are required under 40 CFR
271.21(e) to adopt requirements equivalent to any new Federal
requirements. Pursuant to Section 3006(g) of RCRA, the require-
ments of Section 3019 will be implemented by EPA until each
State receives authorization for this provision. Until States
receive such authorization, the Regions may amend existing
grant Memoranda of Agreement (MOA) with States to> allow them
to assist in reviewing the EIRs. This may be especially helpful
where the State is already reviewing the Part B application.
The State's role in implementing Section 3019 should be clearly
defined in the MOA or other agreements with EPA. The Region
will need to oversee State reviews and follow up if more infor- "
mation is needed under Section 3019, if referral to the Agency
for Toxic Substances and Diseases Registry (ATSDR) is deemed
necessary, or if new permit conditions are needed under 3005(c).
Section 3005(c) (the "omnibus" provision) is discussed in
Section III.E. of this guidance.
II. EIR INITIAL SCREEN AND COMPLETENESS REVIEW (STEP 1)
A. Setting Priorities for EIR Reviews/Identifying Imminent
Hazards
Since the EIR is based in large part on information from the
Part B application, it makes sense in most cases to perform the
Part B and EIR reviews concurrently. Accordingly, the order
in which EIRs are reviewed depends largely on the order in
which the Part B applications-are reviewed. (Since Part B
reviews should generally be conducted in order of environmental
significance, as reflected in .the-annual Agency Guidance and
the National Permits Strategy,: the-priorities for EIR reviews
will therefore have an environmental basis as well.) Never-
theless, the permit writer should conduct an initial screen
of all EIRs upon receipt. If the initial screen indicates
that the EIR provides- new evidence of a release and/or potential
exposure, the permit writer should reevaluate the environmental
significance of the facility and consider raising the technical
review of the Part B and EIR to a higher priority. If the EIR
reviewer suspects an imminent hazard, program and enforcement
personnel should be consulted immediately to formulate an
appropriate course of action. Section III.C describes interim
remedial measures and corrective action responses that may be
necessary in these cases.
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There will -be situations where the Part B and the EIR will
not be reviewe.d concurrently. For instance, when an EIR is
submitted for a facility whose draft permit has been prepared,
it will usually be appropriate to conduct a full EIR review as
soon as possible even though the Part B review has already been
completed. The EIR reviewer in this case must be particularly
careful to ensure that the data provided in the EIR and in the
Part B are consistent and that no new information is provided in
the EIR which affects the draft permit conditions. Unless the
draft permit has already been issued, the EIR reviewer is advised
to review the EIR before the draft permit goes to public notice.
B. Performing the EIR Completeness Review
1. EIR Completeness Review Format
The EIR should be reviewed for completeness "based on the
Permit Applicants' Guidance Manual for Exposure Information
Under RCRA 3019 (PAGM). The EIR completeness review may be
conducted in a fashion similar to that used for a Part B
application completeness review. The EIR reviewer may fill out
a completeness checklist and develop corresponding comments
to summarize any important omissions in the EIR. A completeness
checklist has been provided in Attachment II and may be used
as a guide by the EIR reviewer during a completeness check.
This checklist is based on the permit applicants' checklist
found in the PAGM; however, it has been expanded and revised
to include a section on the "potential for human exposure"
narrative required of the owner/operator.
Although the Part B and EIR reviews should be conducted
concurrently whenever possible, any requests to the owner/operator
for missing information required under 3019 should remain separate
from a Part B Notice of Deficiency (NOD) because the EIR is not
legally a part of the permit application. The regulations in
40 CFR 270.10(c) were amended on July 15, 1985 to provide'that
a Part B which is not accompanied by an EIR will not be deemed
incomplete on that basis alone. The permit writer may find
deficiencies in the Part B which impact-'the EIR. In this
case, a warning letter or enforcement order containing the EIR
completeness comments should note these deficiencies by referencing
the deficiency comments in the Part B Notice of Deficiency (NOD).
For example, if the Part B inadequately described overtopping
control at the surface impoundment, then"the EIR checklist and
comments may simply instruct the applicant to: "See Part B NOD
Comment # regarding overtopping control." Any comments
generated from an EIR review should be simply entitled "EIR
Completeness Review Comments" rather than "Notice of Deficiency
Comments", to further distinguish the EIR review from the Part
B review.
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2. Other Information Sources
a. Permit Writer .and Compliance/Enforcement Personnel
In addition to the Part B application, several other infor-
mation sources may be useful in a completeness review of the
EIR. Both the permit writer and the enforcement official may
have knowledge of the facility's history which will be helpful
in determining whether there are significant omissions in the
applicant's submittal or in pursuing any EIR reference to
other RCRA documents, such as 3004(u) SWMU response letters or
previous facility inspection, compliance, or enforcement reports.
b. Other Federal/State Agencies
The EIR reviewer may consider contacting other Federal or
State environmental agencies during the completeness review if
an applicant's EIR refers to relevant information which is
contained in documents located at these agencies. For example,
the EIR may reference or summarize NPDES permit information or
air monitoring reports which may be located in the Regional
EPA offices or State Water/Air Offices. If the information
appears to be important (e.g., if a release is indicated) the
reviewer may wish to confirm that the document is accessible
and contains the expected information. If important documents
are not accessible to the EIR reviewer (s)he may request the
applicant to submit a copy of the relevant information.
c. Public Submissions
The Exposure Information provision of RCRA also allows the
public to submit information on possible exposures. Public
submittals may be received by EPA either directly, or via
reports forwarded to EPA trom ATSDR. Upon receipt of public
submissions relating to a RCRA site, ATSDR should contact the
appropriate EPA Regional staff and forward a copy of the submission.
Regional staff should attempt to coordinate any needed response
to the public with any response planned by ATSDR, and EPA Public
Involvement staff should be consulted in these situations. In
addition to providing important information to the reviewer, a
report of suspected human exposure from the public may create
a rather sensitive situation in terms of public fears and
expectations. The Revised National Permits Strategy (July,
1985) encourages early publicinvolvementin permitting facilities
and directs Che Region or authorized State to prepare public
participation plans for "environmentally significant" facilities.
Furthermore, the Permits Strategy recommends that the exposure
information be included early in the public participation
process for these environmentally significant facilities.
3. Determining the Adequacy of Submitted Information
RCRA Section 3019 requires the applicant to provide all
"reasonably ascertainable information." Although much of the
information in the EIR can be cross-referenced to the Part B
application, the PAGM does require the applicant to submit
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addicional information. The legislative history of Section 3019
indicates thac Congress did not expect applicants to develop
major pieces of new information; however, if applicants do have
access to already existing data, they should submit or cite the
data, or provide an explanation as to why they could not obtain
the data. See the PAGM for additional discussion of this topic.
Unlike the requirements for the Part B, there is no regula- •
tory requirement for a "complete" EIR beyond the 40 CFR 270.10(j)
requirement to submit exposure information. The PAGM states
that applicants who fully provide the information outlined in
that document will be considered to have satisfied the infor-
mation requirements of Section 3019. From a practical viewpoint,
EIR reviewers should focus on missing information that will be
important in defining one of the three components of exposure,
i.e., data on releases, pathway characteristics, -and target
populations. Therefore, a reviewer need not literally apply
the PAGM information requirements and request that the applicant
submit missing information just for the sake of completeness.
Additional or missing information should only be requested
when it would be useful in determining human exposure. For
example, if an applicant discussed surface water use within a
two-mile radius of the facility, rather than the three-mile
radius requested in the PAGM, the permit writer should decide
whether the additional one-mile radius would really be helpful
in determining human exposure potential.
An important question the EIR reviewer needs to consider
is the best way to collect the further information he/she feels
is necessary to complete the EIR review. If the EIR submission
is obviously incomplete and information missing is deemed impor-
tant, the EIR reviewer may request through a warning letter or
an enforcement order issued under the authority of Section
3008, that the owner/operator submit the information. If a
Part B Notice of Deficiency (NOD) is issued for the facility, the
EIR warning letter should accompany the NOD, if possible.
Additionally, the EIR information request may be included in
an enforcement order that is issued to require additional Part
B information.
However, the needed information might also be gathered by
the reviewer directly from other sources (e.g., State files)
either during the. EIR review or, perhaps, as part of the initial
data gathering efforts for any RCRA Facility Assessment activities
planned under Section.3004(u). The EIR reviewer must determine
which approach makes the most efficient use of resources while
also allowing important information to be gathered in a timely
and complete fashion.
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III. EIR TECHNICAL REVIEW (Steps 2 through 6)
A. Evidence of Significant Prior or Continuing Release (Step 2)
Once the EIR is determined to be complete, the reviewer
should review existing data for evidence of significant prior
or continuing releases from the subject landfill or surface
impoundment.. As noted previously, existing RCRA permitting and
corrective action programs should provide the information to
answer this question.
1. Definition of "Significant Release"
In the case of ground-water releases, Subparts F to
40 CFR Parts 264 and 265 provide regulatory definitions of a
"release". Detection of any parameter above background usually
forces the owner/operator to undertake an extensfve monitoring
program to characterize the extent of the contamination.
Therefore, essentially all releases to ground water from units
subject to §3019 will be examined through the permitting process.
Definitions of "release" for the corrective action authorities
(3004(u) and 3008(h)) are given in the RFA Guidance and in the
Preamble to the Codification Rule (50 FR 28713, July 15, 1985).
These documents define "release" as any spilling, leaking,
pumping, pouring, emitting, emptying, discharging, injecting,
escaping, leaching, dumping, or disposing into the environment.
Furthermore, the "environment" includes all media, i.e., air,
surface water, ground water, and unsaturated soils. The RFA
process attempts to identify releases that threaten human
health and the environment. Although Section 3019 is concerned
with only human exposure, these definitions used by the RFA
process are generally applicable to the 3019 process.
A "significant" release can be further analyzed in terms of
the three exposure criteria, i.e., the type and amount of material
released, possible pathways for migration, and the presence of
nearby populations. However, in this initial stage of identifying
releases, the primary concern is gathering enough data to confirm
that a release of potential significance has occurred. The
extent and seriousness of a release will usually require further
investigation by the owner/operator.
2. Useful Information Sources
If the EIR does not contain conclusive evidence of prior or
continuing releases at the facility, or if the data concerning
the release are not complete, then the EIR reviewer can obtain
additional data via a number of information sources. These
sources are described in more detail in the RFA Guidance/ and
relevant information should be gathered and assessed during
the initial stage of the RFA process.
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a. RCRA Part .B Permit Application
One of the best sources of information is the Part B permit
application. Most importantly, information concerning releases
to ground water is a required element of the application. If
the facility has an adequate well system, the ground-water
monitoring data developed under Part 265 and § 270.14(c) should
reveal if releases to ground water have occurred. Owners/operators
that have submitted inadequate ground-water data in their Part
Bs must upgrade their monitoring systems or conduct additional
sampling as needed. See the Draft RCRA Ground-Water Monitoring
Technical Enforcement Guidance Document (August, 1985) for details
in addressing inadequate ground-water data.
In addition, required Part B information concerning
contingency plans, unit designs, and other features of the
facility can provide useful background on any releases indicated.
The completeness checklist for the EIR given in Attachment II
lists portions of the Part B that may be relevant for assessing
releases .
b. RCRA Sections -3004(u) and 3008(h)
Information concerning releases to surface water, air,
soil, and via subsurface gas may be obtained under the authority
of RCRA Sections 3004(u) and 3008(h), which authorize corrective
action for continuing releases. Data can be gathered from the
SWMU letter responses, from the RFA process, and through 3008(h)
Interim Status Compliance Orders. As described previously,
these authorities will perhaps provide the most effective means
of obtaining additional information. The EIR reviewer should
consult the RFA Guidance for implementing 3004(u) and the
Porter/Price memo (December 16, 1985) on the use of 3008(h).
c. Compliance and Enforcement Records
Information pertaining to the general compliance and
enforcement status of the facility should be evaluated with the
EIR. In addition to the records of the operator's compliance
with the 40 CFR 265 requirements for ground-water monitoring, any
problems in compliance with other RCRA Standards may also be
indicative of potential releases. Both the permitting and
enforcement files should be examined for evidence of improper
management of waste that may have led to releases to any other
pathways.
Additional data gathered from other EPA programs, especially
CERCLA and NPDES, may also provide data on possible releases.
Superfund sources that may be useful include CERCLA PA/SI and
RI/FS reports and Reportable Quantity notifications. Information '
from Federal/State air and water agencies, OSHA, and transportation
related agencies may provide further evidence of release via
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the air, water, worker management, and transportation pathways,
resnectively. Especially useful are records of chronic violations
indicative of releases. Although the owner/operator should
have summarized much of this data in the EIR, the reviewer may
have to oather referenced documents or incomplete/missing data
from these sources.
3. Deciding Future Course of Action
After considering the data initially available the EIR
reviewer must decide whether or not (s)he needs additional data
to rule out or confirm the occurrence of a prior (or continuing)
release. If the available information is adequate, the reviewer
may decide that no evidence for a significant release exists; in
this case, the only Steps remaining in the EIR review process are
5 and 6, i.e., the consideration of any impacts of future releases
and oossible permit conditions needed to address these concerns.
On the other hand, if releases of potential significance are
known (or suspected) to have occurred, then a more detailed
examination of the exposure potential is required as described
in the following section (Step 3).
In some cases additional information will be needed to address
possible releases to one or more of the exposure pathways. As
noted above, these questions may be answered through the RFA
or normal oermittinq processes. Alternatively, the EIR reviewer
may be able to qather enouqh information from existing records
or other Reqional, State, or local officials to satisfy lingering
doubts or conerns about particular leaks, accidents, etc.
Figure 2 provides an example of how evidence of releases
and possible follow-up actions for each pathway were summarized,
followinq review of an actual EIR and other information regarding
a RCRA site. While this example was derived from a review of
data from an actual facility/ the case was simplified somewhat
for il lustratative purposes. In order to put this example in
perspective, Figure 2 also contains background information on
the site.
Figure 2 describes the follow up actions that might be
undertaken during Step 2 to determine if a release has in fact
occurred, and whether the release warrants further investigation.
The EIR reviewer may wish to write up a short summary of the
results of his/her analysis at this stage in the process.
However, other reports or records produced as part of the
nermittinq or RFA process should be adequate to document this
staqe of EIR review.
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Figure 2. Example of Summary Sheet Following Initial Review
of Release Data: Release Evidence and Suggested
Follow UD.
Ooerations:
Units of Concern:
Location:
Background Summary of Example Site
A small off-site cororercial facility treats and stores hazardous
waste; operations include waste oil/gasoline recycling, cyanide
waste treatment, solvent recovery, other treatrtent.
Surface impoundments are used to store and treat wastes before
discharge to waste water treatnent plant on site.
The facility is located in an industrialized area, also bounded
by residential areas.
Pathway
Ground Water
Surface
Water
Air
Soil
Summary of Release Evidence
Existing Part B data not adeguate;
monitoring Plan in developnent.
Possible releases via contaminated
run-off fron area around unit which
enters v«ter through municipal sewer
systan; subseguent treatment by POIW
unclear.
Definite release based on odor.
State monitoring program in
development. Sane corrective
action also taken.
Likely releases from spills,
leaks, and accidents. Extent
of clean up of these past
releases unclear.
Possible Follow Up Action
Follow peEmitting/enforcement
procedures to obtain necessary
monitoring data.
Determine if run-off should be
managed as hazardous waste.
Collect available analytical
data on run-off and determine
if discharge goes to POTW.
Obtain data fron air monitoring
program whe:. available, then
consider need for futher inves-
tigation to study extent of
potential exposure and adequacy
of corrective action taken.
Examine any existing soil
analysis undertaken and assess
need for RFA or RFI follow up.
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Figure 2. (contirued)
Pathway
Release Evidence
Possible Follow UD Action
Subsurface
Gas
No evidence; unlikely for
surface impoundment.
None necessary.
Trans DO rt at ion
Management
Practices
Facility, sweeps nearby streets
to remove dirt, perhaps due to •
track-out problem; may not be
related to operation of surface
impoundments. No record of
releases from spills off-site.
Occupational records submitted do
not indicate significant illnesses
due to unsafe cperating conditions.
No other serious enforcement problems
found for facility operation, beyond
those already noted.
Review existing soil analysis
as noted above. Consider
requiring o/o to analyze dirt
found on nearby residential
street for likely hazardous
constituents via RFA or RFI.
None necessary
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3. Determination of Known/Suspected Public Exposures at
Significant 'Levels ( S t ep 3 )
Once a prior or continuinq release from the surface
impoundment or landfill has been documented, the EIR reviewer
"lust determine whether the public has been exposed to the
release, and if so, whether there is "substantial potential risk"
due to that exoosure (see §3019(b)).
The three human exposure elements noted earlier must be
addressed in order to determine whether the public has been
exnosed to a hazardous release and the significance of this
exposure. Listed below are the three exposure elements and the
information needed by the reviewer to assess the presence of
these components. When a release of concern from a unit is
identified, then the reviewer must assess the adequacy of the
supportinq evidence to confirm that all three elements for
public exposure are documented.
1. Human Exposure Components
a. Evidence that the release from the landfill or surface
impoundment contains hazardous wastes or constituents.
Documentation would include:
o Monitorinq data confirming a release from the unit; and
o Data indicating that the hazardous materials or constituents
of concern are present in the release from the unit.
b. Evidence that the release containing hazardous materials
or constituents of concern has m iqrated off-site (or to on-site human
exposure point). Evidence includes:
o Monitorinq data confirming off-site contamination; and
o Monitoring/modeling data indicating the extent of release
and migration via a plausible pathway.
_c._ .Evidence showing a likelihood that a nearby population
has been, or is being, exposed to toxic constituents from the
release at levels constituting a substantial risk to human health.
Information needed would include:
o Monitoring/modeling data suggesting that the public is being,
or has been, exposed (e.g., contaminated drinking water
wells ); and
o Data showing levels of constituents at the exposure point
indicative of a health threat (e.g., levels exceed existing
Agency standards or criteria).
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2. Gathering Da'ta to Document Exposure
a. Use of the Permitting Process
The permit writer should use the permit process and the
3UU4(u) program to gather information concerning possible releases
and human exposure. The first exposure element, the existence of
a documented release, should have largely been satisfied by a
positive determination for Step 2. Any release should be documented
through the usual permitting process (for ground water) or through
30U4(u)/3008(h) RFA studies (for other pathways). The second
element, documented off-site migration, will normally require the
owner/operator to investigate the extent of migration, both in
terms of the constituents released and the area contaminated.
In the case of ground water contamination, the existing RCRA
Subpart F regulations require the owner/operator to characterize
the plume of contamination in some detail, and devise a corrective
action program. The contaminated ground water must be cleaned up
to Ground Water Protection Standards set at background levels or
existing drinking water standards, unless an Alternate Concen-
tration Limit (ACL) is approved. An ACL demonstration is
essentially an exposure/risk assessment for a ground water
contaminant, and a successful demonstration should be sufficient
evidence that no potential for significant human exposure
exists for that constituent. An unsuccessful ACL demonstration
may still provide information useful to the EIR reviewer in
deciding if human exposure is likely.
However, the existing Subpart F regulations only require
the owner/operator to clean up contamination to the facility
boundary. Section 3UU4(v) of HWSA requires corrective measures
(tor releases to all pathways) beyond the facility boundary, but
§3UU4(v) has not yet been codified in the regulations. (Pending
promulgation of these regulations, EPA may issue 3008(h) orders
to implement the directives of 3004(v).)
In some cases of suspected off-site migration of unit
releases, the owner/operator may elect to gather off-site data
to establish.-the'presence and extent of any contamination. In
the past, cooperative owner/operators have been willing to
monitor off-site.ground water for plume movement in order to
devise adequate^corrective action plans, or to support ACL
demonstrations.; Permit writers are encouraged to try to obtain
data on oft-site releases from willing owners/operators.
for releases to pathways other than ground water, the
owner/operator may be required to gather data on the extent of
contamination under either 3004(u) or 3008(h) authorities. The
permit writer must realize, however, that an investigation under
3(J04(u) on the-extent of the contamination may not be initiated
until after the permit is issued. Generally, compliance schedules
will be used in the permit to require the owner/operator to
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conduct a RCRA Facility Investigation (RFI) under 3004(u). Some
information on the level of contamination may be gathered from
the owner/operator's response to the initial SWMU letter and
from the RFA investigation performed under 3004(u). However, in
most cases, monitoring results at this stage will probably be
focused on detecting a release from a SWMU, not on determining
the extent of contamination.
Because RFIs reguired under 3004(u) will not generally be used
to aather data prior to oermit issuance, the permit writer (in
conjunction with appropriate enforcement staff) should consider
whether enforcement orders are needed to ensure an investigation
of releases and the likely human exposure potential before permit
issuance. The following section describe the enforcement
authorities that might be used and the situations that may warrant
their use.
b. Use of Enforcement Orders
An enforcement order may be issued to reguire the
owner/operator (o/o) to aather information (on-site or off-site)
under 3013 or 3008(h) authorities for releases to any pathway.
The issuance of a 3013 order reouires evidence showing that the
presence or release of hazardous waste from a facility may present
a substantial hazard to human health or the environment. Note
that 3013 oives EPA the authority to perform any needed investi-
aations and recover the costs later if the o/o is incapable of
(or refuses to) gather the reguired information. The use of a
3008(h) order reouires evidence that a release (to any medium)
has occurred. See the RCRA Ground-Water Monitoring Complicance
Order Guidance (August, 1985) for a description of these two
types of orders, and the recent Porter/Price Memo on the use of
3008(h), "Interpretation of Section 3008(h) of the Solid Waste
Disposal Act" (December 16, 1985).
Whether to undertake the investigation of a release from a
facility through the permitting process or an enforcement order
will depend on Regional1 priori ties, resources, and various site
soecific factors. Thrirs decision will encompass considerations
that qo beyond the ffumarn exposure concerns of the 3019 EIR review
process. For example,1 "3008(h ) orders may be used when a release
is miaratinq rap id IY^ ~and; may move off-site. In addition, the
corrective action programs will be used to investigate releases
from all suspect SWMUs:-at a facility, not just regulated landfills
and surface impoundments'.
Another important factor to consider is how close the
facility is to receiving a permit. If permit issuance appears
likely within the near future, the permit writer might decide to
incorporate a compliance schedule for a RFI in the permit, rather
than hold up the permit while awaiting the issuance of an order
to gather more information. A related concern is the level of
cooperation exhibited by the owner/operator in the past, and the
likelihood that he will meet the compliance schedule for RFI in
the permit.
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Situations'- which mighc prorapc che permit wricer to seek more
immediate exposure information than could be provided through
the 3004(u) process include cases in which the existing data
indicate a high potential for human exposure. The EIR reviewer
should undertake a preliminary analysis of available information to
estimate the potential impact of a known release. For example,
if evidence of a release and movement off-site to surface water
exists (e.g- , fish kill, complaints of tainted water), the EIR
reviewer should consider the likelihood of releases from the
unit reaching surface water (distance to river, characteristics
of intervening terrain), potential transport and dilution
(river flow and size vs. potential release, the properties of
likely constituents in a release) , and the likelihood of human
exposure (distance to downstream intakes, other uses of surface
wa t e r).
After such a preliminary analysis, the EIR reviewer may
determine that the release requires attention prior to permit
issuance. In such cases, the EIR reviewer should consult with
enforcement and permitting personnel to map out an appropriate
strategy (which may include the use of 3008(h) or 3013 orders)
to obtain the needed data and initiate corrective action.
Even in cases of suspected human exposure, the RFI may be
implemented through the use of 3004(u) compliance schedules if
there is no current (or imminent) exposure potential. For example,
a case of past human exposure (e.g., eating of contaminated
fish) due to a prior (but not continuing) release to surface
water, might be addressed after permit issuance if no current or
imminent human exposure is expected. [Note, that if the elements
of exposure can be adequately documented, these situations may
still be candidates for referral to ATSDR as described in
Section III.C.2.J
c. Other Sources of Information
Many of the additional information sources used in determining
evidence of a release may also:provide data on migration of the
waste off-site and possible human exposure. Particularly important
at this stage in Che review^is-any evidence of health complaints
related to Che sice. Pub lie..submissions may provide indications
of exposure. For sices with•„ suspected human exposure, local or
State health departments sho.uXd also be contacted by the EIR
reviewer co check for any reporcs of health concerns in the
immediate vicinity of che facility. It is important for Regional
and State pennitcing -scaff Co escablish concaccs wich che local
healch departments for sites at which real problems may exist.
For sites thac are evencually referred co ATSDR for healch asses-
sments, one of Che firsc seeps caken by ATSDR would be co concact
chese local deparcmencs for healch complaincs in che area.
3. Technical Assiscance
The EIR reviewer is encouraged co use all of che above infor-
macion sources and rouces for gachering che daca necessary co
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confirm the existence (or absence) of all chree exposure com-
ponents (release, migration, receptor location). After examining
the data gathered under the permitting and enforcement processes,
the EIR reviewer may have some questions concerning the potential
health impacts of documented/suspected human exposures. . The primary
contact for technical assistance will be the Permit Assistance
Team (PAT) at Headquarters as described below. The capabilities
and possible uses of ORD and ATSDR are also discussed. Finally,
existing EPA manuals which could provide the EIR reviewer with
possible approaches for interpreting the assembled data are
noted.
a. Permit Assistance Team (PAT)
The EPA Permit Assistance Team (PAT) at Headquarters
(FTS/382-4740) stands ready to provide technical assistance.
to coordinate assistance from ORD and ATSDR, and^ to provide help
in deciding when referral to ATSDR is warranted. ORD and ATSDR
may, to a limited extent, be accessed directly by the EIR reviewer
on a consultative basis by telephoning the appropriate individuals
(see below). Such informal consultations could provide quick
response to questions on possible health effects raised by infor-
mation available at that point. However, if- the EIR reviewer
needs more extensive technical assistance (e.g., detailed review
of written reports, monitoring data, models, etc.), (s)he should
contact the PAT at Headquarters. The PAT will draw on the
expertise available within OSW, other EPA Offices, and ATSDR
as needed to respond to the Regional request for assistance.
If warranted, health assessments may be recommended for some
facilities, as described in Step 4 of EIR review process.
b. Office of Research and Development (ORD)
The office within ORD which may be useful to the EIR
reviewer is the Office of Health and Environmental Assessment
(OHEA). Within OHEA, the two groups which can provide the most
assistance in evaluating EIRs are the Exposure Assessment Group
(EAG), located in Washington, D.C., and the Environmental Criteria
and Assessment Office located in Cincinnati, Ohio (ECAO-Cin).
ECAO-Cin can provide assistanee~in determining whether any
constituents found at off-site exposure points constitute a
public health threat at measured or projected exposure levels.
ECAO-Cin has developed a Rapid Response Toxicity Program to aid
Regional and State offices in quickly (i.e., 48 hrs.) evaluating
potential human health hazards posed by chemical releases.
These responses may include: rough estimates of cancer risk or
toxic potential; identification of key chemicals tor further
monitoring; a rough description of possible exposure situations
and their potential health hazards; and some recommendations for
future assessment efforts.
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Most recommendations will require the involvement of EAG to
evaluate monitoring data/methods and for a discussion of likely
exposure scenarios and their uncertainties. While this program
is designed to provide only preliminary estimates of health
hazards, more detailed site assessments can also be provided.
Requests for rapid technical response from ECAO-Cin may be
forwarded directly to Chris DeRosa (FTS/684-7534). Requests for
more detailed assessments should be sent to the PAT, which will
coordinate ECAO/EAG assistance.
Through the PAT, OHEA may be able to help the EIR reviewer
complete an exposure/risk analysis to project the likely effects
from past or ongoing exposure to hazardous constituents. With
the expertise available in OSW and ORD, the PAT can recommend a
variety of models for use at a particular site, and may be able
to assist in using this type of analysis in determining the
extent of constituent transport via the usual pathways and the
likely levels of contamination at projected exposure points.
The PAT may also provide assistance in reviewing any analyses or
projections submitted by the owner/operator.
b. The Agency for Toxic Substances and Disease Registry
(ATSDR)
RCRA §3019 specifically identifies ATSDR as a potential
participant in the evaluation of exposure information. ATSDR is
an agency within the Public Health Service, Department of Health
and Human Services. Its overall function is to carry out
health-related responsibilities under CERCLA and RCRA. An Inter-
agency Agreement (IAG) has been established to define RCRA-ATSDR
interactions, and a Memorandum of Understanding (MOU) is currently
under development.
Sites will be referred to ATSDR when a health assessment is
warranted, as described in Step 4(b). ATSDR has the ability to
perform several different levels of health assessment (see
Attachment III), and the more extensive studies will usually be
preceded by more limited investigations.. ATSDR's major task in
any level of health assessment will be to evaluate populations
with known (or suspected) exposure to hazardous.constituents
as a result of a release from a regulated surface impoundment or
landfill. ..,-" "".
As noted in the Attachment III, ATSDR may also provide
informal "health consultations" to provide health advice and/or
health effects information regarding a specific site. The Regions
should limit their consultative use of ATSDR before referral
to situations that require relatively short-term assistance,
e.g., assistance available through a telephone call. Requests
for more extensive work should be sent to the PAT (ATSDR will
also have a representative on the PAT), and the PAT.will coordinate
ATSDR assistance. The EIR reviewer may contact Ralph Touch at
ATSDR (FTS/236-4551) directly for short-term technical assistance.
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c. Technical Documents
The EIR reviewer may consult a number of EPA manuals
which provide a variety of approaches in assessing the exposure
potential and health impact of releases from hazardous waste
sites. As mentioned previously, the RFA Guidance may prove
useful in the early stages of release investigation. Perhaps
most helpful in cases when the EIR reviewer feels a more extensive
analysis of exposure potential is waranted is the Superfund
Public Health Evaluation Manual (December, 1985) and the companion
Superfund Assessment Manual (January, 1986). Copies of these
manuals have been distributed to Regional Division Directors and
Branch Chiefs; current information on the availability of these
documents may be obtained by contacting OERR (382-2182).
Elements of the Public Health Evaluation Manual that may be
useful in cases where seriousexposureproblems are suspected
include: procedures for selecting indicator chemicals;
physical/chemical and toxicity data for chemicals; and a summary
of existing EPA standards and criteria for hazardous substances.
The Exposure Assessment Manual is a complex and highly
technical compendium of approaches and models to use in assessing
exposure potential. The data requirements of the various models
discussed are provided. The extensive data needs illustrate
the major problem in undertaking such a detailed analysis,
i.e., much of the information needed to use quantitative modeling
will not be available at many RCRA sites, and expensive and
lengthy data gathering efforts would be required. Therefore, the
EIR reviewer is urged to limit the use of complex models unless
the data are available, and may seek assistance in the use of
these manuals from the PAT.
C. Possible Actions in Cases of Human Exposure
(Steps 4(a), 4(b) , and 4(c))
If the EIR reviewer believes that more information is required
to decide if a release has resulted in known or suspected exposure
to the public at significant levels, (s)he should obtain the
necessary data as outlined above. If (s)he decides, that the
criteria for human exposure (see Section III.8.1) are not met,
and that significant human exposure is unlikely, then the EIR
reviewer muse still consider whether corrective action is needed
to clean up che release (Step 4(c)). After this, the reviewer
should also consider the impact of future releases (Step 5) and
possible permit changes, if needed (Step 6). These steps are
discussed in later sections of this guidance. The EIR reviewer
may wish to prepare a short report for the administrative record
summarizing decisions not to refer facilities for health assessments.
Such reports may be useful documents tor explaining the decision
during public hearings.
If the components for human exposure given in Section III.B.I
are present, there are several actions the EIR reviewer should
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consider. These actions include implementing interim remedial
actions with appropriate public involvement (Step 4(a)), referral
to ATSDR for a health assessment (Step 4(b)), and final corrective
action (Step 4(c). Which actions are completed and the order
in which these activities are pursued will depend on the situation;
normally, however, the need for interim measures should be
assessed first to insure that continuing public exposure is
minimized. Furthermore, while a completed health assessment
could be useful in designing a final corrective action plan,
corrective action should not be significantly delayed.
1. Interim Remedial Action (Step 4(a))
Interim remedial measures may be necessary to prevent
further human exposure. These may be pursued through the various
enforcement and program authorities available to EPA, such as
RCRA Sections 3008 and 7003, and CERCLA Sections ^104 and 106.
Examples of interim remedial action would include off-site and
source control measures, such as:
o evacuation of the public from the area if the problem is
so serious as to pose an imminent and substantial
endangerment;
o requiring the owner/operator to provide bottled water
and/or drinking water treatment when public drinking
water is the pathway of exposure;
o temporary suspension of facility operations that may cause
or exacerbate the problem;
o temporary removal/storage of wastes of concern, and
other interim measures to contain or prevent releases (e.g.,
berm stabilization).
The EIR reviewer should consult with appropriate permittin-g and
enforcement staff to map out a plan for needed remedial actions.
A review of response actions available under §3008(h) may be found
in the draft guidance, "RCRA §3008(h) Corrective Action Interim
Measures", issued by OWPE (latest draft, May 13, 1986). The reviewer
should also contact public participation staff in order to design
and implement a public information program to inform the public of
the health concerns associated with the facility and the immediate
and long-term actions planned to address the problems.
2. Referral to ATSDR for Health Assessment (Step 4(b))
a. Referral Authority and Concurrence
If there is sufficient evidence that a release from a
regulated surface impoundment or landfill has resulted in
significant human exposure (i.e., if the three necessary components
of exposure have been established for any of the exposure pathways),
then EPA (or authorized States) may refer the facility to ATSDR
for a health assessment (Step 4(b)). While the statute originally
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- 24 - .
assigned the authority to refer a facility to ATSDR to the EPA
Administrator, this authority has been delegated to the Regional
Administrators. The Regional Administrator, if (s)he so chooses,
may redelegate the authority to the Division Director level.
However, the Delegation provides that, before seeking a
health assessment from ATSDR under §3019, the Region must obtain
the concurrence of the Assistant Administrator for Solid Waste and
Emergency Response.This concurrence requirement is designedto
ensure tnatimportant sites are assessed first, and to encourage
national consistency in the types of sites that are referred to
ATSDR. Regions seeking concurrence for referrals to ATSDR should
contact the Permit Assistance Team (PAT) at EPA Headquarters
(contact Terry Grogan or Bob Kayser, FTS/382-4740). The PAT will
coordinate the review of the information by OSW, OWPE, ATSDR, and
other EPA offices (e.g., ORD) as needed, and make recommendations
to the Assistant Administrator concerning the referral.
b. Documentation of Referral Request
When a Region believes that a health assessment by ATSDR is
necessary, the EIR reviewer must prepare a written report for submission
to Headquarters which summarizes the exposure analysis completed
to date, and identifies the pathways of concern. This report will
serve several functions, including: (1) forcing the EIR reviewer
to formally consider the adequacy of the assembled evidence prior
to referral; (2) allowing the Headquarters concurrence group to
review the data in a timely manner; and, (3) providing a useful
summary document for initial review by ATSDR, if a health assessment
is required.
This report must summarize the evidence that the three elements
for human exposure are present at the site. Section III.B.I
describes the kinds of evidence needed to document human exposure.
The report should follow a logical format and should include:
0 background information on the facility (location, types of
wastes handled, brief description of all units on site, nearby
land use, map of facility);
0 evidence confirming a significant release from the regulated
surface impoundment or landfill (monitoring data and the level
of confidence in data, all hazardous constituents detected,
approximate quantitity of wastes released, identification of
major constituents in waste);
0 evidence indicating extent of contamination and migration path-
way of released constituents (monitoring data or modeling results
showing movement off-site, the ranges of substances detected
throughout contaminated area);
0 evidence indicating a likelihood of human exposure via ingestion,
inhalation, or direct contact at levels suggesting a potential
health threat (location of nearby populations, monitoring
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- 25 -
data at exposure point, health complaints from public, records
of local health departments, constituents measured or projected
at levels exceeding Agency standards or other health-based
criteria);
0 on-going or planned activities to collect more data and institute
remedial action at the site (including public participation
plans ) ;
0 results of any preliminary evaluations or assessments of site
data undertaken by the State, Region, ORD, ATSDR, the o/o, or
others;
0 level of health assessment sought (if possible, include specific
questions ); and,
0 name and phone number of Regional/State contacts most familiar with
details of the site.
The report should summarize pertinent monitoring data in
tabular form with clear indications (i.e., on a map) of the sampling
locations. Any analysis of the data (e.g., by the owner/operator,
contractors, Regional/State staff) should be succinctly described,
and any references used must be cited. While the level of effort
required to prepare the referral report will vary with the complexity
of the site, the report should be a summary document, not a lengthy
treatise on the facility. Source documents (Part B, EIR, etc.)
should be referenced for details, and copies of important pages
from these documents may be provided.
3. Corrective Action (Step 4(c))
Corrective action will be considered whether or not the EIR
reviewer determines that significant exposure to the public has
occurred. If exposure routes have been documented and a health
assessment is initiated, appropriate permitting and enforcement
staff should be kept informed. Permit and/or enforcement staff
developing the corrective action plan should coordinate the plan
with the health assessment, if necessary. The level of clean-up
may be affected by the results of the assessment, if for example,
the health assessment uncovers a causal link between the level
of the hazardous constituent at the exposure point and the parti-
cular health effects in the exposed population. In most cases,
however, the permit writer is urged to proceed with permit issuance
to begin initial clean up activities if the available data on
the extent of contamination are adequate. The permit may be
modified to incorporate any useful information arising out of
health assessment activities. As described in section III.B,
§3008(h) orders may be used to institute corrective action prior
to permit issuance.
The EIR reviewer may decide that the evidence does not
indicate that significant public exposure due to prior/continuing
releases has occurred, and therefore, that referral to ATSDR is not
warranted. However, the permit writer should still examine the need
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for corrective measures to lessen the possibility of f ut u r e
exposures to past releases. In the case of ground-water
contamination, of course, the Subpart F regulations (§264.100)
require clean up to levels set by Ground-Water Protection Standards.
There are other corrective action measures to take and several
vehicles for requiring these measures. Guidance is being developed
to assist the permit writer in instituting corrective measures
under 3004(u), 3004(v), and 3008(h). These authorities are the
primary vehicles available to the permit writer for clean up of
releases from regulated units to media other than ground water.
In those situations involving an imminent and substantial
endangerment to public health, EPA may take action under 7003 of
RCRA or 106(a) of CERCLA to institute remedial action. The
"Endangerment Assessment Memorandum" issued by J. Winston Porter
(November 22, 1985) provides guidance on the preparation of
endangerment assessments to support all administrative and judicial
enforcement actions under CERCLA Section 106 and RCRA Section
7003. An endangerment assessment must be developed in order to
document and justify that an imminent and substantial endangerment
to public health or welfare exists. A supplement to the Guidance
has also been prepared by the Office of Waste Programs Enforcement,
in draft form, entitled the Endangerment Assessment Handbook
(August, 1985).
These authorities described above allow EPA to force clean
up of releases prior to actual human exposure. Therefore, the
EIR reviewer and/or permit writer should consult with enforcement
staff in cases that warrant corrective measures prior to permit
issuance. Section III.E. of this guidance should also be consulted
for possible use of the new "omnibus" provision (3005(c)(3)) in
establishing additional permit conditions to address potential
exposure concerns.
D. Determining the Potential for Significant Public Exposure From
Future Releases (Step 5)
In addition to evaluating prior/continuing releases from all
regulated surface impoundments or landfills (steps 2 through 4 in
Figure 1), the EIR reviewer must also address the potential for
human exposure in the case of future releasest (step 5). As such,
Step 5 is the most conjectural part of the EIR review. When
reviewing EIRs for new landfills and surface impoundments, the
EIR review will consist only of this Step and Step 6, consider-
ation of permit conditions necessary to prevent human exposure.
The timing of Step 5 may vary depending on the need to investigate
prior releases. In addition, the EIR reviewer and/or permit writer
may wish to use this analysis of the impact of future releases
as a tool in focusing attention on human exposure potential
throughout the permitting and RFA/RFI processes.
f'Future releases" also include releases that may have already
occurred; but are not yet detected.
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1. General Approach
The reason for examining the impact of future releases is
to highlight pathways of concern and allow permit conditions to
be modified or strengthened to mitigate site-specific potential
problems (Step 6). Of course, the occurrence of prior releases
to a particular pathway, and any evidence of subsequent migration
and human exposure,.should be used as the primary indicator of
the potential impact of future releases. This is why the flow
chart in Figure 1 also leads the EIR reviewer to consider the
impacts of future releases (Step 5) after the process for prior
releases (Steps 2-4) is followed.
In the absence of a history of past releases, however, the
EIR reviewer should consider the potential exposure rf a release
should occur. The EIR reviewer is encouraged to,use a qualitative
approach for screening facilities for possible exposure concerns
from future releases. In a limited number of cases a more detailed
evaluation may be warranted if the initial qualitative screen
indicates that a future release from the unit is likely to result
in significant human exposure. In these cases, the permit writer
may wish to quantify possible exposure scenarios in order to
justify the imposition of permit conditions that go beyond the
existing Part 264 standards (see next section for a discussion
of the new "omnibus" provision). Future guidance will provide
information on applying a more quantitative approach.
The EIR reviewer may follow the general approach outlined
below to qualitatively screen units. This approach examines the
same elements for exposure as defined for past releases (i.e.,
release, migration, and receptor location). Due to the prospective
nature of the evaluation, however, the approach first examines
the route characteristics and receptor information assuming a
release occurs. If a potential concern is identified, the design
and operating features of the unit should be critically examined
for their adequacy to prevent or detect releases. The infomation
needed to evaluate the major pathways should be available from
the EIR, the Part B, or the other information sources mentioned
in Section I.
The requirement under 3019 to consider the impact of future
releases (i.e., Step 5) has many features in common with the RCRA
RFA process designed to implement 3004(u) and 3008(h). The
potential for future releases becomes an important factor if the EIR
reviewer decides that a particular pathway is of concern. There-
fore, the EIR reviewer (and permit writer) should use the results
of a RFA investigation as a valuable source of information in
deciding if the location, design, and operating features of the unit
are adequate to prevent (or render less likely) future releases
to pathways of concern.
Because the RFA and EIR review processes share many similar
concerns relating to the potential for a release and subsequent
migration off-site, many elements of the methods given in the RFA
guidance have been incorporated into the following qualitative
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approach. The followi.no sections describe important factors for
each pathway that should by considered in an initial qualitative
screen .
2. Pathway-Specific Factors
a. Ground Water
The EIR reviewer should examine the pertinent hydrogeological
and geoloqical factors of the site, as well as the location of
possible taraet populations, in order to assess the potential
impact if a future release to the ground-water pathway occurred.
The important route characteristics and receptor information to
examine are described below.
Route Characteristics Affecting Exposure Potentia.l
An evaluation of the ground water pathway should indicate
the potential for contaminant movement through the unsaturated
zone to the aguifer and subsequent off-site migration in the ground
water to human receptors. Therefore, the important characteristics
to examine should include the soil characteristics (i.e., per-
meability) of the unsaturated zone, the depth of the aquifer, and the
flow rate and direction of the ground water. If the hydrogeology
of the site is properly defined in the Part B (including at least
the oermeablity of the saturated zone and the hydraulic head),
the EIR reviewer should be able to estimate the time-of-travel (TOT)
for the around water to the facility boundary, and perhaps to
the nearest off-site downgradient well. Other factors which may
be important at some sites include the local climate (e.g., net
precipitation, which would effect the generation of leachate),
the existence of confined aquifers, the discharge of ground
water to surface water, and seasonal variations in the water
table.
Receptor information of prime importance include the location
of the nearest down gradient wells, the uses of the ground water
in the area, and magnitude of the population served by nearby wells.
While drinking ground water is an obvious exposure route, other
ground water uses may lead to human exposure through contamination
of food crops (irrigation uses) or other food products (milk). In
addition, nearby populations may be impacted if the site character-
istics promote basement seepage into nearby buildings.
An example of a site of obvious concern would be one at which
the unit overlies a highly permeable unsaturated zone (sand, silt,
permeability > 10~4 cm/sec), the aauifer is shallow, the ground-
water flow is moderately fast, perhaps due to faults, joints, or
solution channels (TOT to facility boundary < 5 yrs.), and
nearby drinkinq water wells lie down gradient (TOT to nearest
well < 10 yrs.). Conversely, if the aquifer were situated
below an extensive impermeable layer (clay; permeability < 10~°
cm/sec), the ground water flow was slow (TOT to facility boundary
> 50 yrs.), and the aguifer was not presently used by nearby
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- 29 -
populacions, then the EIR reviewer could decide chac exposures
via chis rouce are unlikely if a release occurred.
Sicuacions which are noc so clear-cut may scill be of only
limited concern if either a reasonable migration route (i.e.,
moderately fast ground water flow to off-site wells), or likely
target receptors (i.e., nearby populations using the ground
water) are not present. For these intermediate cases, however,
the EIR reviewer may require more information on the hydrogeology,
receptor locations, or aquifer uses. More definitive guidance
on evaluating ground-water vunerability may be found in the manual
Criteria for Identifying Areas of Vunerable Hydrogeology Under
the Resource Conservation and Recovery Act (OSWER7 July,1986).
The EIR reviewer should refer to this guidance if a more complete
analysis of ground water location characteristics is warranted.
Unit Design and Operating Features
If the EIR reviewer has some concerns about the possible
exposure to the public from releases to the ground water, then
(s)he should undertake a review of the relevant design and
operating features of the unit. The relevant features of landfills
and surface impoundments are related to the containment of
leachate and the leak detection/monitoring systems. The adequacy
of the liner and leachate collection systems, leak detection
procedures (e.g., routine leachate analysis), and the ground-water
monitoring systems around the units should be reexamined. During
this examination, the EIR reviewer should decide if any modifications
to the existing systems are necessary to reduce the likelihood
of releases (or increase the probability of detecting releases)
to the ground water. Any special waste characteristics, or pre-
treatment process that might affect the amount of liquid waste
managed should also be considered.
b. Surface Water and Drainage
Assuming a release might occur, the EIR reviewer should first
evaluate the potential for human exposure. Releases that occur
to surface water and off-site surface drainage areas may arise
from leaks, surface run-off, spills, or floods. The effectiveness
of pertinent'design/operating features should be examined if the
EIR reviewer concludes that this pathway is of concern.
Route Characteristics Affecting Exposure Potential
The primary considerations in evaluating the potential
for human exposure for this pathway are the proximity of the
unit to surface water, the likelihood that a release would
migrate overland, and the current uses of the surface water.
Therefore, the requirements for a realistic surface water pathway
for human exposure generally would include all of the following:
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- 30 -
0 surface water located close to the unit;
0 the characteristics (slope, soil type, vegetation, paved areas)
of the likely oaths for run-off from the unit are sufficient
for a relase to reach the water; and
o
use of the surface water for drinking water, commercial fishing,
shellfish harvesting, or extensive agricultural (irrigation of '
food croos ) or recreational uses.
For example, releases from units located in topographically
depressed areas are unlikely to leave the site as run-off. Also,
facilities located close to surface water may still be unlikely
to contaminate this medium if the intervening terrain is
characterized by sandy soil and heavy vegetation; .in this case
run-off is likelv to migrate into the unsaturated-or saturated
zone. On the other hand, a pathway characterized by clayey
soils, little vegetation, and/or the presence of natural or
man-made run-off routes (e.g., ditches, paved areas, storm sewer
systems, etc.) may indicate a potential problem if the usage of
the surface water makes human exposure likely (e.g., drinking
water intake or commercial fishing areas are a short distance
downstream). The permit writer should also consider possible
discharge of contaminated groundwater into surface water.
In the case of a likely route to the surface water, the EIR
reviewer may examine the features of the surface water itself
to estimate the impact of a release. For example, a release
from a relatively small surface impoundment or a limited amount
of run-off from a nearby landfill may not have a significant
impact on a large, fast flowing river due to dilution. However,
the validity of this type of assumption depends to a great
degree on the characteristics of the chemical constituents
which might be released, i.e., the toxicity and fate/transport
properties of the substances. If the EIR reviewer feels that a
more detailed evaluation of the potential for significant exposure
due to future releases to surface water is required, (s)he may
refer to the procedures: contained in the RFA Guidance which
discuss how to assess such releases.
Design and Operating-Features
If a significant., potent ial for exposure due to. a future
release to nearby surface water exists, the EIR reviewer should
examine the pertinent design features. The effectiveness of
landfill and surface impoundment run-off and erosion controls,
the adequacy of collection and secondary containment systems,
overflow alarms, automatic cut-off systems, and dike design
should be considered for surface impoundments. (The EIR reviewer
should also consult* an. OSW policy memorandum from John Skinner
to the Regions dated: November 14, 1985 for details on the manage-
ment of precipitation run-off at landfills). In addition, if the
unit is within the 100-year foodplain, procedures to ensure
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- 31 -
protection from* wash-out during flooding should be reviewed.
The EIR reviewer and/or the permit writer should decide if changes
or additions to the unit design/operating features in the permit
are needed to address ootential exposure from releases to a
surface-water pathway identified as a concern.
c. Air
In general, the two types of air releases of concern are
continuous, chronic releases, and releases that are intermittent
and sudden in nature. Continuous air releases associated with
surface impoundments usually arise from the volatilization of
organic constituents of. the waste handled. For landfills, air
releases may occur by volatilization through inadequate daily
covers, or by narticulate releases generated by filling operations
or wind erosion. (Subsurface gas is a uni-gue ty.pe of air problem
treated seoarately in the next section). Intermittent air releases
may result from accidents (fires, explosions) occuring during
the mishandling of incompatible, reactive, or ignitable wastes.
Route Characteristics Affecting Exposure Potential
Population density and distance from the unit-are the primary
factors in the potential for exposure to an air release. Another
factor to consider is if people are located along the line of
the predominant wind direction at the site. While wind velocity
and direction are variable at most locations, people located
along this vector are more likely to receive increased exposures
to air releases (especially chronic releases). In general,
however, releases to the atmosphere may be rapidly dispersed
throughout the area around the facility, and some exposure to
any of the nearby populations may occur.
Design and Operating Features
Because route characteristics are of limited use in
determining if a release from .a. unit would pose an exposure
problem, the EIR reviewer may Zins tead focus on the potential for
air releases. This aonroacK! ..is essentially identical to the
approach incorporated in, the RFA Guidance and the EIR reviewer
should refer to this manual -for details. In general, this approach
relies heavily on the characteristics of the wastes handled and
unit design/operating features to uncover potential releases.
For example, an impoundment .with a large surface area containing
fairly concentrated solutions of volatile organics may warrant
examination if people are immediately downwind from the unit.
Conversely, surface impoundments handling wastewaters containing
only non-volatile metals should not pose a significant exposure
problem. If volatile wastes are handled at the unit, and population
centers are nearby, the EIR reviewer should examine (and consider
permit changes to correct) unit characteristics that may promote
air releases, such as: large.., uncovered surface impoundments,
treatment methods using aeration, inadequate daily/permanent
landfill covers, and trench fill operations.
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- 32 -
Potential "release and exposures to nearby oopulations due
to accidents such as fires and explosions also will "depend on
waste characteristics. If siqnificant amounts of iqnitable,
reactive, or incompatible wastes are handled, the EIR reviewer
shouM examine the Part B submission to ensure that the relevant
264 standards (264.17, 264.312-314, 264.229-230) are adequately
addressed. Waste analysis/management plans, including procedures
to identify such wa-stes when received and special handling,
treatment, or mixing procedures employed, should be scrutinized
to ensure that additional permit conditions are not needed to
orevent violent reactions, fire, or explosions.
d. Subsurface Gas
Routine subsurface qas releases are most likely from sites
where biodegradable wastes are managed. Landfills used for
codisoosal of nutrescible refuse with hazardous waste pose the
most serious nroblem because of the potential for other volatile
hazardous constituents to become mixed with the methane generated
from the decomposable material. If codisposal has not occurred
(and will not occur in the future), the EIR reviewer may generally
disregard this exposure oathway. However, if codisposal is
known or suspected, the factors that affect migration of subsurface
gas should be examined.
If an analysis is warranted by codisposal practices, the
RFA Guidance should he consulted for details on procedures to
assess the potential for release and off-site migration of sub-
surface aas. Subsurface gas migration may be facilitated by
man-made underground conduits used for power lines, drainage/sewer
pipes, and telephone cables. The presence of natural or engineered
barriers or controls (surface water, ground water, synthetic
liners, slurry walls, gas venting systems) will impede or prevent
lateral migration of gas produced. The geological setting and
climate will have a large impact on gas movement, e.g., soils
with high permeability and effective porosity tend to allow
upward (rather than lateral) gas migration, while relatively
impermeable (or frozen) soils may promote lateral movement.
Nearby buildings must also be present in order for subsurface
gas to consitute a potential threat via explosion of methane
gas, or through human exposure to toxic gases (e.g., vinyl chloride)
If codisposal at a landfill is known or suspected, and if
the site characteristics promote the "lateral migration of gas
to nearby buildings, then a potential for human exposure exists.
Any existing monitoring or control systems for subsurface gas
should be examined, including any passive venting designs (gravel
walls, vents to surface), any active recovery system/ and treatment
procedures used for recovered or vented gas. Normally, the
usual path to assess the significance of this pathway would be
as part of a RFA investigation. Probably only after completion
of the RFA (and RFI, if necessary) would the permit writer consider
additions to the permit that would address these concerns, e.g,
installation of gas venting systems.
i« ,
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- 33 -
Potential exposures due to direct contact with contaminated
soils should be neqliqible if the site at which the unit is located
has the reauired security (see relevant section of Part 3).
Therefore, the orime concern should be intermedia transfer of con-
taminated soil to another pathway and subsequent off-site transport.
For example', any potential for transport off-site by run-off to
surface water or through wind dispersion to air should be examined
under the appropriate pathway evaluations described in the preceding
sections. The potential for food chain contamination should also
be considered if any food crops are grown near contaminated soils.
Design and operating features relevant to contaminated soil
intermedia transfer have been previously described. The SIR
reviewer should review these procedures, as well as the
security procedures . and equipment used to limit 'public access to
active portions of the units, and spill clean-up, procedures
for routine spills, accidents, and leaks. An additional concern
related to the transportation of waste (see next section) is the
adequacy of current operating procedures in preventing the "track
out" of contaminated soils by transportation vehicles from active
portions of the site.
3 . Transportation Factors
Routine transportation releases are associated with leaks or
unloadinq/loadinq practices. The EIR reviewer should examine the
type, capacity, and adequacy of vehicles and other conveyances
(e.q., pipelines) used, and the procedures taken to minimize
releases. The traffic pattern information should be examined
to determine if the routes traveled through nearby populated
areas pose potential exposure concerns. For example, the potential
for exposure is increased if large quantities of waste (especially
acutely toxic, highly volatile, ignitable, or explos ive wastes )
are transported through highly populated areas. Transportation
routes through thinly populated area, or on-site waste disposal,
are less likely to lead to significant human exposure.
If the permit writer has concerns about the potential exposure
arising from transportation of waste, ( s ).he should examine the
past compliance records of the facility, noting any accidents and
transportation violations. The permit writer should also consider
requiring improved emergency spill/clean-up procedures used for
transportation accidents, special contingency plans with nearby
localities, or other ways of dealing with the problem.
4. History of Management Practices
Proper management practices are necessary to ensure the
operation of the unit is adequate to render releases unlikely
or to detect and correct problems. Obviously, the most definitive
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- 34 -
indicator of problems is a past release, and the EIR reviewer
•nust examine the desicjn and operation of the unit to see if
chanaes in permit conditions are warranted to address these
nast nroblems. Other less definitive types of information that
are indicative of the adequacy of the operation/design of the
unit include insurance claims and settlements, and the compliance
history of 'the unit with Federal, State, and local regulations,
especially inspection records and any violation citations.
The EIR reviewer should consider the history of complicance with
RCRA reaulations, as well as other records th'at the owner/operator
submitted or identified in the EIR, such as:
0 occupational health and safety records;
0 NPDES compliance records;
0 compliance records for applicable air regulations; and
0 spills reported under CERCLA.
For example, worker data on injuries, accidents, and illnesses
related to operation of the unit may be used to help identify those
facilities with guestionable management practices, and hence, with
potential for releases. The EIR reviewer should focus on the
nature and freouency of these and other chronic violations
to assess the likelihood that a future release to any pathway
might occur.
If a chronic compliance problem exists, the EIR reviewer
should examine relevant permit conditions (e.g., worker training
problems, contingency plans, inspection schedules/ proposed
compliance schedules) to ensure that the unit is operated in
an adeguate manner. The EIR reviewer should also discuss compliance
problems and possible remedies with appropriate RCRA enforcement
staff.
5. Example of Exposure Potential Determination -
Figure 3 summarizes an example of the results of a qualitative
screen of the potential for exposure from future releases (Step 5).
This example examines the same site that was reviewed in Figure 2
(for prior releases, Step 2) and the same background information
applies. Figure 3 illustrates the types of decisions that can be
made concerning: the potential impact of future releases to each
pathway; when release potential should be considered; and, possible
follow up action to address potential problems. Note that the
existence of prior releases is given important consideration in
assessing release potential, and the outcome of investigations
of past releases will greatly affect possible follow up actions.
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- 35 -
Figure 3. Example of Summary Sheet Following Qualitative Screen for
Future Releases
Background Summary
See Figure 2 for general background. Concerning Management Practices, no chronic
RCRA compliance problems documented; occupational and CERCIA records do not
indicate problems. (Odor violation being examined through prior release analysis;
see air pathway)
Pathway
Potential for Exposure
Release Potential and
Possible Follow-Up Action
Ground Water
Very low. Aquifer not used for
drinking water; ground-water
flow very slow (K < ICT^cm/sec,
minimal hydraulic head).
Not required due to low
exposure potential.
Surface
Water
Very low. Use of nearest surface
water severely limited due to
existing pollution. No overland
route; run-off goes to POTW before
discharge.
Not required due to low
exposure potrential.
Air
Subsurface
Gas
Soil
Transportation
Possible due to population areas
adjacent to site and the handling
of some volatile wastes. Level
of concern raised due to odor
violation.
Very low. While underground con-
duits exist, unlikely route for
surface impoundment.
Possible concern due to record of
facility sweeping nearby resi-
dential street. Direct exposure
of nearby population could result
from track-out of contaminated
soil.
No indication of potential problems
beyond track-out concern raised under
soil pathway.
Based on past releases,
future release likely.
Await results of monitoring
to decide if new permit
conditions warranted.
Not required due to low
exposure potential.
Potential for track-out
exists; if subsequent
RFA or RFI shows soil
contamination, consider
permit conditions (e.g.,
cleaning trucks prior to
off-site transport).
Not required due to low
exposure potential.
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- 36 -
E. Considering Permic Conditions to Mitigate Potential
Exposure (Seep 6)
If che analysis oucLined for Seep 5 indicates che potential
for significant public exposure due to future releases, then the
EIR reviewer should examine the design and operating features of
the unit as described in the preceding section to decide if
additional permit conditions are necessary to decrease the potential
for releases. If this examination suggests that the existing
design and operating features are adequate to address any potential
exposure pathways, then the EIR reviewer may end the EIR review
process.
Alternatively, if the EIR reviewer feels that additional
permit conditions are required, (s)he must consider what conditions
are warranted and how these can be required in the permit. In
some cases, strengthening permit conditions already required under
existing 264 standards may be adequate. In the case of concerns
over releases to ground water, for example, the owner/operator.
might be required to undertake more frequent monitoring of existing
wells, or sink new wells, in order to insure that a release will be
detected in a timely manner. Because the existing regulations
were designed to address primarily ground-water contamination, the
permit writer may find a variety of ways to decrease exposure
potential for this pathway under the existing regulations.
Concerns about releases to other media may also be addressed,
to a limited degree, under existing 264 standards. For example,
release potential to the air might be reduced through a strengthening
of conditions related to waste analysis (to ensure that accidental
releases through explosion, fire, or productions of toxic gases do
not occur through mismanagement). Exposure potential via air
releases may be decreased by insisting on well designed contingency
plans and other agreements with the surrounding communities. In
some cases, however, the permit writer may have to go beyond the
standards contained in Part 264. Permit denial (the "ultimate"
permit condition) is the final option in extreme cases of serious
exposure potential.
The Hazardous and Solid Waste Amendments of 1984 (HWSA)
provided EPA with a new "omnibus" authority in Section 3005(c)(3),
and this provision has been codified in the RCRA regulations in
40 CFR Part 270.32(b)(2). This provision enables the permit
writer to require the owner/operator to comply with permit
conditions "necessary to protect public health and the environment".
The accompanying legislative history indicates that Congress
intended EPA to add permit conditions beyond those specified in
the exisiting regulations (see the codification rule, 50 FR
28722, July 15, 1985).
Therefore, EPA may require permit conditions that go beyond
existing 264 standards if an examination of the exposure potential
of the facility warrants such action. In these cases, the EIR
-------
- 37 -
reviewer/permit- writer may wish to perform a more extensive
analysis of future release/exposure potential to justify additional
oermit conditions. However, for sites at which past releases and
exposures have been documented for a particular pathway (e.q./
via the process beqinnina with Step 2 in the EIR review- process),
further documentation of future release potential via this route
may not be needed.
Examples of additional permit conditions that could be added
under 3005(c) include:
0 new desiqn/operatinq features to rapidly detect releases (e.g.,
require routine air monitorinq for indicator parameters at or
near the s ite) ;
0 additional release control desiqn features (e.g., covers or
wind screens to decrease air emissions from surface impoundments;
increased dike stability requirements and/or secondary containment
systems to prevent release to surface water); and,
0 limitations on the operations of the unit/site (e.g., limit
the handling of wastes with volatile constituents to mitigate
air releases; limit the acceptance and treatment of ignitable
or reactive wastes to prevent possible explosions or intermittent
air releases; limit the acceptance of certain acutely toxic
wa s t e s ) .
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Attachment I Section 3019 Statute
Section 3019. Exposure Information and Health Assessments
•*«:. 3019. (a) EXPOSURE INFORMATIOK.-Beginning on th« date nine months
after the enactment of the Hazardous and Solid Waste Amendments of 1984, each
application for a final determination regarding a permit under section 3005(e)' for a
landfill or iurfact impoundment shall be accompanied by information reasonably
ascertainable by the owner or operator on the potential for the public to be exposed to
hazardous wastes or hazardous constituents through releases related to the unit. At a
minimum, such information must address:
"(1) reasonably forseeable potential releases from both normal operations
and accidents at the unit, including releases associated with transportation to or
from the unit;
-------
Attachment I (Continued)
Registry shall give priority to those facilities or cites at where there is documented
evidence of release of hazardous constituents, at which the potential risk to human
health appears highest, and for which in the Judgment of the Administrator of such
Agency existing health assessment data is inadequate to assess the potential risk to
human health as provided in subjsection (f).
"(e) PERIODIC REPORTS.—The Administrator of such Agency shall issue periodic
reports which include the results of all the assessments carried out under this section.
Such assessments or other activities shall be reported after appropriate peer review.
*(f) DEFINITION.—For the purposes of this section, the term "health assessments'
shall include preliminary assessments of the potential risk to human health posed by
individual sites and facilities subject to this section, based on such factors as the nature
and extent of contamination, the existence of potential for pathways of human exposure
(including ground or surface water contamination, air emissions, and food chain
contamination), the size and potential susceptibility of the community within the likely
pathways of exposure, the comparison of expected human exposure levels to the short-
term and long-term health effects associated with identified contaminants and any
available recommended exposure or tolerance limits for such contaminants, and the
comparison of existing morbidity and mortality data on diseases that may be associated
with the observed levels of exposure. The assessment shall include an evaluation of the
risks to the potentially affected population from ail sources of such contaminants,
cinluding known point or nonpoint sources other than the site or facility in question. A
purpose of such preliminary assessments shall be to help determine whether full-scale
health or epidemiological studies and medical evaluations of exposed populations shall be
undertaken.
"(g) COST RECOVERY.—In any case in which a health assessment performed under
this section discloses the exposure of a population to the release of a hazardous
substance, the costs of such health assessment may be recovered as a cost of response
under section 107 of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 from persons causing or contributing to such release of such
hazardous substance or, in the case of multiple releases contributing to such exposure, to
all such release.
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TAC
HUE NT I I
Facility Name
ID No.
EXfOSUHE INFORMATION REPORT (E1H) REQUIREMENT CHECKLIST
A. General Information
Numbers
A-l.
A-la
A-lb
A-lc
A-ld
A-le
A-lf
A-lg
A-lh
A-li
A-1J
A-lk
A-ll
A-lm
Information Requirement
Information in Part B Application
General description of facility
Chemical and physical analyse* of wastes
Access control and security
description of active portion
General inspection schedule' and procedures
Preparedness and prevention documentation
Contingency plan
Preventive procedures
Facility location information
Closure plan
Post-closure care plan
Documentation of insurance
Topographic mad .(site plotted on uses
quadrangle maps)
List of wastes placed or to be placed
In each unit
Provided Complete Not
Reg. Cite (i/N) (i/N) Applicable Location In Part B or e lit/Comment
27U.14(b)(l>
270.14
and (J)
270.14(b)(4)
270.14(b)(5),
27(1. 17(6)
270.14(6) (7)
27U.14(b)(U)
27U.14(b)(ll)
(i) and (ii)
27U.14(b)UJ)
27U.14(b)(U)
27U.14(b)(17)
270.14(b)(iy)
270.21(a) and
27U.17(a)
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Ill - 2
IMPOKHATIOM REPORT (EM) HBflUIREMBIIT CHECKLIST
A. . General Information (continued)
Information Requirement
Numbers
A-2. Additional Information
A-2a Bxiating riak assessment reports and
information, including liability insurance
analyses, claims, and settlements
A-2b land use and toning map(a) for an area of
4 miles around the unit
A-2c Existing aerial photographs of the facility
A-2d Identify and summarize any waste analysis
data not already aubmlttedi provide
additional data as discussed in text
A-2e Current estimate of annual amount of waste
received and description of any pretreatment
process used
A-2f Identification of any Federal, State, or
local Inspection or compliance records
related to environmental and health programs!
include descriptions of any major violations
Provided Complete Not
Reg. Cite (y/M) IY/H) Applicable
270.101))
270.101))
270.10()»
270.10
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II - 3
EXPOSURE INfORMATION REPORT (E1R) REQUIREMENT CHECKLIST
B. Ground-Mater Pathway
Information Requirement
Number a
B-l. Interaction tn Part B Application
B-la Interim atatua ground-water monitoring reaulta
B-lb Identification of uppermost aquifer.
Including flow rate and direction
'' '•• ' -" IU. I »«!di toUd ' ' a i » .
B-lc Topographic aiapa related to ground-water
protection (well location, water table
elevation contour*, etc.) . ..
B-ld Oeacription of eiiating contamination
B-le Detailed plans for ground-water •onltoring
prograa
B-lf Deacrlption of detection Monitoring
program (if applicable)
B-lg Oeacription of compliance Monitoring
program and characterisation of
contaminated ground water (If applicable)
B-lh ACL deawnatration (if any)
B-lI Corrective action program (if applicable)
Reg. Cite
27u.l4(c)(l)
27U.l«(c)(2)
270.14(c)(J) and
270.14(b)(19)
27U.14(c)(4)
(i) and (11)
270.H(c)(5)
270.14(c)(6)
27U.14(C)(7)
and (c)(7)(il)
270.14(c)(7)(lv)
27U.14(c)(B)
Provided Complete Not
(T/M) O/H) Applicable
Location tn Part B of eiR/Cowwnt
B-l) Deacrlption of liner and leachate collection 27U.17lb)(l)
ayateaw (if applicable) 270.2Kb) (1)
-------
II - 4
EXPOSURE INFORMATION HBPORT (Bill) REQUIREMENT CHECKLIST
B. Ground-Mater Pathway (continued)
Provided Complete Hot
Humbert Information Requirement Reg. Clte (If/M) (Y/N) Applicable Location in fact B or EIR/Comment
B-2. Additional Information
B-2a Bxiating nap showing location of all known
well* within three mlleai number and
location of drinking water wella 27U.10<)) .
B-2b Diacuaaion of ground-water uaea within
three aiilea of unit
27U.1UI])
B-2c Regional aap ahowing areaa of ground-water
recharge and diacharge 270.10(1)
B-2d Net precipitation uaing net awaaoaal rainfall
or other available data - ii. . •< 270.10IJ)
B-2e unleaa otherwlae reported to BPA, available
well data Indicating a release, and
information on any affected public or private
water auppliea. Including populations aerved 270.10(j)
B-2f Any known food chain contamination due to
prior releaae from the unit to ground water 27U.10(j)
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II - 5
EXPOSURE mrORH»TIOH REPORT (E1R) HeQUlHEHgMT CHECKLIST
C. Surface Mater Pathway
Information Requirement
Numbers
C-i. Information In Part B Application
C-la Location information related to 100 yr flood
plain including variance demonstration*
C-lb System for control of run-on fro* each
peak discharge of 2S yr ator*
C-lc System for control of run-off fro* 24 hr,
2S yr storm
C-ld Procedures/equipment to prevent overtopping
C-le Structural integrity of dikes
Reg. Cite
(ill) thru (v)
270.21(bl(2)
270.21(b)(J)
270.17(b)(2),
2t«.221(f I
270.17(bHJ)
Provided Complete Not
(i/M) (y/M) Applicable
location in Part B or tin/Comment
C-2. Additional Information
C-2a Dlacuaaion of aurface water uaea within
three allea of the unit. Including a «ap
•howing the location of all aurface water
bodlee and downatreaa drinking water intake* 270.101))
C-2b velocltlee of atrea>a and rivera paaalng
through and adjacent to the property 27o.lo())
C-2c Oeacrlption of any ayatcB uaed to Monitor
aurface water quality, and a auavMry of the data 270.10)})
C-2d Description of known releaaee to aurface water;
the eiteot of contaailnationi reaiedial action.
If anyi and if known, severity of impact 270.101))
C-2e Any known food1 chain contamination reaultlng
from prior release from the unit to aurface
water 270.101)1
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II - 6
BKPOSURg IMPORHATIOH REPORT
-------
-II - 7
EXPOSURE 1HPOH«ATIOM RBfORT (BIB) REQUIREMENT CHECKLIST
B. subsurface Caa Pathway
Provided Complete Not
Number a Information Requirement Reg. Cite U/M) IK/M) Applicable Location in Part B or eiR/Comment
B-l. Information in Part B Application
(Note: None in addition to General Information Requirements!
B-2. Additional Information
B-2a Any paat dlapoaal of municipal-type waatea in the
unit; approilmate quantitlea and datee of
diapoaal, if known 270.10(}>
B-2b Nap location of any underground conduit*
within the aite and known underground
conduita within 1000 feet of property boundary 270.10IJ)
B-2c Description* of any monitoring or control
mechaniama for aubaurface gaa releases
aummarlie reaulting data 270.lO(j)
B-2d Description of any known releaaea; extent of
contaminations remedial action taken, if anys
and the aeverity of Impact, If known 270.10<))
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II - 0
BKP03URB INrtmmTIOM REPORT (B1R) REgtllHEHEHT CHECKLIST
P. Contaminated Soli Pathway
Provided Complete Not
Numbera Information Requirement Reg. Cite (Y/H) (Y/M) Applicable location In Pact B or em/Comment
f-1. Information In Part • application
(Mote: Hone In addition to General Information Requirements)
P-2. Additional Information
f-2a If aoll •aaplin9 haa been done, a map ahowinq
areaa of aoll contamination, and a aumawry of
analytical result* 270.10(]|
P-2b Oeacriptlon of the typea of major releaaea
that resulted in aoil contamination, and any
clean-up action 270.10(}J
P-2c Any known food-chain contamination resulting from
the use of contaminated aoila for raising crops 27U.lO(j)
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II - 9
B1TOSUHB INfOBMATIOM REPORT (BIB) REQUIREMENT CHECKLIST
0. Tranaportatlon information
C-l.
Information Baquirea»nt
Information In Part 1 aplication
C-le Traffic pattern, voluM, aiMI eoatcolai «cce««
road character t«tlc«
. Ctt«
270.14(b)(10)
Provided Coaplet* Not
(If/M) AppllcabU
Location in Part B or tlK/Com»tnt
C-2. Additional Inforaatlon
C-2a Deacrlptlon of th« typea and capacltiaa of
vehicle* uaed to transport waate 270.101])
G-2b Identification of noraal transport routea
for hasardoua Maate Into the alte and within
one aile of the facility entriea 27u.lo(j)
C-2c Deacriptlon of procedures for clean-up of
transportation-related spill* or leaka 270.10(j)
C-2d Deacrlptlon of any transportation accldenta
releasing hazardous wastes on-site, or in the
lawediate vicinity 270.10(j)
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'II - 10
mronmTioM REPORT (BIB) REUUIREHEHT CH ecu LIST
H. Management Practices InfonMtlon
Information aequlrement
Humbers
M-l. Information in Part B *gpiic«tioa
M-l« Outline of progrM« to trala ••ployce* to
•afely operate and ••iotalo facility,
including eaergency reapooa* actlvitle*
Reg. Cite
27U.14(b)(12)
264.16
Provided Complete Not
Qf/M)
-------
B1POSUBB IMfORMATlOM RBPOBT 18III) BBQUIRBIKMT CHECKLIST
I. Potential tor HuMan Biposure
Information BaquireMcnt
MuMbers
I-I. Croundwater Pathway
I-la Description of hoi* the units' location
•fleet* the potential for and possible
•agnitude ot huMan exposure fro* releases
to groundwater
Provided Complete Not
Reg. Cite Qf/M) (»/M) Applicable Location in Part B or eiR/Coament
270.101])
I-lb Description of the deaiqn and operating
features that affect the potential
for releases to groundwater and the
•agnltude of these releaaea
270.101})
1-2. Surface Mater Pathway
I-2a Description of how the units' location affects
the potential for and poaaible Magnitude of
huMan exposure froM releases to surface
water. 270.10(1)
I-2b Description of the design snd operating
featurea that affect the potential for
releases to surface water and the
Magnitude of these releases. 270.10(1)
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II - 12
BKPOSUBB IlirORHfcTIOM REPORT (BIR) RBQUIHBIgMT CM ECU LIST
I. Potential tor Hu»an Ixposure (Continued)
Provided Complete Not
MiMbers information RegutreMent Reg. Cite (Y/M) (ir/M) Applicable Location in Part B or BIK/Coaaent
I-J. Mr
I-Js Description of how the uslts* location affect*
the potential for and possible Multitude of
husan eipoaure fro* releases to the air. 270.10(j) .
1-36 Description of the design ana operating
features that affect the potential for
releases to the air and the
Magnitude of these releases. 270.10()I
I-Jc Description of wastes indicative of air
rslsases and aaoagestent of these waates. 270.101))
l-Jc(l) Description of any waste characteristics
(e.g., incoapatlblllty, reactivity, Ignita-
bllity, volatility) indicative of potential
for releases to the air. 270.10IJ)
I-Jc(2) Description of speclsl handling, treatment,
or eiiiing procedures used to prevent violent
reactions, fires, explosions, or extensive
evaporation of volatile constituents. 270.101))
1-4. Subsurface Cas Releases
I-«a Description of bow the'units' location affects
the potential for and possible Magnitude of
huaan exposure frosi subsurface gas releases. 270.10())
I-46 Description of the design and operating
featurea that affect the potential for
subsurface gas releases and the
Magnitude of these releases 270.10())
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II - u
UPOSURg IHPORmTlOM BEPORT (BIB) REQUIREMENT CHECKLIST
I. Potential for Hu»an Biposure (Continued)
Provided Complete Not
Number* Information Requirement Reg. Cite Clf/ll) (f/Ht Applicable location In Pact B or tin/Comment
1-5. Release* to Soil
1-5* Description of how th* unit*' location affect*
the potential for and po*«lble Magnitude of '.
human eiposure fro* release* to aoll. 270.101)1
I-5b Description of the design and operating
feature* that affect th* potential for
releaaea to *oll and th* Magnitude of
the** releaae*. 270.10(J)
I-t. Ttan*portatlon-Rel*t«d »*l*a*e*
I-6a Description of how Method* and rout** of
transportation of wa*t* on-*lt* and In th*
iMwdiat* vicinity of the facility affect
the potential for hu«*n eipoaure fro*
transportation-related releases. 27U.10()>
1-7. Horfcer-IUnsqeaent Practice*
I-7a Analysis of worker data and discussion of the
potential for off-alt* Migration and public
eipoaure resulting fro* any release*
related to worker-*anage*ent practice*. 27U.10())
I-7b Description of training prograa* In place for
th* worker* to ensure the safe handling of
wastes and Minlals* the potential for
release* fro* normal operation of the unit*. 270.101)1
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Attachment III. Levels of ATSDR Assistance*
1. Health Consultation; Immediate or-short-term consultation
by ATSDR to provide health advice and/or health effects
information regarding a specific site.
2. Health Assessment; Initial multi-disciplinary reviews by
ATSDR of all readily available data to evaluate the nature
and magnitude of any threat to human health at a site.
These evaluations will adapt EPA's risk assessment for the
characterization of potential health threats at a site or sites,
and may include literature searches, information summarization,
and evaluation of existing environmental data, pilot samples,
testing for food chain contamination, and similar activities.
3. Pilot Study; A preliminary or short-term medical, laboratory,
or epidemiologic study on a limited human population to
decide if additional, large-scale studies are warranted. The
study populations can include those living at, or near, a
site and those not residing at, or near, a site (control
or reference population).
4. Epidemiologic Study; Long-term study by ATSDR involving a
comprehensive protocol designed to add knowledge of the
health effects of a specific substance or substances at a
site or sites.
5. Health Registry; A site-specific or adverse health effects-
specific registry established and maintained to track
specific diseases and illnesses and long-term health effects
to persons exposed to toxic substances.
* These levels of assistance are taken from the EPA/ATSDR
MOU for CERCLA; definitions of these ATSDR activities may
change in the EPA/ATSDR MOU for RCRA.
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