v>EPA
           United States
           Environmental Protection
           Agency
          Office of Solid Waste
          and Emergency Response
          Washington DC 20460
EPA/530-SW-84-015
December 1984
           Solid Waste
Draft

Permit Guidance Manual  on
Hazardous Waste
Land Treatment
Demonstrations
           For Public Comment

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                              DISCLAIMER

     This is a draft manual  that is being  released by EPA for  public
comment  on  the accuracy and  usefulness of the information it contains.
Since the Agency's peer  and  administrative review of this document has not
yet been  completed, it does  not necessarily reflect the  views and policies
of the Agency.  Mention  of trade names or commercial  products does not
constitute endorsement or recommendation for use.
                                  ii

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                                PREFACE

     Subtitle C of the Resource Conservation and Recovery Act (RCRA) re-
quires the Environmental  Protection Agency (EPA) to establish a Federal
hazardous  waste  management program.   This program must  ensure  that  hazar-
dous wastes are  handled  safely from generation to final disposition.  EPA
issued a series of hazardous waste  regul ations under Subtitle C  of RCRA,
published in  40 Code of Federal Regulations (CFR) Parts  260 through  265,
270 and 124.      	

     Part  264  and 265 of 40 CFR contain standards applicable to owners and
operators of all facilities  that treat, store, or dispose of hazardous
wastes.  Wastes  are identified or  listed as  hazardous under  40  CRF Part
261.  The Part 264 standards are implemented through permits issued by
authorized States or the EPA in accordance with 40 CFR Part 124  and Part
270 regulations.  Land treatment,  storage,  and disposal  (LTSD)  regulations
in 40 CFR  Part 264 issued on July  26, 1982, establish  performance standards
for hazardous waste landfills, surface impoundments,  land treatment units,
and waste  piles.

     This  draft manual provides guidance  on treatment  demonstrations, which
are required under §264.272 for all owners/operators of hazardous waste
land treatment units.  The manual  delineates specific laboratory and field
test methods  that may be used to complete  the demonstration and  describes
the applicability of alternative  technical  approaches to and permitting
procedures (e.g.,  short-term permits, two-phase permits,  etc.)  for  various
situations.  The  manual addresses numerous technical  and policy  questions
regarding  the  overall  approach to the  demonstration,  the extensiveness of
the demonstration, and the permitting of land treatment units to  accom-
modate the treatment demonstration.

     This manual and other EPA guidance documents do not supersede the
regul ations promul gated under RCRA and  publ ished  in the Code of Federal
Regulations.   Instead, they provide  guidance, interpretations, suggestions,
and references to additional  information.  This guidance is not  intended to
suggest that other designs  might not also satisfy the  regulatory standards.

     EPA intends to revise this manual as  soon as possible based on com-
ments received.  Comments on  this  manual should be addressed to  Docket
Clerk, Office of Solid Waste (WH-562), U. S. EPA, 401 M Street SW, Wash-
ington, DC  20460.   Because this draft manual was developed before the
passage of the RCRA amendments  of 1984, certain aspects of the document may
be modified once  EPA implements this legislation.
                                  m

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                            EXECUTIVE SUMMARY

     Successful performance of the  land  treatment demonstration (LTD)  is
the key step  in obtaining a final  permit under 40 CFR Parts 264 and 270 for
a hazardous waste land treatment unit.   In consideration of the complexity
of the demonstration requirements,  this  document was prepared both to  give
the applicant guidance on the  preliminary information needed and to help  in
choosing and  implementing an LTD  approach.

     Permit options for land treatment differ from those of other  land
disposal  technologies.   The  LTD,  much  like  the trial  burn  for
incinerators, requires permit alternatives to allow  for trial  performance.
Thus,  the alternatives are the short-term  treatment demonstration permit,
the two phase permit, and the full scale facility permit.  The  applicable
permit alternative depends  on a number of factors,  including but not
limited to 1) whether the unit is  new or existing,  2) the condition of  site
records,  3)  past,  present, and planned operations, 4) data from waste
analyses and p«"el iminary site investigations.


     While much of  the information preliminary to the LTD  should have  been
supplied via  other permit application  requirements,  this document
nevertheless provides supplementary guidance on some aspects of these
application requirements.  Of  particular importance  for existing units  is
guidance on reconnaissance-level  soil sampling and  analysis.   Data  from
this investigation  play  a key role in formulating  the permit and treatment
demonstration approach by  generally  defining  the  spatial  distribution  of
hazardous constituents across  the  HWLT unit.

     The logic and  flow of decision-making in choosing the permit approach
and the technical elements  to  be  performed  in the  LTD  involve answering a
series of questions.  In brief, the  questions ask 1) whether the unit  is
new or existing, 2) whether major  design and operation changes are planned,
3) whether the unit is  operating effectively to  treat  wastes, and  4)
whether  the  operator  has adequate documentation of past activities.  The
answers to these questions and,  to  some extent,  the judgement or preference
of  the applicant  and  the permit writer determine  which  of four LTD
scenarios will be employed.

     Technical methods for performing each step of  the LTD are presented  in
the latter chapters.  By  first choosing  the LTD permit scenario the appli-
cant defines  the technical elements to be carried out and may then assemble
a treatment demonstration plan using  the chapters that describe these
technical elements.  Test methods include  intensive site  sampling and
                                  iv

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                      EXECUTIVE SUMMARY -  Continued

analysis,  acute toxicity testing,  barrel lysimeter and field plot  studies,
and follow-up,  full scale field  monitoring;  these methods  are not neces-
sarily listed In order of performance nor are they  all  required in any
given case.  In addition to  the above information, this manual provides
guidance on how to analyze samples, interpret data, and draw  design conclu-
sions.

     Finally, appendices cover numerous  soil analytical  procedures and
methods for collection and installation of barrel lysimeters  and answer
some commonly asked questions about land treatment.

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                             TABLE OF CONTENTS

                                                                     Page

DISCLAIMER	     11

PREFACE	    111

EXECUTIVE SUMMARY	     1v

LIST OF FIGURES	      x

LIST OF TABLES	     xi

LIST OF ABBREVIATIONS	    xii

ACKNOWLEDGMENTS	xiii

1.0  BACKGROUND AND GENERAL INFORMATION	      1

     1.1  Introduction 	      1
     1.2  Overview of Manual 	      2
     1.3  Approaches to the LTD	      3
          1.3.1  Administrative Approaches 	      5
          1.3.2  Technical Approaches	      8
     1.4  Other Sources of Information 	     10

2.0  PRELIMINARY INFORMATION NEEDS 	     11

     2.1  Soil Characterization	     11
          2.1.1  Soil Survey	     12
                 2.1.1.1  Conducting the Soil  Survey 	     12
                 2.1.1.2  Analysis of Samples Obtained in the Soil
                          Survey	     13
                          2.1.1.2.1  Soil  Physical  Properties. .  .     13
                          2.1.1.2.2  Soil  Chemical  Properties. .  .     13
                          2.1.1.2.3  Soil  Biological Properties.  .     14
          2.1.2  Reconnaissance Characterization of Waste Con-
                 stituent Distribution in Soil	     14
                 2.1.2.1  Soil  Cores	     14
                          2.1.2.1.1  Depth 	     15
                          2.1.2.1.2  Areal Distribution	     15
                          2.1.2.1.3  Number of Samples 	     15

                               —continued—

                                    vi

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                       TABLE OF CONTENTS - Continued

                                                                     Page
                 2.1.2.1   Soil  Cores - Continued
                          2.1.2.1.4  Analysis of Soil  Core Samples    15
                          2.1.2.1.5  Interpretation of Soil  Core
                                     Sample Data	    17
                 2.1.2.2   Soil-Pore Liquid 	    17
     2.2  Waste Characterization 	    18
          2.2.1  Sampling	    19
          2.2.2  Sample Collection 	    19
          2.2.3  Sample Handling and Storage 	    20
          2.2.4  Sample Analysis	    20
          2.2.5  Appendix VIII  Constituents	    21

3.0  TREATMENT DEMONSTRATION SCENARIOS AND DECISION-MAKING ....    26

     3.1  Criteria for Choosing a Land Treatment Demonstration
          Scenario	•    26
          3.1.1  Are Major Design and Operation Changes Planned? .    28
                 3.1.1.1   Planned Unit Processes 	    28
                 3.1.1.2   Planned Waste Application Rates	    29
                 3.1.1.3   Planned Use of Soils	    29
                 3.1.1.4   Guidance on Planned Design and Operation    30
          3.1.2  Is the Performance of the Existing HWLT Unit
                 Acceptable?	    31
                 3.1.2.1   Monitoring System Design 	    31
                 3.1.2.2   Performance Evaluation 	    32
          3.1.3  Are the  Waste  Management Records Complete?.  ...    32
     3.2  Treatment Demonstration Permitting Scenarios 	    33
          3.2.1  Scenario 1	    35
          3.2.2  Scenario 2	    37
          3.2.3  Scenario 3	    38
          3.2.4  Scenario 4	    39

4.0  INTENSIVE SITE DATA  COLLECTION	    40

     4.1  Soil Core Sampling and Analysis	    40
     4.2  Soil-Pore Liquid 	    40
     4.3  Analysis of Samples	    41
     4.4  Interpretation  of Data 	    41

5.0  TOXICITY TEST PROCEDURE	    43

     5.1  Test System Description	    44

                               —continued--
                                    vii

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                       TABLE OF CONTENTS - Continued

     5.2  General Experimental  Procedures	
          5.2.1  Water Soluble Fractions 	     ^
          5.2.2  Test System Operation	     j5
     5.3  Toxicity Test Applications and Procedures	     46
          5.3.1  Application Rate Determination	     46
          5.3.2  Maximum Residual Concentration	     4#
     5.4  Data Interpretations	     49
     5.5  Maximum Acceptable Initial Loading Rate	     50
          5.5.1  MAIL Rate Window Determination	     50

6.0  BARREL LYSIMETER STUDY	     52

     6.1  Experimental Design	     52
          6.1.1  Collection and Installation of Lysimeters ....     53
          6.1.2  Preparation of Lysimeters for Study 	     55
     6.2  Experimental Methods 	     55
          6.2.1  Waste Application 	     55
          6.2.2  Water Management	     55
          6.2.3  Soil Sample Collection and Analysis 	     56
          6.2.4  Soil-pore Liquid Sample Collection and Analysis .     57
     6.3  Data Reduction and Interpretation	     57
          6.3.1  Degradation Rate and Half-Life Determination.  . .     57
          6.3.2  Immobilization	     58

7.0  FIELD PLOT STUDY	     60

     7.1  Experimental Design	     60
          7.1.1  Plot Preparaton	     62
                 7.1.1.1  Size	     62
                 7.1.1.2  Slope	     62
                 7.1.1.3  Plot Isolation 	     62
                 7.1.1.4  Run-off Collection 	     62
          7.1.2  Number, Location, and Installation of Soil-Pore
                 Liquid Samplers 	     63
     7.2  Experimental Methods 	     63
          7.2.1  Waste Application 	     63
          7.2.2  Plot Management	     69
          7.2.3  Sample Collection and Analysis	     69
          7.2.4  Soil-Pore Liquid Sample Collection and Analysis .     70
     7.3  Data Reduction and Interpretation	     70
          7.3.1  Degradation Rate and Half Life Determination.  . .     70
          7.3.2  Immobi 1 i zati on	     72

8.0  DATA INTERPRETATIONS	     73

     8.1  Waste Application Limit	     73
     8.2  Annual  Waste Loading Rate	     73

                               —continued--

                                  vi i i

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                       TABLE OF CONTENTS - Continued

                                                                     Page

     8.3  Required Unit Area 	    75
     8.4  Unit Life	    76

9.0  TWO YEAR FOLLOW-UP STUDY	     79

     9.1  Soil Core Samples	     79
     9.2  Soil-Pore Liquid Monitoring 	     80
     9.3  Soil Core and Soil-Pore Liquid Sample Analysis	     80
     9.4  Interpretation	     80

10.0 TIERED SAMPLE ANALYSIS 	     81
     10.1 Tier 1	     81
     10.2 Tier II	     81
     10.3 Tier III	     82
     10.4 Quality Assurance/Quality Control 	     83

APPENDIX A   SOIL SAMPLING AND ANALYSIS

     A.I  Soil Sampling	     85
     A.2  Analytical Methods for Soils	     90
          A.2.1  Physical  Methods	     90
                 A.2.1.1  Particle Size Analysis	     90
                 A.2.1.2  Bulk Density	     92
                 A.2.1.3  Moisture Retention	     94
          A.2.2  Soil Chemical Methods	     98
                 A.2.2.1  Paste pH	     98
                 A.2.2.2  Lime Requirements by SMP Buffer ....    100
                 A.2.2.3  Double Acid Extractable Phosphorus, Pot-
                          assium, Calcium, and Magnesium	    102
                 A.2.2.4  Total Nitrogen by Kjeldahl Method ...    108
                 A.2.2.5  Sodium Saturated Cation Exchange
                          Capacity	    Ill
                 A.2.2.6  Electrical Conductance of Soil Extract.    114
                 A.2.2.7  Organic Carbon by Low Temperature
                          Ignition	    117

APPENDIX 8  DETAILED PROCEDURE FOR COLLECTING BARREL SIZED UN-
            DISTURBED

     B.I  Scope and Applicaton	    119
     B.2  Lysimeter Installation	    119

APPENDIX C  QUESTIONS AND ANSWERS 	    123
                                    IX

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                              LIST OF FIGURES
Number                                                               Page
 1.1  Treatment demonstration decision flow chart 	       4a
 3.1  Treatment demonstration decision flow chart 	      27a
 7.1  Porous cup soil-pore liquid sampler and pressure vacuum
      pump used to collect sample	      64
 7.2  Glass brick soil pore liquid sampler (pore type). ......      65
 7.3  Soil-pore liquid sample locations 	      66
 7.4  Installation of samplers in pits	  .      67
 7.5  Soil-pore liquid sampling station 	      68
 B.I  Support frame design for barrel lysimeter collection.  .  .  .     120
 B.2  Lifting harness for removing and rotating barrel  lysimeter.     122

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                              LIST OF TABLES

Number

 1.1    Land Treatment Permit Elements	       6
 1.2    Permit Application Content for Each Permit Element.  ...       7
 1.3    Selected References on Land Treatment 	      10

 2.1    Physical and Chemical Anaylsis of Wastes	      21
 2.2    Hazardous Constituents Suspected to be Present in
        Refinery Wastes 	      23

 3.1    Planned Operations Information Needs	      30
 3.2    Criteria for Deciding the Completeness of Waste Management
        Data and Records	      34

 6.1    Waste Application Soil Sampling Schedule for Barrel
        Lysimeter Study	*	      54

 7.1    Waste Application Soil Sampling Schedule for Barrel
        Lysimeter Study	  .      61

 lO.f   Components of Analyitical Tiers Used in the Land Treat-
        ment Demonstration	      82

 A.I    Soil-SMP Buffer pH and Corresponding Lime Requirment
        to Bring Materials to pH 6.5	     102

 A.2    Phosphorus Standards	     105

 A.3    Calcium Standards	     107

 A.4    Magnesium Standards 	     107
                                    xi

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                          LIST OF ABBREVIATIONS
ALC      Application Limiting Constituent
CLC      Capacity Limiting Constituents
EPA      U. S. Environmental  Protection Agency
GRW      Groundwater Monitoring
HWLT     Hazardous Waste Land Treatment
ISS      Interim Status Standards
LTD      Land Treatment Demonstration
MAIL     Maximum Acceptable Initial Loading Rate
PAGM     Permit Applicants Guidance Manual
RCRA     Resource Conservation and Recovery Act
SCS      U. S. Soil Conservation Service
UZM      Unsaturated Zone Monitoring
WSF      Water Soluble Fraction
ZOI      Zone of Incorporation
                                   xii

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                            ACKNOWLEDGMENTS

     This document was prepared by Gordon B. Evans, Jr., William Hornby,
and K.C.  Donnelly  with  the firm  of  K.W.  Brown  &  Associates, Inc.  (6A
Graham Road,  College Station, Texas) under  subcontract to GCA Corporation
(Bedford, Massachusetts; EPA Contract No. 68-01-6871,  Work Assignment No.
14).

     The  authors wish to express their appreciation to  Michael P. Flynn,
EPA Project Officer,  whose  understanding of the technical and  regulatory
aspects of land treatment  technology enabled him to make significant  con-
tributions to the final  organization and content of this document.  Like-
wise, we wish to acknowledge the contribution of John  Matthews of EPA's
Robert S.  Kerr Laboratory,  who drafted one of the foundation documents  used
as a  resource in preparation of this document and provided invaluable imput
into  the  toxicity testing  protocol.  We would  also  like to  thank Charles
Young, who served as GCA Work Assignment Manager, for his assistance and
good  demeanor through the many iterations  in the drafting of the document.
Special praises  also go to Beth D. Frentrup and Debra Hower for hours of
capable  editorial  labors under the  pressure of deadlines and to  Beth
Rutkowski  for her patient and accurate  typing of the  document.
                                 xi i i

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                                Chapter 1

                   BACKGROUND AND GENERAL  INFORMATION
1.1  INTRODUCTION
     Under the Authority of Subtitle C of  the Resource Conservation and
Recovery Act (RCRA),  EPA promulgated regulations  for the treatment,  stor-
age,  and disposal  of hazardous waste in land treatment units  (40 CFR 264).
These regulations  require a  permit  for the  operation  of a hazardous  waste
land treatment (HWLT) unit.   Section 264.272  stipulates  that the first step
in obtaining such  a permit is to complete  a land treatment demonstration
(LTD).

     The land treatment demonstration is used by  the permitting authority
to define two elements of the land treatment program.  First,  the demon-
stration establishes what wastes may be managed at the unit.   Wastes that
will be applied must be subject to degradation,  transformation, and/or
immobilization processes in  the soil  such that hazardous constituents are
not expected to  emerge from the defined treatment  zone.  Second,  results  of
the treatment demonstration will be  used to define the  initial set of waste
management practices,  including loading rates,  that will  be incorporated
into the facility  permit.

     The treatment demonstration can be completed  using  information derived
from published literature, laboratory studies, field studies, and/or  actual
facility operating experience.   However,  the Agency generally believes that
an inadequate data base exists  in the published literature to predict unit-
specific waste-soil  interactions.  Consequently, most land treatment  permit
applicants must use laboratory  studies, field studies,  actual facility
operating experience,  or a combination  of these approaches to complete the
treatment demonstration.

     The purpose of this manual  is  to  provide guidance on specific labora-
tory and field test methods that may  be used to complete the treatment
demonstration as required under §264.272 for all   owners  and  operators  of
hazardous waste land treatment units.   The  manual  also addresses  numerous
questions  on policy and technical  aspects of the demonstration and de-
scribes alternative  permitting approaches and  their applicability  to
various facility "scenarios".

     In this manual,  which is designed to  encourage an information and
decision-making  flow,  care is taken to maintain a logical progression from
the beginning to  the end of  the  treatment demonstration.  Two primary
tenets  used to select tests for the  experimental   portion of  the  protocol
are:

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     1)   avoidance of unnecessary test redundancy  (e.g.,  It is un-
         necessary to determine degradation rates by both soil res-
         pi rometry and bench scale degradation experiments);  and

     2)   performance of only those tests  that yield definitive infor-
         mation  leading to  clear  decisions on issues  pertinent to the
         LTD  (§264.272) (i.e.,  treatability,  waste loading rates, and
         monitoring parameters).

     This manual  clarifies  and elaborates on the general  guidance on treat-
ment demonstrations already provided in the following documents:

     o  Permit Applicants' Guidance  Manual for Hazardous  Waste Land
        Treatment, Storage,  and  Disposal Facilities (EPA,  1984A);

     o  Hazardous Waste Land Treatment  (SW-874); EPA,  1983);  and

     o   RCRA Guidance Document:  Land Treatment Units  (Draft, EPA,
         1983B).

     EPA wishes  to  emphasize that the methods  described  in this manual are
guidance,  not regulations;  an applicant  may use alternative methods,
provided that these methods are equivalent to or more comprehensive than
those described  herein.  While the Agency believes that  the  specifications
provided for each of the described test  methods  are  a reasonable estimate
for a complete treatment demonstration  in  compliance with §264.272, the
permit writer may modify  these  specifications as  necessary.
1.2  OVERVIEW OF MANUAL

     The planning  of a treatment demonstration involves  a decision-making
process  in which  various general technical  approaches  (e.g.,  operating
data,  lab  tests,  field  tests)  are  evaluated, and  in which  regulatory,
technical,  administrative, and practical constraints  are  considered.  Once
the general  technical approach is  determined, the appropriate  permitting
procedure (e.g., short-term permit,  two-phase permit) is selected in con-
sultation with the  permitting authority.   Finally, detailed  experimental
methods must  be developed and the test completed.

     This manual  is organized to assist the permit applicant in planning
and implementing  a  treatment demonstration in compliance with §264.272.
Thus, the manual focuses on the decision-making  process (illustrated in
Figure 1.1) and emphasizes a  logical  flow for the treatment demonstration,
beginning with site  and waste characterization and ending  with  submittal of
the demonstration  results.

     Section  1.3 of  this chapter, a brief  description of the general tech-
nical  and administrative  approaches to the demonstration,   lays the  founda-
tion for a more detailed discussion in Chapter  3 of various permitting
"scenarios"  which  incorporate  certain  technical  and   administrative

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approaches.

     Chapter  2 describes the preliminary waste and site information  (much
of which should already  have been generated to meet the permit  application
requirements  of 40  CFR Part  270) that is necessary in selecting the appro-
priate treatment demonstration "scenario" and details preliminary data
needs in the  following categories:

     1)   waste characterization,  both general and specific to  the
         batches  of waste to be used in  the LTD; and

     2)   soil characterization, including a) a soil survey and chemical and
         physical analyses and b) for existing  sites,  reconnaissance-level
         sampling of  the entire soil profile from  the  surface to six meters
         (or  the  water table) and analysis to determine if degradation and
         immobilization  have been occurring effectively.

     Once the preliminary information  has been collected, the applicant
begins  the decision-making process  in  coordination with the  permitting
authority; the elements of  this process are described in Chapter 3.  The
specific LTD approach  subsequently adopted by  the  applicant will be a
function of  1)  how the  facility conditions and records fit the possible
permitting scenarios;  and  2)  the applicant's  preference among  the various
technical options within each  scenario.

     Chapters 4 through  9 describe how to execute  the  various components of
the technical  approaches and outline not only experimental methods, but
analysis and evaluation of the results as well.  For example, as Figure 1.1
notes, the toxicity test is  described in Chapter 5.

     Chapter 10 describes  a  tiered  sample analysis scheme.   The  objective
of this scheme is to  minimize analytical costs during the  demonstration by
providing for  three  levels  of analysis depending on  the particular data
needs.  The  scheme also specifies the minimum data requirements for each
tier.

     Appendix A describes  analytical  methods  for  the  chemical  analysis of
soil  (discussed  in Chapter  2).   Appendix B details  installation methods
for  barrel  lysimeters.  Appendix C provides guidance  on  frequently  asked
questions on policy and  technical aspects of the treatment demonstration.


1.3  APPROACHES TO  THE LTD

     The decision-making flow chart (Figure  1.1) described in Section 1.2
leads to four possible permitting scenarios which  incorporate various
administrative permitting  procedures and technical approaches.  These ele-
ments are briefly introduced below.

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                                d
                                  PRELIMINARY
                                  INFORMATION
                                    NEEDS
SELECTION AND
DESCRIPTION OF
TREATMENT
DEMONSTRATION
SCENARIOS
                   DESIGN
                  NO OPERA
                   CHANGES
                      NNE
    FIG. I.I.  TREATMENT  DEMONSTRATION  DECISION FLOW  CHART.

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           r
   r
       SCENARIO I
SCENARIO 2
                                          SCENARIO 3
                       SCENARIO 4

ALTERNATIVE /

INTENSIVE
SITE DATA
COLLECTION



X^
1PPROACH

ISSUED PHASE 1
OF A TWO
PHASE PERMIT
A

	 7
s

LEFT UNDER
INTERIM
STATUS
STANDARDS
TEMPORARILY


SH
Tl
OEM
PEF
                                                           SHORT TERM
                                                           TREATMENT
                                                           IMONSTRATON
                                                          PERMIT ISSUED
                                          TOXICITY
                                            TEST
                   BARREL
                   LrSIMETER
                    STUDY
                         TOXICITY
                          TEST
                         FIELD
                         PLOT
                        STUDY
LYSIMETER
 STUDY
                                          TOXICITY
                                           TEST
                              BARREL
                             LYSIMETER
                              STUDY
                                        PERMIT ISSUED
                                                            TOXICITY
                                                             TEST
                                         TWO YEAR
                                         FOLLOW-UP
                                           STUDY
                                  TWO YEAR
                                  FOLLOW- UP
                                   STUDY
FIG.  |.l.  TREATMENT  DEMONSTRATION  DECISION  FLOW CHART. (CONTINUED)

               (NUMBERS  IN BOXES REFER TO CHAPTERS)
                                  4b

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1.3.1   Administrative Approaches

     Land treatment differs from other hazardous waste management technolo-
gies in that,  among other things, all  land treatment units are  required to
complete a treatment  demonstration prior to obtaining a full-scale permit.
If, as the regulations allow, the applicant intends to use field or  labora-
tory tests to make the LTD, these tests, which involve the treatment and
disposal of hazardous waste, can only be performed under a permit.   Special
administrative procedures  allow  applicants to  choose  one  of three permit
approaches,  depending upon their circumstances:

     1)  an  immediate full-scale facility permit;

     2)  a short-term treatment demonstration permit followed by a
         full-scale facility permit;  or

     3)  a two-phase permit.

Short-term and two-phase permits  are  described in 40 CFR 270.63. Table  1.1
outlines  the essential  elements of these  permit approaches, and Table  1.2
briefly covers the content of applications for  each of these types of
permits.

     The  full-scale facility permit  is the "normal" permit used when com-
plete data  is available to satisfy the treatment demonstration.  In the
application for a full-scale  facility permit,  the  applicant submits both
the treatment demonstration plan  and  its results and the other  information
described in Table 1.2.

     The  short-term treatment demonstration permit,  which authorizes small-
scale  laboratory or field  tests, contains only provisions necessary to meet
the  general  performance standards  in §264.272(c) (See Table 1.2).   An
applicant should apply for this permit when  insufficient treatment  informa-
tion  exists to 1) fully satisfy the  treatment demonstration for a full-
scale  permit, or 2)  establish preliminary  permit conditions for the full-
scale  facility  in  a  two-phase  permit.  Normal  permitting  procedures,  in-
cluding public comment and hearing, must be followed.  After  the lab or
field tests are complete, the  applicant must apply for a full-scale
facility  permit.

     The  two-phase permit is a combination of the short-term  permit and
full-scale  facility permit;  Phase I  of the permit includes conditions for
the treatment demonstration, and  Phase 2 includes provisions for the full-
scale facility design and operation.  This permit should be  used in the
following circumstances: when substantial  but incomplete treatment data
exist  to  satisfy the  treatment  demonstration,  and when sufficient  data are
available to determine the preliminary set of full-scale facility

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Table 1.1.  Land Treatment Permit Elements
Full-Scale Facility Permit

-  Used when complete data have  been collected to satisfy the treatment
   demonstration  requirement  (i.e.,  using  available  literature  data,
   operating data, and/or lab or field test results).

-  Must contain provisions  necessary to meet all  the Subpart  M, Part 264
   requirements and all  other applicable Part 264  standards.

-  Requires public comment and hearing.

Short-Tern Treatment Demonstration Permit

-  involves smai I-scale lab or field experiment to demonstrate  that hazar-
   dous constituents in waste can be treated  in the land treatment unit.

-  Used when insufficient "treatment"  information  exists to  satisfy treat-
   ment demonstration requirement for full-scale facility permits or to
   establish preliminary Phase 2 (full-scale) conditions for two-phase
   permit.

-  Must contain only provisions necessary  to meet the general   performance
   standards in §264.272(c).

-  Requires public comment and hearing.

Two-Phase Permit

-  Combination of  above two permits when Phase   1  is  for the treatment
   demonstration and  Phase 2 is  for the full-scale facility design and
   operation.

-  Used when substantial  but  incomplete  "treatment" data exists and when
   sufficient data are not available to completely satisfy treatment demon-
   stration  but are avai 1 abl e to determine  the prel iminary set of ful 1 -
   scale facility permit conditions.

-  Used when Phase  1  and 2  permits are based  on substantial  but incomplete
   information; Phase 2 permit is modified to  the incorporate results of
   Phase 1.

-  Avoids  the  burden of two separate  permitting procedures  (e.g., only one
   public comment and hearing is necessary rather  than two).

-  Contains provisions  necessary  to meet treatment demonstration  (Phase 1);
   contains provisions to meet all applicable Part 264 standards (Phase 2).

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Table 1.2 Permit Application Content for Each  Permit Element
Full-Scale Facility Permit

-  Information addressing the general  standards applicable to all  facili-
   ties - §270.14, "General  Information Requirements"  (see Permit Appli-
   cant's Guidance Manual for General Facility Standards).

-  Information requirements of  §270.20 addressing the Subpart M,  Part  264
   requirements

   — Treatment Demonstration Plan and Results
   — Land Treatment  Program
   — Design and Operating  Requirements
   — Food Chain Crops
   -- Closure and Post-Closure Care
   — Ignitable and Reactive Waste
   -- Incompatible Wastes

-  Information addressing the groundwater protection  requirements  in
   Subpart F, Part 264.


Short-Term Treatment  Demonstration Permit

-  Treatment demonstration plan  including  provisions  to meet the
   §264.272(c) performance  standard.

-  Results  submitted to the Regional Administrator at  end of study and  as
   part of full-scale facility permit application.

Two-Phase Permit

-  Same as full-scale facility  permit except that the results of the treat-
   ment demonstration are  submitted  after completion (Phase 1).
conditions.   For the two phase  permit, the applicant submits the same
information as for the full-scale facility  permit, except that the  results
of the treatment demonstration  (Phase  1) are submitted at a later date.
Thus, the permitting official  first writes a draft permit for Phases  1  and
2 and then,  after  the  treatment demonstration results are submitted,

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modifies the  Phase 2 Permit.   The  primary advantage of the two-phase permit
is that it eliminates the need for two separate permitting  procedures, one
for the treatment demonstration and one for the full-scale facility permit.

     For existing land treatment units with interim status, a final ap-
proach for completing treatment demonstration field tests under a permit is
available.   Because permittees'  interim status facilities are  "treated as
though  they  have been issued permits" (while awaiting completion of the
Part 264 permitting process), field tests on hazardous wastes currently
handl ed at the faci 1 i ty may  be conducted at these uni ts.  However, these
tests must not be carried out in a manner that will lead to a to violation
of the  Part  265  interim status  standards.   If the tests are  likely to
violate  the  interim status standards,  one of  the  special  permits  described
above (short-term or  two-phase) must be  obtained.

     In summary, an applicant who can complete the treatment  demonstration
based on available  literature data or operating data  from an existing
interim status 1 and  treatment unit may  apply directly for a ful 1 -seal e
facility permit.  An  applicant who must use laboratory or field  studies to
complete  the  treatment demonstration,  however,  has  two options  depending
upon the amount of data al ready avai 1 abl e.   He may  1) apply for a short-
term treatment demonstration permit and then  a full-scale facility  permit;
or 2) apply  for a two-phase  permit.  In addition,  field studies in com-
pliance with the  Part 265  standards may be completed  at  an interim-status
land treatment unit.

     The four permitting  scenarios briefly described in Section 1.2 incor-
porate one or more of these administrative  approaches.  However,  the choice
of which permitting scenario  to use depends on a relatively complex set of
criteria which, along with  the practical implementation of  the chosen
permitting scenarios, is the  subject of  Chapter 3.

1.3.2  Technical Approaches

     While three  general  technical  approaches  to  performing a land treat-
ment demonstration  are  explained  in  this  document,  the approach which is
chosen  and how it fits into  the  various permitting scenarios will  vary
depending upon the  applicant's circumstances  (see Chapter  3).  These  tech-
nical approaches are as follows:

     1)   Use  of  existing  operating data,  supplemented with intensive
         site data collection.

     2)   A one year field plot or "barrel  lysimeter"  study, followed
         by a short-term laboratory toxicity  test.

     3)   A short-term laboratory  toxicity test with  a  one year  field
         plot or "barrel lysimeter" study,  followed  by the  laboratory
         toxicity and a two-year follow-up field  study.

     Although the Part 264 regulations allow  the use of existing  literature
data to complete the demonstration, this approach is not considered as a

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viable option at  this  time  because  of  the  lack of detailed site-specific
data available in literature.  To be useful,  literature data must have been
generated under  conditions similar to those at the proposed unit and must
include information on the fate of specific hazardous constituents  (i.e.,
Appendix VIII compounds) present in the waste.   Although it may assist in
the design of laboratory and field tests, literature data alone rarely
satisfies the treatment demonstration fully.    In  the  future  as the data
base improves, literature  data may be more useful.

     The first  technical approach, the use of existing operating data
supplemented with intensive  site data collection,  is  the most straightfor-
ward and economical  method  for  the  demonstration.   Further,  comprehensive
field  data from the operational  HWLT unit is considered to be the best
approximation of reality (i.e.,  the best demonstration of  treatment).   This
approach consists of both  tabulation and evaluation of existing operating
data and high density soil  core sampling and analysis from the surface to
six meters (about 20 ft) to  confirm treatment of hazardous constituents.
The use  of   waste analysis  data and past records in conjunction with soil
core data should demonstrate that degradation  of organics has  been  occur-
ring with no unacceptable leaching  or  build-up  of  hazardous constituents.
The major limitations of this method, which may be used in select cases and
only for existing units,  are the requirements  for  several years of operat-
ing data and records and  relatively consistent  past  and projected  opera-
tions.   Criteria for deciding  if an  HWLT  unit qualifies for this technical
approach are discussed  in Section 3.1.

     Except  for those  well run and documented existing HWLT  units that
qualify for the  above approach, all  new or existing  units must adopt one of
the other two technical  approaches; the criteria  for determining which HWLT
units  qualify for these approaches are  also  discussed in  Section  3.1.  The
second general   approach consists  of  a one year  field plot  study or a
"barrel  lysimeter"  study.   Technically,  since  these  two  options  are
parallel  in design and in the information obtained,  the applicant may
select either option.   The field plot study, which  follows the  traditional
agricultural type study, involves several small scale plots, subject to the
variability  of  soils and  climate  and  to  concerns  such as  plot  fringe ef-
fects.   The  second option in the approach is the "barrel  lysimeter" study,
which is conducted on large undisturbed  soil monoliths or columns collected
(e.g.,  in 55  gallon  drums) from the field.  All  degradation, transforma-
tion,  and  immobilization testing takes  place in these barrel  sized  "lysi-
meters".   (NOTE:   In  this  document,  "lysimeter" refers to the  large  undis-
turbed soil  monoliths;   the  porous ceramic or pan devices used  to collect
soil-pore  liquid  are called "soil-pore  liquid  samplers".  This is consis-
tent with  the use of the  term "lysimeter" in  soil physics terminology.)
Field  plots  and, in most cases,  lysimeter studies must continue for no less
than one year.   Acute toxicity testing is then  used  as a  follow-up to help
set final waste  loading  rates.

     The third general  approach  includes a laboratory acute toxicity test,
followed by a one year  field plot or barrel  lysimeter  study,  a repeated
laboratory toxicity test,  and a two-year follow-up study.  This  approach,
using a short-term test to determine initial waste  application  limits for

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the demonstration,  is employed in instances where  little information exists
on the treatability of a waste (see Chapter 3).   After the one-year field
plot or barrel  lysimeter  study  has  been  conducted, further acute toxicity
testing to determine tentative design criteria leads  to  a  final  two-year
follow-up field study, usually on the full-scale operational  unit, to
confirm the findings of the laboratory and small  scale testing.

     The choice of  the specific technical approach and the particulars
involved are a function of many factors,  including the facility's operating
record under interim status regulations,  technical factors,  and,  to some
degree, applicant preference.   The criteria involved  and all  of the pos-
sible  LTD  permitting scenarios  (which incorporate both administrative and
technical  approaches) are  described  in Chapter 3.

     Chapter 2 specifies  the  preliminary  information  for the demonstration
that is necessary for all  applicants.  Chapter 3 then  assists the applicant
through the LTD decision-making  process.
1.4  OTHER SOURCES OF  INFORMATION

     Whenever possible,  this document avoids lengthy commentary and techni-
cal explanations and attempts  to provide  the applicant with a clear set of
usable instructions.  In some  sections, however, the reader is referred to
one or more of the available  treatises on land treatment (Table 1.3) for
additional explanation.


Table 1.3  Selected References on Land Treatment
Hazardous Waste Land Treatment                SW-874 (EPA,  1983) or
                                             Brown et al.,  1983

RCRA Part 264 Guidance  Document:              EPA,  Draft,  May,  1983B
Land Treatment

Permit Applicants' Guidance Manual            EPA,  1984B
for Hazardous Waste  Land Treatment,
Storage, and Disposal Facilities

Unsaturated Zone Monitoring for Haz-          EPA,  1984A
ardous Waste Land Treatment Units

Design of Land Treatment Systems for          Overcash and Pal, 1979
Industrial Wastes-Theory and Practice
                                    10

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                                Chapter 2

                      PRELIMINARY INFORMATION NEEDS
     Before the land treatment demonstration can begin on either an exist-
ing or a new treatment unit, detailed  information about the waste and site
must be generated.   This information should already have been gathered to
fulfill  the Part 270 requirements  for the Part B  permit application.   In
particular, an in-depth soil  characterization and mapping should have been
conducted.  Waste  analyses should have characterized the waste  streams
(both hazardous  and nonhazarous) to be  land treated and to be used in the
treatment demonstration.   For  existing units,  the  preliminary information
should  also include chemical  characterization of both the waste/soil  mix-
ture in the active  area  of  the unit and the soil below the  treatment zone.

     This chapter summarizes  the Part 270 data requirements  applicable to
treatment demonstration planning and  provides  additional  guidance to the
applicant where  necessary.   This discussion supplements  the guidance pro-
vided in the Permit  Applicants Guidance Manual  for  HWLTSD Facilities (PAGM)
(EPA, 1984A) with some  specifics on how to gather the information suggested
by the PAGM.
2.1  SOIL CHARACTERIZATION

     A basic understanding of the potential for successful degradation,
transformation,  or immobilization of a waste involves an understanding of
the site's physical, chemical, and biological  properties.  Much of this
information (e.g., hydrogeology,  topography,  and  climate) should  have al-
ready been determined  to fulfill the Part 270 information requirements for
Part B of the permit application.   Critical  to the  treatment demonstration
is a thorough understanding of the soil that will  be the treatment medium
for the waste.  Therefore, an in-depth study of the soil as outlined in
this section is necessary.

     Since soil  is  the  treatment medium for the HWLT, a thorough analysis
of the soil is necessary to develop a data base  for  any of the technical
approaches to the LTD  outlined in this  protocol.   This analysis will iden-
tify any limiting conditions that may restrict the use of the site as an
HWLT unit and will  provide an  indication of whether waste constituents are
building up to undesirable concentrations or  leaching out of the treatment
zone.  The major components of interest are the variations  in physical,
chemical, and biological properties of the soil   (EPA, 1982) and the area!
and vertical distribution of waste constituents in the soil.

     Information on  soils in the  treatment  zone is  an important element of


                                    11

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the Part 270 information  requirements  for HWLT units.  Section 270.20(a)(3)
requires that the  Part  B  permit application for land  treatment  units  out-
line the treatment demonstration plan.   This plan must provide, among other
things, a description  of the characteristics of the unit that will be
simulated in the  demonstration,  including treatment zone characteristics,
climatic conditions,  and  operating practices.   Also, §270.20(b)(5) requires
that the land treatment  program  identify the proposed dimensions of the
treatment zone.  Finally, §270.20(c) requires a description of  how the  unit
is or will  be designed,  constructed,  operated,  and maintained in order to
meet the requirements of  §264.273.   Guidance  on  these information require-
ments is provided  in Section  7.4.3.7 of the PAGM.   The following discussion
offers more  detailed guidance on the type of  soils information that should
be gathered.

2.1.1  Soil  Survey

     A soil  survey,  commonly done  for soil characterization, should already
have been conducted for the permit application according  to  PAGM guidance.
Many areas  have already been broadly surveyed by the Soil Conservation
Service (SCS).  If such  a  survey exists for a given site,  it  may be used as
a guide.  However,  an existing SCS survey, unless done specifically for the
site, cannot be used as a substitute for a detailed site-specific survey
and sampling program because  the  scale used  to  conduct the SCS  surveys is
too large, analyses are too few, and often they do not include all of the
pertinent parameters.   If an  acceptable  soil  survey conducted by  a quali-
fied soil scientist has not been done,  a soil  scientist should be retained
to conduct the soil  survey.

2.1.1.1  Conducting  the Soil  Survey--

     In a soil  survey,  the soil series present at a given site are identi-
fied and sampled.  Samples obtained for the soil  survey should  be  collected
at random at a rate of  at least four per acre for the HWLT site.   Sampling
depth will  vary depending upon the soils  present at the site.  Charac-
terization  of waste distribution in soils  requires a more detailed and
carefully controlled sampling program than  is needed for the soil survey
(Section  2.1.1).  Soil  series,  generally  varied from  one  location to
another,  are differentiated on the basis of both physical  and chemical
characteristics.  The soil survey  should  include soil profile  descriptions,
mineralogy, use and vegetation,  and estimated soil  properties:  perme-
ability,  flood frequency and duration, and frost action potential.  The
following information, which is  included in SCS surveys, should also be
included in surveys of  HWLT units:   1) estimates of credibility of the
soil, which are used to calculate terrace spacings and other  erosion  con-
trol structures, 2) information on  the depth  and  texture of surface hori-
zons and subsoils, which  is  used  to determine if  the  soil is  suitable for
contaminant attenuation and for constructing berms  and lined run-off  reten-
tion ponds,  and  3)  depths to seasonal  high water table and zones such  as  a
fragipans that limit vertical water movement.

     Surveying the soils  of a proposed or even an  existing site will  help
define "uniform  areas" of  the  treatment unit as well as identify any  poten-
                                    12

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tial  problem areas such as small  inclusions  of  sandy materials with high
permeability.   Uniform area is defined as  an area of the active portion of
a HWLT unit composed of  soils of the same soil series to which  similar
wastes are applied at  similar rates.  Two different soil  series may be
included in a  given  uniform area  if  a qualified soil scientist certifies
that the characteristics that differentiate the  soil  series will  not have
any affect on success of land treatment (see Question #11  in Appendix C).

     For new units,  the  soil  within the  confines  of  the proposed  land
treatment unit (i.e., within the  boundaries  defined by  the run-on/run-off
control structures)  should be  surveyed along with background soils (i.e.,
untreated soils outside the boundaries).   While  the  same process should be
followed for existing units,  difficulties are  often encountered as the
result of waste additions and drastic disturbances that may have signifi-
cantly altered active area soil  properties.   If a definable native soil
still  exists, the soil  survey  must emphasize deeper  sampling  and a greater
use of test pits to identify the soil  series present, their boundaries, and
their continuity with background areas.  In some  cases, no native soil  will
be present or identifiable.  Nevertheless, the soil  survey should be con-
ducted according to  the guidance in this manual  and  in the PAGM.  The soil
scientist should use this information  to assist the owner/operator in
determining "uniform areas."

2.1.1.2  Analysis  of  Samples Obtained  in the Soil Survey--

     Numerous  samples  should be obtained during the course of the  soil
survey.   Regardless  of whether these soil samples are background  or from
active areas,  a number of  analyses are needed  to characterize their chemi-
cal and physical properties.  The following sections list the  parameters of
concern,  and Appendix A  includes analytical procedures that may not be
widely employed by typical water,  waste,  and  sediment laboratories.  Such
methods are,  however, standard  soil  procedures used by soils laboratories
and are suggested to ensure  reliable results.   Initially, only enough
samples should be analyzed to determine  sample  variance.  If the variance
is large,  all  samples may need to be analyzed to establish the  spatial
variability of  the soils.

     2.1.1.2.1   Soil Physical  Properties—Soil  physical properties,  defined
as those  characteristics, processes,  or reactions of a soil caused by
physical  forces,  are described by physical terms or equations.  Measure-
ments of physical  properties should include  particle size distribution,
bulk density,  and moisture retention  (i.e., available water  capacity). For
an in-depth discussion  of these properties the  applicant  should  refer to
Hazardous Waste Land Treatment (EPA,  1983A).  Specific analytical proce-
dures  for measuring these parameters are listed in Appendix A  of this
protocol.

     2.1.1.2.2  Soil  Chemical  Properties—Chemical  reactions that occur
between waste constituents and the soil must  be considered in land treat-
ment demonstrations.  Large numbers of  complex chemical reactions and
transformations, including exchange reactions, sorption,  precipitation, and
complexing,  occur in the soil.  Understanding the fundamentals  of soil


                                    13

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chemistry and the soil  components that control these reactions makes it
possible to predict the fate of a particular waste  in the  soil.  Chemical
properties  that need to be evaluated  are  cation exchange  capacity,  total
organic carbon, nutrients (pertinent non hazardous  constituents that  may
affect  treatment),   electrical  conductivity, pH,  and  buffering capacity.
Each of these soil chemical parameters is discussed  in detail in EPA  (1983)
and in  Methods of Soil Analysis (Black, 1965).  Analytical  procedures  for
each of these parameters are included in Appendix A.

     2.1.1.2.3   Soil  Biological  Properties—The soil  provides a suitable
habitat for a diverse range of organisms that may help render a  waste less
hazardous.  The  types and numbers of  decomposer organisms present in a
waste-amended  soil  depend  on soil  moisture  content,  available  oxygen,  and
nutrient composition.

     Following the land application of a waste,  the population  establish-
ment of decomposer organisms  begins  with  bacteria,  actinomycetes,  fungi,
and algae (Dindal,  1978),  organisms which have diverse enzymatic capabili-
ties and can withstand extremes  in environmental conditions.  While  enum-
eration of species and numbers of microbes is not  necessary in  site  char-
acterization,  a recognition  of the  importance of these  organisms and  their
role in the waste treatment process is critical.  Indeed, management of  the
unit should be  designed to manipulate environmental  factors to  enhance  the
activity of these decomposer organisms.   A more in-depth discussion of
soil organisms is given in Hazardous  Waste  Land Treatment (EPA,  1983A)  and
Introduction to Soil  Microbiology (Alexander, 1977).

2.1.2  Reconnaissance  Characterization of Waste Constituent Distribution  in
       Soil(Existing  or previously contaminated sites only)

     Regardless of the LTD approach for existing units, reconnaissance data
collection is  required to determine:  1)  if hazardous  constituents have
moved below the defined treatment zone;  2)  if so, how far they  have moved;
and 3) if  degradation,  immobilization,  and/or transformation are occurring
within the  treatment zone.  If hazardous constituents  have leached below  the
bottom of  the  treatment zone,  secondary information  on soil  drainage  class
and HWLT site topographic location (e.g., toe of  slope versus top of slope)
will  assist in decision-making.  These data are  collected through analysis
of soil cores and soil-pore liquid  samples from both the HWLT unit  and
background  soil.

2.1.2.1 Soil Cores-

     Waste constituents may move slowly  through  the soil profile  for a
number of  reasons, a  few of which are:   1) lack of sufficient soil moisture
to leach rapidly through the system,   2) a  natural  or artificial layer or
horizon of low hydraulic conductivity, or  3) waste  constituents that  ex-
hibit only  low to moderate mobility relative to soil  water.  Soil core
monitoring  can  identify any one or a combination of  these effects,  and deep
coring  can  determine if long-term movement of contaminants is occurring.
The intent  of  such  monitoring  is  to  demonstrate whether significantly
higher concentrations of hazardous  constituents are  present and moving in


                                    14

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the material  below the treatment  zone than in background soils.   The
applicant should refer to the guidance on  soil  sampling procedures and
equipment provided in EPA (1984A) but should be aware  that if a shelby tube
or spl it spoon sampler is used, at  least 75% sample  recovery per push  is
expected.  Should unacceptable recovery  occur, the depth increment per push
should be reduced.

     2.1.2.1.1  Depth—The  soil  core  should reach  a depth  of  six  meters  or
just into the top of the first aquifer (not merely perched water), which-
ever distance is less.   After samples of the zone of incorporation are
taken,  that  zone should be removed to avoid contamination of  lower  hori-
zons.   Within  the following zones, each boring may be composited with
depth:  0-15  cm, 15-45 cm, 45-90 cm, 90-150  cm, 150-200 cm, 200-250 cm,
250-400 cm,  and 400-600 cm.

     2.1.2.1.2  Area! Distribution--Whi le  the soil  series delineates the
domain of each  set of soil  samples, the location of each  sample point
within the  domain of each  soil  series is determined randomly.  In addition
to the random sampling points,  locations which represent "hot spots"
within an HWLT unit should also be sampled and should possibly be analyzed
separately.  These "hot spots", which may include but are not limited  to
toe slope positions, are important for soils with  an hydraulical ly restric-
tive lower horizon that may cause primarily lateral movement of  soil-pore
liquid with subsequent accumulation at  the  base  of the slope.   Other pos-
sible  hot spots include swales on the  treatment plots or waste dumping
locations adjacent to roadways, areas where  greater than average amounts  of
waste could  accumulate.  This  soil   series-specific sampling approach as-
sumes that only one waste is being treated at the site.  If more than one
waste is being treated, the domain of each randomly selected sample set
will be  the  "uniform area", defined as an area of the active portion  of  an
HWLT unit composed of soils of the same soil  series  to which similar wastes
or waste mixtures are applied at similar rates.

     2.1.2.1.3  Number of Samples--There should be a minimum of six soil
cores per uniform area of active treatment zone at a density of one soil
core per two acres.  Background soil cores must be collected at  a density
of four  for each soil  series  that occurs  on the HWLT unit.  Background
should be considered the area just outside of  the HWLT unit, not necessari-
ly an undisturbed, pristine area.  Samples should represent the conditions
of this background area and not be selected  in a  biased fashion  that  would
lead to  unreal istical ly low  or high  concentrations of  hazardous consti-
tuents.   If  high concentrations of hazardous constituents in the background
are found,  the fact should be reported to  the  permitting official.

     2.1.2.1.4  Analysis  of Soil Core  Samples—At this point in  the  site
characterization, samples must be analyzed rigorously  (Tier III, Chap-
ter 10).  Such rigorous analysis, necessary  to provide information  about
all  Appendix  VIII  constituents that may  be  present and therefore must  be
monitored throughout the life of the HWLT  unit.  The hazardous constituents
may be those present at  the time of waste application or other degradation
products not originally in the waste.   Because this  level of  analysis  is
not required under interim status  standards (40 CFR 265), the applicant
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does not usually possess data about all  possible hazardous constituents.
Data acquired by soil  core sampling could also  help to determine  the degra-
dation  rate  of  applied waste.
         following stepwise  approach to selecting and  compositing samples
         'sis should be  followed  to  conserve analytical costs while main-
     The
for analysi
taining the  integrity of the  data:
     1)   After splitting each sample increment and reserving a portion
         for possible later use, composite the 0-15 cm zone with the
         15-45 cm zone for each core.  Do likewise with the 45-90 cm,
         and 90-150 cm zones,  and the 200-250  cm, 250-400 cm, and 400-
         600 cm zones.  Four depth increments wi11  resul t: 0-45, 45-
         150, 150-200, and  200-600  cm.   Next,  composite  all  four
         background cores for each soil series to form one  sample set
         per series.  In the active  area, compositing should be done
         to yield three composite sets per  uniform area.   (For ex-
         ample,  if there is only one uniform area at the land treat-
         ment unit, the compositing  will  yield three active area
         sample sets and one  background sample set, with each set
         consisting of four depth increments.)  Next, analyze these
         samples at the Tier III level.

     2)   If any or all of the background sample increments are free of
         hazardous organic  constituents  (i.e.,  below detection
         limits), corresponding active area depth increments that are
         similarly  free of  hazardous organics may be eliminated from
         further consideration.  If any  background depth increment
         does indicate the  presence of hazardous organics, al 1 four
         background cores per soil series  at that depth should be
         analyzed separately at  the  Tier  II level  for only those
         constituents that were identified in the initial  analysis.
         This approach is necessary  to determine the variability and
         distribution of the  hazardous constituents  across  the back-
         ground area.  Once  the background  samples  show no hazardous
         organics or analyses are  begun to determine the mean and
         variance in background samples, appropriate active area sam-
         ples can be selected for  analysis.  For  only those depth
         increments on the  active area that yiel d concentrations of
         hazardous constituents greater than background, samples from
         every core should be analyzed at  the Tier II level  and should
         include  those constituents  that were present at greater than
         background concentrations.

     3)   Finally,  if  greater  than  background  concentrations of hazar-
         dous constituents  are found at a given  depth,  the depth
         increments that were composited to form the increment ana-
         lyzed should now be analyzed separately at Tier II.  Simi-
         larly,  any "hot  spot" should be  analyzed by individual sam-
         pling depths.  In some cases,  resampling and Tier II analysis
         of "hot spots" may  be needed  (a)  to confirm that the initial
         core samples were  not subject to cross contamination from
                                    16

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         other depths and/or (b) to determine the extent of the "hot
         spot".

     2.1.2.1.5  Interpretation of Soil  Core Sample  Data-in  the  analysis  of
the data collected under this section, sound statistical  principles  should
be used.  A land  treatment unit should be designed and operated such that
no vertical movement of significant quantities  of hazardous constituents
occurs  below  the treatment zone.  Thus, the following  null  hypothesis
should be tested:   the population means are equal  (H:   i =  2»  A:  1    2^*
The key to valid comparison between these populations  is  the choice  of
sample size (number of replications)  and  the  use  of random sampling.  The
reconnaissance  sampling program indicated here meets the requirements for a
good statistical  design and is therefore well suited to interpretation
using the "t"  statistic.  A step-by-step  procedure for statistical  inter-
pretation of the data is presented in UZM Manual  (EPA,  1984A).

     The results of the  statistical  interpretation will help to provide the
basis for a decision on the appropriate LTD permitting approach (described
in Chapter 3).  Specifical ly,  this data  assists  the permit writer in an-
swering the question:   "Is the  design and operation acceptable?"  (see
Figure 3.1).  Also,  if 1) a  hazardous constituent  has been  found below the
treatment zone or 2)  an unacceptable degree of degradation of the waste
organics  fraction or specific  hazardous organic constituents or an unac-
ceptable build-up of  conservative constituents (e.g.,  metals)  has  occurred
in the zone of incorporation, the permit writer and applicant will  need  to
address the  following questions:

     1)  Is  the site  permittable?  That  is,  does  an  environmentally
         damaging  situation exist for which no remedial action  can  be
         taken  other  than site closure?

     2)  If the site is not permittable, what  are  the waste management
         alternatives?

     3)  If the site  is permittable, what is the plan for remedial
         action to clean up the contaminated area?

Acceptable  "degradation" (loss  by  some means) is  defined as at least 80%
loss of the total  (organic  fraction or constituent) waste applied over the
facility  life  and no more  than  twice  the concentration of an organic  con-
stituent in the ZOI (0-15 cm) than the concentration applied annually  to
the soil.   For inorganics criteria, consult EPA  (1983A).  It should  be
noted that because all of these decisions involve contact with the  EPA  or
the State, they are beyond  the  scope  of this document.

2.1.2.2  Soil-Pore Liquid-

     Percolating water added to the soil  by precipitation,  irrigation,  or
waste applications may  pass through  the  treatment  zone and  rapidly  tran-
sport  some  mobile waste constituents or degradation  products through the
unsaturated  zone  to  the  groundwater.  Soil-pore  liquid monitoring  is in-
tended to detect these rapid  pulses  of contaminants that occur  immediately


                                    17

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after heavy precipitation  and  that  are  not  likely to be observed through
the analysis of shallow soil  core  samples.  Therefore, the timing (sea-
sonal ity)  of soil-pore  liquid  sampling  is  essential  to the usefulness of
this technique (i.e., scheduled sampling cannot be planned on  a  preset
date, but must be coordinated  with  precipitation).   Soil-pore liquid sam-
pling in the reconnaissance site evaluation is used to determine if any
mobile hazardous constituents are  leaving the treatment zone.   However,
existing monitoring data may suffice if samples have already been  analyzed
at the Tier III level (to  include Appendix VIII  constituents).

     Since interim status standards require the installation and use of
soil-pore  liquid sampling equipment,  data  concerning the status  of soil-
pore liquid below  the treatment zone may already exist.  However,  if these
data do not include all of the parameters of  concern in the LTD  and in
future management and monitoring,  an applicant with presently operational
soil-pore liquid samplers  should  collect current samples and analyze them
at the Tier III level (See Chapter 10).   For  sites without soil-pore  liquid
samplers or with samplers  that are not functioning, the reconnaissance site
evaluation will be based on  soil  core data only.   If soil-pore  liquid
samplers have been  installed but are not functioning effectively,  possible
reasons  for their  failure (e.g.,  improper installation,  mechanical
failures,  installation  in  a soil horizon which has a low hydraulic conduc-
tivity, such as a fragipan) should be investigated.   The applicant  should
note that lack of  compliance with Part 265 soil-pore  liquid monitoring may
affect the allowable permitting scenario (see Section 3.1.2) as well  as
expose the operator to possible enforcement action.    For more detailed
discussion of  soil-pore liquid samplers  see  Chapter 7 and EPA (1984A).


2.2  WASTE CHARACTERIZATION

     A demonstration of the land treatability of a  given waste  must na-
turally begin with waste characterization.   Only after the  thorough charac-
terization of a waste  has been completed can an appropriate LTD  can be
conducted, since comprehensive  waste analytical  data  are needed to identify
and quantify the  hazardous constituents  contained in  the waste.   If signi-
ficant concentrations of hazardous and organic  constituents are  present,
the analytical  procedures  throughout the course of the LTD must necessarily
be more extensive (i.e.,  analyses for many of the 40 CFR 261,  Appendix VIII
compounds versus gross parameters such as  total oil  and  grease).   The
converse also may  be true:  thorough characterization may allow the  elimi-
nation of  certain analytical   procedures throughout  the course of the LTD
(see Chapter 10).

     The  general  Part B information requirements  specified under  §270.14(b)
require the submittal  of  1) chemical and physical  analysis data  on the
hazardous wastes to be handled at the facil ity, including al 1 data that
must be known  to treat,  store,  or  dispose of wastes properly in accordance
with Part  264,  and  2) a copy of the waste analysis plan.   In addition, the
specific information requirements under §270.20  require an owner/operator
of any facility that includes a land treatment unit to submit "a 1 ist of
hazardous  constituents  reasonably  expected to be in,  or derived  from, the


                                   18

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wastes to be land treated based on waste analyses performed pursuant to
§264.13.    Finally,  §270.20{a) stipulates that  the  description  of  the
treatment  demonstration plan must include a list of potential hazardous
constituents in the  waste.

     Although the PAGM provides general  guidance on waste analyses for land
treatment permit applications, information presented in this manual  may
further aid the applicant in determining what is  expected  of  the waste
characterization.   One key point is that the program of routine, broad
scale waste characterization  done  for the Part B  only  partially fulfills
the LTD data needs.   More importantly  for the LTD, representative waste
batches must be obtained and characterized in detail  if an experimental
(i.e., lysimeter or field plot) demonstration  is planned.  If the waste  for
the LTD can be conveniently obtained at the time  of sampling for  general
waste characterization, one set of analyses may suffice for both  purposes.

     Although a treatment demonstration  is not required for land treatment
of a nonhazardous waste, the presence of nonhazardous waste within the  same
treatment  zone as the  hazardous  waste  will affect the  treatment of  the
hazardous waste.  Therefore, in instances where  nonhazardous wastes  are
disposed/treated within  the same treatment zone as the hazardous waste, a
detailed characterization of the nonhazardous waste (including Appendix
VIII hazardous constituents) must also be  provided.  Of course, the appli-
cant has  the option of segregating  the hazardous and nonhazardous wastes at
the land treatment unit, and thus avoid being  subject to the nonhazardous
waste characterization.

     The  characterization phase is also important in identifying possible
capacity  limiting constituents (CLC), often metals, and application  limit-
ing constituents  (ALC).  These constituents will  be positively confirmed
according  to data subsequently obtained  from the LTD.   The limiting  levels
for the CLCs will  depend partially on  the closure method employed at  the
HWLT unit.  For a thorough discussion on CLCs and ALCs,  the applicant
should refer to Chapter  7 of Hazardous Waste  Land  Treatment (EPA, 1983A).

2.2.1  Sampling

     Sampling of waste  is to be conducted  in accordance with good scienti-
fic methods to ensure that  accurate,  representative samples  of  the waste
are obtained.  Specific amounts needed for analysis and use  in the field
plot study or lysimeter  study depend on  the  treatment demonstration chosen
and on whether an existing  site  is being used  for  demonstration of a
waste's treatability.  The applicant should refer  to the appropriate sec-
tions of  this document when estimating amounts of  wastes  required to carry
out the respective treatment demonstration approaches.

2.2.2  Sample Collection

     A  representative sample of the waste  to be applied must  be  collected
for characterization and use in  the LTD.  Because waste uniformity  and
variability always present a problem  in treatment demonstrations,  all
samples should be collected using sampling and  compositing procedures


                                   19

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prescribed by EPA (1982).  In some complex waste generating situations,
sampling may need to be carried out over a period of months to produce a
representative  set  of samples (e.g., due  to  intermittent waste generation
or seasonal  variability).  To decrease the analytical burden, the quantity
of waste to be used in the treatment demonstration could in some cases be
collected and stored at the time of sampling for overall waste  stream
characteri zati on.

2.2.3  Sample Handling and Storage

     Al 1 sampl ing equipment should be  thoroughly clean and free of con-
tamination both prior to use and between  samples; storage containers should
be similarly free of contamination.  While only plastic or Teflon" may be
used for samples intended for  inorganic analysis, glass, Teflon1"  or stain-
less steel may be used for samples intended for organic  analysis.  Care
should be taken that both  the  samples and storage  container materials are
not  reactive with the waste.  Also, if the sample is to be frozen in
storage, ample room for expansion must be provided  in the sample container.

     Following sampling operations,  all  samples should be tightly sealed
and preserved at 4°C, unless known characteristics require  other preserva-
tion methods.  Although other methods should be avoided  for wastes col-
lected for the LTD  to  prevent bias in  the LTD  results, freezing  may be
required when  organic constituents  are expected to  be lost  through  volati-
lization;  this may  be easily  accomplished by packaging all  sealed  sample
containers in dry ice directly after collection if other refrigeration
methods are not immediately available.  The applicant  should make prior
arrangements with the receiving laboratory to ensure sample integrity until
the time of analysis.   Since storage of large waste volumes for the LTD may
present problems  in  terms  of qualitative and quantitative waste integrity,
the applicant should strive to minimize  storage time.

2.2.4  Sample Analysis

     Necessary  physical  and  chemical analyses of waste  are  listed  in the
following table.   The procedures used to  determine these waste properties
should be those  approved by   EPA.  These methods are described  in EPA
(1983A) and Test Methods for  Evaluating  Solid Waste (SW-846)  (EPA,  1982).
                                   20

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Table 2.1  Physical  and  Chemical Analyses of Wastes
Water Content
Solids Content
Ash Content
Soluble Salts*
Nitrogen Series*
Phosphorus Series*
pH             .
Metals (total concentration  and  not EP toxicity data)'
Total Organic Carbon
Total Oil and Grease
Volatile Organics (by purge  and  trap)
*  Pertinent nonhazardous constituents that may affect treatment.
t  Includes hazardous and important nonhazardous metals beyond merely those
   for which a waste is listed as hazardous.
 2.2.5  Appendix VIII Constituents

     In  addition  to the general  parameters  outlined above, Appendix VIII
 (40 CFR 261) constituents present must be identified and quantified accord-
 ing to procedures approved by the EPA (1982).  Where wastes handled at a
 facility  are  from an identified  process (e.g.,   petroleum  refinery
 processes), EPA may accept analysis performed on a subset of Appendix VIII
 compounds which  are "reasonably expected  to be in or derived from the
 wastes to  be  land treated" (see §270.20).  Such a subset, developed by EPA
 for wastes from petroleum refineries,  is  included in Table  2.2.

     The list of  hazardous constituents suspected to be present in refinery
 wastes (Table 2.2) was  derived from a  review of  data on petroleum refinery
 wastewater and sludge characteristics from the following sources:  1)
 literature,  particularly  EPA  research reports;  2)  in-house waste analyses
 completed  by EPA  research laboratories;  3) preliminary  data from the Office
 of Solid Waste  (EPA) refinery waste study;  and 4) an evaluation  of petro-
 leum  refinery  processes.   Although the  above sources were used, the data
 base  on  specific hazardous organic  constituents  in  sludges  was  still
 limited.  Considerable emphasis  was placed on wastewater data as indicators
 of sludge  characteristics (e.g,  API separator sludge).

     Table 2.2 is a generic  list developed by combining waste analysis data
 on all five listed refinery wastes (K048-K052).   Due to the  lack of exten-
 sive  data,  however, no attempt  was made  to  differentiate between the  char-
 acteristics of these five refinery wastes.  Until sufficient information is
 available to  allow development of  separate  lists  for each waste, the
 attached list should be considered applicable only  to dissolved air flota-
                                     21

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tion float (K048),  slop oil  emulsion solids (K049),  heat exchanger bundle
cleaning sludge (K050),  API  separator sludge  (K051), and leaded tank  bot-
toms (K052).

     To compensate for  the  limited data base and variability among re-
fineries,  the attached list is  purposely comprehensive;  it includes a total
of 89 hazardous constituents  or groups of constituents (e.g.,  trichloro-
benzenes), all of which have  been  identified as  possibly present in the
above-referenced wastes.  Many of the compounds on the  list may be present
at low concentrations, and others may not be present at  all  in certain
wastes at some refineries.

     Permit writers  use  the  attached list as  a  guide to the Appendix VIII
constituents that should be addressed in the preliminary waste analyses and
waste analysis plans  for Part B applications that propose land treatment of
petroleum refinery wastes.  A permit applicant may  further refine this list
by providing detailed evidence that certain hazardous  constituents cannot
be present in  the  listed wastes at that  particular  refinery.   In most
cases, however, waste analysis  data  on the constituents  listed in  Table 2.2
is necessary to demonstrate  such  a  claim.   [An interpretative note about
volatiles:  Although current regulations and guidance do not include moni-
toring or interpretations of air emissions,  waste  analysis  calls for data
on the waste volatiles fraction. The major point to be emphasized about
this data is that wastes containing large concentrations of volatile hazar-
dous  constituents (e.g..greater  than  0.5%) may not be amenable  to land
treatment unless applied at very low concentrations, by  the  correct method,
and under favorable  soil conditions. Since the atmosphere could be the sink
for such constituents  if they  are not applied and managed  properly in the
soil, LTD studies  should be  specifically designed to show that  degradation
rather than volatilization is the  primary loss mechanism.]
                                    22

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Table 2.2   Hazardous Constituents Suspected to be Present in Refinery
            Wastes
Acetonitrile' (Ethanenitrile)
Acroleiiy (2-Propenal)
Acrylonitri1e' (2-Propenenitri1e)
Aniline (Benzenaraine)
Antimony
Arsenic
Barium
Benz (c) acridine (3,4-Benzacridine)
Benz (ai anthracene  (1,2-Benzanthracene)
Benzene" (Cyclohexatriene)
Benzenethiol  (Thiophenol)
Benzidine {l,l-Biphenyl-4,4 diamine)
Benzo(b)fluoranthene  (2,3-Benzofluoranthene)
Benzo (j) Fluoranthene (7,8-Benzofluoranthene)
Benzo(a)pyrene (3,4-Benzopyrene)
Benzyl chloride* (Benzene, (chloromethyl)-)
Beryl1i urn
Bis  (2-chloroethyl)  ether  (Ethane, 1,1-oxybis (2-chloro-)
Bis  (2-chloroisoprqpyl) ether  (Propane, 2,2-oxybis (2-chloro-))
**
Bis  (2-ethylhexyl)  phthalate  (1,2-Benzenedicarboxylic  acid,  bis  (2-
  ethylhexylJester
Butyl  benzyl phthalate  (1,2-Benzenedicarboxylic acid, butyl phenylmethyl
  ester)
Cadmium
Carbon disulfide (Carbon bisulfide)
p-Chloro-m-cresol
Chlorobenzene (Benzene, chloro-)
Chloroform*  (Methane, trichloro-)
Chloromethane* (Methyl chloride)
2-Chloronaphthalene  (Naphthalene, beta-chloro-)
2-Chlorophenol (Phenol, o-chloro-)
Chromium
Chrysene (1,2-Benzphenanthrene)
Cresols  (Cresylic acid)  (Phenol, methyl-)
Crotonaldehyde*  (2-Butenal)
Cyanide
Dibenz(a,h)acridine  (1,2,5,6-Dibenzacridine)
Dibenz(a,j)acridine  (1,2,7,8-Dibenzacridine)
Dibenz(a,h)anthracene (1,2,5,6-Dibenzanthracene)
7H-Dibenzo(c,g)carbazole (3,4,5,6-Dibenzcarbazole)
Dibenzo(a,e)pyrene  (1,2,4,5-Dibenzpyrene)
Dibenzo(a,h)pyrene  (1,2,5,6-Dibenzpyrene)

                               --continued--
                                      23

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Table 2.2   Continued

•«WM-WBW—MMW^^H^^WHWWWall-"M*MWH-W--W---M---W»^H*IWMIWWaMW>-
Dibenzo(a,i)pyrene (1,2,7,8-Dibenzpyrene)
1,2-Dibromoethane* (Ethylene dibromide)
Di-n-butyl phthalate (1,2-Benzenedicarboxylic acid, dibutyl ester)
Dichlorobenzenes*
1,2-Dichloroethane  (Ethylene dichloride)
trans-l,2-Dichloroethane" (Ethylene dichloride)
1,1-Dichloroethylen' (1,2-Dichlorethylene)
Dichloromethanej (Methylene chloride)
Dichloropropane*
Dichloropropanol
Diethyl phthalate (1,2-Benzenedicarboxylic acid, diethyl ester)
7,12-Dimethyl-benz(a)anthracene
2,4-Dimethylphenol (Phenol, 2,4-dimethyl-)
Dimethyl  phthalate (1,2-Benzenedicarboxylic acid, dimethyl ester)
4,6-Dini tro-o-cresol
2,4-Dinitrophenol (phenol, 2,4-nitro-)
2,4-Dinitrotoluene (Benzene, l-methyl-2,4-dinitro~)
Di-n-octyl phthalate  (1,2-Benzenedicarboxylic acid, dioctyl ester)
1,4-Dioxane*  (1,4-Diethylene oxide)
1,2-Diphenylhydrazine (Hydrazine, 1,2-diphenyl-)
EthyleneimineT  (Azridine)
Ethylene  oxide* (Oxirane)
Fluoranthene  (Benzo (j,k) fluorene)
Formaldehyde*
Hydrogen  sulfide (Sulfur hydride)
Indeno  (l,2,3-cd)pyrene (1 10(l,2-phenylene)pyrene)
Lead
Mercury
Methanethiol  (Thiomethanol)
3-Methy1chlolanthrene (Benz(j)aceanthry1ene, 1,2-dihydro-3-methy1 -)
Methyl ethyl ketone1" (MEK) (2-Butanone)
Naphthalene
Nickel
p-Nitroaniline  (Benzenamine, 4-nitro-)
Nitrobenzene  (Benzene, nitro-)
4-Nitrophenol (Phenol, pentachloro-)
Pentachlorophenol (Phenol, pentachloro-)
Phenol (Benzene, hydroxy-)
Pyridine
Selenium
Tetrachl oroethanes*!!
Tetrachloroethylene* (Ethene, 1,1,2,2-tetra chloro-)
Toluene*  (Benzene, methyl-)
Tri chlorobenzenes*

                               —continued—
                                     24

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Table 2.2   Continued
Trichloroethanes**
Trichloroethene (Trichloroethylene)
Trichlorophenols*
Vanadium
*  If any of  these groups of compounds  are found,  the specific isomers
   listed in Appendix  VIII  should  be identified.

t  Use Test Method 8240  for these volatile compounds.

#  Use Test Method 3050 in SW-846 for al1 metal s; see Skinner (1984) for
   semi-volatile  organic compounds.

** Bis(Chloromethyl)  ether  deleted because it is  unstable in water
                                    25

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                               Chapter 3

          TREATMENT DEMONSTRATION SCENARIOS AND DECISION-MAKING


     Thus far, this document has introduced the nature and intent of the
land treatment demonstration and has described the information required
prior to the choice and implementation of an LTD approach.  This chapter
states the available regulatory/technical  LTD options and provides  clear
criteria  to enable the applicant, in consultation  with  the permitting
authority, to choose the  appropriate scenario.  The flow chart (Figure  3.1)
which was  introduced in Chapter  1  can  be used as  a  guide to the  LTD
scenarios and as the basis for  further  discussion  and decisions.   The
reader is encouraged to refer to this chart often  since it presents the
scenarios that are the focus of this document in capsule form.  Once a
scenario is selected, the individual technical activities that are required
(see Figure 3.1)  for the chosen scenario can be assembled from among  those
described in  Chapters 4 through 10.

     Briefly, the  flow  chart consists of two major sections.  The top
portion  of the chart shows the decision flow leading  the applicant  to one
of four permitting  scenarios;  the criteria  to  guide the applicant at each
decision point (diamond-shaped box) are provided in  detail  in Section  3.1.
Once the appropriate land treatment permitting scenario has been deter-
mined, the applicant should  refer to the  bottom portion of the chart, which
outl ines the steps invol ved  in  each  scenario;  Section 3.2 explores the
logic behind each scenario more thoroughly.   It should be noted that  while
Scenario 4 represents the case  generally available to most applicants, only
in the most restricted circumstances can an applicant  qualify  for Sce-
nario 1.    Of course, any  applicant may opt  for  a more comprehensive
scenario than the one he  is qualified for  (see dashed "alternatives" arrows
in Figure 3.1).


3.1  CRITERIA FOR CHOOSING A LAND TREATMENT DEMONSTRATION  SCENARIO

     The choice  of  an LTD scenario involves organizing information and
answering four questions, the first of which is  easy: "Is the land treat-
ment unit new or existing?"  As noted  in the regulations (40 CFR 270.2), an
existing unit is one that was in operation or for which construction had
commenced on or before November 19,  1980.     For the purposes of this
document, the unit is considered "new" only if does  not fit this defini-
tion; a  complete definition appears in  the  regulation cited above.  For
existing  units, the following sections address the next three questions in
sequence.
                                   26

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SELECTION AND
DESCRIPTION OF
TREATMENT
DEMONSTRATION
SCENARIOS
                                    PRELIMINARY
                                    INFORMATION
                                      NEEDS
                    DESIGN
                   NO OPERAT
                    CHANGES
                    PLANNE
    IS
 EXISTING
HWLT UNIT
 PERMIT
 WRITER
 DECIDES
SCENARIO
                     WASTE
                     4AGEMI
                    RECORDS
     FIG. 3.1.  TREATMENT  DEMONSTRATION  DECISION FLOW CHART.
                                    27a

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          r
   r
       SCENARIO I
                         SCENARIO 2
                 SCENARIO 3
                       SCENARIO 4



INTENSIVE
SITE DATA
COLLECTION


FULL SCALE
.PART 264
FACILITY
PERMIT
ISSUED
ALTERNATIVE /

IVE
VTA
riON


x
tPPROACH

ISSUED PHASE 1
OF A TWO
PHASE PERMIT
A

7
s

LEFT UNDER
INTERIM
STATUS
STANDARDS
TEMPORARILY

*
SH
Tl
OEM
PEF
                                                          SHORT TERM
                                                           TREATMENT
                                                          iMONSTRATWN
                                                         PERMIT ISSUED
                   BARREL
                  LYSIMETER
                    STUDY
        FIELD
        PLOT
        STUDY
                                                 FIELD
                                                 PLOT
                                                 STUDY
TOXICITY
 TEST
LYSIMETER
 STUDY
                                                      BARREL
                                                     LYSIMETER
                                                       STUDY
                                        PHASE I OF A
                                         TWO PHASE
                                        PERMIT ISSUED
                                         TWO YEAR
                                         FOLLOW-UP
                                           STUDY
                                  TWO YEAR
                                  FOLLOW-UP
                                   STUDY
                                                          FULL SCALE
                                                           PART 264
                                                           FACILITY
                                                            PERMIT
                                                            ISSUED
FIG. 3.1.  TREATMENT  DEMONSTRATION  DECISION  FLOW CHART. (CONTINUED)

              (NUMBERS  IN  BOXES  REFER  TO  CHAPTERS)
                                 27b

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     While permitting Scenario 4 is generally required  for  new units (see
Figure 3.1), one special case may al low the use of one of the other three
scenarios. The regulations  allow existing operating data (from another HWLT
unit that  is  very similar to the  proposed  unit) or literature  data  to
satisfy the demonstration if strict criteria are met. Since experimental
evidence and  practical experience has  shown that a single waste  or similar
wastes behave differently when placed in a  different setting  (i.e., dif-
ferent climate, soil, management, etc.), the following criteria must be met
for data from another HWLT unit to  satisfy the LTD:

     1)  Wastes must be qualitatively and  quantitatively similar
         (i.e., the same set  or a  subset of  hazardous or pertinent
         nonhazardous constituents);

     2)  This  same previously demonstrated waste must have been tested
         in the same climatic  regime;

     3)  Soils and shallow hydrogeology of the two  sites must be
         practically the same according to accepted classification
         methods and supporting analyses;

     4)  Anticipated waste application rates  at the  applicant's unit
         must be  the same or less than  those at the demonstrated
         site; and

     5)  Management techniques should be essentially comparable in
         their ability to achieve the  desired results.

In the above  sense, the concept of a regional LTD might be feasible for
several operators  who share these common features.

3.1.1  Are Major Design and Operation Changes  Planned?

     For an existing HWLT unit to  be permitted on the basis of  current
design and management,  the planned  future  activities  under  a Part 264
permit must involve a generally  similar waste application rate  and method
which both maintains similar waste(s)  quality and  management practices and
continues  to use the same  soil  as  the treatment medium.   If current and
future activities  are not  the  same, the planned changes must lead to more
conservative  application  rates,  better waste quality (i.e.,  lower concen-
trations  of hazardous  or  pertinent nonhazardous constituents), or better
management practices or design.   In  addition,  the soils presently used
cannot be replaced by others.   To demonstrate future  consistency of opera-
tion, three areas  - planned unit processes,  waste application  rates,  and
use of soil - must be accounted for.

3.1.1.1  Planned Unit Processes--

     No changes should be planned in the unit processes generating the
wastes because such  changes would  result  in  substantial  qualitative dif-
ferences  in the waste streams to be land  treated.   Substantial  differences
are primarily considered to be the introduction of measurable  amounts  of
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hazardous or pertinent nonhazardous compounds  not  previously found in  the
wastes.   Because  these substances would not have been tested in the treat-
ment demonstration, their behavior in the HWLT unit would not be known.
This is not meant to imply that later refinements in unit process design
and/or operation or the addition of new production units will  necessarily
warrant  a new LTD.  However, if qualitative waste changes occur,  another
LTD may be necessary.  It is also recognized that the relative abundance of
the various waste constituents in even a single waste stream  will  vary  due
not only to seasonal effects but also to such influences as fluctuations in
feed stocks, relative market demand for the various  products of the waste
generator, and the  intermittent batch  generation of certain wastes.  These
variations should already be taken into account  in the waste characteriza-
tion.  In any case,  the ongoing waste monitoring  program must be capable of
detecting substantial  long-term changes  in waste quality.  For the LTD,  the
best that can be done is to identify anticipated changes that could affect
waste quality.

3.1.1.2  Planned Waste Application  Rates--

     The applicant may anticipate a significant increase in the waste
application  rates due to a decrease in the usable  land area  available  for
HWLT or  increases  in the  rate of  production for one or  several waste
streams;  in either case, this significant increase in application rate must
be taken into account in the LTD. Anticipated increases on the order of  20%
or less  would be considered acceptable.  Should  greater increases that  are
not  accounted for in the LTD be anticipated,  or should  such increases occur
at anytime in the future, additional  LTD work would be warranted.   De-
creased  application rates  present  no problem.

     Planned application rates should be expressed in  terms of the concen-
trations and application rates  of  limiting constituents or constituents
that are nearly  limiting but not  in terms of gross parameters  such as  oil
content.   This way of expressing application  rates prevents not only misin-
terpretation of the artificial effects of dilution but also the false
impression that no change in a gross parameter  such as oil or water content
has  occurred and, thus,  that no application  rate change has  occurred.   For
example, increases in hazardous constituent production rates that  are
merely offset by dewatering  still  constitute an increased application rate.

3.1.1.3  Planned Use of Soils—

     The use of soil other than that already in place significantly affects
the  behavior and fate of waste  constituents.  Due to inherent differences
among the  physical, chemical,  and biological  properties of  soils, treat-
ability  of waste  likewise varies (Brown  et al., 1983);   thus, planned
operations should include  the  continued  use of present soils.  An expansion
of the HWLT unit onto a different soil  series would be considered a change
in treatment medium  and  would thus  require a  separate LTD.  Likewise,
removal  of soil present on an existing active area or replacement with soil
from a different series,  also regarded as  a change of treatment  medium,
would require a separate LTD.  Finally, a major disruption of the treatment
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zone would  significantly alter conditions as well.  While normal operations
are expected  to  disrupt surface soils in the zone of incorporation,  major
disruption  involves one  of  the  following:  deep tillage (an activity which
mixes the lower portion of  the  soil  profile that should normally  remain
undisturbed during HWLT operations) or the artificial drainage and lowering
of a seasonal high water table that had previously encroached  into  the
treatment  zone  in order to meet the separation requirements of  40  CFR
264.271 (c)(2)

3.1.1.4  Guidance on Planned Design and Operation--

     Management  personnel should be consulted to determine possible near-
term modifications  to the waste streams  or  land  treatment  unit.  Table 3.1
shows the categories of information needed and summarizes the previous
discussions to aid in interpreting this information.  Long term changes
become a question  of assessing whether  it is more  effective to  do the  LTD
for the revised unit now or  later.  If it  is determined  that design  and
operation  changes will occur,  HWLT permitting Scenario 4  is required
(Figure 3.1).   If it is determined that  no  changes in design and operation
are planned,  the applicant should proceed to the  third question (and deci-
sion point  on  the  chart), discussed  in the next section.


Table 3.1  Planned Operations  Information Needs
                                         Confirmation of No Design
    Category                                and Operation Changes


Unit Processes                      No anticipated measurable quantities
                                   of additional  hazardous or pertinent
                                   nonhazardous constituents that are  not
                                   presently in the  land treated wastes.

Waste Application Rates             No greater than a 20% increase in  the
                                   quantities of hazardous or pertinent
                                   nonhazardous constituents applied  per
                                   unit area per unit time (kg/ha/yr).

Soil                                No expansion  onto new  soil  series;
                                   no importation  of different  soils  for
                                   use as the treatment medium; no major
                                   disruption of existing soils.
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3.1.2  Is the Performance  of  the Existing HWLT Unit Acceptable?

     The third question to be answered in the flow of decisions (Figure
3.1)  is  whether the performance of the existing HWLT unit is acceptable.
EPA will address this question by evaluating the results of:

     1)    Unsaturated zone monitoring  (UZM)  performed and recorded by
          the owner or operator in accordance with 40 CFR §§265.278
          and 265.73:

     2)    Groundwater monitoring  (GWM)  performed and recorded  by the
          owner or operator in accordance  with 40 CFR  §§265.90 -265.94
          (Subpart F) and  §265.73;  and

     3)    Reconnaissance sampling  conducted as part of the preliminary
          assessment of the site (see Chapter 2, Section 2.1.2).

     The discussion below regarding UZM and GWM  pertains only  to informa-
tion  needs for  permitting  HWLT  units;  it does not relieve  the  owner/
operator of possible enforcement action for inadequate compliance with
interim status monitoring  requirements.

3.1.2.1   Monitoring System Design--

     To provide  reliable  and useful data, the unsaturated zone  and ground-
water monitoring systems must be properly  designed and implemented.   Major
deficiencies in these monitoring systems significantly limit the usefulness
of any data and automatically trigger a more comprehensive approach   to the
treatment demonstration (i.e.,  Scenario 3  or  4).

     EPA uses the following minimum criteria  to  detemine  whether the moni-
toring  systems  provide  useful and reliable data for  the treatment  demon-
stration:

     1)    The UZM program must have included, since the date  that the
          HWLT unit was granted interim status (usually  November 19,
          1980),  at least semi-annual  sampling  analysis of soil cores
          and soil-pore liquid from at least three locations within the
          active portion of the HWLT unit.  Also, background data from
          at least one  location outside of the active  poriton  should
          have been collected for both soil core and soil pore liquid.
          In addition, the monitoring program must have  met  the gen-
          eral monitoring  objectives defined in §265.278.

     2)    The groundwater  monitoring program must have met, since the
          effective date of  the interim status  groundwater monitoring
          requirements,  the minimum requirements  specified in Subpart
          F of Part 265.

The applicant  must  use  the information  required  in  the  facility operating
record for monitoring (§265.73(b)(6)) to document that the above  criteria


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have been met.

3.1.2.2   Performance Evaluation--

     Using the criteria below, EPA evaluates the performance of the HWLT
unit according to the results of unsaturated  zone  and groundwater monitor-
ing during interim status and  recent reconnaissance  sampling (for all
Appendix VIII hazardous constituents) of the  site.

     1)    The unsaturated zone monitoring data (including soil  core
          and soil-pore liquid data) collected during interim status
          and  included in the  operating record as required under
          §265.73 must  show no  significant  migration of  hazardous
          waste constituents below the proposed treatment zone.  Also,
          the GWM data must not indicate the  presence of contamination
          as defined in  Subpart F of Part 265; and

     2)    The reconnaissance sampling data (including soil core and
          soil-pore liquid data) must show:

          a.  no significant increase of hazardous constituents  (Ap-
             pendix VIII) below the proposed treatment zone within
             the active portion compared to  background; and

          b.  no unacceptable build-up of hazardous organic consti-
             tuents within the zone of incorporation (ZOI) (e.g.,  0-
             30 cm). The concentration of hazardous organic consti-
             tuents in  the ZOI are  acceptable  if  they  are 1)  no
             greater than two times the annual  loading rate of  that
             constituent when  the ZOI  is   sampled  after waste  is
             incorporated and dried, or 2) no greater than  the annual
             loading rate of that constituent when the ZOI  is sampled
             immediatley  prior  to a scheduled waste  application.

     For HWLT units that satisfy  the  criteria  in  sections 3.1.2.1 and
3.1.2.2,  the  next and final step is  to  determine whether their waste
management records  are complete (see Section 3.1.3).   This   last  step also
determines if the HWLT unit falls  into Scenario 1 or  2.

     HWLT units that do  not meet  the  criteria  in  Sections 3.1.2.1 and
3.1.2.2 fall into Scenario 3 or 4.  After considering  the unit's current
design and operation, the permit writer decides whether the unit should
follow  Scenario 3 or 4.   If possible interim status  violation becomes
apparent to the permit writer, he will  inform the EPA or State enforcement
officials for possible enforcement action.

3.1.3 Are the Waste Management Records Complete?

     The final question in  the decison-making process is whether the waste
management records are complete.  If the land treatment demonstration is  to
rely primarily  on past  operating  data  to  satisfy  the treatment demonstra-
tion (i.e., Scenario 1), this operating data must include detailed waste


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management records that clearly  document  the  set of conditions  that  pre-
viously allowed  successful treatment of hazardous waste at the site.   This
documentation provides the necessary background and  support for the permit-
ting official to establish specific permit conditions for  future operation.

     Table  3.2 lists what constitutes complete the waste management  data
and records.   These records, which must include  the history of waste appli-
cation (i.e., application rates, timing, and location) and the history of
waste quality (i.e.,  waste analysis and unit process data),  are more com-
prehensive  than  those  required  under  interim  status  but  are necessary to
provide adequate data for  the  demonstration.

     The records described in Table 3.2 include data from recent and  past
operations.   Since wastes  are  continually  being treated in the system, the
recent years are most important to the historical construction.  As one
looks further into the past,  each preceding year has a diminishing impact
on current treatment  zone  characteristics.   The  completeness of the records
can thus be judged against two frames of reference:

     1)  recent activities that are most influential  and require rela-
         tively detailed records  of waste application rates, distribu-
         tion, timing,  and quality; and

     2)  older operations  that are usually  less  influential  and re-
         quire only  general estimates  of past activities.

Based on half-lives  of less than one to two years for most land  treatable
organic  constituents  in  soils (Brown et al., 1983), four years of good
records  should suffice for the first frame of  reference.  With  regard to
the  longer  time  frame,  only estimates of the  waste application  rates are
needed beyond four years.

     If the  waste management records  are complete (as documented by the
operating record required under §265.73)  and the HWLT unit has satisfied
the  other criteria  described in Sections 3.1.1 and 3.1.2,  the owner or
operator may qualify  for the Scenario  1 demonstration approach.  Section
3.2.1 describes  the  technical approach taken  in Scenario 1.  Those HWLT
units that  have  incomplete records yet have satisfied  the other decision
criteria in Sections  3.1.1 and 3.1.2  fall  into Scenario 2.
3.2  TREATMENT DEMONSTRATION PERMITTING SCENARIOS

     At this point,  with  the guidance for choosing  an LTD permitting scena-
rio  presented,  applicants  should  be  able to identify  the  proper  scenario
for  their conditions.  Before proceeding, however, the applicant should
obtain approval of the chosen scenario by  EPA or the State in a pre-LTD
meeting or review.  As noted in the previous section, the choice of one of
four scenarios is possible.   This section describes the content of  and
justification for each of the  four scenarios.

     Using Figure 3.1  and the  following descriptions,  each  of  which  notes


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Table 3.2   Criteria for Deciding the Completeness of Waste Management Data
           and Records
   Category
   Item
Minimum Degree of Completeness Needed
History of Waste
 Application
History of Waste
 Quality
Years in service
and annual quan-
tity of wastes
land treated
                  Placement of
                  wastes on land
                  treatment plots
                  Estimated annual
                  quantity of was-
                  tes  land treated

                  Approximate
                  placement of
                  wastes
Waste analyses
                  Unit Processes
Records of measured annual waste
quantity (dry weight) treated over the
life  of the HWLT  unit or for  four
years, whichever is less.  Must in-
clude al 1 wastes, both hazardous and
nonhazardous, that are managed on the
same unit.
Records of  quantity  (dry weight),
date,   and   location  of each waste
application  for each  land-treated
waste over the  1 ife of the LT unit or
for four years,  whichever is less.
Estimated annual waste quantity (dry
weight)  treated  during  the life of the
unit excluding the most recent  four
years.
Approximate  quantity  (dry  weight),
timing,  and location of each waste
application  during the life of the
unit excluding the most recent  four
years.

Semi-annual  analyses of each land-
treated  hazardous  waste during the
last four years.  (Nonhazardous waste
analyses are also necessary if these
wastes are land treated in  same  plot
as hazardous wastes.)   Parameters  must
include  bulk organics (e.g., TOC, oil
& grease, solvent extractable, etc.),
key metals  (totals on a dry weight
basis and  NOT  EP  toxicity test re-
sults) and some measure of residual
solids (i.e., after loss of water and
organics).
History  of  unit processes employed in
the generation and treatment of the
land treated wastes (i.e., wastewater
treatment) for  the  entire unit life.
Processes must have been relatively
constant during  this  period,   with
little change in waste quality.
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what is expected technically,  the  applicant should be able to assemble a
land treatment demonstration.   The technical elements of  the  LTD  are de-
scribed in Chapters 4 through  10.  The information in this section is de-
signed to be used as the basis  for a written LTD  plan,  as  required by
§270.20(a), and to guide the applicant in the performance of  the  LTD.

3.2.1  Scenario 1

     Owners/operators of HWLT units who have gathered the preliminary
information described in Chapter 2  and  have met the decision-making cri-
teria described earlier in this chapter may satisfy  the LTD with the,Scen-
ario 1 approach.  Scenario 1, which  involves the use  of past operating data
along with a one-time intensive soil characterization,  is based on the
assumption that for well  documented,  designed, and operated  HWLT units an
approximate mass balance can  be estimated between  the hazardous consti-
tuents applied and those remaining.  As described below, this approximate
mass balance is estimated according to a combination  of complete historical
data from past operation and more detailed, current intensive soil  and
waste characterization data.   If  proper data is  available, the Scenario 1
approach  should confirm that hazardous constituents are  being  degraded,
transformed, or immobilized at the  HWLT  unit.

     The first step in determining the approximate mass balance is compila-
tion of the  past history of the HWLT unit performance,  temporal  and areal
distribution of the land treated wastes, and waste  characteristics.   Three
types of  information  are needed to construct this past history:
                             /
     1)  documentation of acceptable performance of  the existing HWLT
         unit (as defined in Section 3.1.2);

     2)   history of  waste application (Section  3.1.3); and

     3)   history of  waste quality (Section 3.1.3).

     This historical  data collected during interim status will have certain
limitations because the ISS waste analysis  and UZM  standards required the
owner or operator to  address only those "hazardous waste constituents" that
1) are in  40 CFR  261 Appendix VII for listed wastes,  or 2) cause a waste to
exhibit the EP toxicity characteristic for characteristic wastes (see Table
1 of §261.24).  The land treatment  demonstration standard, however,  re-
quires data on al 1 hazardous constituents  in Appendix VIII of 40 CFR 261
present in the waste.  Thus, the historical record must be supplemented
with more comprehensive data addressing all hazardous constituents  in the
waste.   This may be accomplished by  first  collecting detailed,  intensive
data on current waste quality and site conditions and  then correlating this
data to the general waste and  site data included in the historical  record
(i.e., making  a  retrospective  extrapolation).  For example,  the  applicant
may be able  to establish  a  correlation  between the  concentration of waste
constituents analyzed during interim status and  the concentration of Appen-
dix VIII  constituents  identified in the current  comprehensive waste ana-
lyses for the Part B appl ication (see Chapter 2).  It may  be assumed that


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the comprehensive waste analyses represents  the mean of the waste stream
population.  Records from past analyses  should be used to support the
assumptions.  This  correlation can then be used along with the data on
waste application rates in the  historical  record  to  roughly estimate the
loading rate  of  individual hazardous constituents.

     Therefore,  in addition to the historical  records,  the applicant must
gather and include  the following information  in his analysis for Scen-
ario 1:

     1)   current  complete  characterization  of soils (i.e., reconnais-
         sance sampling)  and representative waste  streams for all
         hazardous and pertinent nonhazardous  constituents (as de-
         scribed  in Chapter 2);  and

     2)   recent  intensive  site characterization  for hazardous consti-
         tuents  (as described  in Chapter  4).

     The intensive  site-data  collection  (Chapter 4)  provides data on pre-
sent site conditions such as concentrations of hazardous constituents in
and migration below the treatment zone.  Although the sampling prescribed
in Chapter 4 is  much more comprehensive  than reconnaissance sampling de-
scribed in  Chapter 2,  some or all of the data obtained from  reconnaissance
sampling may nevertheless be applicable.  The intensive  site  sampling
involves coring  and  subsampling from the  surface to 200 cm. Analyses should
be performed  for all hazardous constituents known or suspected to  be in the
waste or waste degradation by-products.   Background site information can
be used as a basis for judging  the  contribution from naturally  occurring
constituents  (e.g.,  metals).   (Note:   Chapter  4  also describes  the inter-
pretation of all  data from the Scenario  1 analysis.   Once information
gathering and presentation are complete and acceptable,  the applicant may
apply for a full-scale  Part 264 facility  permit.)

     In considering  the  Scenario 1 option,  the  applicant should  recognize
the limitations  of  this approach.  First, the approach requires  documented
historical  records and  intensive soil and waste  characterization  data that
must allow one to make reliable retrospective extrapolations and conclu-
sions  regarding the  treatment of  individual  hazardous  constituents.
Second,  the applicant is limited to the  waste application rates and fre-
quencies used during  the past operations  (i.e., the applicant does not have
the opportunity to evaluate higher loadings  or frequencies).   Third,
because  Scenario 1  is  a  retrospective analysis,  it  is  unlikely  that
sufficient  information on  the relative  mobility  and  degradation  of
hazardous constituents will be available  to  determine the  "principle
hazardous constituents" that may  serve  as indicators  for  UZM during full-
scale operation.  In most cases,  prospective  studies  (as  presented for
Scenarios 2-4)  are  needed to provide sufficient data to make selection of
PHCs possible.
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3.2.2  Scenario 2

     Scenario 2 is generally designed for existing HWLT units which demon-
strate relatively good design and operation (i.e., comply with ISS,  have
waste  application  rates at  or  below  optimum for  good degradation  of
organics, and show no significant hazardous  constituents leaching below the
treatment zone) but which lack  adequate long-term records to  establish a
reliable  mass  balance  of waste  application and constituent fate.   From a
permitting  perspective,  this  scenario  involves  a two-phase  permit
(described in Chapter  1);  technically, it requires the applicant to choose
and carry out  either a barrel lysimeter study  (Chapter 6) or a  field  plot
study (Chapter 7)  to be followed  by  acute toxicity testing (Chapter 5).

     An  applicant who  has determined in consultation with the permitting
official that his HWLT unit qualifies for Scenario  2 should submit a Part B
permit application for  a two-phase permit.  As required under §270.20(a),
this application should outline a  treatment  demonstration plan, which
should include  the barrel lysimeter study,  field plot study, or an equiva-
lent study design.  The  applicant should  identify his preference in the
pre-application meeting with  the  permit  writer to allow a  discussion of any
questions or issues  early in  the  permit  process.

     Under  this scenario, the permit writer writes a two-phase permit:
Phase 1 outlines conditions  necessary to meet §264.272(c)  for the treatment
demonstration, and Phase  2 outlines provisions for  the full-scale facility
design and  operation (including all  Subpart  M  and other  general  require-
ments).  All the  administrative  steps (except permit modifications) for the
two-phase permit,  including  public hearings,  occur at this point.

     After  the  two-phase  permit  is issued,  Phase 1 is effective during the
period of the treatment demonstration (i.e., approximately  one year in this
case).   It should  be noted that Phase 1 of the permit  is only applicable to
the barrel  lysimeters or the portions of the  HWLT  unit on  which  field  plot
demonstration tests are being done;  these  portions may be the size recom-
mended in Chapter  7 of this document or some larger area   designated by the
permit writer.  Since  the interim status of the  remainder  of the HWLT unit
is unaffected during  Phase 1, the owner/operator  may continue to operate
under  interim  status  on this remaining  area  during the demonstration.
Nevertheless,  the owner/operator  is  subject  to enforcement action if in-
terim status violations occur in  this remaining  area.

     The  owner/operator  must submit  the following  to the  permitting
authority within 90 days of completion of the tests:  1) a certification
that the LTD tests have been  carried  out in accordance with Phase 1 of the
permit and  2) all the data collected during the LTU along with  interpreta-
tions and final design adjustments.

     The permitting authority then evaluates the  results  and modifies the
second phase of the permit (usually a minor modification  under  §270.42) to
incorporate  these results.  Phase 2 of the  permit  (i.e.,  full scale opera-
tion) becomes effective after  the modifications  are completed.
                                     37

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     Technically,  Scenario 2 allows the applicant a choice between  barrel
lysimeter (Chapter 6) or field plot studies  (Chapter 7).  It is assumed
that enough  is  known about the site to  limit the  LTD work to a single test
system without  prior toxicity  testing or other  bench  scale work.  Depending
on findings  and climatic conditions (e.g.,  unseasonably  dry weather or poor
degradation  rates may lead  to an extended time  frame), the barrel  lysimeter
study and the field plots should  run for one year or more.  In  the mean-
time, routine monitoring of the HWLT unit according to the monitoring plan
and analysis for all hazardous and pertinent nonhazardous constituents
should continue in  conjunction with the barrel  or field plot testing.
Finally,  acute  toxicity testing must be  performed as  described in Section
5.3.2, Maximum Residual Concentration.

3.2.3  Scenario 3

     If an owner or operator of an  existing HWLT unit plans to continue the
same or a more  conservative design  and operation but the design and  opera-
tion are  unacceptable  according  to the  criteria in Section  3.1.2, Scenario
3 or 4 are the available options for  the  LTD.  The  permit  writer will
determine which option  should  be followed.  The deficiencies  in  such HWLT
units require  that a greater amount of information be collected in this
scenario than  in Scenarios 1  or 2.  Additionally, the permit approach is
significantly different from Scenario 2 in terms of when a two-phase  permit
is issued.

     Lack of information to allow a satisfactory two-phase  permit to be
written prevents  such a permit from being  issued until considerable LTD
work is al ready complete.  Under §270.63(a)(l), a two-phase permit  may be
issued only  if  the Part B application includes  substantial, although  incom-
plete or  inconclusive,  information upon which  to base  the issuance.   Since
owners or operators subject to Scenario  3 do not immediately  satisfy this
requirement, the  first portion of testing in Scenario 3 is designed to
generate  "substantial,  although incomplete or inconclusive, information" so
that the  facility may  qualify for  a  two-phase  permit.   This first portion
of testing,  which  includes  a  laboratory toxicity test  and a  barrel   lysi-
meter or field plot study, may be  done while ISS remain in force for the
HWLT unit.   Upon completion of the first portion of testing,  Phase 1 of  a
two-phase permit  is issued to cover a non-intensive, two year follow-up
study on  a  large scale.  Finally,  Phase 2  of  the two-phase permit becomes
effective pending  satisfactory completion of the follow-up work.

     The  above  approach is the most expeditious route to completion  of the
LTD and to final  permitting  of HWLT units falling into Scenario  3.  As
discussed in Chapter 1,  owners/operators may conduct treatment demonstra-
tion studies at an interim status unit,  provided  the ISS are not  violated;
such an approach  is taken in  the  first portion  of  this  scenario.   As an
alternative, however, the applicant may  choose Scenario 4 and may apply for
a short-term permit.

     The  technical requirements for Scenario 3 involve several  steps.
First,  the laboratory-level acute  toxicity  test (Chapter 5) determines the
concentration  of fresh waste in  soil   that  would be  acutely toxic to


                                   38

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decomposer organisms  and helps set waste application rates  for  the  second
step, either barrel  lysimeter studies  (Chapter 6) or a field plot study
(Chapter  7).  Findings of the first two steps along  with  results of follow-
up acute toxicity testing (Section 5.3.2) may lead to lower or even  higher
annual waste loading rates than applied previously at the HWLT  unit.  The
revised  loading rate and any  other necessary improvements in design and
operation are  then verified  in  a  large scale two year  follow-up study
(Chapter 9), done under Phase  1 of a two-phase permit, that may encompass
the entire HWLT  unit.   Satisfactory  completion and documentation  of the
Phase 1 follow-up study would lead to modifications  to Phase 2 of the
permit.   Phase 2, which applies to the full-scale operation, becomes  effec-
tive  after the modifications are  made.   Thus, Scenario 3 requires  approxi-
mately 3 years  from initiation of the LTD to the final decision on Phase  2.

3.2.4  Scenario 4

     Any new or redesigned existing land treatment  unit, including cases of
al tered waste  qual ity (i.e.,  different hazardous constituents to be 1 and
treated),  significantly increased waste  loading rates,  or drastic changes
in the soils used, requires that  the applicant follow Scenario 4  to  obtain
a  permit.  Likewise,   units having significant ISS violations may also be
required  to follow Scenario 4.   While  its  technical  requirements are the
same  as those of Scenario 3,  Scenario 4  is  unique  in its use of  the  short-
term  permit option (described  in  Chapter 1).

     Prior to beginning the LTD, the applicant must obtain a short-term
treatment demonstration permit which  should incorporate only  those  provi-
sions necessary to meet  the  general performance standards in §264.272(c).
Public comment and hearing are required.   Once this permit is obtained, the
LTD  may  begin.   If the facility is  existing and if the unit is in com-
pliance with the  ISS  requirements, continuance of present operations under
interim status  may be permitted during LTD  performance.  Once the  technical
effort for the LTD is complete,  a  final Part B  application incorporating
the LTD results should be submitted.   A  full scale  Part 264 facility  permit
is issued after appropriate administrative  steps, including a second  manda-
tory  period for public comment and hearing, are taken.

     The technical steps involved are identical to the Scenario 3 approach.
First, acute toxicity testing  (Chapter 5) is done  as a preliminary screen-
ing measure to hel p  set waste appl ication rates prior  to either a barrel
lysimeter (Chapter 6) or field plot study (Chapter 7).  Follow-up acute
toxicity testing  (Section 5.3.2) is  then  done to help set annual  waste
application rates.  Finally,   information from this intensive  study  on the
degradation,  transformation, and  immobilization of the waste(s)  guides the
design  to  be  tested  in a non-intensive two year  follow-up  study
(Chapter 9).
                                    39

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                               Chapter 4

                     INTENSIVE SITE DATA COLLECTION
     For those sites with good  records  of waste analysis,  waste
application, unsaturated zone and groundwater monitoring,  and operating
acceptably,  on  intensive soil sampling of the facility to  confirm treatment
of hazardous constituents may be undertaken.  (See Chapter 3 to confirm
whether this  technical approach is acceptable for  a given site.)   The
intensive  soil  sampling data  described in this chapter may be supplemented
by  data  collected in the  reconnaissance  soil  sampling  (Chapter 2).
Together,  these two sets of  data  (along with the historical record) satisfy
the  Scenario  1 demonstration  approach.  The following describes  the
intensive  soil  sampling that is  needed as a component of Scenario 1.
4.1  SOIL  CORE SAMPLING AND ANALYSIS

     With  some  exceptions,  the  soil  core  sampling  approach  should  follow
that described in Chapter 2, reconnaissance site data collection.  Within a
uniform area,  twelve soil cores should be collected  randomly,  unless the
uniform area is greater than 12  acres,  in which case a minimum of one  soil
core per acre  should be collected.  If reconnaissance sampling was done at
half this density, as recommended in Chapter 2, only one additional  core
per two acres is  needed to complete the requirement.  Unless widespread
contamination was  found outside the HWLT unit, no further background  sam-
pling is necessary.   Additional  soil  core  samples  should be collected at
select locations  (i.e.,  "hot spots") within the HWLT unit where wastes are
most likely  to build up or migrate.   Except for well  run units  (where
attention  is placed on uniformity  of waste applications  and management) few
sites can  avoid at least  some  sampling of  select locations  in addition to
the random sampling.

     The depth  of  sampling  should  be  as follows:  0-15, 15-45, 45-90, 90-
150, and 150-200  cm.  Depending on the number of  samples analyzed and the
type of analyses performed, the analytical data obtained from the  recon-
naissance  investigation may be  used to  partially fulfill  the  data require-
ments of this  investigation.


4.2  SOIL-PORE LIQUID

    The applicant should collect samples from the existing  soil-pore liquid
samplers  as  soon as possible for analysis.   These  devices should be
randomly located  at a rate  of  one  per  two acres,  with a minimum of six per
uniform area.  Additional  samplers  may  be needed at select "hot spot" loca-
tions,  as determined by  soil,  topography,  waste  distribution,   and
                                   40

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operational  features.


4.3  ANALYSIS OF  SAMPLES

     For purposes of the intensive site data collection described  herein,
analysis should be at Tier II,  as outlined in Chapter  10,  for all  soil
samples collected between 0 and 2 meters and for all  soil-pore  liquid
samples.


4.4  INTERPRETATION OF  DATA

     Because the  intensive  site  data collection approach is  a mass balance
method,  the applicant should present his analytical data from waste, soil
cores, and soil  survey samples, along with records of past  activities, to
meet two objectives:

     1)  To assess  contaminant immobilization, statistical analysis of
         soil core  and  soil-pore liquid data should be done by compar-
         ing the  concentrations  of  hazardous constituents in  soil and
         soil-pore liquid  below the treatment zone with background
         values.   A significant difference would indicate hazardous
         constituent mobility unless other circumstances account for
         any such differences (e.g., pockets of buried materials not
         associated with  the  land  treatment operation).

     2)  To assess degradation and transformation,  treatment zone
         waste application  data  and waste and soil  analyses  should be
         used to  determine  the  quantity  of organic hazardous
         constituents  (OHCs) degraded and the  conserved  species built
         up.  Apparent degradation, which may in fact include other
         losses such as volatilization or leaching, can  be  expressed
         as:

              OHCs  Applied - OHCs Remaining = OHCs  "degraded"

         This relationship  should  be determined for all  nonconserva-
         tive  hazardous constituents (e.g., organics).

In the  latter  evaluation, the "zone of incorporation" (typically 30 cm or
less,  but a maximum of 60  cm) should be considered  separately from the
remainder of  the treatment  zone.  This  is because  active degradation pri-
marily  occurs  in the zone of incorporation, while  any materials that have
penetrated deeper or have been covered by successive waste applications are
effectively buried.  Although some  degradation may  occur at depth, only the
soil's capacity to  immobilize these deeper  materials  should  be considered
to achieve treatment  in most cases.  Within the  zone  of  incorporation
(ZOI),  the mass balance for each hazardous organic  constituent should show
that:
                                    41

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     1)   Less than 2Q% of the total amount of each hazardous organic
         constituent applied over the life of the unit remains  in  the
         zone of incorporation (as measured  at or adjusted to  the
         beginning or end of the degradation  season) (API,  1983); and

     2)   The concentration of each hazardous organic constituent in
         the top portion of the ZOI  is  less  than  two times  the annual
         concentration of that constituent applied (EPA, 1983A).

The top  portion  of the treatment zone is chosen to avoid artificial dilu-
tion due to the transition to deeper,  "cleaner"  soils.  Below the transi-
tion from the ZOI  but still  within  the  treatment zone (e.g., 45-90  and 90-
150 cm), concentrations of  hazardous constituents should decrease with
depth to practically background levels near the lower treatment  zone boun-
dary.  If great depths  of  undegraded organics are present (e.g., the land
surface  is one or more meters above the  original  level  due  to organics and
solids build-up),  the issue must be addressed appropriately  in the  closure
plan. More importantly, this condition eliminates Scenario  1 as  the appro-
priate permitting/LTO option.
                                   42

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                                Chapter 5

                         TOXICITY TEST PROCEDURE


     The acute toxicity assay should provide two groups of  data.  First,  an
evaluation of the toxicity of the soil, waste, and four soil-waste mixtures
is made to estimate  the initial waste application  rates {mass/area/applica-
tion) for use  in the barrel  lysimeter or field plot  studies (Chapters 6  and
7).   Second,  the  analytical  data from the barrel  lysimeter field plot
studies are used to  refine the waste application rate prior to  the  follow-
up field study (Chapter  9) or final permit issuance. Refinements in the
application rates are based upon the  data from acute toxicity testing  of
the most resistant  specific hazardous organic constituents found in the
lysimeter or field plot studies. A revised waste loading rate may be deter-
mined by  estimating  the  maximum allowable residual concentration  in soil
of each hazardous  organic constituent at the land treatment unit and calcu-
lating  the  degradation rate of  that constituent found in  the lysimeter  or
field plot work.

     The  toxicity test procedure selected should employ a single species,
acute toxicity test to estimate the acute impact of waste application  or
waste fractions on the soil biota  responsible for waste treatment.

     For any toxicity  test to be  practical  for environmental monitoring,  it
must be  validated extensively.  The Microtox System™ suggested below is a
rapid and simple toxicity test which has been validated with a large number
of pure  compounds and complex industrial  waste waters  and sludges.  This
procedure, as any other bioassay which  could be recommended,  offers poten-
tial disadvantages.  First,  the Microtox™ test organism is a photolum-
inescent bacteria of marine origin, which  may not accurately represent  the
response of soil microbes.  In addition, this test measures the toxicity  of
water soluble constituents  and may therefore  underestimate the toxicity  of
hydrophobic compounds.  Extensive developmental work and  evaluation that
involves a variety  of waste-soil mixtures tend to discount  either disad-
vantage  as a hinderance for the  purposes of the test.

     Alternate procedures of measuring acute  toxicity  include  the  follow-
ing: tests that  use  aquatic organisms  such  as  the Daphnia and  fathead
minnow (Peltier, 1978), phototoxicity tests that measure  root elongation
(Edwards and Ross-Todd, 1980), a terrestrial toxicity  test  that uses earth-
worms (Neuhauser et al.,  1983), and a plate count assay that uses soil
bacteria (Brown et al., 1983).  Each of these alternate procedures offers a
separate set of potential advantages and problems.  In addition, none
approaches the rapidity and simplicity of  the Microtex™ test.

     No single bioassay can provide a comprehensive  view of toxicity. Only
through a battery of  acute and  chronic toxicity tests can a  comprehensive


                                    43

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 T
view of toxicity be obtained.   However,  almost any  validated  toxicity test
can produce  the information required  in  this chapter for a treatment demon-
stration, since the  primary objective of such a procedure,  within the
context of  a  land treatment  demonstration,  is  to  use a rapid,  single
species toxicity test to indicate the optimum initial  application rate for
a specific  hazardous waste.


5.1  TEST SYSTEM DESCRIPTION

     Since the test system used as an acute toxicity bioassay should be
rapid and simple and should have  been  validated with a large number of
samples, the  Microtox System™ (registered  trademark,  Beckman  Instruments,
Inc.) is suggested  as  the primary toxicity  bioassay.  Numerous evaluations
have revealed that Microtox is sensitive to a wide spectrum  of toxicants,
with results  correlating  with other procedures  (Qureshi et al.,  1982;
Casseri et  al., 1983; Burks et al., 1982).  The Microtox System™,  which
utilizes a suspension  of the  marine  luminescent bacterium (Photobacterium
phosphoreum) as a bioassay organism for measuring acute toxicity  in aqueous
samples, is an instrumental approach in  which  bioassay organisms are han-
dled  like  chemical  reagents.   Suspensions containing approximately
1,000,000 bioluminescent organisms are "challenged" by the addition of
several concentrations/dilutions of an unknown sample.   A temperature con-
trolled photometric device with attached recorder quantitatively measures
and records  the light output of the organisms in each suspension before and
after they are challenged;  a reduction of light output  reflects  a deterior-
ation  in the  state of  health of  the organisms,  thereby indicating the
presence of toxicants in the sample.  A comprehensive discussion of the
Microtox System™,  including  its  benefits and limitations, principles of
operation,  operating procedure, and basic data  reduction  schemes, has been
prepared for distribution by Beckman  Instruments,  Inc.  (1982).

     Two major pieces  of experimental apparatus are required to  conduct the
toxicity test  procedures.  First,  a tumbler shaker,  a  wrist-action shaker,
or a platform shaker is used to extract the water soluble fraction from
each sample, and then the Microtox™ system  is  used to test this extract.


5.2  GENERAL EXPERIMENTAL PROCEDURES

     The Microtox1"  test is conducted on the water soluble fractions from
two groups of  samples.  The following sections  outline  the methods used to
obtain these  samples and provide a  brief description  of the  Microtox™
procedure.

5.2.1   Water Soluble Fractions

     The following  procedure  is used to  obtain the water soluble fraction
(WSF):
                                    44

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    a.  Place a 100 g (dry wt) sample of soil, waste,  or soil-waste
        mixture into the extraction  vessel.  If the waste has a high
        water content, a thoroughly mixed sample can  be centrifuged
        to obtain the WSF for toxicity testing, thus eliminating-the
        need for the extraction step.

    b.  Add 400 ml  of distilled,  deionized  water (4:1 vol/wt ratio)
        to the vessel  and cap tightly.

    c.  The tumbler shaker is the method of choice.   However, if a
        wrist action shaker is used, place the vessel  on the shaker
        at a 180°  angle; if  a platform shaker is used, place the
        vessel  on  its side.   In all cases, be certain the cap is on
        tightly.

    d.  Allow the  flasks or bottles to shake for 22 ±2 hr at approxi-
        mately 30  rpm in the tumbler  shaker or 60 rpm on the wrist-
        action or  platform shaker.

    e.  Following  the specified mixing period;  remove  flasks from the
        shaker  and al low them to  sit  for one hour.  Pour the decant
        into  high-speed centrifuge tubes,  adding 0.49  of NaCl for
        each 20 ml  of sample, shaking, and then centrifuging at  2,500
        rpm for  10 minutes.

    f.  Prepare a  sample from each test  unit for Microtox™ testing by
        carefully  pipetting 20 ml  of  centrifugate from each centri-
        fuge tube  into a clean graduated cylinder and  storing  at 4°C.
        Care must  be  taken to ensure  that any  floating material is
        not transferred.  As soon  as all samples are  prepared, begin
        Microtox™  testing; conduct all  tests the same day that they
        are prepared.

    g.  Follow the test procedure  outlined in the Microtox  System
        Operation  Manual (Beckman  Instruments,  1982).

5.2.2   Test System  Operation

    While detailed instructions,  reagents,  and the instrument can be
obtained from  Beckman  Instruments,  Inc. (Carlsbad, CA), the following is a
brief  outline  of  the procedure:

    a.  Adjust the instrument to the desired temperature (15°C for
        most applications).

    b.  Rehydrate  the cell  suspension.

    c.  Place 5-7  pairs  of cuvettes  in incubation block.

    d.  Add 0.5 ml  diluent followed by  0.01  ml  of cell suspension to
        one member of each pair of cuvettes.
                                    45

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     e.  Add 1.0 ml of appropriate sample  dilution (or sample to be
        compared) to the other  member of each pair of cuvettes.   One
        cuvette receives diluent only and serves  as a blank.

     f.  Allow 10 minutes for cuvettes to reach test temperature.

     g.  Take an  initial  reading of  light  output (relative to blank)
        for each cell  suspension.

     h.  Transfer 0.5 ml  from blank and sample cuvettes  to appropriate
        cell suspension.

     i.  After  the desired reaction  time (5 minutes  for most
        applications) take final reading of light output for  each
        cuvette.

     j.  Use blank to correct sample  for time-dependent drift in light
        output.


5.3  TOXICITY TEST APPLICATIONS  AND PROCEDURES

     It was  stated earlier that the acute toxicity test is used  for  two
purposes.  The following sections describe the methods for the two determi-
nations  and  provide  a rationale  for each.

5.3.1  Application Rate Determination

     Where some  question exists  about the acceptable annual  waste  applica-
tion rate  influenced by degradation (due to current site overloading,  a
desired  increase  in  application  rate  over past practices, or a new site)  a
method must  be employed to select  a  reasonable rate(s)  for testing out of
the universe of possibilities.   A well  designed  acute  toxicity  test pro-
vides a reasonable starting point by  defining the amount of waste  that  may
be applied in  a  single dose  to  avoid undesirable impact on  soil microbial
populations essential to organics degradation.     The specified single
application  limit in a barrel   lysimeter or field plot  study that  employs
varying application frequencies (Chapters  6 and 7) can then be  used to
determine  the frequency of application  and  annual waste loading rates.  The
following method is designed to determine  the single application rate
(mass/area/application):

     a.  Obtain  a  5  kg sample of soil and a 500 g sample of the waste
        to  be tested.   Be certain that the characteristics  of  the
        samples of soil and waste  are representative of the char-
        acteristics anticipated at the  site.

     b.  Conduct Microtox™  test on  waste WSF.  If the waste has a
        significant water content, obtain a sample  for  toxicity
        testing as  described in section 5.2.1.3.  Add 0.45  Nad to 20
        ml  of contrifugate and  conduct Microtox™  test as described in
        Section 5.2.2.  For  other waste samples, obtain the WSF  for
                                   46

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    Microtox™ testing  as described  in  Section 5.2.1.   If the
    waste WSF has an  EC50  of greater than 33,  no  additional  tests
    are required since acute toxicity will not  be  a  significant
    problem.

c.  Choose four loading  rates  for waste-soil Microtox"1  testing
    according to the  following criteria:

       1)  the highest loading rate to be used is equivalent to
           the lower  limit of the 95% confidence  interval  for the
           waste WSF  EC50;

       2)  calculate  waste WSF EC50 and 95% confidence interval;
           and

       3)  the remaining three loading rates  represent 1/4, 1/2,
           and 3/4 of the  high rate selected.

d.  Weigh out two 100 g samples of air-dried  soil which has been
    crushed and sieved to 2 mm.   Extract  the  WSF as described in
    Section 5.2.1 and conduct Microtox™ tests  on  each  sample.

e.  If the soil WSF  is  non-toxic {i.e.,  no  significant light
    reduction is effected in the 100%  WSF  dilution),  normal
    dilution water can be used to conduct the remaining tests.
    If the soil  WSF  effects 'a  significant  light reduction  (i.e.,
    the soil  has some residual toxicity),  the  soil extract should
    be used as diluent to determine ECso's  for each loading rate
    tested.

f.  Weigh out four 300 g samples of soil.   Add waste  to the soil
    samples  at  loading  rates  (wt/wt) determined  by the criteria
    described above.
                   )
g.  From each of the  four  samples,  remove two 100 g (dry wt) sub-
    samples and place in a flask or bottle for extraction.  Dis-
    card the remainder of the  sample.

h.  Extract  each of  the eight subsamples with distilled, de-
    ionized water according to the procedure described in  Section
    5.2.1 and  conduct  Microtox™  test  on  the  water soluble
    fraction.

i.  Calculate the EC50 for each waste-soil  WSF.   The  EC50 is the
    effective concentration of  the  WSF  which  causes a 50%
    decrease in  light output by the test organisms.   Transpose
    each EC50 value to toxicity units in soil  using the following
    equation:
                     Soil Toxicity = 42°-  x 4
                               47

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        Prepare  a  log-log plot of loading rates  versus toxicity
        units.  The interception point for 20 toxicity units is the
        predicted  maximum acceptable initial loading rate (MAIL).
        The three rates  for subsequent tests are the MAIL  rate  +25%.

5.3.2  Maximum Residual Concentration

     In  order for the specific  organic degradation  rate data obtained from
the barrel lysimeter or field plot study to be of any use,  that rate of
degradation must  somehow be related to an upper limit of accumulation in
soil for each important constituent.  The upper  limit  is characteristically
the concentration  at which soil  microorganisms succumb to the compound's
toxic characteristics.  If degradation  rates  of all hazardous  organic
constituents are more rapid than the bulk organic fraction (e.g., oil  and
grease), annual  waste application rates may be based merely on the bulk
fraction or other limiting factor (e.g., leaching hazard); however, more
resistant  hazardous organics, especially those present in  relatively large
concentrations, may be the waste constituents that  ultimately limit degra-
dation.  The following  method should be used  as  a  follow-up  to  barrel
lysimeter or field plot testing and  the results  used to help  establish
final  permit conditions or  conditions for  a two year follow-up study.

     a.  Using the  results from  the lysimeter or field plot study,
        determine the most resistant  specific  hazardous organic con-
        stituents.

     b.  Obtain a 2 kg sample of soil and chroraatographic  grade sam-
        ples of each resistant hazardous organic constituent  to be
        tested.  Be  certain  that the characteristics of the  soil
        sample are representative  of  the characteristics anticipated
        at the site.  If the HWLT unit is currently operating, the
        soil  should come from active areas to which waste has not
        recently been applied  (i.e., the area is considered  to be
        ready for reapplication of  waste).

     c.  Weigh out  five  300 g samples of soil per  chemical  to be
        tested.  Add each chemical to four of  the  soil samples at
        four  loading rates,  leaving the fifth  soil sample as an
        unamended  control.  Prepare  a sixth sample with an aqueous
        solution of the  chemical  at its solubility limit.

     d.  From each of the five  soil  samples for each  chemical tested,
        remove two 100 g (dry  wt) subsamples and place in  a flask or
        bottle for extraction.  Discard the remainder of the  sample.
        Split the aqueous  solutions into duplicates.

    e.  Extract  each of the ten soil  subsamples with distilled,
        deionized water  according to  the procedure described in Sec-
        tion 5.2  and conduct the  Microtox™  test on the water soluble
        fraction.   Using soil  extract rather than diluent as blank,
        determine the concentration of each  waste  constituent (wt/wt)
        required to give 80 percent reduction in light output


                                   48

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        If the chosen chemical additions to the soil are not enough
        to induce a toxic response  (EC8D) to the water soluble  ex-
        tract, greater  amounts of chemical should be  added to  and
        extracted from additional soil  samples  for analysis unless
        even  the  saturated  aqueous  solution  induces  no  toxic
        response.

        The concentration  in soil  (wt/wt,  dry)  of each specific
        hazardous constituent  producing an 80  percent light reduction
        (EC80) in the water  soluble extract is considered the thres-
        hold  or  critical (Ccn-t)  concentration at which unacceptable
        microbial  toxicity occurs (Brown et al.,  1983).   In some
        cases, a given  constituent may not be capable of inducing
        such  toxicity, thus releasing it from concern  as  a  limiting
        constituent from the standpoint  of degradation.
5.4  DATA  INTERPRETATIONS

     Data  from the Microtox™ test are  used to determine  both the percent of
fresh waste in soil (wt/wt) required to give  a WSF EC50 value of 20 percent
and the concentration (mg/kg) of each specific hazardous constituent in
soil  required  to give an 80 percent reduction in light  output (ECop).
These calculations define the initial  waste loading  rate for  later pilot
scale testing (based on overall  waste toxicity effects) and  the maximum
allowable residual  concentration in soil for specific hazardous consti-
tuents,  respectively.  The maximum residual  concentration,  considered in
conjunction with the compound degradation  rate (i.e., half-life in soil)
found in the  lysimeter  or lab study and desired land treatment unit  life,
can provide  an  acceptable waste loading rate to be used in either the
follow-up field study or a full  scale  facility permit.

     a.  Determine mean chart readings for three blank cuvettes (cell
        diluent)  and two cuvettes for each  sample  concentration at 5
        minutes  (t5) after adding sample to reconstituted  cell  sus-
        pension.

     b.  Calculate the gamma 1 ight decrease (ratio of 1 ight lost to
        light  remaining)  for each waste-soil WSF or compound concen-
        tration  in soil  using the following formula:
     where:    =  gamma light decrease;
              =  mean chart reading  for blank at time  t;  and
              =  mean chart reading  for sample.

     Calculations for the remaining  WSF dilutions or soil concentrations
are as fol lows:
                                    49

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         =  corrected 0 time Tight level
            5 minute light level  for sample

    corrected 0 time light level  = (0 time light level) x (blank ratio)


        Blank ratio = (5 minute blank light  level)
                      (0 time blank light level)
     c.   Plot gamma  light decrease  vs.  concentration  of  waste  WSF or
         compound  in  soil  on  log-log paper.   This  should convert the
         dose-response curve to a straight line and allow the estima-
         tion  of the  waste-soil WSF  EC50  or the EC80 concentration of
         potential residual toxicants in soil.

     d.   Profit analysis  provides  an  attempt method for determining
         EC5Q  values and a 95% confidence  interval.

     e.   Average duplicate test unit  ECgQ or ECgQ values  for each
         sample.

     f.   Complete calculations  as desribed  in Section 5.3.Hi) to
         determine the MAIL rate.
5.5  MAXIMUM ACCEPTABLE INITIAL LOADING  RATE

     Detoxification of a hazardous waste in soil can be achieved only if
the waste is applied at such a rate that the matrix of toxic constituents
contained in the waste does not significantly impact  soil  bacteria.   The
Microtox01 acute  toxicity test described  in  this chapter provides one method
of determining a MAIL rate window which  is  acceptable to the soil microbes.

5.5.1  MAIL Rate Window Determination

     The following steps  are  used to establish the MAIL rate window for
subsequent demonstration studies:

     a.  Calculate an ECcQ and the 95% confidence interval for the raw
         wast WSF.  The Tower  ECtjQ limit for  the confidence  interval
         provides the upper loading rate for waste-soil toxicity test-
         ing.  Additional  rates for testing are 1/4,  1/2, and 3/4  of
         this  rate.

     b.  Calculate an ECg0 for  each waste-soil loading rate WSF.

     c.  Transpose ECcg values for each  loading rate to toxicity units
         using the following formula:
                                    50

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                   Toxicity Units =    °   x 4
d.  Prepare a log-log plot of the WSF toxiclty unit values  versus
    the  waste-soil  loading rates extracted.   Find  the
    interception point for 20 toxicity units.

e.  Determine  the  loading  rate window (waste weight %) according
    to the waste-soil loading at this interception point +25%.
    This loading  rate can  be transposed as  desired if the  water,
    solids, oil , etc. of the waste and the bulb  density  of the
    soil are known (i.e., oil content per m , etc.).
                               51

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                                Chapter 6

                         BARREL LYSIMETER STUDY

     Design and  operating requirements for  a  land treatment unit are
focused on maximizing soil  treatment of hazardous constituents  via  degrada-
tion, transformation, and/or immobilization processes within the treatment
zone and on minimizing the escape of these constituents to  groundwater,
surface water,  and air.  The potential  for  transport of  hazardous  consti-
tuents from the treatment zone  via vertical migration depends on  the con-
centration  of  water soluble  constituents in the waste,  the absorptive
potential  and capacity  of  the  soil,  the kinetics of  soil  water movement,
and the degradation potential  of mobile waste constituents and  intermediate
degradation  products  (EPA,  1983A; Kaufman,  1983).

     The barrel  sized lysimeter provides a test apparatus that can be used
to interpret the various interactions influencing land treatment.   A barrel
lysimeter is a large, undisturbed soil  monolith  enclosed by a watertight,
waste compatible casing and equipped with leachate collection devices.
Twelve  such units are typically required to conduct  most treatment demon-
strations.   Although  the barrel lysimeter  is  of limited size compared to
field plots, both degradation  and mobility can be measured with  this ap-
paratus, with test conditions closely approximating  those  anticipated in
the field.   The barrel size suggested  here  (55 gallon drum) is  large enough
to encompass most soil macrofeatures and  soil-water  relations.   However,
alternative designs which use an approximate diameter  to depth  ratio of
1:1.5 may also  be  acceptable.

6.1  EXPERIMENTAL DESIGN

     The experimental design suggested for  the  barrel  lysimeter  study is a
randomized complete block design, with three replications  of each treatment
per soil series  to receive waste in the actual  HWLT unit. Previous ex-
perience with  a  well operated HWLT  unit  (see permitting Scenario 2 in
Chapter 3) or the results of acute toxicity testing (see Scenario 3  or 4)
as described in Chapter 5 should determine the waste application  rate  to be
studied.  Unless no  change in current waste  loading rate is desired or
anticipated,  this study  should typically test three annual waste  loading
rates and a control  and  should yield  12  barrel  lysimeters  per soil series
(uniform area) tested.

     For Scenarios 3  and 4,  where acute toxicity testing  is  employed to set
waste application rates, the concentration of  waste  in soil corresponding
to the LD50  is used to determine the rates. The LD50 waste concentration
is the amount of waste to be applied in  a single application  (kg/ha/appli-
cation); all  treatments that receive waste  should have this amount applied
initially.   The frequency  of  waste reapplication will then determine the
                                    52

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annual waste loading rate (kg/ha/year).  For barrel  lysimeter testing,
waste application is recommended on three schedules (Table 6.1) resulting
in the suggested three waste application rates.

     The schedule shown  is for a 12 month  study.  Group numbers  correspond
to treatments receiving various  respective waste application frequencies.
As the table demonstrates, the ideal application frequencies for the test
are  semiannual,  quarterly, and  bi-monthly.  In  relatively  harsh climates
such as cold northern locales, applications  may  need to be  limited to the
warm season; however,  if the local climate is suitable for year round
biological activity, the  applications may be spaced evenly throughout the
year.

     Under Scenario  2, the current annual  loading rate (kg/ha/yr) should be
divided into four equal  applications at appropriate intervals through the
year.  These same single application amounts (kg/ha/application) should be
applied to the other treatments at different intervals  (i.e.,  every two
months and six months)  to yield three annual loading rates.  As for the
above  scenarios, Table 6.1 may be used as a guide to waste application and
soil  sample  scheduling.

6.1.1  Collection and Installation of Barrel  Lysimeters

     Because the use of lysimeters for demonstrating waste  treatability may
be a relatively unfamiliar subject to the  applicant, the following discus-
sion of general  installation techniques is provided.

     The experimental  apparatus, a barrel sized monol ith of undisturbed
soil,  should be collected in a straight-walled cylindrical casing 57 cm OD
and  85.7 cm  tall or in  an equivalently configured container.  (A white
painted exterior is  recommended to help control the  absorption of radiation
that may  increase soil  temperature.)  The casing  is placed in a support
device and gently pushed into the soil  with a backhoe.  With the backhoe
and  a lifting  harness, the  monolith is then  lifted from the soil  and
rotated to  permit installation  of  soil-pore liquid samplers and leachate
removal  devices.  Following installation  of these devices,  the  casing lid
can  be sealed with silicon caulk or an appropriate waste-compatible sealant
or gasket and can be clamped  into place.  After the barrels are righted,
they may be transported  as desired  for performing tests.   Soil should then
be backfil led into the  trench,  particularly if the lysimeters were col-
lected from within  the  active land treatment area. To reproduce  thermal
gradients similar to normal soil,  lysimeters should be insulated or par-
tially buried.   The procedures  for collection  and installation of lysi-
meters, described in detail by Brown et al.  (1974) and Brown  et al. (1984),
may  be found in Appendix B of  this  document.
                                    53

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       Table  fa.l.  Waste Application Soil Sampling  Schedule for Barrel  Lysimeter Study
en
Waste
Appl ication
Treatment Frequency
Groups (months)
A 0

B 6

C 3

0 2

Sampling Schedule*

0 30
Z2 Zl

Z2 Zl

Z2 Zl

Z2 Zl

Day
60 90
Zl Z2

Zl Z2

Zl Z2f
Zl
Z21" Zl
Zl

120 150 180
Zl Zl Z3
C3
Zl Zl Z31"
C3
Zl Zl Z3
C3
Z2f Zl Z3
Zl C3

240
Zl

Zl

Zl

Z2t
Zl

270
Z2

Z2

ZZ*
Zl
Zl


300
Zl

Zl

Zl

Z2f
Zl

3bO
Z2
C2
Z2
C2
Z2
C2
Z2
C2

       *  Sampling schedule:   Z = zone of incorporation (0-15 cm); C = core samples (15-45 cm; 45-90 cm).
          Levels of analysis:  1 = Tier  I; 2 = Tier  II; and  3=TierIIL

       t  Waste  reapplication date.   Analyze zone of incorporation  at Tier II prior to application;  collect
          sample after application for Tier  I analysis.

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6.1.2  Preparation  of  Lysimeters for Study

     Using the general  installation techniques  from Section 6.1.1,  the
applicant may assemble the  lysimeter study as follows:

     a.  Collect twelve  undisturbed soil  monoliths  (lysimeters) from
         the site of the  land treatment unit.  Fewer  lysimeters may be
         collected by applicants  for  facilities  at  which the design
         and operating  requirements (e.g.,  expected waste  loading
         rate)  have already been more clearly  defined.  The applicant
         may want to reduce experimental  protocol and investigate only
         one application  rate and  frequency, which would require only
         three barrels.

     b.  Transport  soil monoliths  to experimental  site  and install the
         leachate collection system.  Collect 200 g soil  from  the zone
         of incorporation (deeper  for soils  already  containing wastes
         from an active unit) of  each  lysimeter.   These  samples  will
         be used to define the background of  each lysimeter.  Simi-
         larly,  leachate samples  representing approximately  0.2 pore
         volumes (about  20  liters)  should be collected for baseline
         characterization.  Leachate should also be generated for a
         second purpose:   with 100 ppm bromide as a tracer,  0.2 pore
         volume increments of leachate should  be collected and tested
         for bromide  to  determine the Br breakthrough  curve.   This
         procedure  confirms that sidewall  flow will  not  shortcircuit
         the system and bias  the  subsequent soil-pore liquid quality
         data.


6.2  EXPERIMENTAL METHODS

     Performance of the barrel lysimeter  study (described below)  involves
application of waste,  management of the water budget,  and sampling of soils
and soil-pore liquid.

6.2.1  Waste Application

     Waste application and reapplications should be done according to the
schedule given in Table 6.1.   To apply waste, remove  the  zone  of incorpora-
tion (e.g.,  15  cm) from a given lysimeter and mix the waste with the soil
at  the  chosen  application  rate(s)  (see Section 5.3.1) until  the mixture is
homogeneous.  Lay a  plastic barrier around the edge of each  casing to
prevent side channel  flow,  as described in  Appendix  B.  Replace the soil-
waste mixture into the  lysimeter in 5 cm lifts, tamping each successive
layer if necessary,  to achieve field bulk  density.

6.2.2  Water Management

     Lysimeters should be  sheltered  from  normal  precipitation  (e.g.,  with
an open-sided pole barn), and  instead,  water should be  applied in specified
amounts and timed  to  simulate the moisture  distribution of a wetter-than-
                                     55

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normal  degradation  season.  The site water budget developed earlier may be
useful  in terms of  water  added  via  other  sources (e.g.,  irrigation).   How-
ever, it is most suitable to  choose a  specific wet year from the climatic
record.  After calculated losses  due to run-off  have been subtracted,
appropriate  amounts of water may be  applied  according  to the precipitation
record  (and  planned irrigation schedule, if irrigation  is to  be used).  The
rationale of this approach is  that climatically  induced wet/dry cycles may
cause the waste constituents to  behave differently than they  would if,  for
example, regularly scheduled  water applications were to keep  the soil
continuously moist.

6.2.3  Soil  Sample Collection  and Analysis

     Soil samples should  be collected  according to the schedule described
in Table 6.1.  The Tier  III  analysis of  soil  core samples collected on-site
at the  time  of  lysimeter collection can serve as baseline samples for  the
lysimeters if the two are  taken from adjacent locations.  If 12 lysimeters
are used, they are  divided into four groups of three replications.  The
first group,  which receives no waste application,  serves  as a control;  the
second group receives  one waste application on day  0;  the third  group
receives two waste appl ications, on days 0 and 90;  and the fourth  group
receives three waste applications, on days 0, 60, and 120.   Immediately
after the first waste application, a 200 g soil  sample  should be  collected
from the zone of incorporation of each  lysimeter; these  samples  should be
evaluated using Tier II analyses (Chapter 10). Thirty  days following waste
application, a second  200 g  soil  sample is collected from the zone of
incorporation of each lysimeter for Tier I  analysis.   On day 60,  a 200 g
soil sample is collected  from each lysimeter in  Group  IV  (Table 6.1)  prior
to a second waste application,  and  the three samples are analyzed using a
Tier II analysis.  Finally,  after  the waste is reapplied to the  three
lysimeters in Group IV, zone  of incorporation samples are collected from
all  lysimeters for  Tier I  analysis  and the sampling and waste  application
routine is repeated  (see Table  6.1).

     On day  180, zone of incorporation and soil core samples  are  collected
from all  lysimeters and analyzed at  Tier III  instead of Tier II  in order to
identify  possible  degradation products. The three replicate soil core
samples from the respective treatments should form one core,  partitioned
into 15 cm depth increments.   Subsamples of the composite cores are com-
bined into 0-15, 15-45, and 45-90 cm increments and used for the initial
analysis. The  remaining 15 cm core  increments should be  stored as reserve
samples in case a more  refined  estimate of  hazardous  constituent penetra-
tion is needed.  The sampling  and  waste application schedule should be
continued for the next  180 days according to  Table  6.1.

     The experiment may be terminated when  the results of  soil  core  and
soil-pore liquid analysis  are adequate  to characterize degradation/immobi-
lization.   In  some  cases, termination may  occur  as  soon as  the 180  day
analytical results are complete, assuming adequate amounts of leachate have
been generated, as discussed below.
                                    56

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6.2.4  Soil -Pore Liquid Sample Collection and Analysis

     Soil -pore liquid samples should be collected according to a schedule
based on the pore volume of the lysimeter.   If  the simulated water budget
is relatively "arid," or  if "tight"  soils limit  leachate  production,
leachate sampling may have  to be modified to coincide with leachate produc-
tion  rather than be  conducted on a set schedule.   In addition to  the
determination of  the bromide  breakthrough  curve  described earlier, a back-
ground leachate sample equal  to 0.2 pore  volumes (approximately 20 liters)
should be collected  from each  lysimeter  prior to waste  application.  Fol-
lowing waste application, leachate should be  collected via continuous
suction until a  total of 2.0 pore volumes have been gathered  from each
lysimeter.   Two pore volumes  is considered adequate to yield usable hazar-
dous  constituent mobility results.  A total of five composite  leachate
samples, each representing 0.4 pore volumes,  should be collected, and a 2-
liter subsample of  each composite leachate  sample should be extracted  and
subjected to a Tier  II analysis.   One  exception  is  that  the first sampling
of treatment group C should be analyzed at Tier  III.  As  noted above, water
is added  to the  lysimeters  according to a schedule based on  the  water
budget at  the land treatment unit. Collection should  continue, and  the
leachate samples  should be stored until  the degradation study is complete
and  two pore volumes have been collected.  (NOTE:  In arid regions or
"tight" soils, this  approach  may  need to be modified).


6.3   DATA REDUCTION  AND INTERPRETATION

      The data provided by the barrel  lysimeter study is used to evaluate
the  potential of a  waste to  be adequately treated in the  land  treatment
system and  to determine the half-life  (or degradation rate) of the organic
fraction or specific hazardous organic constituents  of  the waste.   Half-
life is defined  as  the time  required for  a 50 percent disappearance of
applied carbon (EPA, 1983A).  The  degradation rate of  the sludge is also an
important parameter  for evaluating the frequency of application of  the
waste and  the time  required between the last application of the waste  and
closure.   Soil core and soil -pore liquid analyses  further  confirm whether
or not hazardous  constituents (or pertinent nonhazardous constituents)  are
being immobilized by the  soil.

6.3.1 Degradation Rate and Half-Life Determination

      The method used to determine degradation  rate, outlined in Section
7.2.1.2 of  Hazardous Waste Land  Treatment (EPA, 1983), involves the  ex-
traction  of the organic fraction from the soil.  Calculations are done
f ol 1 ows :
              Oto
                                    57

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where:  Dto = fraction  of  organic carbon degraded over time;
        Cao = the amount of carbon applied in the organic fraction of
              the waste;
        Cro = the amount of residual carbon in the organic fraction of
              waste amended soil; and
        Cs  = the amount of organic carbon which can be extracted from
              unamended soil .

The following equation is  used to determine the degradation rate of indivi-
dual  organic subfractions:


                    Dt1 =                                           (6.2)


where:  D   = fraction  of  carbon degraded in subfraction i;
        cai = cart>on applied  from  subfraction i in the waste;
        Cr-j = carbon residual  in subfraction i in waste amend
        Csl- = the amount of carbon present in an unamended soil  from
              subfraction  i.

The clarity  of  separation  of  all  subfractions should be  verified  for  ex-
ample by gas chromatography.

     Once the degradation rates are determined, half-life of  the waste or
constituents thereof may be calculated as  follows (EPA, 1983):

                               1/2                                  {6.3)
where:  t = time in days that  the waste was degraded to generate the
            data used in equations 6.1 and 6.2;
     tj/2 = half-life of waste organics in soil (days); and
       D^ = fraction of carbon or specific hazardous constituent
                degraded in  t  days.

An optional  method  that may  be used to calculate half-lives is to plot
cumulative percent  carbon or  specific hazardous constituent degraded as  a
function of  time on  a  semi-log scale graph.  The point in time when 50
percent of the waste has been degraded  may be read  directly.  The more
resistant compounds should be identified  as  possible candidates  for  limit-
ing constituent, and the results may be used in the follow-up  acute toxi-
city testing  (Chapter 5).

6.3.2   Immobilization

     Immobilization  is  determined by  data  from the analysis of soil core
and soil-pore liquid samples.  For the  gross parameters (total  organic
carbon and total extractable hydrocarbons), the data from waste amended  and
control lysimeters are compared.  If the quantity of either gross parameter
is significantly greater in the waste-amended  lysimeters  than  in  the con-


                                    58

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trol lysimeters, the waste has failed the immobilization  test.  The waste
has also failed the immobilization test if any Appendix VIII  constituent is
detected in  a soil-pore  liquid or lower portion  of a soil core.  If a
hazardous constituent is detected in one of the composite soil cores (15-45
or 45-90  cm), the core should be subsampled in 15 cm increments and re-
analyzed for the mobile constituent to further define the concentration and
rate at which the compound is moving through  the  soil.
                                     59

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                                Chapter 7

                            FIELD  PLOT STUDY

     The treatment demonstration required  under 264.272(a) can be partially
accomplished using information derived from the following field plot study.
As in the  case of the barrel  lysimeter study (Chapter 6),  the  primary
objectives of  the field plot study are to demonstrate whether or not a
particular waste will  be degraded,  transformed, or immobilized within the
defined  treatment zone.   Accomplishing these objectives  in  the field in-
volves  intensive (high sampling density) monitoring of the unsaturated zone
and the treatment zone of experimental field  plots.   The following field
plot design and procedure should be followed unless an alternative method
can be justified to  the EPA.  The duration of testing should be a  minimum
of one year.


7.1  EXPERIMENTAL DESIGN

     The experimental  design  suggested for the field plot study is a ran-
domized  complete block design,  with three replications  of  each treatment
per soil series to receive waste  in the HWLT unit.  Previous experience
with a well operated HWLT unit (see permitting  Scenario 2 in Chapter 3) or
the results of acute toxicity testing (see Scenario  3 or 4 in Chapter 5)
should  determine the  waste application  rate to be studied.  Unless no
change in current waste loading rate is desired or anticipated, this study
should typically test three waste loading rates and should yield nine field
plots per soil  series  tested.

     For Scenarios 3 and 4, where acute toxicity testing is employed to set
waste application rates,  the  concentration of waste in soil corresponding
to the LD50 is used to determine the rates. The LD50 waste concentration
is the amount of waste to be applied in a  single application (kg/ha/appli-
cation).  All  treatments that receive waste should  have  this amount of
waste applied initially.   The frequency  of waste  reapplication will  then
determine  the  annual  waste loading  rate (kg/ha/year).  For  these two
scenarios,  waste  application  is recommended on three  schedules (Table 7.1)
resulting in the  suggested three waste application rates.  Treatment groups
correspond  to the three replications of each treatment  and their respective
waste loading rates  and frequencies.  As  the table demonstrates, the ideal
application frequencies are semiannual, quarterly,  and bi-monthly.  In
relatively  harsh climates such as  cold northern locales, applications may
need to be limited to the warm season; however,  if the local  climate is
suitable for year round biological  activity, the applications may be spaced
evenly throughout the year.
                                    60

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Table 7.1.  Waste Application  Soil Sampling Schedule  for Field Plot Study
Waste
Application
Treatment Frequency
Groups (months)
A 0

B 6

C 3

D 2

Sampling Schedule*

0 30
12 Zl

Z2 Zl

Z2 Zl

Z2 Zl


60
Zl

Zl

Zl

Z2t
Zl
Day
90
Z2

Z2

Z2t
Zl
Zl


120
Zl

Zl

Zl

Z2f
Zl

150
Zl

Zl

Zl

Zl


180
Z3
C3
Z3t
C3
Z3
C3
Z3
C3

240
Zl

Zl

Zl

Z2t
Zl

270 300
Z2 Zl

Z2 Zl

Z2f Zl
Zl
Zl Z2f
Zl

360
Z2
C2
Z2
C2
Z2
C2
Z2
C2
*  Sampling schedule:   Z  = zone of incorporation (0-15 cm); C = core  samples (0-200 cm). Levels of
   analysis:   1 - Tier I;  2 = Tier II; and 3 = Tier III.

t  Waste reapplication date.   Analyze  zone of incorporation at Tier II prior to application;  collect
   sample after application for Tier  I  analysis.

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     Under  Scenario 2, the current annual loading rate (kg/ha/yr) should be
divided into four equal  applications at appropriate  intervals (see above
discussion)  through the year.  These same single  application  amounts
(kg/ha/application) should be applied to the other  treatments  at different
intervals  (i.e., every two months and six months) to yield three annual
loading rates.   As  for the  above  scenarios, Table  7.1 may be used as a
guide to waste application and soil sample scheduling.

7.1.1  Plot Preparation

     While the location of experimental plots on the HWLT unit is deter-
mined to some extent by  the location of representative soils,  ease of
access and  isolation  from existing waste treatment must also be considered.
Plots should be  located  so that al 1 si ope  positions are  represented.  A
scale  drawing  depicting the  location of the plots on the facility and
indicating  treatments to be applied to  each plot should be included in the
treatment  demonstration plan  required  under §270.20(a).

7.1.1.1 Size-

     Each experimental field plot should be  12 feet (3.6 meters) wide by 48
feet (14.4  meters) long with  a defined treatment zone up to 1.5  meters
deep.  Larger plots  may be used if application techniques require a larger
area.  However, with  larger plots, more monitoring samples are  necessary to
maintain the same density of sampling.

7.1.1.2 Slope—

     The slope  on which a field plot is established  should be  representa-
tive of the HWLT unit as a whole (e.g., if the unit is in  a rol 1 ing  nil 1
setting,  field  plots should  not be placed on level ground alone).   In all
cases,  plots should  run up and down the slope to include  variability due
to slope  in the  data  analysis.

7.1.1.3 Plot Isolation—

     The  experimental  field plots  should be isolated from existing waste
treatment  areas  using  berms around and between plots to eliminate the
possibility of  cross contamination from existing waste.  The berms, which
can usually be constructed from on-site materials,  need to be  high enough
and wide  enough  to contain stormwater  flow.   Additionally, they must meet
40 CFR 264.273(c) and (d) requirements for run-on  control   and  run-off
containment from  a 24 hr/25 yr storm.

7.1.1.4 Run-off  Collection-

     Small  sumps or  impoundments  at the low slope position  of each plot are
needed to contain run-off  in order to prevent off-site  contamination.  The
size of the collection  area  is calculated based on the water balance com-
puted for the site.   Run-off collection ponds should be  designed to contain
run-off from the  24  hr/25 yr storm for the treatment  demonstration site or
individual  plots.
                                    62

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7.1.2  Number, Location, and Installation of Soil-pore Liquid Samplers

     Each plot normally should have two each of two sampler  types,  the
pressure-vacuum  porous ceramic  cup  (Figure 7.1)  and  the  pan design (Figure
7.2),  with the samplers located as shown  in Figure 7.3.  Up to  three of
each sampler per plot may  be needed or desired in some cases,  so Figure 7.3
reflects this arrangement.   The  outline below should be followed during the
installation of the sampler.

     1.  Cut trenches  for sample collection tube using a ditching
         machine or other  piece of equipment.

     2.  Dig installation pits 5.5  ft x 6  ft (approximately) as  lo-
         cated on Figure  7.3.   As it is removed, segregate  soil by
         horizons for later replacement.

     3.  Install  soil-pore liquid samplers  (Figure 7.4).

     4-  Install  sample col lection stations (Figure 7.5 and Figure
         7.3).

     5.  Back-fill pits  and trenches,  replacing  soil  horizons in
         proper  sequence and compacting the soil  to  field  bulk density
         in  lifts.  Some  settling may occur  if trenches  have not  been
         backfi11 ed properly.

     6.  Grade site to desired slope.

Locate trenches  and pits as indicated in Figure  7.3 to minimize  the area of
disturbance on the plots.  After the site is graded,  the  plots are ready to
receive waste.   More detailed descriptions of the sampler types may be
found in  Section 7.2.2 and in EPA (1984).  The latter reference  also in-
cludes detailed instructions for sampler installation  and operation.


7.2  EXPERIMENTAL METHODS

     The performance of the field plot study involves application  of waste,
site management,  and sampling of soils and  soil-pore liquid.

7.2.1  Waste Application

     Application of waste onto experimental plots should duplicate the
procedures to be used on the land treatment unit.  Even distribution of the
waste over the plots is very important.  Incorporation  of waste into the
soil  should, if  possilbe, be accomplished  with  the  same  type of  equipment
that will  be used on the HWLT unit.
                                    63

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cr>
     POROUS -
     CERAMIC
     CUP

                                     SAMPLE DISCHARGE
                                          HOSE
                             PRESSURE/VACUUM
                                 HOSE
                                            VACUUM
                                                                        I— PRESSURE
         FIGURE  7.1  POROUS CUP  SOIL-PORE LIQUID  SAMPLER AND  PRESSURE
                     VACUUM PUMP USED  TO COLLECT SAMPLE.

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en
tn
                12
                                                GEOTEXTILE

                                                 FIBER
HOLLOW  SAMPLE

STORAGE AREA
                                                                     X
                                                                         TO SAMPLE

                                                                         COLLECTION

                                                                         EQUIPMENT
            FIGURE 72  GLASS  BRICK SOIL-PORE-LIQUID SAMPLER (PAN TYPE)

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O1
                                          TRENCH
                                          6"wld«x30"dt«p
SOIL PORE LIQUID SAMPLERS

   D  GLASS  BRICK (FIGURE 7.2)

Q      PRESSURE/VACUUM-
      POROUS CERAMIC CUP
      (FIGURE 7.6)
                                                                                     INSTALLATION PITS
                                                                                     66" x 72" (opprox.)
                                                                                     SAMPLING STATION
               FIGURE 7.3. SOIL PORE LIQUID SAMPLE  LOCATIONS  IN  FIELD PLOTS

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                         PIT  SIDE WALL
     •TO SAMPLE STATION
          PAN TYPE SAMPLER
                         PIT SIDE WALL
     TO SAMPLE STATION
        PRESSURE/VACUUM SAMPLER
FIGURE 7.4. INSTALLATION OF  SAMPLERS  IN PITS
                        67

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                                       4  PVC CAP
                                      3/8  PLEXIGLASS PLATE
                                      4" PVC

                                      1/4" 1.0. LATEX TUBING

                                      I/4"O.D. POLYTUBING
FIGURE 7.5.  SOIL-PORE LIQUID SAMPLING STATION
                          68

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7.2.2  Plot Management

     Management of field plots,  which  should simulate conditions  that will
occur under ful 1-scale operation of the HWLT unit, requires 1) tillage,
which must be practiced  in  the field plot study, 2)  irrigation/drainage,
and 3) soil amendment.   Soil  amendments should include liming of soil as
necessary to maintain a near neutral pH and adding nitrogen  fertilizer to
reduce the carbon:nitrogen ratio of  waste/soil  mixture  to  at least 100:1.
More guidance on unit management practices may be found in  EPA (1983A).

7.2.3  Sample Collection and  Analysis

     Monitoring of experimental  plots, designed to ensure accurate assess-
ment of waste treatability, involves  both soil core and soil-pore  liquid
sampling and analysis.   Analysis of  soil  cores  is  necessary to monitor the
behavior of hazardous constituents  present in the  treatment zone, to
identify any possible degradation products, and to detect slowly migrating
hazardous constituents  below  the treatment zone.

     The monitoring schedule  shown in  Table  7.1 is designed to sample soil
at frequent enough intervals  to determine whether a waste  is being de-
graded, immobilized, or transformed  and whether hazardous constituents are
passing below the treatment zone. To  set a  zero  time  for  degradation and
half-life  determinations,  ZOI soil samples must be taken immediately after
the  initial waste application and incorporation.  Note  that soil core
samples need only be taken at the same frequency  as  soil-pore liquid  sam-
ples (Table 7.1).

     Zone of incorporation soil  samples and soil cores  should be  collected
at random  on each plot with an appropriate device (e.g., Shelby  tube sam-
pler).  EPA (1984A) provides guidance on the appropriate  sampling  device
for  specific soils.  Scheduled  ZOI samples should  be collected to a depth
of 15  cm,  and soil core  samples should be collected to a  depth  of two
meters for a 1.5 m treatment zone, with analysis of each 15  cm section.  At
a minimum, six sample locations per  plot are required for  both zone of
incorporation and soil core samples.  Samples may be composited within
plots  to provide  one composite  sample (or set of samples) for analysis per
plot for each sampling date.

     During waste characterization  (Chapter  2), a  subset of  Appendix VIII
constituents may have been identified.  This does  not,  however,  eliminate
the  need  to analyze at Tier III some time during the first year  of the
field plot demonstration,  since  degradation products which were not present
in the waste initially may appear or a constituent may build up to above
detection  limits after successive waste applications.  Therefore, Tier III
analysis should be  performed on  ZOI  samples obtained from  plots  in  treat-
ment group C (i.e., the highest  waste loading rate  tested) at 180 days.  In
this case, Tier III should  include the  list of compounds for which the
potential hazardous degradation  products based  on an assessment of degrada-
tion pathways for the parent compounds.  All  other samples should be  ana-
lyzed at Tier I or Tier II as indicated in Table 7.1.
                                    69

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7.2.4  Soil-Pore Liquid Sample Collection and Analysis

     Percolating water  added to the soil  by precipitation,  irrigation,
snow-melt,  or waste applications may pass through the treatment zone and
rapidly transport some mobile waste constituents or degradation  products
through the unsaturated zone to the groundwater.   Soil-pore liquid monitor-
ing is intended to detect these rapid pulses of contaminants  since they may
not be observed through  the analysis of  soil  cores.  For this reason, the
timing of soil-pore liquid sampling is a key to the usefulness of this
technique.  Seasonality is the rule with soil-pore  1iquid  sample timing
(i.e., scheduled  sampling cannot be done on a preset date in many areas,
but must be geared instead to major leachate generating  events).  Soil-pore
liquid sampling in the field plot demonstration is used  to  determine if any
mobile hazardous  constituents are leaving the  treatment zone.

     As previously indicated,  two types  of soil-pore liquid samplers are
needed for the field plot study:  the pan-type soil-pore liquid sampler
(Figure 7.2) and the pressure-vacuum,  porous  cup  soil-pore liquid sampler
(Figure 7.3).  These  two types of soil-pore liquid  samplers  are described in
detail  in  EPA (1984A).   While  each sampler has  advantages and  disad-
vantages, one major reason for using pan  lysimeters  is to confirm whether
large quantities  of leachate are flowing  through  structural  macropores and
possibly bypassing much  of the soil's  treatment capacity.  In highly struc-
tured soils which  allow  a high flux of liquid (e.g., after  precipitation or
irrigation),  the  pan type  sampler collects a  sample  very efficiently be-
cause it acts as a textural  discontinuity in  the soil  profile,  forming a
perched water table above the pan surface.  Water then flows through the
holes in the  top  surface to be collected  and  stored in the collection area
(Figure  7.2).  The sample  must be  removed  soon (e.g., within  24  hours)
after a rapid influx of  liquid to prevent sample  quality changes within in
the pan type  sampler.

     Under  moist  conditions with a low flux of moisture and  little macro-
pore flow,  the pressure-vacuum soil-pore liquid  samplers may more effi-
ciently collect a soil-pore  liquid  sample.  However, proper operation of
the pressure-vacuum sampler is essential (see EPA,  1984B). Timing the
removal  of the sample for  analysis  is determined by soil moisture condi-
tions, and  once the amount of  time required to  fill  the  storage capacity of
the sampler is determined,  samples should  be collected within 24 hours to
assure good quality.  Both types of samplers must be  checked frequently to
monitor  the  accumulation of the sample (with pan-type) or to see if the
sample can  be obtained (with pressure-vacuum  type).

     If one of the two sampler types performs decisively better after 90
days, the other may be eliminated for the remainder of the  study.  Finally,
soil-pore liquid  samples should  be  collected using  the  one sampler type
every 90 days  or as liquid is available.  For  each sampling date,  all
liquid obtained from samplers  of  the  same  type within each plot should be
composited, resulting  in three replicate liquid  samples per treatment per
quarter.

     While  analysis of soil-pore  liquid  samples  should be at Tier  III for


                                    70

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the first sampling date for treatment group C,  Tier  II  analysis  will  suf-
fice for all  other sample sets.


7.3  DATA REDUCTION AND  INTERPRETATION

     The data provided by the field plot study is  used to evaluate  the
potential of a waste to be adequately treated in the land treatment system
and to  determine  the half-life  (or  degradation rate) of the organic frac-
tion or specific hazardous organic constituents  of  the waste.  Half-life is
defined as  the time required for a 50 percent disappearance of applied
carbon (EPA,  1983A).  The  degradation rate of the sludge is  also an impor-
tant parameter for evaluating the frequency of application of the waste and
the time required between the last  appl ication of the waste and closure.
Soil  core and soil-pore liquid analyses further confirm  whether or  not
hazardous constituents  (or pertinent  nonhazardous constituents)  are being
immobilized by the soil.

7.3.1  Degradation Rate and Half-Life Determination

     The method used to determine degradation rate, outlined in Section
5.3.2.3.2 of Hazardous Waste Land Treatment (EPA, 1983), involves the ex-
traction of the organic fraction from the  soil.  Calculations are done
fol1ows:
where:  Dto = fraction of organic carbon degraded over  time;
        Cao = the amount of  carbon applied in the organic fraction of
              the waste;
        CrQ = the amount of  residual carbon in the organic fraction of
              waste amended  soil; and
        C.  = the amount of  organic carbon which can  be extracted from
              unamended soil.

The following equation  is used to determine the degradation rate of indivi-
dual  organic subfractions:


                    Dti  =                                         (7.2)


where:  Dtl- = fraction of carbon  degraded in subfraction i;
        C^! = carbon applied from subfraction i in the  waste;
        C*] = carbon residual  in  subfraction i in waste amended soil; and
        C ] = the amount of  carbon present in an unamended soil from
              subfraction i.

The clarity  of  separation of  all subfractions should  be  verified for ex-
ample by gas chromatography.


                                    71

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     Once  the degradation  rates  are determined,  half-life of the waste or
constituents  thereof may be calculated as follows (EPA, 1983):

                                                                  (7.3)
where:   t =  time  in days that the waste was  degraded to generate the
            data  used in equations 7.1 and 7.2;
          =  half-life of waste organics in soil  (days); and
        * =  fraction of carbon or specific hazardous constituent
               degraded in t days.

An optional  method that may be used to calculate half-lives  is  to plot
cumulative percent carbon or specific hazardous constituent  degraded as  a
function of time on a semi-log scale graph.  The point in time  when 50
percent of  the waste  has been degraded may be  read  directly.  The more
resistant compounds  should be  identified as possible candidates for limit-
ing constituent,  and the  results may be used  in the follow-up  acute toxi-
city testing (Chapter  5).

7.3.2  Immobilization

     Data from sampling for hazardous constituent  leaching  should  be com-
pared statistically with background concentrations.  If either soil  core or
soil-pore liquid data  indicate a leaching hazard at the waste loading rates
tested,  a reduced waste loading rate is in order.  The optimum treatment
within the field plot  study is  the  treatment that allows for  the  largest
application  rate at the greatest frequency  without migration  of hazardous
constituents below the  treatment zone.
                                    72

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                                Chapter 8

                          DATA INTERPRETATIONS

     Following completion of the field  plot  or  lysimeter  study, the data
which has been  accumulated from on-site field studies, barrel lysimeter or
field plot tests,  and the Microtox™ test may be interpreted to form the
basis for the treatment demonstration.  The interpretation of  these data
will be used to determine 1) the maximum residual concentration  of specific
hazardous organic constituents  (Chapter  5), 2) the waste degradation rate
(Chapters 6 and 7),  3) the waste application  rate and frequency,  4) the re-
quired unit area, and 5)  the anticipated unit life.   While  interpretations
of items (1) and (2) are  found in the appropriate sections of Chapters 5,
6, and 7, the remainding  information, some of which  has  been modified from
Hazardous Waste Land Treatment (Brown et al., 1983),  is presented in this
chapter.
8.1  WASTE APPLICATION LIMIT

     The first parameter that should be determined is the  amount of waste
that can safely be  applied  in a single application (mass/area/application).
Although this parameter can be  determined by the LD50 (calculated from the
Microtox™ test, Section 5.4),  acute toxicity may not always be the most
restrictive factor influencing waste application  rate.  For example, the
waste application rate may  have to be reduced in situations where leaching
of undesirable constituents occurs at the optimum application rate for
degradation.   In these situations,  the application limiting constituent
(the constituent that limits the  amount of  waste  that may  be applied in a
single dose) may be determined  through  leaching observations conducted as
part of  the  barrel  lysimeter (Section  6.2.4) or field plot (Section 7.2.4)
studies.   Thus,  the  amount of waste on a given area per  application is
limited by either the acute toxicity or the  mobility of waste constituents.
The ALC is typically  lost very  rapidly from the soil;  however, overloading
in a single application may present a hazard to human health or to the
environment or may drastically inhibit soil  biological  activity.


8.2   ANNUAL WASTE  LOADING  RATE

     The limit of  how much waste may be applied  in a single application
(based on the ALC)  combined with the frequency of  application yields the
first  estimate of the  annual waste loading rate (mass/area/year).  The
experimental designs  suggested  for  the barrel   lysimeter study  (Chapter 6)
and the  field  plot study  (Chapter  7) include testing this ALC-determined
application limit at  several frequencies and monitoring the tests' yielded
data on degradation  rates and mobility for the  specific hazardous con-


                                    73

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stituents  found  in  the waste.  Further,  acute  toxlcity testing of three or
more of the most resistant organic constituents identifies  the constituents
of greatest concern according to their potential  toxicity to soil biota
(LC8o).  The  following guidelines permit the  appropriate application rate
and frequency to be chosen.

     1) For  each  resistant organic  compound  tested,  choose the
        frequency  of application at which the compound exhibits the
        shortest half life (T1/2);

     2) Depending upon  the  concentration of each compound in the
        waste and  the choice of  frequency from step 1,  calculate the
        respective annual loading rate for each compound as follows:
     4)

                                   x C,
                                      w
         where:
              uyr
             LR
             =  the rate of application of the compound or frac-
                tion of interest  to soil (kg/ha/yr);

             =  annual waste loading rate  tentatively  estimated
                using the application limit and frequency for
                the compound of interest (kg/ha/yr);
              Cw   =  concentration  of the compound or  fraction of
                     interest in  the  bulk waste (kg/kg) from waste
                     analysis.

     3)  Calculate the  macimum accumulation that will occur for each
         compound:
         where:
              'max
                     cmax = 2 x Cyr x T1/2
                maximum accumulation  that will  occur during the
                unit life under  th given conditions (kg/ha);
             Tl/2 =  half
                      life of
                Chapter 6 or  7
the  compound
(yr).
as calculated in
    Compare  compounds using the  ratio of the Cmax to the critical
    concentration in soil (Ccr1t) at which toxicity occurs, as
    measured by  the  LD8Q  in  the acute  toxicity  test (Chapter 5).
    Among those constituents that exhibit a ratio of greater  than
    1,  the constituent having  the  largest ratio is termed the
    rate limiting constituent  (RLC).  If  no  constituent has a
    ratio greater than 1,  there is effectively no RLC in the
    degradable organics fraction.

5)  Calculate an adjusted annual waste loading rate with the
    equations below and the derived  values for the parameters:
                                    74

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         and
                       LRRLC
         where:
              LRmr  =  the  adjusted annual waste loading rate based on
                      the  RLC (kg/ha/yr).

The above procedure  leads the applicant to a loading rate that may  be
incorporated into the  final  facility permit (permit Scenario 2) or that may
be managed on the unit during the two year follow-up study  (Scenarios 3 and
4).   If,  however,  a  Teachable constituent constrains waste  applications  to
lower  rates due to  potential groundwater hazards, this more restrictive
condition supersedes waste degradation as the limiting factor.   Mobility
results and the associated calculations  are discussed in the interpretation
sections of Chapters 6 and 7.


8.3  REQUIRED UNIT AREA

     After the most limiting constituents are identified,  the final  deci-
sions on the required land area and the  minimum number of applications per
year are made using  the following calculations:
                     A =


where:

            A     =  required  treatment area (ha);
            PR    =  waste (wet weight) production  rate  (kg/yr); and
            LRRLC =  waste loading rate based on the RLC (kg/ha/yr).

If  the  value calculated for A  is  greater than the area  available  for
treatment, 1 and treatment cannot  accommodate al1 of the waste produced.
                         NA =
     where:
            NA    =  number of applications  per year and is equal to
                     the smallest integer greater than or equal to
                     the actual value calculated;
            LRRLC =  waste loading rate based on  the RLC (kg/ha/yr);
                     and
                                     75

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           AL    =  application   limit  based   on  the   ALC
                    (kg/ha/applicaton).
8.4  UNIT  LIFE

     The land treatment  unit life and concomitant choice  of  a capacity
limiting constituent (CLC) are predicted in a relatively straightforward
manner. The choice may be based purely on a calculation approach rather
than on any  particular piece  of data from the  LTD.   Three classes  of
potentially conservative constituents  have  been identified:  1)  metals,  2)
phosphorus,  and  3)  inorganic acids,  bases,  and  salts.   Calculating a unit
life based on each  allows the design unit life  and CLC to be  chosen as that
constituent which  is the most restrictive.  Phosphorus is redistributed
throughout the  treatment  zone while  salts  (if  conserved, such  as  in cli-
mates or soil drainage conditions  where they usually accumulate and do not
leach)  tend to  accumlate  near the surface and thus can  be described by the
following equation:

                     UL  =


     where:

           UL    =   unit life  (yr);
           LCAPpS =   waste  loading capacity beyond which the CLC will
                     exceed allowable  accumulations (kg/ha); and
           LRRLC =   waste  loading rate based on the RLC (kg/ha/yr).

     Since metals,  by  contrast, are practically immobile and are  mixed  in
the waste  with a heterogeneous matirx of water,  degradable organics, mobile
consituents,  and nondegradable  residual  solids, waste  application  is not
merely  the addition of a pure element to soil.  Because residual solids
fraction  (RS) adds to  the original  soil  mass, wastes containing  high  RS
concentrations can significantly raise the level of the  land treatment unit
as well as limit the amount of  soil which can be used to dilute the  waste.
If the  concentration of a given  metal  in  the RS of a waste is less than the
maximum allowable concentration  in soil, the given  metal cannot limit waste
application.  The  metal  with the largest ratio greater than  one is the
possible CLC, and unit life  is determined as follows:

     1)  determine the concentration  (ca) of the  metal in  the  waste
        residual solids  (mg/kg);

     2)  calculate the residual  solids  loading rate from the equation;

                  LRRLC  x (wei9nt fraction of residual
                                 solids in waste)
             z. =                                       x 1(T5
             3                   BRS
                                   76

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     where:
          za     =   volumetric waste  loading rate on  a  residual
                     solids basis (cm/yr);
           BRS   =   bulk  density of residual solids, assumed to be
                     the same as that of the  soil  after tillage and
                     settling (kg/1); and
            10~5 =   conversion factor from 1/ha to cm;
     3)  choose  a  tillage  or waste-soil  mixing method and  determine
        the "plow" depth (zp) in cm;
     4)  from  the background soil  analysis,  obtain the  background
        concentration (mg/kg) of the  given metal (cpo);
     5)  from  reference to  the  specific metal   in  Chapter  6  of
        Hazardous Waste Land  Treatment (EPA, 1983) of  that metal
        (mg/kg);
     6)  using these quantities, solve for n in the following equation
        (Chapra,   unpublished paper)   where n  is  the  number  of
        applications which result in the concentration of the surface
        layer being cpn:
                       n =
     7)   determine the corresponding unit  life as:
                       UL = nt.
                              a
     where:   ta = time between applications.
     The equation idealizes  the process  of application and plowing as a
continuous  process.  To do this, the following assumptions must be made:
     1)   that sludge is applied at equal intervals, ta in length.
     2)   that the sludge always has the  same concentration ca.
     3)   that the sludge is always applied at  a  thickness of za.
     4)   that there  is  complete mixing  of the surface layer to depth
         Zp due to plowing.
     5)   that the plowed soil and the sludge have equal porosity.
     6)   that the annually applied waste  degrades  and dries approxi-
         mately down to residual solids.
                                    77

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     Finally,  a design  unit life (years)  is chosen from among salts, phos-
phorus,  and metals, with the shortest life of the three the  desired value.
For many waste constituents,  inadequate  information is available to pro-
perly assess  loading rates.   Pilot experiments and  basic research are
needed in this area to begin to develop an understanding  of the fate of
various  constituents in soil; however,  such research is beyond the scope of
this document.  When land treatment is proposed for a waste constituent
about which only  scant knowledge is available and for which no pilot
studies  have been conducted, the loading rate chosen for such a constituent
should be conservative to provide a factor of safety.
                                   78

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                                Chapter 9

                        TWO YEAR FOLLOW-UP STUDY

     The  interpretation of  the  data  obtained up to this point in  the  land
treatment demonstration has been explained  in respective chapters  and
assembled comprehensively in Chapter 8.   The information  now tentatively
known about  unit performance includes:

     1)   degradation rate and half-life of waste organics, including
         specific constituents;

     2)   mobility of  waste constituents at  varying waste  loading
         rates; and

     3)   tentative  waste  loading rates to be confirmed in follow-up
         field monitoring.

     If  the  waste  is  land treatable,  determined by data collected to  this
point, the follow-up  study mentioned above may be needed to  verify this
data for permitting  Scenarios 3 and  4  {see Chapter 3).  The owner/operator
of the HWLT unit  applies  waste  to full  scale land treatment  plots during
the two  year follow-up study.   Monitoring, analysis,  and interpretation is
accompl i shed according to the  following schedule of  sample density  and
frequency.
9.1  SOIL CORE  SAMPLES

     Soil sampling during the  two year follow-up study differs from opera-
tional  monitoring at a full  scale  facility  in  that samples are taken from
the surface  to 2  meters.  Unsaturated zone monitoring requirements for
hazardous waste  land treatment units call  for sampling only the  layer
immediately below the treatment zone (Part 264.278).   Otherwise,  the sam-
pling density and frequency  are essentially comparable to  an operational
monitoring  plan,  including compositing by pairs.

     The suggested minimum number of soil cores is 6 per uniform area, to
be taken from locations  chosen at random at a minimum rate of one sample
per two acres;  soil core  samples should be collected  to a 2-meter depth in
15 cm increments.  In addition  to the random samples,  two more cores should
be collected per uniform area  if any  sites  on  the facility are considered
to be anomalous  (e.g., toe of slope or swales  where waste may collect in
larger quantities than is common for the uniform treatment area).   Cores
should be collected quarterly.
                                    79

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9.2  SOIL-PORE LIQUID MONITORING

     Soil-pore 1iquld monitoring devices should be installed at random
locations  on the  land treatment unit a minimum  rate  of one per four acres
with at least three samplers installed per uniform area.    Installation and
sampling procedures are  described in detail in EPA  (1984A).  Samples are to
be collected and analyzed quarterly.


9.3  SOIL  CORE AND SOIL-PORE LIQUID SAMPLE ANALYSIS

     An interpretation of data generated in the  previous stages of the land
treatment  demonstration may be used to reduce the list of constituents that
must be analyzed  for in the  follow-up  study.  Those constituents that
potentially pose a mobility hazard or that are resistant to degradation may
be justified as indicator parameters.  Nonhazardous constituents may be
helpful in reducing  the long term costs  associated with monitoring;  in
order to qualify, however, such a constituent's behavior must correlate
well with the  hazardous constituents of concern.   If  a  constituent is
chosen on the same basis, it is official ly termed a "principal hazardous
constituent (PHC)" according to 40 CFR 264.278(a)(2).  (PHC's are  defined
as "hazardous constituents contained in  the wastes to be applied at the
unit that  are the most difficult to treat, considering the combined effects
of degradation, transformation, and immobilization.")  Analysis of both
soil core  and soil-pore  liquid necessarily includes these indicator consti-
tuents  (i.e., "PHC's") in addition to the Tier I  analysis described  in
Chapter 10.
9.4  INTERPRETATION

     The purpose of the follow-up study is  to determine if the assumptions
made based on the short-term field plot  or barrel  lysimeter study will hold
for the long term  under ful 1-scale operation.   Success or fail ure stil 1
depends upon whether or not the waste is degraded, transformed,  or im-
mobilized  within  the treatment  zone,  as  determined by  the monitoring
results.
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                               Chapter 10

                         TIERED SAMPLE ANALYSIS


     To minimize the cost of sample analyses and still  obtain  sufficient
information for a treatment  demonstration,  three tiers of sample analyses
are employed (Table  10.1),  with  each higher tier involving a  more intensive
group  of analyses than the previous one.  The intensity  of  the  sample
analysis depends on  the source of the sample and the  information required.


10.1  TIER  I

     This  tier includes gross parameters that can be measured by relatively
simple techniques.  All samples collected are analyzed to at  least the Tier
I  level,  with evaluated parameters  including,  but not  limited  to, water,
ash, solids, soluble salts, total nitrogen, total  phosphorus, pH, total
organic carbon,  and  total extractable hydrocarbons.


10.2  TIER  II

     Tier  II analyses  include,  in  addition  to  the  gross  parameters
evaluated  in Tier I,  the hazardous organic constituents  that were  identi-
fied in:

     1)  Tier III waste analysis;

     2)  the preliminary  reconnaissance  site sampling  and  analysis
         program (Chapter 2); and

     3)  (for new sites with  no  history of waste applications to soil
         at the site  or in surrounding areas) the Tier III analytical
         results from the  180th  day soil and leachate sampling  of the
         barrel  Isyimeter  or field plot study (Chapter 6  or  7).

     The constituents analyzed  in  Tier II  are  not  to be  confused with the
"principle hazardous constituent" (PHC) described in the land treatment
regulations (40 CFR 264.278(a)(2)); PHC's are  intended to  be  indicators
chosen for  monitoring purposes in the final operational monitoring program.
These  constituents cannot be chosen effectively until  the experimental
                                    81

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Table 10.1.  Components of Analytical Tiers Used in the Land Treatment
             Demonstration
Tier
   Parameters Measured
       Reference for
   Analytical  Procedure
Tier I
Tier II
Tier III
Water
Ash
Soli ds
Soluble Salts
Total Nitrogen
      Phosphorus
             Total
             PH
             Total
      Organic Carbon
Total Extractable Hydrocarbons

All Tier I Parameters
Hazardous Organic Constituents
 Identified in the Waste  or
 Waste-Soil Mixture
All Metals Present in  Waste
 (totals, NOT EP Toxic)

All Tier I Parameters
Total Metals
Total Organic Halogens
Volatile Organic Constituents
Appendix VIII Hazardous
 Constituents or Those Known
 or Suspected to be in the
 Waste or Waste-Soil Mixture
EPA (1983A)
Rhoades (1982)
Bremner and Mulvanex (1982)
01 sen and Summers (1982)
McClean (1982)
Nelson and Summers (1982)
EPA (1982)
EPA (1982)

EPA (1982)


EPA (1982)

EPA (1982)



EPA (1982)
portions of the LTD are complete.  As discussed in Chapter 3, PHC's  may  be
chosen  for  the two-year, follow-up study monitoring program since  this
phase of the LTD follows the experimental  phase and is,  in  essence,  a  full
scale operation.
10.3  TIER III

     The most comprehensive analytical program conducted, Tier III includes
(in addition to  the  Tier I analyses)  analyses  for total metals, total
                                    82

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organic halogens, volatile organic constituents, and al 1  Appendix VIII
constituents or a justifiable  subset of those known or suspected to be in
the waste or its degradation product.  As the organic characteristics of
hazardous waste streams  are  better  defined by an  increasing national data
base, it may be possible to eliminate some compounds from the list; how-
ever, others may possibly be added.  For example, EPA (Skinner, 1984) has
compiled a list of 89 Appendix  VIII  constituents suspected to be present in
refinery wastes.   This  list may be used  for Tier III analysis for these
wastes.   The rapid acquisition  of new data may allow further modifications
to this EPA list for refinery wastes.


10.4  QUALITY ASSURANCE/QUALITY CONTROL

     Before the first sample is collected for analysis as part  of a treat-
ment demonstration program, a quality  assurance/quality control  (QA/QC)
program must be installed to ensure  the integrity  of the resulting data.  A
quality assurance program is an integral  part of the overall   program be-
cause the analytical  data it  generates is used to determine the treatment
potential of a specific hazardous waste.  The primary goal of the quality
assurance program is to ensure the fol lowing:  that al  1 testing be con-
ducted according to proper  scientific procedures,  that testing  be directed
and performed by qualified individuals, that the physical facilities be
operated in the proper manner,  and  that data recording,  handling, storage,
and retrieval  be  carried out or-maintained in a  scientifically  sound man-
ner.  The  development  of standard operating  procedures and a quality
assurance program will  contribute  significantly to the quality and reli-
ability of the analytical  data. A quality  assurance program for a land
treatment demonstration program should include procedures which address
laboratory  testing,  field studies,   and data handling.   Specifically,  the
quality assurance program should address:

     1)  A detailed flow scheme  of the work to be  performed during the
         land treatment  demonstration program; individuals responsible
         for each specific test procedure, including chemical analysis
         and data interpretation; approximate dates of sampling and
         analysis.

     2)  Detailed procedures to ensure  the collection  of representa-
         tive soil or waste samples; procedures  for a  sample receipt
         log that will  include information on storage conditions,
         sample distribution, and sample identification.

     3)  A master schedule for tracking all  samples  through the
         screening program.  This  schedule  should include the test
         performed,  individual responsible, and dates of initiation
         and completion.

     4)  Standard operating  procedures  (SOP's) which  outline specific
         details of each test  procedure and associated QA/QC require-
         ments.
                                    83

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     5)  A study  folder for each waste screened that  includes the
        study  protocol, a complete set of  raw data for each test
        procedure,  the Individual  generating the data,  and the data
        generating  dates.

     6)  A complete report for each waste that includes  data calcula-
        tions and interpretations from  each test procedure.

In addition, all  analytical procedures should be done  according to test
methods approved by the EPA.  Any deviations  from approved procedures
should first be documented  for review by the laboratory QA officer and then
approved by  the  laboratory director.  Additional  information on  QA/QC
procedures can  be obtained from  EPA  (1982)  and EPA (1980).
                                  84

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                              APPENDIX A

                       SOIL SAMPLING AND ANALYSIS
A.I  SOIL  SAMPLING
     The methods used for soil sampling are variable  and depend partially
on the size  and depth of the sample  needed and the number and frequency of
samples to  be taken.   Of the available equipment,  Oakfield  augers  are
useful if small  samples need  to be taken by  hand, while bucket augers give
larger samples.

     Different sections  of this protocol  require  different methods  for
sampling (e.g. for  the soil  survey, surface soil  sampling will predominate
making the Oakfiled Auger an  appropriate tool).   Powered coring equipment
is the preferred choice for sampling existing sites  and field plots,  since
it can  rapidly sample to the desired depths and provide clean,  minimally
disturbed samples for  analysis.  Due to the time  involved in coring to
1.5 m and farther, powered equipment can often be less costly than hand
sampling.  In any case, extreme care  must be taken to prevent cross con-
tamination of samples.  Loose soil should be scraped away from the surface
to prevent it from contaminating samples collected from lower layers.  For
further   discussions   of  soil  sampling  please   refer   to
Unsaturated  Zone Monitoring for HWLT Units (EPA,  1984A), Soil Chemical
Analysis (Jackson,  1967) or Methods of Soil Analysis (Black, 1965).
                                    85

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                    Soil  Moisture Sampler Sample Record
Plot No.  	          Sample No.
Sampler Type	          Laboratory No. 	
Liquid Volume  	          Split Sample 	Yes   	No
Collectors Name(s)
Date                            Time
Date Sent to Lab
Method of Preservation
Destination of Sample
Destination of Split Sample
Remarks:
                                     86

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                          Soil Core Sample Record
Plot No.	          Sample No.
	  Composite    	  Depth             Laboratory No.  	
Sample Random Coordinates                  Split Sample 	Yes   	No
a)  	       c) 	
b)  	d) 	
Collectors Name(s)
Date                            Time
Date Sent to Lab
Method of Preservation
Destination of Sample
 Destination  of  Split Sample
 Sample  Comments:
      a)                                c)
      b)                                d)
                                     87

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                                                                CHAIN  OF  CUSTODY  RECORD
oo
oo
                            PRO). NO.
                                       PROJECT NAME
                                     (Si|ntl»fl)
                           STA.
                            NO.
                                  DATE
                                        TIME
                                                           STATION LOCATION
NO. OT
ONTAINERS
                                     til (Si|»ll»M>      Otli/Ti*f)   Rtoiof'
                                                        Dill/Tint
                                                                     _
                                                                   (S'ifnttvrt)
                                                                                                                                     REMARKS
                                                                                                                         Ditt/Tim

-------
00
UD
PROJFCT NO TRFATMFNT
OATF ppppAppn BY

SAMPI F NO S fT
CT
HIT

DA DAUPTCTD
r*A K AM c T c. n
















) SAMPLE WT.tvo
)
)
) r



ng. DRY WT.Wflutlc
SAMPLE NO.
I
















n
















JB
















«) mg H 0 1L



T*SO
















                     FIGURE 6.1 SAMPLE DATA SHEET FOR "Bbl LYSIMETER" OR "FIELD PLOT" STUDY.

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A.2  ANALYTICAL METHODS FOR SOILS

A.2.1  Physical Methods

     Soil  physical  characteristics affect the long-term use of the soil  for
land treatment.   In contrast, chemical  properties are of extreme importance
in the short-term. Chemical properties can be more easily modified  and
changed than  physical  properties.

A.2.1.1  Particle Size Analysis (Hydrometer Method) —

     This method  depends on the rate at which soil  particles  settle  from  a
water suspension.  The soil particles are put into suspension by mechanical
stirring with the aid  of a dispersing agent.

     Temperature is  reported in  the  sedimentation procedure since  the
density and viscosity of water changes with  temperature.  As the  tempera-
ture increases, the time required for particles to settle out of suspension
decreases.  The hydrometer  is usually calibrated for 19.4  or 20°C  (67 or
68°F).    For  each °F above the hydrometer calibration temperature,  0.2 g is
added to the reading.  Conversely, 0.2  g is subtracted  from  the hydrometer
reading for each  °F below.the calibration temperature.

A. 2.1.1.1  Chemicals—

 a.  Dispersing  agent:  Dissolve 35.7 g sodium metaphosphate (NatPOo)^)
     (Fisher  Scientific Company No.  S-333  or  equivalent)  and 7.94  g  sodium
     carbonate (NapC03)  in  distilled water and  dilute to  a  volume of
     1  liter.  ThelJa2C03 is used as  an alkaline buffer to prevent  the
     hydrolysis  of  the metaphosphate  back to orthophosphate which  occurs
     in acidic solutions.   NOTE:  Instant Calgon available from Calgon Cor-
     poration, Pittsburgh, PA  can be substituted.

 b.  Distilled water.

A.2.1.1.2   Materials—

 a.  Bottles, French square,  1 liter  (32 oz)  with caps.

 b.  Shaker, horizontal  reciprocating type, 6.3 cm (2.5 in) stroke,  120
     strokes  per  minute.

 c.  Glass sedimentation cylinder with markings at  the 1130 ml  and 1205 ml
     levels (Bouyoucos cylinder).

 d.  Standard hydrometer  (ASTM  152 H, with  Bouyoucos scale in grams  per
     liter).

 e.  Balance, can be read to  0.1  g.
                                    90

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f.  Plunger.   NOTE:   This can be made using  3  mm  (0.125 in)  diameter wire.
    At one end  make a circle 5.5  cm (2.125 in)  in diameter.  The wire
    should be manipulated so the handle extends at  a right angle from the
    center of the circle for  56  cm (22 in).   Stretched rubber bands
    bisecting the wire circle are spaced around the  circumference until  it
    is largely covered by rubber  bands overlapping at the center.

g.  Thermometer, 0-100°F.

.2.1.1.3  Procedure—This procedure is modified from Bouyoucos (1951).

a.  Weigh 50  g (oven-dried at 105°C overnight)  of  a  fine textured or 100 g
    of coarse textured (90-100%  sand) soil  and  place in a shaker bottle.

b.  Add 125 ml of dispersing  agent and 400 ml of distilled water to shaker
    bottle.

c.  Cap bottle snugly and place  horizontally on a reciprocating shaker for
    16 hours at 120 strokes  per minute.

d.  Remove bottle and bring  suspension to room temperature.

e.  Wash all  contents of shaker  bottle into a sedimentation cylinder.

f.  Set cylinder in a place  away  from vibrations.

g.  Place hydrometer in suspension.

h.  Fill  to  lower mark (1130 ml) with distilled  water for a 50 g sample.
    Fill to upper mark (1205  ml)for a 100 g sample.

i.  Remove hydrometer.  Take plunger in one hand  and hold the cylinder
    with the  other.  Strongly move plunger up and down being  careful  not
    to spill  contents of cylinder.

j.  After all  sediment is off cylinder bottom,  carefully  remove plunger
    and record time immediately.  NOTE:   Add  a drop of amyl  alcohol if the
    surface is covered with  foam  and restir the suspension if necessary.

k.  Record hydrometer reading at meniscus  top at  the end of 40 seconds.
    NOTE:  About  10 seconds before  taking reading, carefully  insert
    hydrometer and steady by  hand.

1.  Remove hyrometer from suspension.  CAUTION:  Do  not leave hyrometer in
    suspension longer than 20 seconds as particles will settle out on its
    shoulders.

m.  Measure  and record  suspension temperature.   For each °F above  the
    calibrated temperature  of  the hydrometer add 0.2 g  to the reading.
    For each  °F below  the calibrated temperature  subtract 0.2  g.

n.  Record corrected hydrometer  reading.


                                    91

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 o.  With  the plunger, restir suspension.  Take a reading at the end of  two
     hours.  Correct  hydrometer reading (see step m) and  record  corrected
     hydrometer reading.

 p.  Make  3 blanks by placing 125 ml of dispersing agent in 3 sedimentation
     cylinders.   NOTE:    Blanks  should be  run for  each new  batch  of
     dispersing  agent.

 q.  Fill  cylinders  two-thirds  full with distilled water.   Insert  hydro-
     meter and fil 1 cylinder to the lower  mark  (1130  ml)  with distil led
     water.

 r.  Take hydrometer reading  and temperature  of suspension.   Correct
     hydrometer  reading using step  m.

A.2.1.1.4   Calculations—

 a.  Dispersing  agent  correction  factor  =  Sum total   of  temperature
     corrected hydrometer readings  of blanks/3.

 b.  Weight corrected 2 hour  reading = (Temperature corrected  2 hour
     hydrometer  reading) - (Dispersing  agent correction factor).

 c.  Weight corrected 40  second reading = (Temperature  corrected  40  second
     hydrometer  reading) - (Dispersing  agent correction factor).

 d.  % Clay =  (Weight corrected 2 hour reading/oven-dry weight of total
     sample) x 100.

 e.  % Silt = [(Weight corrected  40 second reading -  Weight corrected 2
     hour  reading)/oven-dry weight  of total  sample] x 100.

 f.  % Sand = 100  - (% clay + %  silt).

A.2.1.2 Bulk Density--

     Soil  bulk density determination is  based on two measurements,  a mass
measurement and  a  volume measurement.  The mass is measured by  oven  drying
the sample at  105°C until  a constant weight is obtained.  The bulk  volume
measurement includes  the  space  between the  soil  particles as well  as  the
space occuppied  by the soil  parti Ices.  Bulk  density,  the  ratio  of  sample
mass to sample  volume, is  expressed as grains per cubic centimeter (Blake,
1965).   The procedure described below  may  be difficult or impractical  to
use in soil  containing rock  fragments.

A.2.1.2.1   Chemicals—No chemicals  are  required.

A.2.1.2.2  Materials—

 a.  Double-cylinder core sampler with  cutting edge, driving  head,  and
     removable brass  or aluminum sleeves.
                                    92

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 b.   Core cylinder, 7.6 (3  in) in diameter and 7.6 cm (3 in) in height with
     3.2  mm (0.125 in) thick walls.
 c.   Balance, can be read to 0.1 g.
 d.   Drying oven.
 e.   One-pint containers.
 f.   Air  tight  plastic bags.
 g.   Aluminum weighing pans.
 h.   Cloth diapers.
 i.   Desiccator containing drierite.
A.2.1.2.3  Procedure--
 a.   Assemble  double-cylinder core sampler  according to the instruction
     manual.
 b.   Prepare a  flat soil surface at depth in  profile to be sampled.
 c.   Drive core sampler  into the soil with the driving head until the soil
     fills the  brass or  aluminum sleeve and extends slightly above it.
 d.   Remove driving head and twist double-cylinder core sampler.
 e-   Excavate  soil  on one side of the core sampler until  the bottom of the
     cutting edge can be clearly seen.
 f.   To ensure  that  the contact of the core  with  the main soil  body is
     broken, run a  knife across  the  bottom of  the cutting edge.  NOTE:  Do
     this step  taking care not to disrupt the soil core.
 g.   Pack a cloth diaper into  the  top  of the double-cylinder core sampler
     until  it  rests  on  the top of the soil core and hold in place with
     one  hand.
 h.   Gently tilt the  top of the sampler toward  the excavated side until the
     cutting edge of the sampler is exposed.  Put the other hand across the
     bottom of the cutting edge to hold soil  core in place.  Remove core
     sampler from excavation.
 i.   Remove the core and sleeve from sampler  by raising the cutting edge
     and  applying gentle pressure  to bottom of soil core while using the
     cloth diaper to ensure that the soil core does  not slide or fall from
     the  sleeve.
                                    93

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 j.   Trim any  excess  soil  off  both ends of the soil core so a flat surface
     exists  flush with the edges of the sleeve.

 k.   Remove the soil from the sleeve ring and place in a pint container
     lined with a plastic bag.   Take  care  that no soil is lost in transfer.

 1.   Label the sample as to location, depth sampled and  any other pertinent
     information.

 m.   Transfer  the samples to the laboratory.

 n.   Weigh a labeled  aluminum pan and record  the weight  (A).

 o.   Transfer  the moist soil sample to the pan and  record the weight (B).

 p.   Place the pan  with sample in an oven and allow to  dry for 24 hours at
     105°C.

 q.   Remove the pan  with  sample from the oven and cool  in  a desiccator.
     Weigh pan and  contents.  Record  weight (C).

A.2.1.2.4  Calculations—

 a.   Bulk Density  =  (C  -  A)/347.5 cc,  where  347.5  cc is the volume of  the
     cylinder.

 b.   Percent Field  Moisture = [(B - C)/(C  - A)] x 100.

A.2.1.3  Moisture Retention (Pressure Plate Method)--

     The amount of  work needed to remove water from soil is measured by  the
pressure plate approach.   This work  equals the energy with which the soil
sample holds the  water.  In this procedure a  saturated soil sample rests on
a semipermeable membrane and is subjected to controlled  pressures in excess
of atmospheric pressure.  A water continuum,  which  is at atmospheric pres-
sure outside the  apparatus, exists from the  surface of  the soil  sample to
the  open-air side  of  the  semipermeable membrane; therefore, the compressed
gas  forces water out  of the pores of  the sample through  the membrane by  way
of  the  water  continuum.   Water out-flow from the chamber ceases when
equilibrium has been  reached (i.e., when the pressure exerted  by  the gas is
counteracted by the tension with which the soil  particles  hold  the water).
It is possible to determine directly  the moisture content of the  soil at
that particular  tension.  Normally a moisture characteristic curve is
developed by  equilibrating soils at pressures from 0 through  0.15 bars
(Richards, 1965).

A.2.1.3.1 Chemicals—

 a.   Distilled water.

 b.   Compressed nitrogen gas.
                                    94

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A.2.1.3.2  Materials—
 a.  Five bar pressure plate extractor (Soil  Moisture Equipment Company
     Catalog No.  1600 or equivalent).
 b.  Pressure control manifold,  accuracy of control  within 1/100 psi  in the
     0.50 psi  range (Soil  Moisture Equipment Company Catalog  No. 700-3  or
     equivalent).
 c.  One bar pressure plate  cells (Soil Moisture Equipment Company Catalog
     No. 1290 or  equivalent).
 d.  Three  bar pressure plate  cells  (Soil  Moisture  Equipment Company
     Catalog No.  1690 or equivalent).
 e.  Soil sample  retaining  rings  (Soil  Moisture Equipment  Company Catalog
     No. 1093 or  equivalent).
 f.  Connecting  hose (Soil  Moisture Equipment  Company Catalog No. 1293  or
     equivalent).
 g.  Nitrogen gas tank  gauges  -  1  for tank pressure  and 1 for out-flow
     pressure.
 h.  Large spatula or small  pancake turner.
 i.  Wax paper.
 j.  Plastic teaspoon.
 k.  Balance, can be read to 0.01 g.
 1.  Drying oven.
 m.  Aluminum pans for weighing  samples.
 n.  Laboratory notebook.
 o.  Desiccator with silica  gel  desiccant.
A.2.1.3.3  Procedure—This apparatus and procedure are used for negative
pressures of 0i to -3  bar.   Read  instrument's instruction manual  before
starting procedure.
 a.  Check pressure in the nitrogen tank.
 b.  Check all fittings by  pressurizing system.   NOTE:   Take  a toothbrush
     and a  bar of soap and mix up a soapy foam.  Brush  foam over each
     fitting to see if there are any leaks in the system when pressurized.
                                    95

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c.  Check ceramic plates by forcing compressed air into outlet valve.
    Seal off valve and submerge ceramic plate in pan  of  water.   If  any
    bubbles appear, there  is a hole in  the rubber gasket sealed to  the
    plate.  Repair the leak  or do not use the plate.

d.  Place the ceramic plate to be used  in a pan of distil led water  and
    soak overnight (12-16  hrs).   This  is done when the ceramic  plates have
    been dried over a period of time.   If the ceramic plate has been used
    for a previous determination, this prolonged soaking is not necessary.

e.  Take the  aluminum pans  and place a soil sample retaining  ring inside
    the pan.  Draw a line around the top  of the ring so  that the approxi-
    mate height of the ring  is outlined on the inside  of the aluminum pan.
    The desired  volume  of subsample  that would be put  into the  aluminum
    pan would  be slightly less than needed  to fill  the soil  sample
    retaining ring.

f.  Using a thin plastic teaspoon, lift the soil from  the container  and
    fill the aluminum pan to the volume mark.   Do  two replicates in  the
    same manner.  NOTE:   Be sure  that all the pans are marked with  the
    soil sample number.

g.  After the ceramic plate has been  soaked overnight,  place the soil
    sample retaining rings  on the ceramic plate in such a  fashion  that  a
    diagram can be easily made of the set up showing the sample number  for
    each particular ring.

h.  Take the aluminum pan  containing the approximate volume of  soil  sample
    needed and  carefully  dump it into the proper soil  sampling  retaining
    ring  on  the ceramic  plate.  Take  the spatula or  the spoon  and
    carefully flatten  the sample until it  is level with  the  top  edge of
    the soil  sample retaining ring.  NOTE:   Do  not  compact this material.
    Just carefully flatten by spreading.

i.  After all the soil samples have been placed on the soaked ceramic
    plates, add an excess  of water to the  surface  of the ceramic  plate  and
    allow  the  samples to  soak for  16 hours.   NOTE:  Be sure there is
    enough water on the ceramic plate to  allow samples  to wet without
    removing  water from the  pores of the  plates.

j.  Cover samples and ceramic plate with wax paper to  prevent evaporation.

k.  After the samples have  soaked overnight (16 hours),  remove the excess
    water from the surface of the ceramic plate  by means of a pipette.

1.  Remove the wax paper from the soil  samples.   Connect the out-flow tube
    on  the ceramic plate  to  the out-flow tube on  the wall  of  the
    extractor.
                                                                    H nil
m.  Cover the extractor with the metal top.  NOTE:   Be sure that the "0
    ring seal  is in place.
                                  96

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n.
     Clamp the  lid to the bottom of the extractor with clamping bolts.
     Tighten  the wing nuts on the clamping  bolts by hand.

 o.   With the needle  valve,  the "Nullmatic" type regulator,  and the coarse
     adjustment  regulator on the manifold all  closed, pressurize the system
     by means of the controls on the nitrogen tank.  Turn the "Nullmatic"
     type regulator valve to wide open and use the  coarse  adjustment valve
     on  the  manifold  to get a  reading on  the pressure gauge  of  very
     slightly in excess of the desired pressure.

 p.   Use the  "Nullmatic" type regulator to  get the  desired pressure reading
     on the manifold's  pressure gauge.

 q.   Slowly open the  needle  valve at the end of the manifold and pressurize
     the pressure plate extractor.   NOTE:  Two hours after system  is pres-
     surized, check pressure gauge on manifold for  any final adjustment.

 r.   Samples that are 1 cm high can be removed any  time after 48 hours from
     initiation  of the extraction.   Some soils approach equilibrium in 18
     to 20 hours; therefore, after  20 hours  the out-flow tube is tested
     periodically with blotter  paper.   If  no moisture accumulates on the
     blotter paper after it has been held against  the out-flow tube for
     approximately 1  minute, equilibrium has  been  reached and the extrac-
     tion can be stopped.

 s.   Clean aluminum pan previously used.  Oven dry, cool in desiccator, and
     weigh to nearest 0.01 g.  Record weight (A).

 t.   Put a piece of tubing over  the  out-flow  tube and clamp the tubing off
     with a pinch clamp.  Shut the pressure  source off, then drain the
     system of compressed  gas  slowly by  using the  coarse  adjustment  valve
     on the manifold.

 u.   After the  system  has been drained of compressed gas, disconnect the
     hose  leading to the extractor.  NOTE:   This will  ensure that the
     extractor is  no  longer pressurized.

 v.   Remove the  clamping bolts and extractor lid.

 w.   Remove the  samples one at a time and place in weighed aluminum pans.

 x.   Quickly weigh the  aluminum weighing  pan and the sample.   Record weight
     (B).

 y.   Place samples in the drying oven  at 105°C.   Allow samples to dry
     overnight.

 z.   Remove samples from drying  oven and place in a desiccator filled with
     silica gel  desiccant.  Allow samples to cool.

aa.   Weigh samples  and  weighing pan.   Record weight (C).
                                   97

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bb.  Discard  sample.

cc.  Make sure that  the pressure at which the extraction was carried out is
     recorded in the laboratory notebook.

A.2.1.3.4  Calculations—

 a.  Legend:   A = Weight of aluminum weighing pan.
              B = Weight of moist sample and  aluminum weighing pan.
              C = Weight of aluminum weighing pan and oven-dry sample.

 b.  Percent  moisture = [(B - C)/(C-A)]  x 100.

A.2.2  Soil Chemical Methods

     One  method for  each of the required tests is listed.  The step-by-step
procedures listed in this section  are  from  Field and Laboratory Method
Applicable to Overburden  and Minesoil  (EPA,  1978).The procedures in this
publication are applicable to native soil and are outlined in  a very  easy-
to-follow format.  Other methods published elsewhere  are equally effective
and may be substituted at the discretion of the laboratory.

A.2.2.1  Paste pH—

     Perhaps the most commonly measured soil characteristic is pH.  Al-
though pH was defined by  Sorenson (1909) as  the negative  logarithm of the
hydrogen  ion  concentration, in actuality, the hydrogen ion  activity is mea-
sured.   Soil  pH is measured by a glass electrode incorporated with a  pH
meter.  After water is  added to the sample to form a paste, the electrode
is placed in the  paste.  The pH can  be read directly  from  the meter.

     Six  factors  affecting  the  measurement of pH  are:   1) drying the soil
sample during preparation;  2) soil:water ratio;  3)  soluble salts content;
4) seasonally influenced carbon dioxide content; 5) amount of grinding
given the soil; and 6)  electrode  junction  potential  (Jackson,  1958;  Peech,
1965).

     Care must be taken to ensure electrode  life and accurate pH measure-
ments.  The electrode  should not remain in  the sample  longer than  neces-
sary, and it  should be washed with a jet of distilled water from a wash
bottle after  measurement (sample or buffer).   The electrode should then  be
dipped in  dilute hydrochloric acid and washed with distilled water  to
remove any calcium carbonate film which  may  form.  Drying  out  of the  elec-
trode should  be avoided.  The pH meter should be placed in  standby position
when the  electrode  is not in a solution  (Jackson, 1958; Peech,  1965).

     The  following procedure describes  the technique for measuring pH with
a glass electrode and meter.

A.2.2.1.1  Chemicals—

 a.  Standard  buffer solution, pH  4.00 and pH 7.00.


                                    98

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 b.  Distilled water  (H20).
A.2.2.1.2  Materials—
 a.  pH meter  (Corning model 12 or equivalent)  equipped with combination
     electrode.
 b.  Paper cups,  30 ml  (1 oz) capacity.
 c.  Plastic cups.
 d.  Stirring rod.
 e.  Wash bottle  containing distilled water.
 f.  Balance, can be  read to 0.1 g.
A.2.2.1.3  Procedure—
 a.  Turn  on,  adjust  temperature  setting,  and  "zero"  pH meter  per
     instruction  manual.
 b.  Place  pH 4.0  and pH 7.0 standard buffers in two  plastic cups (one
     buffer  in each cup).   NOTE:   NEVER return used buffers  to  stock
     bottles.
 c.  Place electrode  in  the pH 7.0 buffer.
 d.  Adjust pH meter  to  read pH 7.0.
 e.  Remove electrode from buffer solution and wash with a jet of distilled
     water from a wash  bottle.
 f.  Place electrode in the pH 4.0  buffer and check the pH  reading.  NOTE:
     If pH meter varies more than +0.1 pH units  from  4.0, something is
     wrong with the pH meter, electrode,  or buffers.
 g.  Weigh 10 g of less  than 60 mesh material  into a paper cup.
 h.  Add 5 ml of distilled water to sample.  NOTE:   Do not stir!  Allow
     water to wet sample by  capillary action  without stirring.  With most
     soils,  the 2:1 (soil:water) ratio  provides a  satisfactory  paste for pH
     measurements; however, for very coarse textured and very fine textured
     material, more material  or water can  be  added to bring the soil  near
     saturation.  At near saturation conditions,  water  should  not be
     puddled nor  should dry soil  appear at the surface.
                                    99

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 i.   Stir  sample with a spatula until  a thin paste  is  formed, adding more
     water or soil  as required to keep soil  at saturation point.  NOTE:  At
     saturation,  the soil  paste glistens as  it reflects  light,  and the
     mixture slides off the spatula easily.  Wash the spatula  with a jet of
     distilled water before stirring another  sample.

 j.   Place electrode in paste and move carefully about to ensure removal of
     water film around the electrode.  CAUTION:   Do  not  trap particles
     between electrode  and  inside surface  of the  sample  container.
     Electrodes are easily scratched.  Contact between  paste  and electrode
     should be  gentle  to avoid  both  impact and  scratching  damage,
     especially in sandy  samples.

 k.   When reading  remains  constant, record  pH and  remove  electrode from
     paste.   Carefully  wash  electrode with  distilled water to  ensure
     removal of all  paste.   If all pH measurements  are  completed, the
     electrode should be stored in a beaker  of distilled water.   NOTE:
     After every 10 samples, check meter calibration with standard buffers.

A.2.2.2   Lime Requirement by SMP Buffer-

     By measuring  a change in pH of a buffer caused by  the  acids in a soil
Shoemaker et al. (1962) determine the lime requirement of a  soil.  The lime
requirement  is read directly from a  table based on  the pH of a soil after
the  SMP  buffer has been added.

     The  SMP buffer method is very reliable  for soils with a 2  tons per
1000  tons of material lime requirement (2 tons per  acre furrow slice).  An
acre furrow si ice is 6 inches (15 cm) deep over an area of  1 acre (0.4 ha).
It adapts well  for acid  soil with a pH below 5.8 containing less than 10
percent organic matter and  having appreciable quantities of soluble alumi-
num.  A sensitivity of 0.1 pH unit is needed for accurate interpretation of
this  method.  A  difference of 0.1 pH unit will result in a lime requirement
difference of 0.5 to  0.9  tons of  lime per 1000 tons of material for mineral
soils.   Increased exposure time causes greater acidity,  thus causing a
greater  lime requirement.  Increases in organic matter  and/or clay content
increases absorption of acidic cations.

A.2.2.2.1  Chemicals—

 a.   Standard buffer solutions, pH = 4.00 and pH = 7.00.

 b.   SMP  buffer solution:  Dissolve  1.8 g p-nitrophenol  (N02C6H4OH), 2.5 ml
     triethanolamine (CcHjcNO-j), 3.0 g potassium chromate (K^CrO^,  2.0 g
     calcium  acetate  (CatcOoCHoio), and  53.1  g  calcium chloride
     (CaClo*2H20)  with  distil fed water and dilute to 1  liter.   Filter
     througn a fiberglass sheet  if  suspended material is present.  Connect
     an air  inl et  with a 2.54 x 30.5 cm (1 x 12  in) cyl inder of drierite, a
     2.54 x 30.5 cm cylinder of ascarite, and a 2.54 x  30.5  cm cylinder of
     drierite in series.
                                   100

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A.2.2.2.2  Materials—
 a.  Cup, 50 ml glass, plastic,  or wax  paper of similar size.
 b.  Pi pet, 10 ml capacity.
 c.  Shaker,  horizontal  reciprocating  type,  6.3  cm  (2.5 in) stroke, 250
     strokes per minute.
 d.  pH meter (Corning model  12  or equivalent) with combination electrode.
 e.  Balance, can be read to  0.1 g.
A.2.2.2.3  Procedure—
 a.  Weigh 5 g of less than 60 mesh sample into a 50 ml cup.
 b.  Add 5 ml of distilled water.  Mix  for 5 seconds.
 c.  Wait for 10 minutes and read the soil pH (see Section A.2.2.1).
 d.  Add 10 ml SMP  buffer solution to  the cup for mineral soils with a pH
     of 6.5 or less.
 e.  Shake for 10 minutes on  reciprocating shaker at 250 strokes per minute
     or stir.
 f.  Let stand for 30 minutes.
 g.  Read  pH of  the soil-buffer solution to the nearest 0.1  pH unit (see
     Section A.2.2.1).
A.2.2.2.4  Calculations—
    Determine lime requirement from Table  A.I.
                                     101

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Table A.I  Soil-SMP Buffer pH and Corresponding Lime Requirement (L.R.)
           to Bring Material  to pH 6.5*
pH
(tons/1000  tons)1"
pH
                                                     (tons/1000 tons)1"











6.9
6.8
6.7
6.6
6.5
6.4
6.3
6.2
6.1
6.0
5.9
0.3
1.0
1.8
2.4
3.1
3.9
4.6
5.3
6.1
6.0
5.9
5.8
5.7
5.6
5.5
5.4
5.3
5.2
5.1
5.0
4.9
4.8
8.1
8.9
9.6
10.4
11.1
11.7
12.5
13.2
14.0
14.7
15.5

it
t
Adapted from
Agricultural
Shoemaker et al .
ground limestone
(1962).
TNP at least 90 percent.


A.2.2.3  Double Acid Extractable  Phosphorus, Potassium, Calcium, and
         Magnesium--

     This method is a modified  North Carolina double acid method first pub-
lished by Mehlich  (1953) and then by  Nelson et al. (1953).   Phosphorus  (P),
potassium (K),  calcium  (Ca), magnesium (Mg) are extracted  from  the  sample
using a solution containing dilute hydrochloric and sulfuric acid.   Phos-
phorus concentration in the extract is determined using  a  colorimeter and
calibration curve.   The concentrations of K, Ca, and Mg in  the extract are
determined using an  atomic  adsorption spectrometer and calibration curve.
The concentration  of each element can then be converted  into  pounds per
1000  tons.

A.2.2.3.1  Chemicals—

 a.  Hydrochloric acid  (HC1), concentrated.

 b.  Sulfuric acid  (H2S04),  concentrated.
                                     102

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 c.   Extracting solution:  To make 0.05 N HC1  and 0.025 N HoSO*, measure
     about 10 liters deionized water into an 18 liter pyrex bottle.  Add
     12  ml  H2S04 (96%) and 73 ml HC1 (37%).  Make to 18 liters with dis-
     tilled water  and  mix thoroughly by shaking.  Allow 12 hours to  come to
     equilibrium.

 d.   Ammonium molybdate ((NH4)6Mo7024«4H20).

 e.   Ammonium vanadate
 f.  Nitric acid (HNOo), 1 N:  Dilute 64 ml of concentrated HNOo (69.5%) to
     1 liter with distilled water.                             J

 g.  Molybdate  -  Vanadate solution:  Dissolve  25 g of ((NHd)6Mo7Oo4'4HoO)
     in 500 ml  of distilled water.  Dissolve  1.25 g of NH4V03 in 500 ml of
     1 N HN03.  Store  in separate bottles.  Mix equal  volumes of these
     solutions (1 ml  required per sample).  Prepare fresh mixture each
     week.

 h.  Monobasic  potassium phosphate (KH2P04).

 i.  Phosphorus standard  solution:  Dissolve  0.1098 g of KH2P04 in 500 ml
     of extracting solution.  Dilute to  1  liter  with extracting  solution.

 j.  Potassium atomic absorption standard  (1000  ppm).

 k.  Calcium atomic absorption standard  (1000  ppm).

 1.  Magnesium atomic absorption standard  (1000  ppm).

 m.  Potassium (K)  standard stock solution (100 ppm):  Place  10 ml of
     potassium atomic absorption standard  (1000 ppm)  in a  100 ml  volumetric
     flask.  Bring to volume with deionized water.  Make fresh daily.

 n.  Calcium (Ca)  standard stock solution  (200 ppm):   Place  20 ml of magne-
     sium  atomic absorption standard  (1000  ppm) in  a 100 ml  volumetric
     flask  and dilute to volume with deionized water.  Make  fresh daily.

 o.  Magnesium (Mg) standard stock solution (100 ppm):  Place 10 ml of
     magnesium atomic absorption standard  (1000 ppm)  in a  100 ml  volumetric
     flask  and dilute to volume with deionized water.  Make  fresh daily.

 p.  Lanthanum chloride (LaCl3'6H20),  5%:  Dissolve 127 g of LaCl3'6H20
     with deionized water and bring to a volume  of 1  liter.

 q.  Activated  charcoal (Darco G-60 or equivalent).

A.2.2.3.2  Materials—

 a.  Atomic absorption  spectrophotometer (Perkin-Elmer Model 403 or equiva-
     lent).
                                    103

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 b.  Colorimeter (Bausch and Lomb  Spectronic 20 or equivalent).
 c.  Flasks, Erlenmeyer, 50 ml.
 d.  Flasks, volumetric, 100 ml.
 e.  Flasks, volumetric, 200 ml.
 f.  Pipet, 1 ml.
 g.  Pipet, 2 ml.
 h.  Shaker,  horizontal  reciprocating type, 6.35 cm (2.5 in) stroke with
    120  strokes per minute.
 1.  Filter paper (Whatman 40 or equivalent).
 j.  Pyrex bottle, 18 liters.
 k.  Pyrex bottle, 8 liters.
 1.  Balance, can be read to 0.1 g.
A.2.2.3.3 Procedure—
 a.  Place 5.0  g of less  than 60 mesh sample  in a 50 ml  Erlenmeyer flask.
    Add 0.2 g  of activated charcoal.  Prepare two blanks using  only  0.2 g
    of activated charcoal.
 b.  Add 25 ml  of extracting  solution  and  shake for  5 minutes on the
    reciprocating shaker at 120 strokes per minute.
 c.  Filter using  filter paper  and save filtrate for P,  K,  Ca, and Mg
    determinations.  NOTE:   If  filtrate  is cloudy,  refliter.
 d.  Subdivisions  2.1.3.3.4  through 2.1.3.3.6 include the determination of
     individual elements.
A.2.2.3.4  Phosphorus—These  steps  are used for the determination of phos
phorus.
 a.  Turn on colorimeter 15 minutes before  use  and adjust according to
    instruction manual.
 b.  Pipet 4 ml of filtered extract  into a colorimeter tube.
 c.  Add  1 ml of molybdate-vanadate  solution and allow to stand  10 minutes.
 d.  Mix  by inverting tube and shaking by  hand for a few seconds.
 e.  Place tube in instrument and  read percent transmission (%T).
                                    104

-------
     Using %T, determine  the ppm available P  from a  calibration curve
     prepared as  follows:   A) To  separate colorimeter  tubes,  add the
     amounts of chemicals given in Table A.2; B)  Treat as outlined  in
     2.1.3.3.4 steps b-e; C) Plot ppm on the horizontal  axis and % T  on the
     vertical axis.  NOTE:  If sample  does not fall  on calibration  curve,
     samples must  be diluted and results multiplied by the  dilution factor.
     The dilution  factor is obtained by taking the final volume and  divid-
     ing it by the initial aliquot.
Table A.2  Phosphorus Standards
Phosphorus
Standard
Solution
(ml)
0.0
0.5
1.0
1.5
2.0
2.5
3.0
3.5
4.0

Extracting
Solution
(ml)
4.0
3.5
3.0
2.5
2.0
1.5
1.0
0.5
0.0
	 • 	 • •' • • 	 ., ,fc
Molybdate-
Vanadate
Solution
(ml)
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
^MMMtf«"Hllhh«*MIMIMH^IIVBIlMH»MVIVIHBVHIVHIV«IB»«H-IBHHBI«^^
Phosphorus
in
Standard
(ppm)
0.0
2.5
5.0
7.5
10.0
12.5
15.0
17.5
20.0
A.2.2.3.5   Potassium --These  steps are  used for the  determination of
potassium.

 a.  Set  the atomic  absorption spectrophotometer unit on emission mode
     following  the instrument's instruction manual.

 b.  Use the extractant for zero setting.

 c.  Put the extracted sample solution  under the aspirating tube and record
     readings.

 d.  Determine  ppm of K in the sample  from  the calibration curve prepared
     as follows:  A)  Into  separate 100 ml  volumetric flasks,  dilute the  K
                                    105

-------
     standard  stock  solution  with  extracting  solution  for  a  range  of 0 to
     80  ppm  increments; B) Take reading with the atomic absorption spectro-
     photometer;  C)  Plot  available K (ppm)  on the horizontal  axis  and the
     instrument  reading on the vertical axis;  D)  Plot  a curve through the
     points.  NOTE:   If  samples do not fall on the  calibration curve,
     dilute  samples  with extracting solution and multiply results by  dilu-
     tion factor. The dilution factor is obtained by dividing  the final
     volume  by the initial aliquot.

A.2.2.3.6  Calcium and Magnesium—These steps are  used for the determin-
ation of calcium and magnesium.

 a.  Adjust  the atomic absorption  spectrophotometer  following the  instru-
     ment instruction  manual.

 b.  Pipette to 1.0  ml of sample extract  and blank into separate 100 ml
     volumetric flasks.   Add  1.0 ml of 5%  LaCl3'6H20  to each flask.

 c.  Bring to  volume with extracting solution  and  mix by hand shaking.

 d.  In  separate 100 ml volumetric flasks,  prepare the calcium standards as
     shown in  Table  A.3.  Aspirate each standard  into the instrument  until
     a steady  reading  is obtained.   Record reading.

 e.  Make a  calibration curve plotting Ca  (ppm) on the horizontal axis and
     the instrument  reading on the vertical axis.   Plot a curve through the
     points.

 f.  Into separate  200 ml volumetric flasks,  prepare  the  magnesium  stan-
     dards as  shown  in Table  A.4.  Aspirate each  standard into the  instru-
     ment until a steady reading is obtained.   Record reading.

 g.  Make a calibration curve  plotting  extractable  Mg  (ppm)  on  the
     horizontal  axis and  the instrument reading on the vertical axis.   Plot
     a curve through the  points.

 h.  Aspirate  sample extracts  into  the atomic  absorption spectrophotometer
     and record readings.

 i.  Determine ppm  of calcium and  magnesium  from calibration  curves.  If
     samples do not  fall  within  the range of the  calibration  curve, dilute
     sample with extracting solution and add 5% Lado'SHoO, but not to
     exceed 1% La in the  final dilution.  Multiply results by dilution
     factor.  The dilution factor is obtained by taking the  final  volume
     and dividing it by the initial  aliquot.
                                    106

-------
Table A.3  Calcium Standards
Stock Ca
Solution
200 ppm
(ml)
0.0
1.0
2.0
3.0
4.0
5.0

LaCl3'6H20
(ml)
2.0
2.0
2.0
2.0
2.0
2.0
•
Extracting
Solution
(ml)
98.0
97.0
96.0
95.0
94.0
93.0
^^^•.^••^^^•••^•«»^»i^^i^^^^i^»«i^»»^^»^^^»^^^^* • • i •
Calcium
in
Standard
(ppm)
0.0
2.0
4.0
6.0
8.0
10.0
Table A.4  Magnesium Standards

Stock Mg
Solution
100 ppm
(ml)
0.0
0.5
1.0
1.5
2.0
2.5
3.0


LaClq'6HoO

-------
 b.   ppm P in the soil = ppm (read from the curve) x 6.25 x OF.  NOTE:  The
     6.25 is  obtained  from the following equation:   6.25  =  25 ml extracting
     solution/5 g sample)  X  (5 ml  final  volume/4 ml  extract).

 c.   ppm K in the soil = ppm (read from the  curve) X 5 X OF.  NOTE:  The 5
     is  obtained from the following equation:   5 =  (25 ml  extracting
     solution)/(5 g sample).

 d.   ppm Ca  in the soil = ppm (read from the curve) x 500 x DF.  NOTE:  The
     500 is  obtained from the following equation:  500 = (25 ml extracting
     solution/5 g sample)  x  (100 ml  final volume/1  ml  extract).

      pm Mg  in the soil = ppm (read from the curve) x 500 x DF.  NOTE:  The
      00 is  obtained  from the following equation:  500 (25 ml  extracting
     solution/ 5 g sample)  x (100  ml  final volume/1 ml  extract).

 f.   pp2m of element in the  soil = (ppm of element in the soil)  x 2.

A. 2. 2. 4  Total Nitrogen by Kjeldahl  Method—

     In  the  Kjeldahl  procedure,  nitrogen is converted to  the ammonium ion
by oxidation with concentrated sulfuric acid  with the addition of a cata-
lyst such as copper,  selenium, or mercury.  This oxidation, which normally
progresses  very  slowly, can be accelerated by raising  the boiling  point.
This  can be done  by  adding such salts as sodium  sulfate or potassium
sulfate. The procedure is described below.

A. 2. 2. 4.1  Chemical s--

 a.   Kel-pak powder No. 3  (HgO + K2S04) (available  from Matheson Scientific
     Co.).

 b.   Sulfuric acid (hSO,  concentrated.
 c.  Sulfuric  acid  (H2S04), dilute  (approximately 0.1  N):   Dilute 44.8  ml
     of concentrated H2S04  to  16  liters with distilled water.

 d.  Sodium hydroxide (NaHO), 45% with sodium thiosulfate (Na2So03'5H20):
     Under a fume hood in a rubber bucket mix 4545.9 g of NaOH flakes (for
     nitrogen determination) with 438.0  g of Na2S203'5H20.  Dissolve and
     dilute  to 11.355 liters (3 gal) with carbon  dioxide-free water.   Cool
     overnight and  siphon  into  dispensing apparatus.   Protect from C02 in
     the  air with soda lime or ascarite in a guard tube.

 e.  Boric acid (H3B03), 4%:  Dissolve 720.0 g of H3B03 in distilled and
     deionized water on  a  hot pi ate.  Oil ute to 18 liters with distil led
     and  deionized water.   Add 60 ml of bromocresol  green-methyl  red
     indicator  (see below).

 f.  Bromocresol green-methyl red indicator:   Mix 0.5 g of bromocresol
     green and  0.2 g methyl  red with 100 ml of ethyl  alcohol (90%).  Adjust
     to medium  color (brown) with a  few drops of weak NaOH.
                                    108

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 g.  Zinc (Zn), granular.
A.2.2.4.2  Materials—
 a.  Kjeldahl  electric digestion  manifold.
 b.  Kjeldahl  electric distillation  rack.
 c.  Room equipped with exhaust fan.
 d.  Flasks, Kjeldahl, 800 ml.
 e.  Flasks, Erlenmeyer, widemouth,  500 ml, marked at 230  ml.
 f.  Sieve, 20 mesh.
 g.  Balance,  can be read  to 0.1  g.
 h.  Asbestos  gloves.
A.2.2.4.3  Procedure--
 a.  Place 10 g unground sample (sieved  to  20 mesh) wrapped  in filter paper
     in  Kjeldahl  flask.   Also  prepare two  blanks without  soil,  but
     containing filter paper.
 b.  Add 2 packets of No.  3 Kel-pak.
 c.  Turn on exhaust fan.
 d.  Add 40 ml  concentrated H2S04.  NOTE:  While rotating flask, run acid
     down side to carry sample.
 e.  Mix contents by gentle swirling and  place flask carefully on Kjeldahl
     rack.
 f.  When all  flasks are in place, set all  knobs so that a moderate boiling
     and digestion of the  sample  can be  seen.
 g.  After 30  minutes, increase heat to a rapid  boil  for 30  minutes so that
     sulfur dioxide can be released to ensure complete  digestion of the
     sample.
 h.  Rotate flasks  180° and continue heating until  all  the black organic
     matter is digested (usually  about 1  hour).
 i.  Allow  sample  to cool  on digestion rack and stopper.  CAUTION:  Do not
     place stopper  in hot  flask as it may implode upon cooling.
                                    109

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 j.  Let stand until  solution reaches room temperature and cautiously add
     300 ml distilled water to each flask.  NOTE:   Rotate flasks while
     pouring  to wash neck.

 k.  Swirl  flasks gently to dissolve crystals.

 1.  Add 1/4  teaspoon granular zinc to each  flask.

 m.  Pour 30 ml ^803  (4% containing indicator)  into 500 ml wide mouth
     Erlenmeyer flasks.   NOTE:  One required for each sample and blank and
     numbered to correspond to each Kjeldahl  flask.

 n.  Place Erlenmeyer  flasks  on Kjeldahl  distillation rack.  NOTE:  Top of
     glass delivery tube must be below surface of H3B03.

 o.  Turn condenser water switch  to manual.  After 30 minutes turn water
     switch to automatic if unit is so equipped.

 p.  Add 133 ml NaOH (45%)  slowly  to each Kjeldahl  flask.  NOTE:  Allow
     NaOH to  run down side of flask so that  it lies on  the bottom.

 q.  Place each flask on Kjeldahl distillation rack as NaOH  is added,  using
     steps r-u.

 r.  Wet hands with distilled water and apply water to  rubber stoppers.

 s.  Place stopper securely in flask.  Set flask on burner.

 t.  As soon  as flask  is in position, turn burner switch to make a moderate
     boil but not enough to cause solution to boil  into flask neck.

 u.  Swirl  flask  to  mix NaOH  layer with the  rest of the sample solution and
     set back in position making sure stopper is tight.

 v.  When 200 ml  has distilled into receiving flask,  set receiving  flask
     (Erlenmeyer) down and turn off heat. CAUTION:   Be sure to  set flask
     down before turning off heat, or distillate may suck back through
     condensers.  NOTE:  Distillate color  should be green  or  dark blue.

 w.  Wash delivery  tube with  a small  stream of distilled  water from a wash
     bottle before removing receiving flask.
 x.  When cool,  titrate distillate with  0.1 N H2S04 until  solution becomes
     clear and then turns  pink.

 y.  Record reading.

A. 2. 2. 4. 4  Calculations—

 a.  Average of  sample blanks = [reading  (blank  1) + reading (blank 2)]/2.
                                    110

-------
 b.  Corrected  sample reading  =  (sample reading) - (average of sample
     blanks).

 c.  Constant =  (N  acid)  X  (meq.  wt.  of  N)  X  (100)  X  (1/wt. of  sample);
     where N acid  = 0.1,  meq. wt. of  nitrogen = 0.014,  and 100 changes
     constant to  percent.

The equation can  then be written:

Constant  = (0.1) X (0.014)  X (100) X (1/wt.  of sample),  which can be
simplified to:

Constant = (0.14) X  (1/wt. of sample).

 d.  % nitrogen  = (corrected sample reading) X constant.

A.2.2.5  Sodium  Saturated Cation  Exchange  Capacity—

     Cation exchange capacity (CEC) is  defined as the sum of the exchange-
able  cations in a soil.  Several methods  are used  for determining the  CEC
of a soil.  In the method  given  here (Sobeck, 1978) the soil is saturated
with a solution  of  sodium acetate to replace all other exchangeable cations
on  the exchange sites with sodium.   Sodium is then removed from  the
exchange complex by saturating the soil with an ammonium  acetate solution.
CEC is measured  by  determining the  amount  of sodium in the ammonium acetate
extract.

A.2.2.5.1  Chemicals—

 a.  Sodium acetate (NaOAc), 1.0 N: Dissolve 136 g of NaOAc in distilled
     water and dilute to 1 liter.   NOTE:  The pH of  this solution should be
     8.2.   If needed,  add a  few  drops  of  acetic acid or NaOH solution to
     adjust the  pH  to 8.2.

 b.  Ammonium acetate  (NH4OAc), 1.0 N:  Dilute 114 ml  of glacial acetic
     acid  (99.5%) with distilled water  to  a  volume of  approximately
     1 liter.  Then  carefully add 138 ml of concentrated ammonium hydroxide
     (NH4OH) and  slowly add distilled water  to  obtain a volume of approxi-
     mately 1980 ml.   Check the pH of  the solution and add more NH4OH as
     needed to obtain  a pH  of 7.0.  Dilute  the  solution to a volume of
     2 liters with  distilled water.

 c.  Isopropyl alcohol, 99%.

 d.  Potassium  stock solution, 10,000  ppm:  Dissolve 19.07  g of potassium
     chloride (KC1)  in  1 liter of deionized water.

 e.  Standard sodium solution,  1000 ppm, atomic absorption spectroscopy
     grade.
                                    Ill

-------
A.2.2.5.2  Materials—
 a.  Centrifuge tubes, 50 ml,  round bottom polypropylene.
 b.  Rubber  stoppers (to fit centrifuge tubes).
 c.  Shaker, horizontal  reciprocating type, 6.35  cm (2.5 in)  stroke,  120
     strokes per minute.
 d.  Centrifuge (International  Equipment Company Model K  with No. 279 head
     or equivalent centrifuge and  12-place head).
 e.  Volumetric flasks, 100 ml.
 f.  Atomic  absorption  spectrophotometer  (Perkin-Elmer model  403  or
     equivalent).
 g.  Balance, can be read to 0.01  g.
A.2.2.5.3  Procedure—
 a.  Weigh  4.0 g of  less than 60 mesh  material  and transfer to 50 ml
     centrifuge tube.   NOTE:   If the material is  very coarse textured
     (loamy  sand or sand), a 6.0 g sample is used.
 b.  Record  weight of sample (A).
 c.  Add  33  ml of 1.0 N NaOAc solution to the centrifuge  tube.
 d.  Stopper the tube and shake in a reciprocating shaker at  120 strokes
     per minute for  5 minutes ensuring that the  solid material in  the
     bottom  of the tube is completely dispersed.
 e.  Unstopper the tube  and centrifuge until the supernatant  liquid is
     clear  (at least 5 minutes  at  2000  RPM).  Decant and discard  the
     liquid.
 f.  Repeat  steps c through e three more times.
 g.  Add  33  ml of 99% isopropyl  alcohol to centrifuge tube.
 h.  Stopper tube and  shake on reciprocating  shaker  for 5 minutes ensuring
     that the solid material  in the  bottom of the tube is completely dis-
     persed.
 i.  Unstopper centrifuge tube and  centrifuge it until the supernatant
     liquid is clear (at least 5 minutes at 2000  RPM).  Then decant and
     discard the liquid.
 j.  Repeat  steps g through i  two  more times.
                                    112

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 k.   Add  33 ml  of  1 N NH4OAc to centrifuge  tube, stopper tube  and shake for
     5  minutes  ensuring  that the solid material in the bottom of the tube
     is completely dispersed.

 1.   Unstopper  tube  and centrifuge until  supernatant  liquid  is clear (at
     least 5 minutes at 2000 RPM).

 m.   Decant liquid into a 100 ml  volumetric flask.

 n.   Repeat steps k through m two more times.

 o.   Fill the  volumetric flask to  the 100 ml  mark using the 1 N  NH4OAc
     solution.

 p.   Take 10  clean 100 ml volumetric flasks and label them 0, 5, 10, 20,
     30,  40,  50, 60, 70, and 80 ppm sodium.

 q.   Pipet 0.5  ml  of the 100 ppm sodium standard into  the  flask labeled 5
     ppm sodium.  Into the flasks labeled 10  through 80  ppm,  pipet 1 ml
     through  8  ml, respectively,  of the 1000 ppm sodium standard solution.

 r.   Dilute all  flasks to volume with 1  N NH4OAc solution.  NOTE:  The
     flask labeled 0 ppm will  contain only the  1 N NH4OAc  extracting solu-
     ti on.

 s.   Turn on  the atomic  absorption unit and wet  it for  emission mode.  Read
     instruction manual  carefully  and set all  operating parameters accord-
     ing  to  the instrument instruction manual.

 t.   After the  atomic  absorption unit is ready, zero  the  instrument using
     the 1 N  ammonium acetate extracting solution, not distil led water.
     Aspirate standards  and record readings.

 u.   Plot a standard curve using ppm sodium on the horizontal axis and the
     instrument readings on the vertical axis.

 v.   Record  the  instrument  readings for  all  unknowns and read  the
     concentration (B) of sodium from the standard curve.  NOTE:   If the
     unknown  does  not fall within the range of the standard curve which you
     have plotted,  dilute  the  unknown with  NH4OAc  and  potassium stock
     solution using 2 ml of the potassium stock solution for every 10 ml  of
     NH4Ac.   Then measure the amount of sodium present.

A.2.2.5.4 Calculations—

 a.   Legend:  A = Sample weight
             B =  ppm of sodium as read from the standard curve.
             DF = dilution factor, which is  1  or  unity if no dilution of
                 the unknown  had to be made to get it to  read within the
                 range of the standard curve.
                                    113

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 b.  CEC  (meq/100  g) =  (B/1,000,000) x  (DF) x  (Volume extracting
     solution/sample wt.) x (1000 meq/eq.  wt  Na)  x 100 g.

     Where:   Volume extracting solution =  100 ml
                          eq. wt of Na =  23

     The above  equation can be reduced to:

           CEC  (meq/100 g) = (B x DF x 10) /  (23  x A).

A.2.2.6  Electrical Conductance of Soil Extract

     Pure water (water that contains no dissolved substances) is not a good
conductor of electric  current.   With  the  addition of  absorbed  salts,  how-
ever, water becomes a better electric current conductor. Because of this
fact, measuring the amount of electric current conducted through a  soil
extract made with  pure water  provides information about the  amount of salt
present in the  soil.   This sample measurement provides an accurate indica-
tion of the concentration of ionized constituents in the soil extract.   The
electrical conductivity (EC)  of  a soil extract   is closely  related to the
sum of cations  (or anions) as determined chemically.   This measure  usually
correlates closely with total dissolved solids.

     The soil material used for  EC measurements should not  be oven dried.
Material should be air dried and ground to pass a 60 mesh  sieve.

A.2.2.6.1  Chemicals--

 a.  Distilled  water.

 b.  Potassium chloride  (KC1), 0.01  N:  Dissolve  0.7456 g of  KC1  in
     distilled water,  and  dilute with distilled  water to 1 liter.   This is
     the standard reference solution, and  at 25°C  it  has  an  electrical
     conductivity  to  0.00141 mho/cm.

 c.  Sodium metaphosphate ((NaP03)6), 0.1%: Dissolve 0.1  g of  (NaP03)6
     (Fisher  Scientific #S-333) in distilled  water and dilute to 100 ml.

A.2.2.6.2  Materials--

 a.  Wheatstone bridge, alternating-current type, suitable for conductivity
     measurements.  (Industrial   Instruments   Incorporated Model RC-16B2  or
     equivalent).

 b.  Conductivity  cell,  pipette-type,  with platinized platinum electrodes.
     The cell constant should be  approximately 1.0 reciprocal centimeter.

 c.  Flask,  volumetric, 1000 ml.

 d.  Balance, can be read to 0.01 g.

 e.  Aluminum can with lid (large enough to contain sample).


                                    114

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 f.  Spatula.

 g.  Aluminum  weighing  pan.

 h.  Drying oven.

 i.  Dessicator, with silica gel dessicant.

 j.  Buchner type  filtering funnel, 11 cm inside diameter.

 k.  Filter flask.

 1.  Filter paper  (Whatman 42 or equivalent).

 m.  Vacuum source.

 n.  Graduated cylinder,  100 ml volume.

 o.  Pipette,  measuring,  10 ml capacity.

A.2.2.6.3  Procedure—This procedure  is modified from the U. S. Salinity
Laboratory Staff  (1954).

 a.  Weigh 400 g of air-dried soil.  Transfer the soil  to an  aluminum can
     (with lid).

 b.  Add water to  the sample in small  increments by pouring the water down
     the side of the can.  Water  is added to the sample in this fashion
     until  the saturation point of the soil is almost reached.

     NOTE:  Do  not stir soil  sample  while adding water.   Since water
     movement through puddled  soil  is  very slow,  the soil is first allowed
     to wet by capillarity and then mixed to ensure against puddling.

 c.  Stir the  wetted soil with a spatula until a condition of saturation is
     reached.   Small  amounts  of water  may  be  added while mixing  to  ensure
     that the  saturation  point  has  been reached.  NOTE:   At saturation the
     soil paste glistens as it reflects light, and the mixture  slides off
     of the spatula  easily.

 d.  After the mixing has been completed,  place the lid  on the  aluminum can
     and let sample stand for  1 hour or more.

 e.  After the sample has set for the required amount of time,  check  sample
     for saturation.   NOTE:   If the  paste has  stiffened or  lost  its
     gl isten, add more water and mix it again.   On the other hand, if free
     water has collected on the surface of the paste,  add additional  air-
     dry soil  to absorb free water and remix the sample.
                                    115

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f.   After  a  saturated paste has been obtained, remove a teaspoonful of the
    saturated paste for oven-drying and  replace  lid.  Allow  the  saturated
    soil  paste  to stand at least 4 hours.

g.   Weigh an  oven-dry aluminum  weighing pan  to the  nearest 0.01  g.
    Record weight (A).

h.   Place subsample of the saturated soil  paste (from step 6) in aluminum
    weighing pan.  Weigh  pan and  sample to the nearest 0.01  g.  Record
    weight (B).

i.   Place weighing pan and  sample in an oven at 105°C  for 16 hours (or
    overnight).  Remove from oven  and cool  in a dessicator.

j.   Weigh oven-dry  sample and pan.   Record  weight (C).

k.   After the saturated soil paste has stood for at least 4 hours (from
    step f), transfer it  to a  Buchner  funnel  fitted  with  one sheet of
    Whatman  #42  (or equivalent) filter paper.

1.   Attach filter flask to vacuum  source,  apply vacuum, and collect fil-
    trate.  Terminate  filtration when  air begins to pass through the
    filter.   NOTE:  Refilter if filtrate  is turbid.

m.   Add one  drop of 0.1% sodium hexametaphosphate solution for each 25 ml
    of extract.

n.   Allow the  standard 0.01 N KC1 solution and the sample of the soil-
    water extract  to adjust to room temperature.  NOTE:  As long as the
    temperature  of  the  room  is within the  range of  20-30°C,  the absolute
    temperature of the solutions are  not important.   However,  it is
    extremely important that the  standard  solution  and the extract be at
    the same temperature.   If greater precision  is required,  bring the
    standard solution  and  soil-water extracts to a temperature of 25°C in
    a constant  temperature bath.

o.   Turn on  Wheatstone bridge and  allow  instrument to warm up.

p.   When instrument is  ready,  rinse and  fill  the conductivity  cell  with
    the standard 0.01 N KC1 solution.

q.   Balance the Wheatstone bridge according to the instruction  manual
    provided by  the manufacturer.   Record the cell resistance  (D) in ohms.

r.   Rinse and fil 1 the eel 1 with  the soil-water extract.  NOTE:  If the
    volume of the extract is limited,  rinse the cell  with distilled water
    followed by acetone.  Dry the  cell  by drawing air through it  until the
    acetone  has  evaporated.  Allow the cell  to come to room temperature.

s.   Balance  the  bridge and record  the cell  resistance (E)  in  ohms.
                                   116

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A.2.2.6.4  Calculations—
 a.  Legend:  A = Weight of oven-dry weighing pan.
              B = Weight of saturated soil  and weighing  pan.
              C = Weight of oven-dry soil  and weighing pan.
              D = Initial cell resistance.
              F = Final cell resistance.
 b.  % Moisture of sample at saturation = [(B-C)/(C-A)]  x  100.
 c.  Electrical conductivity (EC) mmhos/cm, at 25°C  = [(0.0014118 x D)/F].
 d.  Total cation concentration, meq/liter = 10 x (EC).
A.2.2.7  Organic Carbon by Low Temperature Ignition
     Water and hydroxides are driven  off  the sample by heating at 105°C.
Organic matter  is oxidized by heating at 400°C for 7 hours.  The percent of
organic matter  can be determined by weight loss, as described  below.
A.2.2.7.1  Chemicals—No chemicals are required.
A.2.2.7.2  Materials—
 a.  Muffle furnace.
 b.  Drying oven.
 c.  Desiccator with drierite desiccant.
 d.  Balance, can be read to 0.01 g.
 e.  Crucibles  or evaporating dishes.
A.2.2.7.3   Procedure—This procedure is modified from Jackson  (1958).
 a.  Weigh a clean and dry crucible.  Record tare weight (A).
 b.  Weigh 10.00 g of less than 60 mesh sample in tared  crucible.
 c.  Place in oven and heat for 4 hours at 105°C.
 d.  Remove sample and allow to cool in desiccator.
 e.  Weigh sample.  Record weight (B).
 f.  Place sample in oven and heat for 7 hours at 400°C.
 g.  Remove sample and allow to cool in desiccator.
 h.  Weigh sample.  Record weight (C).
                                     117

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A.2.2.7.4  Calculatlons--

 a.  Legend:   A = Tare weight of crucible.
              B = Weight of sample and crucible  after  heating 4  hours  at
                  105°C.
              C = Weight of sample and crucible  after  heating 7  hours  at
                  400°C.
              D = Weight of sample after heating 4  hours  at  105°C.
              E = Weight of sample after heating 7  hours  at  400°C.

 b.  D = B -  A.

 c.  E = C -  A.

 d.  Organic  matter oxidized by heating = D  -  E.

 e.  % organic matter in sample  =  (Organic matter  oxidized  by heating/D) x
     100.
                                     118

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                               APPENDIX B

   DETAILED PROCEDURE FOR COLLECTING BARREL SIZED UNDISTURBED LYSIMETERS .


B.I  SCOPE AND APPLICATION

     This appendix (adapted from Brown et al., 1984)  provides a detailed
description of the technique for collecting barrel-sized monoliths of
undisturbed soil.   Since the  properties of an undisturbed  soil  differ from
those of a disturbed profile  (Cassel  et al.,  1974),  the  use  of  undisturbed
monoliths is desirable for  studies designed to evaluate hazardous waste
fate and contaminent movement in soil.  In a land treatment demonstration,
a lysimeter can be used to measure  both mobility and degradation on undis-
turbed soil monoliths collected from the site of the land treatment unit.


B.2  LYSIMETER INSTALLATION

     Lysimeter casings must be special ly ordered from a  barrel manufac-
turer.  The straight wal 1 ed cyl indrical casing (57 cm  ID and 85 cm tal 1 )
should be manufactured from 20 gauge steel, painted on the outside, and
coating-free on the inside.  Both ends of the casing  shoul d be rol 1 ed to
accept standard size removable lids.  Prior  to  installation,  four  2.86 cm
diameter hoi es shoul d be dri 11 ed 1 cm bel ow the rol 1 on the upper end of
the casing, and the  inside 0f the casing should be cleaned and painted with
a chemical and moisture resistant non-reactive  paint.

     A one piece  support frame (Figure B.I), required for lysimeter  collec-
tion, is clamped around the casing to support the casing  while it is pushed
into the soil.  The bottom 10.2 cm beveled cutting  edge of the  support
frame  is made to  be the same inside  diameter as  that of the  lysimeter
casing.

     To  fill  the  casing with an undisturbed monolith,  the frame  with
enclosed casing is placed on a vegetation-free soil  and leveled.  A steel
plate  (1.9 cm thick) is placed on top of  the support  frame,  and vertical
pressure is gently applied by means of a backhoe bucket. A trench approxi-
mately 45 to 50 cm wide by 30-45 cm deep (depending  on soil texture) is
excavated with the backhoe  around two sides of  the  support frame; then the
sides of  the  monolith  are  trimmed manually to within  2.5  cm  of the proper
diameter.  The frame and casing can then be forced down over the monolith
by exerting pressure on the top plate  with the backhoe.  The excess 2.5 cm
of soil  is trimmed away by the cutting edge of the  support frame as it
moves down  over the monolith.  An experienced operator  should  be  able to
press the casing  in  increments of 15  to 25 cm  between excavations without
damaging the monolith.

     When the casing is filled to within 15 cm  of the top,  a 51  cm diameter
plywood disk is placed  on the soil surface of the  monolith,  and two 1.9 cm
diameter steel bars placed  through the holes in the top of the casing.
Pressure is again applied to the top plate  until  the plywood is in  firm
contact with the  steel  bars.  In a very sandy soil,  it may be necessary to

                                   119

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                             «•>!»>

                             ICC OCTAIt I
ro
o
                 ITHAI6NT SlOCO • MII
                                                               ALL DIMENSIONS IN CENTIMETERS
                                                                                 I DETAIL 2
                  FIG. B.I. SUPPORT FRAME  DESIGN  FOR  BARREL  LYSIMETER

                          COLLECTION.

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use an hydraulic ram to  push a 0.64 cm steel plate horizontally through the
soil under the cutting edge of the frame.  This steel plate is secured to
the frame to prevent soil  from fal 1 ing out.  In a loam or clay soil, the
structure is usually sufficient to prevent soil  loss during handling.  At
this point,  the  monolith is ready for removal.

     After the monolith has been  tipped  slightly to break it loose, the
lifting and rotating harness  (Figure B.2) is used to remove it from the
hole.  Next,  the casing is rotated  to an upside down position and placed on
two 20 x 20 x 41 cm concrete building blocks.  The support frame can then
be removed from around the  casing  and the soil trimmed to allow installa-
tion of  the  leachate collection system and the lid.   Three porous ceramic
suction cups (Coors Type 7001 P-6-C) are typically installed into  the  soil.
Suction cup  installation is accomplished by excavating a hole just large
enough to receive each  cup and by packing the excavated soil  around each
cup.  A 2.0 cm hole is then  drilled through the soil from the bottom to the
top of the monolith.  Next, a  piece of 1.3 cm ID PVC pipe is installed in
this hole to serve as a conduit for the tubes from  the suction  cups through
the  monolith to the soil  surface.  After  the  soil from bottom  of the
monolith is  leveled and the casing rim cleared, a bead of silicon adhesive
is placed on the rolled edge of the casing, and a sponge  rubber gasket and
lid  are  installed.  A lever lock type clamp is used to attach the  lid.  The
monolith is  then turned upright and transported to  the experimental  site.

     A barrier  to minimize sidewal 1  f1ow should be instal1 ed around the
inside edge  of  each monolith.   This is accomplished by excavating a small
trench (7.5 cm wide x 7.5 cm deep) around the upper edge of each monol ith.
The  inside wall  of the casing  is then washed with water and air dried.  The
barrier is  composed of a 5 cm wide strip of duct tape, which is folded in
half and placed in the bottom  of the trench.   Half  of the strip of tape is
then  taped securely  to the side of the  casing  wall  with  a second strip of
duct tape.   Finally, the soil is replaced and packed into the  trench on top
of the duct  tape, and the  lysimeter is ready to use.
                                     121

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ro
                 CHAIN OR CABLE
                         63.5
                                                  7.0 dia.
,0.6  dia,
                                           63.5
                                                            —   -2.5
                                            1.3
                                                              12.7
                                                                         I 6.5
             ALL DIMENSIONS IN CENTIMETERS
                 FIG. B.2. LIFTING HARNESS FOR  REMOVING AND  ROTATING
                         BARREL LYSIMETERS.

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                               APPENDIX  C

                          QUESTIONS AND  ANSWERS

1.   The treatment demonstration  standard (§264.272) requires the owner or
     operator  to  demonstrate that hazardous constituents can be "com-
     pletely" degraded, transformed, or immobilized iin the treatment zone.
     In this  context, what does "completely" mean?

     The intent of this "complete"  treatment  demonstration  requirement is
to ensure that during the demonstration sufficient data is generated to
allow one  to predict that hazardous constituents can be treated at the
proposed unit.   The extent  of  this  predictive data will vary depending on
the treatment mechanism examined.  When mobility  is examined, test results
must  be able to predict that no statistically significant releases of
hazardous  constituents will  occur from the treatment zone at the proposed
unit.   Obviously,  a successful  demonstration must at least show  "complete"
immobilization (i.e.,  no release)  during  the time  frames of  the  demonstra-
tion.   When the degradation  of organic hazardous constituents is examined,
the critical  results are degradation  rates showing that  the  hazardous
constituents will be completely degraded in the proposed unit prior to
escaping from the  treatment  zone.  A successful  demonstration of  treatment
via degradation does not necessarily require that the organic  hazardous
constituent be completely or (i.e.,  100%) degraded during the limited time
frame of the demonstration.  Rather, the  degradation rate data can be used
in combination with the mobility test results  to  predict successful  treat-
ment  at the proposed  unit.


2.   Section §264.272 requires the owner or operator to demonstrate that
      hazardous constituents can be completely degraded,  transformed, or
      immobilized.   Can this requirement  be  met by demonstrating that all
      hazardous  constituents  (inorganic  and organic)  are  treated  by
      immobilization only?

The preamble to the  Part 264, Subpart M regulations  (47 FR 32325)  states
that degradation and transformation  are  the  primary treatment mechanisms
involved in  land  treatment.  Immobilization  should be  reserved as a treat-
ment mechanism only for the smaller inorganic  and persistent organic con-
stituents  in a land treatable waste.   A treatment demonstration based
solely  on  immobilization as the  primary treatment mode for all   hazardous
constituents  is unacceptable.


3.   Must  air emissions of hazardous  constituents be addressed  in the
     demonstration?

      In the treatment demonstration, the  owner or operator  must address the
mobility of all  hazardous  constituents,  the degradation/transformation of
all  organic  hazardous constituents,  and  the  toxicity of the waste to soil
microbes.   At the  present time,  the evaluation of  air  emissions  of hazar-
dous  constituents in the demonstration is not required  because  of the
problems  associated with air emission measurements  and  the  absence of
regulatory standards  to evaluate the results.  This  position modifies the

                                    123

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guidance  presented  in  the  Permit Applicants Guidance Manual for Hazardous
Waste Land Treatment,  Storage,  and Disposal  FacilitTeT   (Final  Draft,
1984) and the RCRA  Guidance Document:   Land TreatmentTJnits (EPA, 1983).
The appl  icant wil 1,  however, have to meet any state regulations  on  air
emissions of  hazardous constituents and  should be  aware that the Agency is
in the process of developing regulations pertaining to air emissions.


4.   If an owner/operator intends to do  interim status treatment demonstra-
     tion field tests on one or more plots of an existing land treatment
     unit,  and the  EPA issues  a short-term  demonstration  permit or  a  two-
     phase permit to cover these tests, how is the  interim status  of  the
     remaining plots of the land treatment unit affected?

     In certain cases,  treatment demonstration  field  tests may  be completed
at an existing land treatment unit provided that they are not conducted in
a manner  that  leads to a violation of the interim status standards.  In  the
event that the tests are likely to cause a  violation of the ISS, a special
permit must be obtained for these tests.  However, if a short term  permit
or a two-phase permit  is issued to allow these tests on a few  plots  of  the
unit, the interim  status  of the remaining plots is unaffected, and  the
owner/operator can  continue  to  operate  under  ISS  for the remaining  plots.
In special cases, such as small  land treatment units, the short-term  permit
or Phase I of a  two-phase  permit may apply to a large part of  the  entire
interim status unit.
5.   In a mul ti-unit facil ity, can the two-phase permit approach be used
     for the land treatment unit while the remaining units are processed
     according to  the normal  permitting approach?

     Yes.  Section 270.1(c)(4)  states that the  EPA  may issue or deny a
permit for one or more units at  a  facility without simultaneously issuing
or denying  a  permit  to all of  the units at  the facility.   The interim
status of any  unit for which a permit has neither  been issued nor denied  is
not affected by issuance or denial  to any other unit of  the facility.


6.   Scenario  3 includes the completion  of a laboratory  toxicity test and a
     field plot or barrel lysimeter at an HWLT unit while it is still  under
     interim status.   Chapter 3  of this manual states that demonstration
     studies may be done at an IS unit provided interim status standards
     are not violated.   Can  these  laboratory  tests be done at an off-site
     laboratory  that has neither  interim  status nor  a  final  Part 264
     permit?

     Yes.  Part 264.4 of the regulations states that a sample of solid
waste or a  sample of  water, soil, or air, which is col lee ted for the sole
purpose of  testing to determine its characteristics or composition,  is not
subject to any requirements of Parts 262-267 or Parts 124 and 270.  Part
264.4  does,  however,  specify certain conditions that must be met in regard


                                    124

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to shipping the sample to qualify for this exemption.  The laboratory test
described in this document is a short-term  test on a small  sample volume to
evaluate  the  biological  toxicity characteristics  of the waste.  Since the
act of testing does not  constitute treatment of  samples,  laboratories do
not need a permit to conduct such testing.


7.   In determining the application rates for the demonstration,  how many
     rates should be considered?

     Where limited data are  available about the behavior of the waste(s) at
the given  unit (e.g.,for new units), or where past  operating practices have
been poorly defined or have  resulted in poor treatment of the waste(s),
this protocol suggests  that  the applicant should,  ideally, consider testing
three annual  loading rates.  More rates may lead to unnecessary costs while
testing fewer rates risks a failure of the  initial  LTD endeavor, leading to
costly delays in  the permitting procedure and  to  expensive retesting,  and
possibly even to permit denial  and/or enforcement  action.  Even when a unit
is well documented and loading rates are relatively well  understood, use of
only one  rate in  the testing,  although allowable, may  risk  a similar LTD
failure, especially if the current waste  loading  rate is high. For lightly
loaded units,  use of  the current rate  may unnecessarily  limit the future
(full) utilization of the site's  inherent  capacity to treat waste.


8.   If several  hazardous  wastes are treated at the  same unit,  must a
     separate LTD be performed for each?

     A single demonstration will  suffice  if the wastes are generated rou-
tinely (e.g.,  monthly) and co-mingled on the same parcel  of land.   In such
cases, proportional amounts of each waste may merely be combined and ap-
pliedas  if they were one. This mixture should also include significant
nonhazardous wastes that are applied at the site.  An alternative  is to do
an LTD for the worst quality  waste among those  land treated at the site.
For example, if  the data show no substantive differences between an API
separator sludge, DAF  float, and  slop-oil  emulsion solids, only one may be
used to make the demonstration.  If, however, the  washes are maflaged1 on
separate portions of the unit, separate demonstrations should be performed
for each  unless  it can  be  shown that the wastes are  not substantively
different.


9.   How does one deal  with  wastes that are generated only infrequently?

     Infrequently generated  wastes should be managed  on separate parcels of
land and  should  be demonstrated separately if there are substantive dif-
ferences between  the wastes.  The answer  to Question 8 may partially answer
this question.  The frequency of application in  the LTD should be altered
from that proposed in  this document to match the  frequency  of waste genera-
tion (i.e.,  wastes  generated less than one per year should be tested using
a one time  application).
                                     125

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10.   In  choosing the constituents to be  monitored in the demonstration,  can
     the applicant  ignore hazardous constituents present  in  low concentra-
     tions  and use  indicators instead?

     Because  of the influences of sample size, analytical  detection limits,
and background concentrations,  all  hazardous constituents that can be
detected in  the  waste or  its degradation  products should be analyzed
throughout  the experimental phases of the LTD.  Since compounds  or  elements
that have been identified  as  hazardous  are often so even  in  low concentra-
tions and because these compounds, if they are resistant  to  treatment,  may
build up in soil over time,  any identifiable constituent  is  of  concern.
Chapter 10 of this  document should give some guidance on this issue. The
authors  have  taken  particular  care to limit the analytical  burden  and cost
of the procedures presented in this document  to  that information considered
essential  to the demonstration. It should also be noted that few wastes
contain a very extensive array of the  constituents listed in 40 CFR 261
Appendix VIII.


11.   The test protocols in  this  manual  indicate that different  soil series
     should be examined separately in  the demonstration.  Are there any
     exceptions to  this general rule?

     Soils with  different  characteristics should be examined separately in
the demonstration because these  differences may significantly affect waste
treatment.  The USDA, SCS  classification system  is used to define different
soils (i.e.,  "soil  series") because it is a standard, widely recognized
classification  system.  An owner/operator may, however, demonstrate through
certification by a qualified soil  scientist that the differences in the
"soil series" at his HWLT unit will  not significantly affect the treatment
of hazardous waste at the unit.  If this demonstration  is  approved, the
different soils  series will be considered  the same for the purposes of  the
demonstration and the UZM  program.
                                            •U.S. GOVERNMENT PRINTING OFFICEI  1985-461-221/24031
                                    126

-------
                                  ERRATA SHEET

                Draft Permit Guidance Manual on Hazardous Waste
                     land Treatment Demonstrations (12/84)


     Due to an error, the following equations and the reference list were
inadverently omitted from the draft manual printed by GPO.  Please make
note of these additions.

Equations

p. 49    T = _ X R _  - 1 ;   where:  T = gamma light decrease
                   _                           Xg = mean chart reading for blank
                   X s              •           _    at time t; and
                                               Xg = mean chart reading for sample


p. 50     *f =  f corrected 0 time light level      - 1 1
               I 5 minute light level for sample       j


p. 57    Dto = Can - (CTO - Cs)
                    ^ao

p. 58    Dti = Caj - (Crj - Csj)
                    Cai

p. 71    Dto = Can - (Cro - Cg)   ;     Dti = Cai - (CH - Csi )
p. 75    Cyr =  1/2 Ccrit    ;   LRRDC =  Cyr  ;  A = PR     ;  NA =
                 T 1/2                 Cw       LRRLC           AL
                                      x  (weight fraction of residual
p.  76    UL = LCAP     ;    z  = _ solids  in waste) _   x   10~5
p. 77     n  =   Z    In
Reference  List   (see next page)

-------
                                REFERENCES


Alexander,  M.   1977.  Introduction to soil  microbiology.   John  Wiley and
Sons, Inc.  New York.

Alexander,  M.  1980.  Biodegradation  of  toxic  chemicals in water and soil.
pp. 179-190 In:  R. Haque (ed.) Dynamics, Exposure,  and Hazard Assessment
of Toxic Chemicals.  Ann Arbor Science Publ.,  Inc.   Ann Arbor, MI.

American Petroleum Institute.   1983.   Land treatment  practices  in  the
petroleum  industry.  Environmental  Research  and Technology,  Inc.  Concord,
MA.

Beckman  Instruments,  Inc.   1982.   Beckman   Microtox™  System  operating
manual.  63 p.

Black,  C.  A.   (ed.)  1965.  Methods of soil analysis.   Am.  Soc. of Agro-
nomy.  Madison, WI.

Blake,   G.  R.   1965.   Particl e density.  In:   C. A. Bl ack (ed.) Methods
of Soil  Analysis.    Agron.  9:371-373.    Am.  Soc.  of  Agronomy.    Madi-
son, WI.

Bououcos,  G.  J.    1951.   A  recalibration  of the  hydrometer method  for
making mechanical  analyses of soils.  Agron J.  43:434-437.

Bremner,  J.   M.    1965.   Total  nitrogen.  In:   C. A. Black (ed.) Methods
of Soil  Analysis.    Agronomy 9:1149-78.    Am.   Soc.  of Agronomy.   Madison,
WI.

Bremner,  J.  M.  and C. S. Mulvanex.   1982.   Nitrogen-total,   pp. 595-624.
In:   A.  L.  Page,  R.   H. Miller, and D.  R. Keeney (eds.) Methods of Soil
Analysis Part 2.   Chemical and Micro-bological Properties.   Amer.  Soc. of
Agronomy.  Madison, WI.

Brown,  K.  W.,  K.  C»  Donnelly,  and  L.  E, Deuel, Jr.  1983.  Influence of
nutrient   additions,   sludge   application    rate,   and   frequency   on
biodegradation of  two oily sludges. Microbial  Ecology 9:363-373.

Brown,  K.   W.,  C.  J.   Gerard,   B.  W.   Hipp, and  J. T. Ritche.  1974.  A
procedure for placing large undisturbed monoliths  in lysimeters.  Soil Sci.
Soc.  Am. Proc. 38:981-983.
                                      127

-------
Brown,  K.   W.,   J.  C. Thomas, and M. W.  Aurellus.  1984.  A procedure  for
collecting  barrel  sized undisturbed soil  monoliths.   Soil  Sci.   Soc.   Am.
Proc. (in review).

Burks,  S.   L.,   M.  Amalon, E. F. Stebler, J.  Harmon, F. Leach, M. Sanborn,
and  J.   Matthews.  1982.  Comparison of  acute response  of Microtox1",
daphnia Magna, and  fathead minnows to oil  refinery wastewaters.   Progress
Report to Oil   Refiners'  Waste Control  Council  by Oklahoma  State  Univer-
sity,  Water Quality Research Laboratory.  Stillwater, Oklahoma.  24 p.

Cassel ,  D. K., T. H.  Kruger, F. W. Schroer, and E. B. Norum.  1974.  Solute
movement through disturbed and undisturbed  soil  cores;  Soil  Sci. Soc.  Am.
Proc. 38:36-40.

Casseri,   N. A.,  W. Ying, and S. A. Soiyka.  1983.  Use  of a rapid bioassay
for assessment of industrial  wastewater treatment effectiveness.  Presenta-
tion at the Purdue Industrial Waste Conference.   18 p.

Dindal,  D. L.   1978.   Soil  organisms  and stabilizing wastes.  Compost
Sci./Land  Utilization  19(4):8-11.

Edwards,  N. T.  and  B.  M. Ross-Todd.   1980.  An improved bioassay technique
used  in solid waste leachate phytotoxicity research.    Environ,  and  Exp.
Bot. 20:31-38.

EPA.   1980.   Guidelines   for quality assurance/quality  control  Program.
Environmental  Monitoring Systems Laboratory,  Las Vegas, NY.  QAMS-005-80.

EPA.   1982.   Test methods  for evaluating solid  waste:   physical/chemical
methods.   Second Edition.  U. S. EPA Office of  Sol id Waste and Emergency
Response.  'Washington, D.C.  SW-846.
                                                                       /*

EPA.  1983A.  Hazardous Waste Land Treatment.   U. S.  EPA Office of Solid
Waste.  Washington,  D.C.  SW-874.

EPA.  19838.  RCRA  Guidance  document:   land treatment units.   U. S.  EPA
Office of Solid Waste.   Washington, D.C.

EPA.   1984A.   Unsaturated  zone monitoring for  hazardous  waste land
treatment units.   U. S.  EPA Office of Solid Waste.   Washington, D.C.

EPA.  1984B.  Permit applicant's  guidance manual  for  hazardous  waste land
treatment, stroage, and disposal facilities,   U. S. EPA Office of Solid
Waste.  Washington,  D.C.

Jackson,  M.   L.  1958.  Soil chemical  analysis.   Prentice-Hall,  Inc.
Englewood  Cliffs, NJ.

Kaufman,  D.  D.   1983.    Fate of toxic organic  compounds in  land-applied
waste.   pp.  77-151.   In:  J.  F. Parr,  P. B. Marsh,  and J. M. Kia (eds.).
Land  Treatment  of Hazardous Wastes.    Noyes  Data   Corp.   Park   Ridge,
NJ.
                                     128

-------
McClean, E. 0.  1982.   Soil  pH  and  lime requirement,  pp. 199-224.   In:   A.
L.  Page,   R.  H.  Miller,  and  D. R. Keeney (eds.) Methods of Soil  Analysis
Part   2.    Chemical   and  Microbiological  Properties.   Am.  Soc.   of
Agronomy.   Madison,  WI.

Mechlich, A.   1939.  Use of triethandamine acetate -  barrier hydroxide
buffer for determinators  of  some  base exchange properties and lime
requirement of soil.  Soil  Sci. Soc. Am. Proc. 3:162-166.

Nelson,  W.  L,  A.  Mehlich,  and E.  Winters.    1953.   The  development,
evaluation,   and  use  of  soil  tests for  phosphorus  availability.    In:   W.
H. Pierre  and A.  G.   Norman (eds.) Soil  and Fertilizer  Phosphorus.
Agron.  4:153-188.

Nelson,  D. W. and L.  E.  Somrners.  1982.  Total carbon,  organic carbon, and
organic matter.    pp.   539-580.   In:   A. L. Page, R.  H. Miller, and D.  R.
Keeney  (eds.)  Methods  of  Soil Analysis Part 2.   Chemical and Microbiologi-
cal Properties.   Am. Soc. of Agronomy.  Madison, WI.

Neuhauser,  E.  F.,   M.  R.  Malecki, and R. C. Loehr.  1983.  Methods using
earthworms for the evaluation of potentially toxic materials  in soil.   In:
R. A. Conway and W.  P. Gulledge (eds.) Hazardous and Industrial  Solid Waste
Testing:  Second Symposium.   ASTM STP 805.  American Society  of Testing and
Materials.

01 sen,  S. R. and L. E. Sommers.  1982.  Phosphorus,  pp. 403-43U.   In:   A.
L.  Pae,  R.   H.  Mil 1 er, and D. R.  Keeney (eds.) Methods of Soi 1 Analysis
Part   2.   Chemical  and  Microbiologal Properties.   Am. Soc.  of  Agronomy.
Madison,  WI.

Overcash, M.  R.  and D. Pal.  1979.  Design of land treatment systems for
industrial wastes-theory  and practice.   Ann Arbor Science Publ., Inc.  Ann
Arbor,  MI.

Peech,  M.    1965.  Hydrogen ion activity.   In:  C. A. Black (ed.)  Methods
of Soil Analysis. Agron  9:914-920.

Peltier,  W.    1978.  Methods for measuring the acute toxicity  of effluents
to aquatic organisms.   EPAr-600/4-78-012.

Rhoades, J. D.  1982.   Soluble  salts,  pp. 167-180.  In:   A.  L.  Page,  R.  H.
Miller,  and  D.  R. Keeney (eds.) Methods of Soil Analysis Part  2.   Chemical
and  Microbiological  Properties.    Am. Soc. of Agronomy.    Madison, WI.

Richards,  L.  A.    1965.  Physical  conditions of water in soi 1.   In:   C.
A. Black (ed.) Methods of Soil  Analysis.   Agron.   9:128-137.    Am.  Soc.  of
Agronomy.   Madison,  WI.

Shoemaker, H.  E.,  E. 0. McLean, and P. F. Pratt.  1962.   Buffer methods for
determination   of lime requirements of soils with appreciable   amounts   of
exchangeable  aluminum.  SSSAP 25:274-277.
                                     129

-------
Skinner,   J.   1984.  Guidance on petroleum  refinery waste analysis  for land
treatment  permit  applications.   Report to Hazardous Waste  Permit Branch
Chiefs from  Office of  Solid  Waste.   U.  S.  EPA Office of  Solid Waste.
Washington, D.C.

Sobeck, A. A., W. A. Shuller, J. R. Freeman, and  R. M Smith.   1978. Field
and laboratory methods applicable  to overburdens and minespoil.  U. S.  EPA
No. 600/2-78-054.  U. S.  Environmental  Protection Agency.  Cincinnati, OH.
200 p.

Sorensen, S.  P. L.  1909.  Cited by Peech,  M.  1965.

U. S.  Salinity  Laboratory Staff.  1954.  Diagnosis and improvement of
saline and alkali soils.  U. S. Department of Agriculture  No. 60. U. S.
Government Printing Office.  Washington, D.C.
                                    130

-------
                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
  DATE:
SUBJECT-:
  FROM:
    TO:
Draft Permit Guidance Manuals for Hazardous Waste  Land
Treatment Units^_
       jf^^Sktu&r-
KennetrPA. Shuster, Chief
Land Disposal Branch (WH-565)

Addressees
             Attached  for  your information are two draft manuals
        entitled,  "Permit  Guidance  Manual  on Hazardous Waste Land
        Treatment  Demonstrations"  and  "Permit Guidance Manual on
        Unsaturated  Zone Monitoring for Hazardous  Waste Land Treatment
        Units."  The availability  of these draft manuals for public
        comment  and  review was recently announced  in  the Federal
        Register (see  attachment).

             "Permit Guidance  Manual on Hazardous  Waste Land Treatment
        Demonstrations" provides detailed  guidance on specific labo-
        ratory and field test  methods  that may be  used to complete the
        treatment  demonstration, which is  required under §264.272 for
        owners/operators of land treatment units.   The manual also
        describes  alternative  permitting approaches (e.g.,  two-phase
        permit,  short-term permit,  etc.) for various  situations.

             "Permit Guidance  Manual on Unsaturated Zone Monitoring for
        Hazardous  Waste Land Treatment Units" provides guidance on the
        development  and implementation of  effective unsaturated zone
        monitoring systems for land treatment units.   The manual covers
        both soil  core and soil pore-liquid monitoring and addresses
        equipment  selection, installation, and operation, sampling
        procedures,  chain  of custody considerations,  and data analysis
        and evaluation.

             A limited number  of additional copies of these manuals may
        be obtained  from the RCRA  Hotline.  Any comments or questions
        should be  directed to  Mike  Flynn of my staff  (WH-565E) at
        FTS-382-4489.

        Attachments
        Addressees:

        OSW  Senior Staff
        OSW  Branch Chiefs
        OERR Senior  Staff
        OWPE Senior  Staff
        Mike Barclay (WH-527)
        Amy  Svoboda  (LE-134W)
        Sam  Napolitano  (PM-220)
        Mark Greenwood  (LE-132S)
        Nancy Hutzel (LE-132W)
                                 Susan Schmedes  (LE-132W)
                                 Dick Scalf, RSKERL-Ada
                                 Norb Shomaker,  SHWRD-Cinn
                                 Les McMillion,  EMSL-LV
                                 Will LaVeille  (RD-682)
                                 EPA Headquarter's Library
                                 EPA Regional Libraries
                                 State Hazardous Waste Agencies
EPA Form 1320-6 (Rev. 3-761

-------
 1238
Federal  Register / Vol. 50,  No. 7 / Thursday, January 10,  1985 / Proposed Rules
 non-conveyed properties, there shall be
 included on account of such costs, in
 those cases involving mortgages on
 which the unpaid principal obligation at
 the time of the institution of foreclosure
 exceeds 80 percent of the appraised
 value of the property as the date the
 mortgage was accepted for insurance,
 an amount not in excess of the greater of
 the following:
 *****
 (Sec. 7(d), Department of HUD Act (42 U.S.C.
 3535(d)), Sec. 211, National Housing Act (12
 U.S.C. 1715(b)), Sec. 204(a). National Housing
 Act (12 U.S.C. 1710(a))
   Dated: November 30,1984.
 Maurice L. Barksdale,
 Assistant Secretary forHousing—Federal
 Housing Commissioner.
. [FR Doc. 85-617 Filed 1-9-85; 8:45 am]
 BILLING CODE 421O-27-M
 ENVIRONMENTAL PROTECTION
 AGENCY

 40 CFR Part 264
 [OSWER-FRL-2754-5]

 Hazardous Waste Treatment, Storage,
 and Disposal Facilities; Availability of
 Information

 AGENCY: Environmental Protection
 Agency.
 ACTION: Notice of availability of
 information and request for comments.

 SUMMARY: The Environmental Protection
 Agency today announces the
 availability of two draft Permit
 Guidance Manuals for public comment.
 These manuals are (1) Permit Guidance
 Manna! on Unsaturated Zone
 Monitoring for Hazardous Waste Land
 Treatment Units (EPA/530-SW-84-016),
 and (2) Permit Guidance Manual on
 Hazardous Waste Land Treatment
 Demonstrations (EPA/530-SW-84-015).
 The first manual provides guidance on
 unsaturated zone monitoring for
 hazardous waste land treatment units. It
 can be used by permit applicants and
 permit writers to develop effective
 monitoring systems that comply with the
 Part 264, Subpart M regulations. The
 second manual provides guidance on
 treatment demonstrations that are
 required under § 264.272 for all owners
 and operators of hazardous waste land
 treatment units.
   These manuals may be used for
 information and  guidance by owners
 and operators of facilities that treat or
 dispose of hazardous waste in land
 treatment units. These manuals will
 assist in the implementation of the 40
 CFR Part 264 hazardous waste
 management regulations by helping
                        owners/operators and permit officials to
                        design and carry out comprehensive
                        treatment demonstrations and to
                        develop effective unsaturated zone
                        monitoring programs.
                        DATE: Comments on these draft permit
                        guidance documents must be submitted
                        on or before March 11,1965.
                        ADDRESS: Comments should be
                        addressed to Docket Clerk, Office of
                        Solid Waste (WH-562), U.S.
                        Environmental Protection Agency, 401M
                        Street. SW.. Washington, D.C. 20460. All
                        communications should identify the
                        document title and publication number
                        (e.g., Permit Guidance Manual on
                        Hazardous Waste Land Treatment
                        Demonstrations (EPA/530-SW-84-015)).
                          Copies of these draft guidance
                        manuals are available for reading at the
                        EPA Library Public Information
                        Reference Unit (Room 2904} and the
                        Subtitle C Docket Room (Room S212),
                        both located at 401 M St.  SW,
                        Washington, D.C., 20460,  as well as at
                        all Regional Office Libraries, Monday
                        through Friday during the hours of 9:00
                        a.m. to 4:30 p.m. A limited number of
                        personal copies of the draft manuals
                        may be obtained by calling the RCRA
                        Hotline at (800) 424-9346 (toll free] or at
                        (202) 382-3000.
                        FOR FURTHER  INFORMATION CONTACT:
                        RCRA Hotline, at  (800) 424-8346 (toll
                        free) or at (202) 382-3000. For technical
                        information, contact Michael Flynn,
                        Office of Solid Waste (WH-565E), U.S.
                        Environmental Protection Agency, 401M
                        Street, SW.. Washington, D.C. 20460, at
                        (202) 382-4489.
                        SUPPLEMENTARY INFORMATION: Subtitle
                        C of the Resource Conservation and
                        Recovery Act (RCRA), Section 3004,
                        required the Environmental Protection
                        Agency (EPA) to promulgate regulations
                        setting performance standards for
                        owners and operators of facilities that
                        treat, store, or dispose of hazardous
                        waste. 40 CFR Part 265 contains the
                        standards applicable to owners and
                        .operators of interim status  facilities,
                        while 40 CFR Part 264 contains
                        permitting standards for new and
                        existing facilities.
                          To help implement these standards,
                        the EPA has developed a series of
                        guidance documents. There are  three •
                        types of documents: RCRA Technical
                        Guidance Documents, Permit Guidance
                        Manuals, and Technical Resource
                        Documents. The Permit Guidance
                        Manuals are directed to permit
                        applicants and EPA/State permit
                        writers. They describe the  permitting
                        process, present the regulatory
                        requirements, and provide
                        recommendations for the preparation of
                        a permit application and the
development of the resulting permit.
Certain Permit Guidance Manuals also
provide detailed technical and policy
guidance on specific regulatory
requirements that must be addressed in
the facility's permit. The detailed policy
guidance in these documents is an
elaboration of the Agency's policy
guidance already described in the
preamble to the regulations.
  Today's notice announces the
availability of two draft Permit
Guidance Manuals. These manuals are
Permit Guidance Manual on Hazardous
Waste Land Treatment Demonstrations
and Permit Guidance Manual on
Unsaturated Zone Monitoring for
Hazardous Waste Land Treatment
Units.
  Permit Guidance Manual on
Hazardous Waste Land Treatment
Demonstrations provides permit
applicants and writers with guidance on
land treatment demonstrations required
under § 264.272. The manual identifies
specific laboratory and field test
methods  that may be used to complete
the demonstration, and describes the
applicability of alternative treatment
demonstration approaches and
permitting procedures (e.g., short-term
permit, two-phase permit, etc.) to
various situations. The manual
addresses numerous technical and
policy  questions regarding the overall
approach to the demostration, the
extensiveness of the demostration, and
the permitting of land treatment units to
accommodate the treatment
demonstration.
  Permit Guidance Manual on
Unsaturated Zone Monitoring for
Hazardous Waste Land Treatment
Units is directed toward permit
applicants and permit writers who are
developing unsaturated zone monitoring
programs for hazardous waste land
treatment units required under § 264.278.
This manual covers both soil core and
soil pore-liquid monitoring. Equipment
selection, installation, and operation,
sampling procedures, chain of custody
considerations, and data evaluation are
all addressed. The installation and
sampling procedures are presented in a
step-by-step format so that the manual
may be easily used by field personnel.
   The  Agency requests comments on the
accuracy and cpmpletness of the
information presented in these draft
documents. EPA encourages
commenters to suggest remedies and
alternatives should inaccuracies or
incompleteness be identified.
List of Subjects in 40 CFR Part 264
   Hazardous materials Packaging and
containers, Reporting and recordkeeping

-------
                Federal Register  /  Vol. 50, No.  7 / Thursday, January 10, 1985 / Proposed Rules
                                                                           1239
requirements, Security measures, Surety
bonds, Waste treatment and disposal.
  Authority: Sees. 1006, 2002(a), 3004 and
3005 of the Solid Waste Disposal Act as
amended by the Resource Conservation and
Recovery- Act of 1976, as amended (42 U.S.C.
6905, 6912(a). 6924, and 6025).
  Dated: December 26,1984.
lack McGraw,
Acting Assistant Administrator for Solid
Waste and, Emergency Response.
[FR Doc. 85-704 Filed 1-9-85; 8:45 am]
BILLING CODE (SM-50-N  .
FEDERAL COMMUNICATIONS
COMMISSION

47 CFR Part 73

(Gwi. Docket No. 82-797; FCC $4-647]

Commission Policy Regarding the
Advancement of Minority Ownership in
Broadcasting

AGENCY: Federal Communications
Commission.
ACTION: Report and Order; Denial of
Proposed Rule.

SUMMARY: This Report and Order
declines to adopt the change in
Commission Rule § 73.1150 proposed in
the Notice of Proposed Rule Making in
Gen. Docket 82-797. Specifically, the
Commission determined that allowing a
seller-creditor to retain a reversionary
interest in the license in a seller-
financed sale of a broadcast property to
a minority buyer is prohibited by the
Communications Act of 1934, as
amended. The Commission further
concluded that permitting a seller-
creditor to contractually guarantee a
contingent right to reassignment of a
broadcast license would be inadvisable
as a matter  of policy. The Commission
found that such action would pose a
serious threat to the ability of a minority
buyer to freely and independently
operate a broadcast station in the public
interest.
FOR FURTHER INFORMATION CONTACT
Marcia C Alterman, Mass Media
Bureau, (202) 632-7792.
SUPPLEMENTARY INFORMATION:

Report and Order (Proceeding
Terminated)
  In the Matter of Commission Policy
Regarding the Advancement of Minority
Ownership in Broadcasting; General Docket
No. 82-797.
  Adopted: December 21,1984.
  Released: January 8,1985.
  By the Commission.
  1. Before the Commission for
consideration are comments filed in
response to the Notice of Proposed Rule
Making ("Notice") in the above-
captioned proceeding.' The Notice
solicited comments with respect to
permitting alternative security
arrangements in seller-financed sales of
broadcast properties to minorities.

Background
  2. The Commission has long supported
increased minority participation and
ownership in the broadcast industry.
Such participation benefits not only
minorities, but the general public as
well, by diversifying control of the
media and thus the  selection of
available programming. Accordingly, the
Commission is firmly committed to the
goal of encouraging minority
participation in the  broadcast industry.
In 1981, we created  the Advisory
Committee on Alternative Financing for
Minority Opportunities in
Telecommunications (Advisory
Committee) in furtherance of this goal.*
The Advisory Committee examined
regulatory and economic conditions
thought to hinder minority acquisition of
telecommunication properties and its
Report^ offered a number of proposals
designed to enhance minority
ownership. Several  of these proposals,
such as the expanded use of distress
sales and  the broader availability of tax
certificates, have already been adopted.4
This Report and Order deals with the
Advisory Committee's  proposal
concerning the possible expansion of
seller-creditors' rights in seller-financed
transactions.
  3. The Advisory Committee found that
obtaining  "financing [particularly] has
remained  the greatest obstacle" to
minorities' entrance and establishment
in the telecommunications industry. In
this regard, the Advisory Committee
observed:
many minority broadcasters do not know
how to obtain financing and financial
institutions have misconceptions about
potential minority broadcasters. * * * [Also]
the  small or minority entrepreneur * *  * does
not  have access to fixed rate long-term funds.
As a result, that entrepreneur is subject to the
vicissitudes of short-term rates.'
  ' Notice of Proposed Rule Making in Gen. Docket
82-797,48 FR 5976 (February 9,1983).
  'The Advisory Committee was comprised of
leaden in both the private and public sectors of the
financial and telecommunications communities.
  ' Strategies for Advancing Minority Ownership
Opportunities in Telecommunications: The Final
Report of the Advisory Committee on Alternative
Financing for Minority Opportunities in
Telecommunications to the Federal
Communications Commission (May 1982) (hereafter
 "Deport").
  ' Commission Policy Regarding the Advancement
of Minority Ownership in Broadcasting, 48 FR 5943
(February 9,1983) (hereafter "Policy Statement

  'Report at 25-28.
The Advisory Committee recommended
that seller-financing, already prevalent
in broadcast-sale transactions, be
further encouraged "particularly since it
is obviously one of the ways that
minorities can obtain broadcasting
properties."'Specifically, the Advisory
Committee proposed the Commission
expand the  options accorded seller-
creditors to include the right to retain a
reversionary interest in the license of
the station being sold.
  4. The Commission's current Rule,
found at 47 CFR 73.1150, prohibits
agreements, express or implied, which
permit a broadcast licensee to: (1)
Retain an interest in the license; (2)
claim a right to future assignment of the
license; or (3) reserve a privilege to use
the broadcast facilities, upon the sale or
transfer of its interest in a station. In
addition, as we observed in the Notice,
the Communications Act of .1934, as
amended, and longstanding Commission
precedent, as affirmed by the United
States Supreme Court, appear to support
this prohibition.7 However, the Notice
also stated that:
we believe it appropriate to inquire as to
whether certain limitations could be
removed, consistent with the provisions of
the Communications Act, so as to further
encourage the use of this financing tool,
particularly where the transaction would
enhance minority ownership of the mass
media communications.
The Notice solicited comments from the
public on this proposal, specifically
inviting interested parties to address the
following:
the type of security interest that may be
retained by a seller-creditor whether that
interest can or should include a reversionary
interest in the license itself and the legal
process, if any, that should be required before
the creditor could exercise its reversionary
interest
Comments
  5. Parties  supporting the expansion of
seller-creditors' rights argued that the
proposed rule was necessary to
stimulate minority acquisition of
broadcast properties.'These
commenters asserted that because the
physical assets of a station rarely
represent more than a small portion of
the purchase price, reliance on a
security interest in only those physical
assets forces a seller-creditor to place
his own capital at significantly greater
risk. To minimize the risk associated
  •/Vo//ceat 5976.
  'For a detailed discussion, see Notice at 5977.
  •Comment* supporting the proposed rule were
 submitted by: Bone and Woods. Columbia
 Broadcasting Systems, Inc., and National Radio
 Broadcasters Association.

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