VOLUME #4 (BD-25 - BD-32)
DRAFT BACKGROUND DOCUMENTS
RESOURCE CONSERVATION AND RECOVERY ACT
SUBTITLE C - HAZARDOUS WASTE MANAGEMENT
SECTION 3004 - STANDARDS APPLICABLE TO OWNERS AND
~~~OPERATORS OF HAZARDOUS WASTE TREATMENT,
STORAGE, AND DISPOSAL FACILITIES
BD-25 - SECTION 250.45-1 STANDARDS FOR HAZARDOUS WASTE
INCINERATION
BD-26 - SECTION 250.45-2 STANDARDS FOR LANDFILLS
BD-27 - SECTION 250.45-3 STANDARDS FOR SURFACE
IMPOUNDMENTS
BD-28 - SECTION 250.45-4 STANDARDS FOR BASINS
BD-29 - SECTION 250.45-5 STANDARDS FOR LANDFORMS
BD_30 - SECTION 250.45-6 CHEMICAL, PHYSICAL, AND
BIOLOGICAL TREATMENT FACILITIES
BD-31 - SECTION 250.46 STANDARDS FOR SPECIAL WASTES
a) Cement Kiln Dust Wastes
b) Utility Waste
c) Phosphate Rock Mining,
Beneficiation, and Processing
Waste
d) Uranium Mining Waste
e) Other mining Waste
f) Gas and Oil Drilling Muds and
Oil Production Brines
BD_32 - REGULATORY ANALYSIS
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B D-25
Resource Conservation and Recovery Act
Subtitle C-Hazardous Waste Management
Section 3004 - Standards Applicable
to Owners and Operators of Hazardous Waste
Treatment, Storage, and Disposal Facilities
DRAFT
BACKGROUND DOCUMENT
Section 250.45-1 Standards for Hazardous Waste Incineration
U.S. Environmental Protection Agency
Office of Solid Waste
December 15, 1978
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This document provides background information and support
for regulations which are designed to protect the air, surface
water, and groundwater from potentially harmful discharges
and emissions from hazardous waste treatment, storage, and
disposal facilities pursuant to Section 3004 of the Resource
Conservation and Recovery Act of 1976. It is being made
available as a draft for comment. As new information is
obtained, changes may be made in the regulations, as well
as in the background material.
This document was first drafted many months ago and
has been revised to reflect information received and Agency
decisions made since then. EPA made changes in the proposed
Section 3004 regulations shortly before their publication
in the Federal Regis tea?-.- We have -^tried to ensure -that all
of those decisions are reflected in this document. If
there are any inconsistencies between the proposal (the
preamble and the regulation) and this background document,
however, the proposal is controlling.
Comments in writing may be made to:
Timothy Fields, Jr.
U.S. Environmental Protection Agency
Office of Solid Waste
Hazardous Waste Management Division (WH-565)
401 MStreet, S.W.
Washington, D.C. 20460
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Regulations to Control
Incineration
1.0 Introduction
1.1 Authority
1.2 Definitions
2.0 Rationale for Regulatory Action
2.1 Actual Damage
2.2 Potential Damage
2.3 Sources of Public Health and
Environmental Hazards
2.4 EPA Testing of Commercial Incineration
3.0 Identification of Regulatory Framework
3.1 Types of Standards
3.2 The Clean Air Act and Amendments
3. 3 Air Contaminant Concentration Limits
to Protect Workers
3.4 Standards to Protect Workers, Nonworkers,
and the Environment
3.5 Existing Federal, State or Local
Regulations
4.0 Identification and Analysis of Regulatory
Options
5.0 Identification and Rationale for Proposed
Regulation
5.1 Proposed Regulations for Incineration
5.2 Rationale for Proposed Incineration
Regulations
6.0 Appendix - Damage Incidents
3.
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1.0 Introduction
1.1 Authority
The Congress of the United States via Section 3004
of Subtitle C of the Resource Conservation and Recovery
Act (RCRA) of 1976 (PL 94-580) mandates that the Admini-
strator of the U.S. Environmental Protection Agency
promulgate regulations establishing performance standards
applicable to owners and operators of hazardous waste
treatment, storage, and disposal facilities as may be
necessary to protect human health and the environment.
These standards are to include, but need not be limited
to, requirements respecting: (1) operating methods,
techniques, and practices; (2) location, design, and
construction; and (3) contingency plans for effective
action to minimize unanticipated damage that might occur
at these facilities.
All provisions of this Act (including Section 3004)
must be integrated with the Clean Air Act (42 U.S.C. 1857
and -.;- following) , the Federal Water Pollution Control Act
(33 U.S.C. 1151 and following), the Federal Insecticide,
Fungicide, and Rodenticide Act (7 U.S.C. 135 and follow-
ing), the Safe Drinking Water Act (42 U.S.C. 300f and
following), the Marine Protection Research, and Sanctu-
aries Act (33 U.S.C. 1401 and following) and such other
Acts of Congress as grant authority to the EPA Administra-
tor. A stated purpose of the above requirement was to
avoid duplication to the maximum extent possible. Such
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integration, however, is to be effected only in a manner
consistent with the goals and policies expressed in RCRA
and the above-listed acts.
1.2 Definitions
The following definitions should aid the reader in
understanding the area of concern covered by this document
and the regulations for which this document is intended
as background information.
1. "Disposal of Solid or Hazardous V7aste" (as
defined in the RCRA), means the discharge,
deposit, injection, dumping, spilling, leaking,
or placing of any solid waste or hazardous waste
into or on any land or water so that such solid
waste or hazardous waste or any constituent
thereof may enter the environment or be emitted
into the air or discharged into any waters,
including groundwaters.
2. "Disposal Facility" means any facility which
disposes of hazardous waste.
3. "Facility" means any land and appurtenances
thereto used for the treatment, storage, and/or
disposal of hazardous waste.
4. "Fugituve Emissions" means air contaminant emissions
other than those from stacks, ducts, or vents
or from non-point emission sources.
5. "Hazardous Waste" means hazardous waste as defined
in the RCRA and in Subpart A.
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6. "Incinerator" means an engineered device using
controlled flame combustion to thermally degrade
hazardous waste. Examples of devices used for
incineration include rotary kilns, fluidized beds,
liquid injection incinerators, pathological
incinerators, cement kilns, and utility boilers.
7. "Incompatible Waste" means a waste unsuitable for
commingling with another waste or material, because
the commingling might result in:
(1) generation of extreme heat or pressure,
(2) fire,
(3) explosion or violent reaction,
(4) formation of substances which are shock-
sens itive._friction.^sensitive, or. otherwise
have the potential of reacting violently,
(5) formation of toxic (as defined in Subpart A)
dusts, mists, fumes, gases, or other chemicals,
and
(6) volatilization of ignitable or toxic chemicals
due to heat generation, in such a manner that
the likelihood of contamination of groundwater,
or escape of the substances into the environment,
is increased, or
(7) any other reactions which might result in
not meeting the air human health and environ-
mental standard.
8. "Monitoring" means all procedures used to
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systematically inspect and collect data on
operational parameters of the facility, or on the
quality of the air, groundwater, or surface water.
ur
9. "Open Basning" means the combustion of any material
without the following characteristics:
(1) Control of combustion air to maintain adequate
temperature for efficient combustion,
(2) Containment of the combustion-reaction in
an enclosed device to provide sufficient
residence time and mixing for complete
combustion, and
(3) Emission of the gaseous combustion products
through a stack duct or vent adequate for
both visual monitoring .and.point, source
sampling.
10. "Owner/Operator" means the person who owns the
land on which a facility is located and the person
who is responsible for the overall operation of
the facility.
11. "Point Source" means any discernible, confined,
and discrete conveyance, including, but not
limited to, the following:
(1) For point sources of water effluent, any
pipe, ditch, channel, tunnel, conduit, well,
discrete fissure, container, rolling stock,
concentrated feeding operation, or vessel or
other floating craft from which pollutants
are or may be discharged; and
7.
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(2) For point sources of air contaminant emissions,
any stack, duct, or vent from which pollutants
are or may be discharged.
12. "Retention Time" means the time hazardous waste
are subjected to the combustion zone temperature.
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2.0 Rationale for Regulatory Action
The authority for regulatory action comes from section
3004 of RCRA. This section requires the Administrator to
promulgate regulations establishing such performance standards
applicable to owners and operators of facilities for the
treatment, storage and disposal of hazardous wastes as may
be necessary to protect human health and the environment.
The direction to address the air environment is specified
in the RCRA definition of disposal. Disposal is defined as
any act which allows hazardous wastes to enter the environment
or be "emitted into the air." Since Section 3004 of RCRA
requires the Administrator to establish performance standards
necessary to protect human health and the environment, that
are applicable to facilities that by the definition of
hazardous waste can emit constituents of the waste into the
air, standards for hazardous waste incinerators must be
promulgated to ensure that air pollutants do not adversely
affect human health and the environment.
2.1 Actual Damage
TRW Inc., under contract to EPA to evaluate emission
control criteria for air emission standards under 3004 of
RCRA, summarized information compiled by the Office of Solid
Waste staff on specific incidents for which damage to human
health and the environment took place at hazardous waste
treatment, storage and disposal facilities.
These hazardous waste disposal damage reports are
included as appendix A. A summary is provided in Table I.
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Table I
SUMMARY OF DAMAGE INCIDENTS
Incident
Nb.a
Manageraent
Method
Waste
Pollution
2
3
4
5
6
7
8
9
10
llb
12C
13d
14e
Incineration
Landfill
Evaporation Ponds
Landfill
Holding Basin
Evaporation Pond
Landfill
TsmAf i 1 1
Landfill
Landfill
Landfill
Landfill
Sand Pit
Solvent Recovery
Residue
Mg chips and Misc.
^identified Indust.
(Compaction)
Misc. Industrial
Industrial and Minicipal
Alkyl Lead
Mixed Allylic flraine
Pesticide (uncovered)
Asbestos
Asbestos
HCB
Agricultural Chem.
Unidentified Indust.
Misc. Industrial
Eb, Zn containing
gases
Explosion. & Fire
Explosion ft Fire
Noxious Fumes
Fire
ALkyl Lead Fumes
Fumes (amines,
chlorides, hydro-
carbons)
BBC Fumes
Wind blown asbestos
Wind blown asbestos
HCB
H2S frcBft reaction
Explosion & Fire
Noxious fumes, fires
a See Appendix for corresponding Incident Report.
b EPA/530/SW-151.3, pp. 6-9 (June 1976)
c EPA/530/SW-151.3, pp. 10-12 (June 1976)
d EPA/530/SW-151, pp. 6-8 (June 1975)
e EPV530/SW-151.2, pp. 9-U (Decenfcer 1975}
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2.2 Potential Damage; Identification of Sources of
Hazards to Human Health and the Environment.
As can be readily seen from the summary of damage
incidents, damage to the environment and to human health
can o€cur from several methods of disposal. The damage
incidents demonstrate in most cases negligence on the part
of owners and operators of facilities that treat and store
hazardous wastes using one or more of the methods. For
example, sludges from oil and solvent recovery operations
could contain a large amount of heavy metals including lead,
zinc, and cadmium. Uncontrolled incineration of these
sludges will result in significant air emissions of hazardous
waste constituents.
Properly run "physical" disposal methods (e.g., incineration,
pyrolysis) impose restrictions on the kinds and quantities
of hazardous materials present by virtue of design limitations
(e.g., attainable incineration temperatures, throughput
ur
requirements for efficient baring, pollution control
technology, waste volatility or reactivity). Failure to
respect those limitations increases the probability of adverse
environmental and health impact.
Whether or not physical limitations inherent to proper
use of incineration are sufficient to protect human health or
the environment is an important question to be answered by
the regulatory agency charged with the mandate to do so.
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2.4EPA Testing of Commercial Incineration
EPA completed a program in 1976 which had as one of it*s
objectives, development of background data for standards
for incineration of hazardous wastes. A series of test
burns was conducted in pilot and full-scale units to
Demonstrate the state-of-the-art capability of incineration.
These tests showed that existing incinerator facilities
are capable of destructing a wide variety of organic
hazardous wastes to 99.99 percent or better. This
efficiency is attained by control of the major and minor
performance variable using standard incineration equipment.
Table 2 presents operating conditions used which attained
destruction efficiencies of 99.99 percent or better for
various typical hazardous wastes in differ en t-types of
facilities. While only contact time and temperature are
defined, it should be noted that efficient combustion will
only occur when attention to other major and minor performance
features are also considered. Major performance features
include turbulence of fuel and air in the combustion zone,
oxygen supply, and conversion of waste material to fine
particle form. Minor performance affecting the attainment
of adequate temperature, time, turbulence, or particle
size include: use of auxiliary fuel, quenching control,
bypass control, back-mixing control, turn-down effects,
lining heat retention, burner on-time and shut-off efficiency,
use of pretreatment and use of additives.
The EPA tests provide the hard operating data that
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99.97
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Sources: Facility Reports numbers one through six. Destroying Chemical
Wastes in Commercial-Scale Incinerators, EPA contract
68-01-2966, (1976-1977).
Burning Waste Chlorinated Hydrocarbons in a cement kiln.
Report EPS 4-WP-77-2 Fisheries and Environment Canda, (1977).
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demonstrates the state-of-the-art of incinerator technology.
Regulations based on the excellent results of this test
program seem reasonable and prudent.
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3.0 Identification of Regulatory Framework
3,1 Performance Standards
The following discussion outlines the development
of performance standards to protect human health and
5
the environment from damage by facilities that
incinerate hazardous wastes.
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3.1.1 Performance Standards
In the Report to Congress, Disposal of Hazardous
Waste 1974, the types of hazardous wastes standards
that might be used in regulations were described.
Because this report to the Congress provided background
for the passage,, of the Resource Conservation and
Recovery Act of 1976, part of this discussion is
reproduced below:
"Because of the nature of the discharges
associated with improperly managed hazardous
waste, two types of standards are likely to be
necessary in order to satisfactorily regulate
hazardous waste treatment and disposal: (1)
the "performance" standard would set restric-
tions of quantity and quality of waste
discharged from the treatment process and on
the performance of the disposal site (e.g.,
the amount and quality of leachate allowed);
(2) the "process" standard would specify
treatment procedures or process conditions to
be followed (e.g., incineration of certain
wastes) and minimum disposal site design and
operating conditions (e.g., hydraulic connec-
tions are not allowed)."
3.1.2 Best Available Technology
Performance standards normally do not specify
design, construction and operating requirements.
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However, process standards may prescribe specific requirements
as to what must be done with the waste in what kinds of
facilities. The Congress mandated in Section 3004 that
performance standards would include requirements respecting:
11 (3) treatment, storage or disposal of
all such waste received by the facility pursuant
to such operating methods, techniques and
practices as may be satisfactory to the
Administrator;
"(4) the location, design, and construc-
tion of such hazardous waste treatment, disposal
or storage facilities."
Thus, performance standards which include process
specifications to meet these requirements have been developed.
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3.1.3 Summary
The requirement tfc promulgate performance
standards that include design, construction, and
operating methods, techniques and practices at
facilities that incinerate hazarsous wastes as
necessary to protect human health and the
environment requires two distinct and separate
tasks:
Identify standards and guidelines limiting
pollutants from the facility which have
health or environmentally based criteria,
apply a safety factor to protect human
health and the environment, and require
that the facilities not exceed these levels
beyond their property lines.
Describe the design, construction, and
operating methods, techniques and practices
that represent good practicable technology
for the incineration of hazardous waste,
and prescribe their use.
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3.2 The Clean Air, Provisions Respecting Hazardous Waste
The following discussion reviews provisions of
the Clean Air Act, as amended, (CAA), and its relationship
to the regulation of hazardous waste incinerators. The
applicable sections related to the Air Quality Criteria
and Control Techniques (Section 108), National Primary
and Secondary Ambient Air Quality Standards (NAAQS)
(Section 110), Standards of Performance for New Stationary
Sources (NSPS) (Section 111), and National Emission
Standards for Hazardous Air Pollutants (NESHAPS) (Section 112).
3.2.1 Air Quality Criteria and Control Techniques.
Section 108 of the CAA mandates the Administrator to:
"publish... a list which includes each air pollutant
"(A) which in his -judgment -has-air-adverse
effect on public health and welfare;
"(B) the presence of which in the ambient
air results from numerous or diverse mobile or
stationary sources; and
"(C) for which air quality criteria had
not been issued before the date of enactment of
the Clean Air Amendments of 1970, but for which
he plans to issue air quality criteria under
this section."
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3.2.2. National Ambient Air Quality Standards
CAA Section 109 mandates the Administrator to:
"publish proposed regulations prescribing a
national primary ambient air quality standard and
a national primary secondary ambient air quality
standard for each air pollutant for which air
quality criteria have been issued prior to such
date of enactment; and
" by regulation promulgate such proposed
national primary and secondary ambient air quality
standards with such modifications as he deems
appropriate."
"(2) With respect to any air pollutant for
which air quality criteria are issued after the
date of enactment of the Clean Air Act, the
Administrator shall publish, proposed national
primary and secondary ambient air quality standards
for any such pollutant."
" (b) (1) National primary ambient air quality
standards, prescribed under subsection (a) shall
be ambient air quality standards the attainment
and maintenance of which in the judgement of the
Administrator, based on such criteria and allowing
an adequate margin of safety, are requisite to
protect the public health. Such primary standards
may be revised in the same manner as promulgated."
Standards have been promulgated for particulate,
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sulfur dioxide, carbon monoxide, photochemical oxidants,
hydrocarbons, nitrogen dioxide and more recently for lead.
Owners and operators of facilities which incinerate
hazardous wastes must, comply with these standards if they
emit any of the pollutants for which there is a National
Primary or Secondary Standard. An "ambient air quality
standard," however, requires translation to an "emission"
standard for purposes of enforcement since by definition
the sources of any one pollutant for which there is an
ambient standard are "numerous and diverse" (not Section
108 (a) (1) (8) above). No one source therefore, is held
"responsible" for meeting an NAAQS, (without an emission
standard) although emissions from such a source must not
by themselves^ exceed the~-NAAQS. -Emission standards.- are
established under Federal law either by the states under
the authority of Section 110 of the C&& and/or established
by EPA under the authority of Section 111 of the CAA.
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3.2.3 Section 110 - State Implementation Plans
The translation of National Ambient Air Quality
Standards (NAAQS) into emission standards that will
ensure ambient air concentrations of the "criteria"
pollutant takes place in part through Section 110.
Here Congress mandated the States to adopt and submit
plans which provide for the implementation, maintenance,
and enforcement of the NAAQS. Thus, emission limitations
which apply under the CAA Sections 109 and 110 to
facilities which hazardous wastes would be found within the
respective state implementation plans (published in 40 CFR
Part 52t Approval and Promulgation of Implementation Plans),
Incineration emission standards, where they exist, are
most often regulated Jay JAe-.JStafces.~tQ., sont rol- suspended
particulate concentrations, (by weight), or to control
visible emissions (by opacity).
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3.2.4 The New Source Performance Standards
promulgated under CAA Section 111 are primarily erranision
standards for sources of any of the pollutants for which
there is a National Primary of Secondary Ambient Air
Quality Standard. For municipal incinerators, a limit
of .08 grains of particulate per dry standard cubic foot
was established while sewage sludge incinerators particulate
emissions were limited to 1.30 pounds of particulate per
ton of dry sludge input. Neither of these standards
applies to hazardous waste incinerators unless municipal
solid waste or sewage sludge is burned.
Under Section 111(d), emission standards may be
established for existing sources and new sources as well as
for those- poll-utants other-than thtase-for-which-'therg is
a National Primary or Secondary Ambient Air Quality
Standard or which have been listed as "hazardous pollutants"
under CAA Section 112. The authority under Section 111 (d)
is rarely used. Regulated "designated" pollutants, as
they are called under Section lll(d), and their sources
include fluorides from phosphate and aluminum plants, sulfuric
acid mist from acid plants, and total reduced sulfur
compounds from paper mills.
Performance standards promulgated under Section 111
are based upon the best practicable technology approach,
and are defined under Section 111(d) as:
"...a standard for emissions of air pollutants
uf
Which reflects the degree of emission limitations
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achievable through the application of the best
system of emission reduction which (taking into
account the cost of achieving such reduction),
the Administrator determines has been adequately
demonstrated."
3.2.5 Section 112, National Emission Standards for
Hazardous Air Pollutants mandates the Administrator to
list hazardous air pollutants and establish emission
standards which "...provides an ample margin of safety
to protect the public health from such hazardous air
pollutants."
Unlike the "best practicable technology" method
mandated under- Section JJLl--£or_JI-New—Source -Performance,
Standards" this Section of the CAA provides no mechanism
for prescribing the best system of emission reduction.
A maximum allowable concentration provides an ample margin
of safety to protect the public health which therefore
requires a threshold first be determined for the lowest
concentration for which an adverse effect to the public
health might occur in addition to incorporate an "adequate
margin of safety."
Alternatively, for substances for which a low threshold
cannot be determined, values must be assigned as a maximum
allowable concentration which incorporate an adequate margin
of safety. Assigned values to the low threshold for
adverse effects of such pollutants are not determined.
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An adequate "margin of safety" is also required in
developing the source emission standards, since one
numerical value and conversion factor must be used to
translate the ground level concentration exposure limit,
"ambient air goal", to an emission standard while taking
into account the conditions that could reasonably take
place to allow high concentrations at human breathing level.
Although the assumptions made in determining this
"diffus'ion factor" are quite general, the meteorological
assumptions that were used for beryllium and mercury
typl ify conditions of atmospheric stagnation and poor
dispersion of the hazardous pollutants emitted. This
"National Atmospheric Dispersion Model" used a gaussian
plume equation similiar to that described by Turner
in his workbook of Atmospheric Dispersion Estimates
(1970).
Five air pollutants have been "listed" as Hazardous
Air Pollutants:abestos, beryllium, mercury, vinyl chloride,
and more recently, benzene. For asbestos, an adequate
threshold for which an emission standard would be developed
could not be established since measurement techniques for
asbestos fibers had not been established. For beryllium
and mercury, such thresholds or ambient air objectives
were established and the '"National Atmospheric Dispersion
Model" was applied. The ambient goals were 0.01 and 1.0
30-day average concentrations respectively.
Vinyl chloride was the first (and latest) hazardous
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air pollutant for which emission standards were promulgated
under CAA Section 112. Because vinyl chloride had been
*
•hown to be carcinogenii, the EPA judged that a threshold
for no adverse effects to human health could not be
established. However, a judgement was made that a "zero
emissions" limit was unduly restrictive and impossible
to meet without shutting down a major segment of our
economy. The issue was resolved by using the "best
practicable technology."
Though the use of "best practicable technology"
was not expressly required by the CAA, a value was
nonetheless set for human exposure. This technologically
fixed amount of emissions may or may not allow the
"theoretical t-hroahnld," *-*v»t mayJhaxe. Jaeen_set^__howe\zer.. _ .
imprecisely, to be exceeded. This exposure level and the
definitive threshold that was indirectly set is the
emissions that will result from best practicable technology,
however good the controls. Data are not available for
comparision of this theoretical threshold and a definitive
threshold that might have been set based upon the "health"
data that was available. Additionally, emissions are,
in theory, allowed to be discharged with no limits wherever
the best technological control methods were not applied
(hence prescribed).
The best practicable technology based standard
effectively replaced the dose-effect or health-based
standard for Section 112. Best technology may be described
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as one of several options listed below:
1. Technically feasible, regardless of costs;
2. Technically feasible, at a cost that does
not shut down the industry;
3. Technically feasible at a reasonable cost
(new source performance standards).
Concept 1 is always the most stringent (where it
is applied). Concept 3 is the least stringent. EPA
(OAQPS) applied Concept 2 to vinyl chloride under the
authority of Section 112. 3*4iy constructed the regulation
by finding the best technology for individual emission
points at a variety of plants and used judgement to extend
those controls where it was determined more control was
feasible, and developed_a regulation.-that, applied -the.- collective
technology to all plants.
Although the Clean Air Act Amendments of 1977 provides
a mechanism for a shift from "ambient concentration-
based standards" to "best technology" a judgement that
a threshold or limit cannot be determined is not one of
those mechanisms. This section of the CAA of 1977 is
shown below:
"(e) (1) For purposes of this section, if in the
judgement of the Administrator, it is not feasible
to prescribe or enforce an emission standard for
control of a hazardous air pollutant or pollutants,
he may instead promulgate a design, equipment, work
practice, or practical standard or combination thereof,
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which in his judgement is adequate to protect the public
health from such pollutant or pollutants with an
adequate margin of safety. In the event the Administrator
promulgates a design or equipment standard under this
subsection, he shall include as part of such standard
such requirements as will assure the proper operation
and maintenance of any such element of design or
equipment.
" (2) For this purpose of this subsection, the
phrase "not feasible to prescribe or enforce an emission
standard" means any situation in which the Administrator
determines that (A) a hazardous pollutant or pollutants
cannot be emitted through a conveyance designed and constructed
to emit or ^capture ^stich^oilrtttanter^^-fekafecany-.requirement
for, or use of, such a conveyance would be inconsistent
with any Federal, State, or local law, or (B) the application
of measurement methodology to a particular class of sources
is not practicable due- to technological or economic limitation
"(3) If after notice and opportunity for public
hearing, any person establishes to the satisfaction of the
Administrator that an alternative means of emission
limitation will achieve a reduction im emissions of any
air pollutant at least equivalent to the reduction in emissions
of such air pollutant achieved under the requirements of
paragraph (1), the Administrator shall permit the use of
such alternative by the source of purposes of compliance
with this section with respect to such pollutant.
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"(4) Any safeguard promulgated under paragraph
(1) shall be promulgated in terms of an emission standard
whenever it becomes feasible to promulgate and enforce
such standard in such terms."
Additionally, the Clean Air Act of 1977 requires
that EPA determine if cadmium, arsenic, polycylic organic
matter (POM) and certain radioactive pollutants should
be added to the "list" published under Section 108 (a) (1)
or 112 (b) (a).
3.2.6 In summary, National Ambient Air Quality Standards
for total suspended particulate, carbon monoxide, sulfur
dioxide, ozone, total hydrocarbons, nitrogen dioxide and
lead or pollutants have been promulgated. Mew Sources
Performance Standards for five of the above six criteria
pollutants and three "designated pollutants" are applicable to
a variety of sources including municipal and sewage sludge
incinerators (particulate emissions). National Emission
Standards for four hazardous air pollutants have been promul-
gated. Standards for benzene and arsenic are currently under
development. Cadmium, arsenic, POM, and certain radioactive
pollutants also must be evaluated for inclusion as a result
of the Clean Air Act Amendments of 1977.
3.3 Air Contaminant Concentration Limits to Protect Workers
The American Conference of Governmental Industrial
Hygienists (ACGIH) was organized in 1938 to provide a medium
for the promotion of standards and techniques in industrial
health. The OSPHS Bureau of State Services was established
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in 1944 and contained the industrial hygiene program,
which included until 1955, the federal air pollution program.
The ACGIH publishes and updates yearly a list of chemicals
with specific concentrations, called "Threshold Limit Values"
(TLV). The lists are published as guides in the control
of health hazards and were not intended to be legal requirement!
The Occupational Safety and Health Administration (OSHA)
adopted the TLVS (1968) as legal requirements in 1972.
Worker standards and guidelines (TLVS) represent
conditions under which it is believed that nearly all
workers may be repeatedly exposed, day after day, withour
adverse effect. The TLVS are the weighted average
concentrations for a normal workday.
Although the standards apply to human health, they can
not be considered adequately protective of the population
at large. The health status of workers is more healthy
than the general population which contains more susceptible
subpopulations including the elderly, young children and
the infirm. Additionally the public may be exposed to
hazardous air pollutants continuously rather than on an
eight hour basis. The ACGIH in their annual publication
listing of the TLVS preface those values by warning,
"These limits are intended for use in the practice
of industrial hygiene and should be interpreted
and applied only by a person trained in this
discipline. They are not intended for use or for
modification for use: (1) as a relative index of
hazard or toxicity; (2) in the evaluation for
control of community air pollution nuissances;
(3) potential of continuous uninterpreted exposures..»
-------
Data demonstrating that 90-day continuous exposures of
TLV concentrations can result in effects ranging from mild
toxicity to 100% mortality became available during tests to
insure safe atmospheres for space-craft occupants (Back and
Thomas, 1970; House, 1964; Sandage, 1961 a and b) .
Despite known pitfalls, and expressed ACGIH warnings,
the TLVS have been "interpreted" by many persons who are
not industrial hygienists. Additionally, the TLVS have been
compared with one another to determine toxicity. The TLVS
have been used as legal limits rather than guidelines (OSEA)
and used as a benchmark for comparison in determining maximum
allowable air contaminant concentrations in the community
(Battelle, 1976 and Cl^and et al. 1977).
The modification JDf JIL5ZS_JEor_use-as jnaximunL allowable
air contaminant concentrations in the community is covered
in the next section.
3.4 Air Contaminant Concentration Limits to Protect Workers
Non-Workers, and the Environment.
It should appear from the above discussion in 3.3 that
protection of human health and the environment on a continuous
basis from air contaminants on the ACGIH TLV list would
require an additional measure of safety or numerical division
than an adoption of the TLV concentration limits alone. At
issue, ho'v;ever, is whether a singular factor applied to all
of the OSHA or ACGIH TLV's can or should "guarantee"
freedom from harm at an exposure equivalent to the limit
-------
that is set. On the one hand, no limits, per se, could be
interpreted by some as allowing unlimited emissions. In
counter argument, limits are also "safe exposure levels"
Cf.
since, in effect, an exposure to corientrations of contami-
nants less than a "limit" is allowed. It is important to
recognize however that owners and operators of facilities
that emit hazardous air pollutants may be liable for damages
to health and environment, if it can be proven in a court of
law to a reasonable person, a judge, that air contaminants
caused the harm (regardless of whether the level was above or
below a given limit).
The use of the ACGIH TLV's times a safety factor for
the protection of more than the working force for more than
a working c^y y^s j.ngfrlinjtre<3 by.t*h^ flrneyiioan S^citrfcy for
Beating, Refrigerating and Air Conditioning Engineers (ASERAE)
Standard 62-73 "Natural and Mechanical Ventilation." ASHRAE
Standards for Natural and Mechanical Ventilation were developed
in accordance with American National Standards Institute
(ANSI) approved procedures. ASERAE in an active accredited
ANSI standard writing organization (ASHRAE, 1973}.
The purpose and scope of ASHRAE Standard 62-73 is to
define "ventilating requirements for spaces intended for
human occupancy and specify minimum and recommended ventila-
tion air quantitites for the preservation of the occupant's
health, safety, and well being." In Section 3.3 (of ASHRAE
62-73), the Standard states that:
-------
"air shall be considered unacceptable for
ventilation use in accordance with this standard
if it contains any contaminant in a concen-
tration greater than one-tenth the Threshold
Limit Value (TLV) currently accepted by the
American Conference of Governmental Industrial
Hygienists."
One-tenth is, of course, convenient since it allows
a simple manipulation of the decimal point of the TLV. The
greater lack of precision (in terms of the number of signifi-
cant figures) relates to the general inability to quantify
in exact terms factors such as protection of susceptible
individuals. Adding or multiplying such factors is also not
precise-since- their sensitivities.-and-relative- -degrees ~of
importance differ.
Examples of such safety factors and their use is shown
in Table 3
-------
Table 2 - Factors to adjust Workplace Limits to Community
Wide Limits
Factor
Basis
Use
Comments
1/3
5/21
1/4
1/10
1/30
8 hrs for workers
24 hrs a day
40 hrs for workers
168 hrs per week
community
40/168 as above
rounded to even
fraction
One order magni-
tude from workers
to public health
standard
1/3 x 1/10 (?)
not used by one exact
itself; used number (3)
in factor among many
1/300 in exact factors,
not used alone (as above)
used in factor
1/420
interim guide- (as above)
line by Navy
ASHRAE;
New York
State
guideline
Colorado
Dept. of
Health Maximum
Allowable
Concentration
This factor
and those
preceeding
assumes OSHA
standards
adequate to
protect
workers.
(as above)
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Table 3. - Factors to adjust Workplace Limits to Community
Wide Limits (cont.)
Factor
Basis
Use
Comments
1/100
1/300
1/420
10 for each
8/24jHABER'S
LAW
8/24 x 1/100
40/168 x 1/100
TRW recommended
action to HWMD
(1973) (provi-
sional limits)
Monsanto Research
Corp. for EPA
Battelle
Columbus Lab.
(1976) for EPA;
Research
Triangle Inst.
(1977) for EPA
See comments
above for. * f
5/21 x 1/100
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There is little disagreement among toxicologists and industrial hygienists
that an application of a singular safety factor or time weighted adjustment
factor to convert occupational standards to community wide standards
is most often inappropriate. All might agree that the data that support
TLV's should be reviewed by regulatory bodies on a pollutant by
pollutant basis including data of more recent vintage that may be
compiled from those investigations that have taken place since the
TLV decisions were made. Of significance to this question, however,
is the amount of time, money, and data that are necessary to set a
particular health based standard, particularly, when the data consists
solely of rat or mouse acute toxicity studies. Although efforts may
be better spent focusing on the control technologies, criteria for
the amount of control to be applied are paramount.
The use of an adjusted worker standard, so long as it is on an
interim basis until a pollutant by pollutant risk assessment is made
and a concentration limit for each pollutant is developed may be permissable.
-------
&$' Existing Federal, State or Local Regulations
Most states have not established regulations dealing
specifically with incinerators combusting hazardous wastes.
Generally, state regulations specify particulate emissions
standards for incinerators which are consistent with the
federal performance standards for incinerators, or which
are to some degree more stringent than federal regulations.
Many states have also adopted some form of the federal
emissions standards for the hazardous pollutant beryllium.
However, few states have incorporated explicit regulations
which would restrict the numerous other pollutants emitted
during incineration of hazardous wastes.
Federal regulations for municipal incinerators limit
particulate.emissions-to~,Q8 grains .per dry standard-cubic
foot corrected to 12% CCL
^•municipal incinerators burning more than 50 tons/day.
Sewage sludge incinerator emissions are limited to 1.3 pounds
of particulate matter per ton of dry sludge input, and to
20 percent opacity or greater. Federal emission standards
for hazardous materials limit air emissions of beryllium
from incinerators (or other sources) to 10 grams per day.
In some instances, states have adopted more stringent versions
of these federal regulations (e.g., in Maryland particulate
emissions from municipal incinerators are limited to .03
grams/dscf.
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In the absence of conclusive regulations which address
potential emissions from incinerator burning hazardous waste, states
j
have restricted the operations of hazardous waste incinerators by th*
authority of a general protection or "nuisance" rule. The general
nuisance rule of the Wisconsin Department of Natural Resources
is a typical example:
NR 154.19 Control of Hazardous Pollutants. General limitations
Ho person shall cause, suffer, allow, or permit emissions into
the ambient air of hazardous substances in such quantity, con-
centration, or duration as to be injurious to human health*
plant or animal life unless the purpose of that emission is for
the control of plant or animal life. Hazardous substances
include but are not United to the following materials, their
mixtures, or compounds: asbestos, beryllium, cadmium, chromiua,
clorine, fluorine, lead, mercury, pesticides, or radioactive
material.'
While the rule provides no specific regulatory guidelines, the
general authority of this type of regulation has been used to impose
a' variety. 6f~e«lsgionrTeg1ytetft»s^^
states. The formality and criteria associated with the determination
of suitable restrictions varies greatly from state to state. Typically,
the permitting agency requires the applicant to demonstrate the environ-
mental acceptability of the proposed incinerator operation. This
usually involves documentation of proposed equipment design and
operating procedures, and expected emission levels of specific pollutant
Dispersion modeling is often-required to determine if ambient air
quality will be maintained to the agencies definition of acceptable
concentration limits.
While the existing restrictions on incinerator operations can
be expanded by authority of the general protection rules, this is often
unnecessary because the existing state and federal regulations for
incinerator emissions of particulate matter alone have resulted in
costly control equipment requirements which make incineration of
both municipal or hazardous waste less economical than landfill disposii
3*-
-------
Thus, in many states, there are currently no facilities
which operate a hazardous waste incinerator. It is estimated that
less than 15% of all hazardous waste is currently destructed by
incineration and that only 6% is managed by controlled incineration
which is environmentally acceptable fi.e. controlled by federal
or state incinerator regulations)."
The most explicit regulations applicable to hazardous waste
incineration have been developed in Colorado (Regulation No. 8) and
New York (Part 212). The Colorado regulations provide specific
direction for establishing emission standards for a large number of
chemical substances or physical agents on a source-specific basis. The
New York regulations also provide for source-specific determination of
an allowable emissions rate, however, the criteria for determining
this are less definitive than those of the Colorado rules.
The Colorado Emissions regulation is intended to set emission
standards such that ambient air concentrations resulting from the
emissions source will not exceed 1/30 the occupational threshold limit
value when emissions are generated continuously or for more than nine
(9) hours per day. For some specific materials, as defined by the
regulation, the ambient air objective may deviate from T/30. These
materials include: 1) compounds which are human or experimental
carcinogen-s and have no assigned TLY, 2) fluorocarbon chain (e.g.,
fluon, teflon) decomposition products, and 3) mixtures of compounds.
The regulation provides for application of best available technology
in the former two cases and specifies procedures for consideration
of mixtures of toxic compounds in the latter case.
-------
The Colorado Regulation allows greater emission levels when
the emitter source duration is short terra, or less than 9 hours per day.
Specified excursion factors are applied to the long term allowable
emission standard to define the maximum allowable short term emissions
rate (for a 9 hour period).
Figure 3-12 illustrates the variables which are considered
in establishing emission standards for a given facility emitting
hazardous pollutants in the State of Colorado. The allowable emissions
level is determined from the TLV and a nomograph, which incorporates
the air quality/emissions relationships of the Pasquill-Sifford
diffusion equation 3 plus assumed values for meteorological variables
representing the "worst case" conditions for air pollution. The
only input needed to the nomograph 1s the effective stack height of the
source, which is calculated using the Moses Kairner plume rise technique _
The parameters needed to determine effective stack height are stack
height, effluent flowrate, and effluent temperature.
JMM_ 4% <•
The^Col
No. 8 as inadequate in Its present form and is proposing amendments
concerning two major drawbacks: 1) the arbitrary ambient objective
(1/30 TLV) of the regulation, and 2) the air diffusion relationships
which are overly generous in distributing of emissions. The CotMission
is not satisfied that the 1/30 TLV ambient target is appropriate* or
whether a single factor should be applicable to pollutants of different
toxicities. The Commission is critical of the diffusion model because
it Is not sensitive to topographical effects and may not incorporate
consideration of "worst case" meteorology for a site specific case.
In one case where permit approval had been given, emission
rates meeting the required levels? resulted in ambient levels
exceeding OSKA Standards when the stack plume looped to the ground on
a hill above the facility stack. The operator was cautioned by the
Commission of the health hazard and has Installed a monitoring and
alarm system to enable mitigating action when the meteorology causes
high ambient levels of HgS. The "generosity" of the model in dictating
control requirements has also been apparent in other applications of
Regulation No. 8. The Commission is considering a regulatory amendment
-------
Effective
Stack Height |
(He)
—allowable
emission rate
Substances and Agents
Mix with Aabient Air
and Diffuse
Sti
Height h
tance oi emission point
above ground level)
•Point of Msjcison Gr'
Level Concentration
1/30 T.L.V.
level
/////////////////////////////////////////////////////////////////////,
Figure J. Site Specific Considerations Incorporated in the
Determinationsof Colorado Emissions Standards[5].
in which source-specific determination of emissions standards will be
maintained, but in which a discretionary judgement for model selection
may be permitted. Model selection would include consideration of
special meteorological and topographic factors affecting high local
ambient concentrations.
In New York, Part 212 of the State air pollution regulations
outlines criteria for assessing an environmental rating for any specific
emission source, and specifies the degree of emission control required
for permit approval based on the environmental rating and the
potential emission rate. Table 111-17 shows the environmental rating
criteria of the regulation. The criteria are judgemental, although
the Department of Environmental Conservation utilizes some internal
guidelines which are more specific to establish A, B, C, or D ratings
for hazardous substances. In general, any source emitting a carcinogen
is rated "A", and other sources emitting substances on the toxic
contaminants list of the New York Process Source Handbook
are also rated "A", with the exception of those sources whose
emissions do not reach receptor areas. Previously the Department
-------
had also used an ambient air quality criteria, assigning an "A" rating
to any source creating receptor exposures greater than 1/10 the listed
TLV of the contaminant. Judgement of the environmental rating using
the ambient air quality criteria required air diffusion modeling, a
questionable means of assessment because of prevailing topographic
effects not generally considered by standard models. The ambient
criteria still serves as an attainment goal, but is seldom used in
assessing the environmental rating of a substance. The control
technology required to attain the safe ambient air quality near any
source operation is specified by fixed criteria as shown in Table 111-18,
Sources emitting "A" rated contaminants must generally be equipped with
best available technology regardless of size.
TABLE 3. CRITERIA FOR ENVIRONMENTAL RATING OF EMISSION SOURCES,
NEW YORK AIR RESOURCES REGULATION PART 212
Crttorte
, wboi* Q* 4iicbart* at
ru» roHtttt. or wool* rono-iV? b» 0x500:0* to xo-
wtt. to Mriovs adv«no *94ea OB nca^tou or tt« .n^T.fpi..^!- tk«M cffoea
may bo of a health. —«-»~^ — .-T^.^4fl Tn^im tirtnr nrnMtrfiit uf thua.
tedatea proiioiia. «ad «daa*e aad TOBtQattea qrstaaj i«ior» tho alitaatat
of a coatairtnaat or ecctasteaats roatt*. or traold naaaaabtr •• cnoeud to
la only «og«M» esd nuatltllr kieattad oSoeta; or wfctfo th« R=|I
' af Mcreo* of tfc» cactamiaasi or oootaxciscsa In SBJ ftv«e oraa. f i
«a to r«}Biro ac ovoraU NJac^ec of tk« atatoaphorle tardoa oTbat
ftv«B
ofttat
C
x>
piuLiim, aad oxtecst aad
afti tjdbeBot and Toatttetton
othor iaetor*. it CM bo
or eoBtete»Bt» «C1 not
.
*"~""*-trtrl that dtaetux* of U
la aaanrabU or oaMrnUo oBwa
.
of UM ~-"-J-^>T
to «E «Jd«tteC or BrxUctaMo •mo^Horic terioa oi that
•—"! vtdea •Mold nuoaablr bt o^ootol to OMM
of tte
or astleipatod AKhUat air qeaBqr la «fets£(r of 100000
^TfffltJ* TOiatilSff to *fff*ft Of
T****- ^*>-—
-------
While other states have not established definitive regulations
controlling the incineration of hazardous waste, the requirements
imposed on incinerator operators through individual perorft approvals
typically reflect the approach defined by the New York regulation.
Operators are generally required to demonstrate the environmental
adequacy of the facility to dispose of toxic wastes, and this is
usually accomplished by utilization of best practical technology and
reference to previous experience defining the proper operating conditions
for optimal destruction of wastes. In many cases, the permitting
agency will require test bums prior to permitting full scale inciner-
ation. The test burn is utilized to define appropriate stipulations
for the permit approval.
TABLE y-f DEGREE OF AIR CLEANING REQUIRED VS. ENVIRONMENTAL
RATING OF "EMISSIONS^"
S2USSIOK
Lot* IX. !-» ( » I 200 t JB7 1 *.WO t I^sa I -M** I 3tjt»
Jteifeff I tfcsjs, to to Co fc> to to to I to I s*£
I u I » I » I JOB I sea I itao I /JDC t 4x»> t sfjeat \ Oecrcr
i Oft OMSJ.T3SS
, -1 .
30-Slft 1 91-34*
C 1 " TO-75* [ TW5*
1 1 !
*«*
-S5-SC*
S4-9TO
90-93*
3T-»3i
3S^3T. [ SKfOrCrsaSftr
SS-S5t3 I S5-4S7J 1 S£f* ae Greater
3«5r»* of «lr cl«*=ia5 required ahall *^ ^^ta^* Ky»v^. mnrrri,Ti.
-------
While incineration may enable nearly complete destruction of
hazardous materials, the combustion products may not be environmentally
. acceptable if emitted to the atmosphere. Therefore, certain wastes
should not be incinerated unless the combustion products are treated
with an emission control device such as a wet scrubber, electrostatic
precipitator, bag house, or catalytic or thermal afterburner. Wastes
of concern include chlorinated hydrocarbons (resulting in hydrochloric
acid ^materials containing heavy metals, and wastes with high sulfur
content. The degree of control required would be based on the expected
level of toxic emissions and the resulting impact on ambient air quality.
Because of the wide variability of wastes accepted by Incineration
facilities, the ability of the facility to manage these wastes depends on
versatile air pollution control equipment. High efficiency wet scrubbers
usually provide the versatility required, as chemical solution may be
varied suitably to treat different effluent contaminants, including toxic
loadings of incomplete combustion materials resulting from improper
or transient operating conditions.
Precautionary control equipment to prevent unacceptable
transient emission loadings may also be Included in the design of
the incineration facility. Such equipment Includes gas monitors for
continuous measurement of combustion products (e.g., CO, C02, fO , p?)
combustion temperature monitors, and automatic feed shut-down following
malfunctions or undesirable variations In operating conditions.
Whatever the regulatory approach adopted for controlling thermal
destruction of hazardous wastes, the numerous performance variables of
the system, including the type of waste itself, suggest the need for
test bums prior to full scale Incineration to 1) insure the desired
destruction 1s attainable, and 2) identify system operating parameters
corresponding to the desired destruction or emission control goals.
tHt-
-------
Section 4.0
Analysis of Regulatory Options
The following options represent strategies for standards development.
Option 7 summarizes the performance standards as presently proposed. A
summary of issues related to adoption of each of the options is discussed.
4.1.1 Option 1
Promulgate standards which require only compliance with provisions
of the Clean Air Act.
Pro; New Source Performance Standards (NSPS) are based on the best
available (practicable) control technology method while National
Emissions Standards for Hazardous Air Pollutants (NESHAPS) have been
based on ambient air goals for beryllium and mercury and best
available technology for asbestos and vinyl chloride.
Con: To set such standards, however, a pollutant must first be listed,
which sets in motion a significant EPA commitment to limiting emissions
of this singular pollutant at all significant sources. For each
singular pollutant, hazardous waste incinerators as a whole may
qualify as low emitters in terms of the amount of each pollutant
emitted. In many cases, however, the species or contaminants are
many and the total amount can be significant to nearby residents.
-------
In summary, the Clean Air Act alone does not provide a mechanism
that enables EPA to limit hazardous air emissions from facilities that
incinerate hazardous wastes as directly or efficiently as Section 3004
of the Resource Conservation and Recovery Act. Other regulations in
addition to applicable provisions of the Clean Air Act must be established
that will focus on the air emitting operations of hazardous waste
incinerators.
4.1.2 Option 2
Promulgate standards which require compliance with the following:
1. All provisions of the Clean Air Act, and,
2. On an interim basis, worker standards times a safety factor
to account for the difference between protection of workers on
an eight-hour bases and the protection of (all) human health
and the environment (e.g., worker standards times 0.1).
This option possesses similar pros and cons as the previous option
since it also requires compliance with the Clean Air Act with the addition
of the adapted worker standards. However, uner this option, those air
contaminants which are of conern in the work place will also have limits
in the community.
Pro: The number of pollutants covered (400-600) by worker standards could
be judged necessary to protect human health and the environment since
it effectively requires that owners and operators of hazardous waste
treatment, storage and disposal facilities know to what extent possible
concentrations of hazardous air emissions are emitted and may be found
at the property line of the facility.
-------
Con: This option may not be considered protective since thousands of
pollutants potentially may be emitted. Attempting to prescribe
limits for every potential pollutant would be a costly and time
consuming effort. Also this option lacks design, construction,
and operating standards mandated in RCRA. Without such standards,
owners and operators of hazardous waste incineractors would not be
given the benefit of knowing how to meet these emissions standards.
The lack of precision of models to predict limits at the fence!ine
and thus the inability to specify exact emission rates from incinerators,
make this option a poor choice on which to regulate.
4.1.3 Option 3
Promulgate performance standards which require only compliance with
design, construction, and operating prescriptions which are based upon
a best technology approach.
Pro: This option would not require any compliance with ambient air standards.
Being based on the best technology approach, it would also be the
most easily enforceable and least costly to determine compliance.
Con; With no standards that are health based, this option alone could not
be considered for adoption as performance standards "necessary to
protect human health and environment." Complete data for all tech-
niques, methods and the factors that must be prescribed is not
available at this time to comprehensively cover the many sources
of waste disposal emissions.
-------
The best technology prescribed may not be adequately protective,
and conversely, "good" technology which is much less costly than
the "best" may be all that is "necessary" taking into account
factors related to risks and controls.
4.1.4 Option 4
Performance standards would include two previsions as follows:
A. Promulgate those design, construction, and operating procedures
that can be identified as best practical technology. Compliance
with these procedures allows the owners and operators of
hazardous waste facilities to be permitted.
B. Promulgate standards which require compliance with the following:
1. All provisions of the Clean Air Act as amended, and,
2. On an interim basis until standards prescribed by a
pollutant by pollutant risk assessment are promulgated
by EPA, compliance with one-tenth the TLV's published
by the ACGIH.
This option combines the requirements for protection of human
health and the environment inherent in Option 2, and the requirements for
design, construction, and operating procedures found in Option 3.
Pro: Like the law (Section 3004), there is no precedent for both the use
of emission standards/ambient air goals based upon health and the
use of good practicable technology together. The latter are based
upon- health and the use of goodipracticable technology together.
-------
The latter are based upon design, construction and operating principles
demonstrated to perform their intended function (i.e. destruction
via incineration) practically and most completely without threatening
the communities that they are located in. Monitoring is conducted
to ensure that the technology is operating as designed (e.g., CO, C02,
temperature to ensure that incinerators operate towards maximum
combustion and destruction efficiencies).
Facilities applying for permits to operate a process which is not
covered under the recommended procedures must prove or demonstrate that
human health and the environment will not be threatened. To do so a
comparison of probable emissions based on the wastes accepted will be
required to be compared, via an acceptable dilution model with the ambient
goals at the property line. Once the technology, however, is determined
to be adequate, operating, design and construction procedures may be
written as permit conditions. A more direct approach for obtaining a
permit for new technologies is to demonstrate technological equivalence
with those technologies covered under the recommended procedures. Like
OSHA, monitoring for more than 400 pollutants for which standards apply
will not be required at every facility. Enforcement activities should
focus on design, operating and construction standards compliance.
Con: k¥ acceptable dilution model requires at the very least emission
rates or concentrations for the pollutants regulated. No data is
presently available nora method presently in use to provide EPA or
owners and operators with emission values.
H-f
-------
The standards especially the ambient goals, must be carefully
reviewed, revised and promulgated as amendments to Section 3004 of RCRA
provisions or Section 112 of the CAA in order to more precisely define
what is necessary to protect human health and the environment. In this
option, emphasize must be placed on updating maximum concentration values
for those judged inadequately protective or those for which limits are
not prescribed already.
This option is a poor choice for regulating since resources must
be devtted towards fenfeline values and dispersion modeling. Such
models are not available nor are means to relate disposal emissions to
ambient.
4.1.5 Option 5
Promulgate performance standards which require compliance with design,
construction , and Qper^ling^rocedorgsy^^mbtent nt^gtndel tnes v ate
provided via Section 1008 of RCRA in order to compare the adequacy of
procedures to health-based goals.
Pro: This option reflects a strategy towards controlling air contaminant
concentration levels and the need for air quality goals. In this option,
prescribed operating and design specifications are the basis for per-
formance standards, with ambient air guidelines (promulgated under
Section 1008 of RCRA) provided to compare monitored air concentration
levels with those listed in the guidelines. Since the ambient air
guidelines would not be mandatory standards, they could be reviewed,
evaluated, and revised without amending the Section 3004 regulations.
-------
New toxicological and epidemiological information could be used
to periodically revise the guidelines for particular air contaminants.
This option avoids prescribed ambient concentration limits which
have not been evaluated by EPA for their adequacy or validity on a
pollutant-by-pollutant basis. Additionally, this option avoids the
complexity and costs associated with area source emission rate determinations,
atmospheric dispersion modeling, or establishing individual air contaminant
A
a t
background levels. This option could be adopted as a permit condition o£
the discretion of permitting officials.
Con: As guidelines, the ambient air requirements are not enforceable
unless adopted as permit conditions. As unenforceable standards,
the use of ambient guidelines may not satisfy the mandate to protect
human health and the environment by establishing performance standards.
Additionally this option* 1 ike Option? ^assumes faithHn-the"prescribed
concentration limits, the ability to determine emission rates and
to model their transport.
Also, since this option involves utilizing a section (1008) of the
Act for a purpose for which it was not intended it is a poor choice for
regulations.
4.1.6 Option 6
Promulgate performance standards which require compliance with design.
construction, and operating procedures. Provide a list of ambient air
pollutants of concern to be monitored.
-------
This option, like options 2 and 3 relies primarily on best available
technology. Unlike option 2 extensive monitoring would be required to
determine the adequacy of the technologies prescribed. Unlike option 3,
no numerical ambient air goals are included. Regulatory activities would
focus on evaluation of the ambient air data obtained, via monitoring, to
determine if the air contaminant concentrations are of concern.
Pro; Like,option 5 this option avoids a prescribed ambient air contaminant
concentration limit. Also, the complexity and costs to industry
and the government (associated with determining source emission
rates and atmospheric dispersion modeling) would be avoided.
Con: This option would require extensive and costly ambient air quality
monitoring anddata interpretation. This option does not provide a
means for interpreting the data obtained by air quality monitoring.
Al so, the 4ee4s4otrjof-vfoat acwitumrt nairtr xHSfltreiltrtttons "afe o-f concern
(or what standard of performance is necessary to protect human health
and the environment) would, as in option 5, be made outside of
Section 3004 and the public participation that accompanies the
regulatory process.
Finally, this option may not satisfy the mandate to protect human
health and the environment if more comprehensive standards based upon
health are not prescribed. This option alone is a poor choice for air
emission standards.
-------
Option 7
4.1.7 Performance standards proposed include the following provisions:
A. Compliance with applicable regulations promulgated pursuant
to Clean Air Act (Sections 110, 111, and 112).
B. For point sources (e.g., incineration); Compliance with design,
construction, and operating procedures identified as good
practicable control technology. Variances may be granted on the
basis that proposed alternative methods for specific waste
cases will result in equivalent degree of control (e.g.,
destruction) that would have been achieved by the control
technology standards.
This option comprises facets of the previous options to prescribe
operating, design, and construction standards while also providing for
variances for procedures that can be shown to be the equivalent of those
prescribed.
Pro: Several facets of the previous options and their policy implications
have been incorporated. However, this option does not include
fenceline standards comprised of the worker standards times a safety
factor. While this would limit the number of contaminants for which
ambient human health and environmental limits are prescribed, it
would also limit the formidable problems associated with the fenceline
worker adopted limits. In summary these problems included:
-------
3. a general lack of air modeling techniques for non-point
sources that are sufficiently developed to be legally
defensible.
2. A significant lack of support by the regulators and the regulatees
that the limits provide human health and environental protection
since a "limit" is also considered to be a "safe exposure".
Since OSHA regulations apply to the workplace, workers at hazardous
waste treatment, storage and disposal facilities are also protected. Thus,
air concentrations from the facilities must be less than OSHA limits. An
adoption of these regulations by EPA provides a necessary measure of
protection to human health and the environment since owners and operators
could effectively meet OSHA standards by requiring workers to wear breathing
protective devices.
OSHA air contaminatttonoaitors^i^ttl^
unless non-point sources receive a reactive waste, an ignitable waste, a
waste that is incompatable with those already disposed or is a volatile
waste. Monitoring for compliance with the OSHA limits would be required
if the owner/operator choses to dispose of any of the above listed waste
in a non-point source.
-------
5.0 Rationale for Chosen Regulations
Based on the selection of Option 7 which specifies compliance with design,
construction and operating procedures identical as practicable control
technology for incineration, the following regulations have been developed,
The basis for these design, construction and operating standards are
explained in this section.
-------
5. 1 Proposed Regulations for Incineration
250 . 45-1 Incineration
(a) An owner/operator of an incinerator shall comply with
the requirements of this Section when burning hazardous
waste.
(b) Trial Burns
(1) The owner/operator shall conduct a trial burn
for each hazardous waste which is significantly different
in physical and chemical characteristics from any
previously demonstrated under equivalent conditions.
The trial burn shall include as a minimum the following
determinations :
(i) An analysis of the hazardous waste for
concentrations .
hazardous components ;
(ii) An analysis of the ash residues and
scrubber effluent for the principal hazardous
components;
(iii) An analysis of the exhaust gas for the
concentrations of the principal hazardous
components, hydrogen, halides, CO, CO.* &%• and
total particulates;
(iv) An identification of sources of fugitive
emissions and their means of control;
(v) A measurement of combustion temperature
and computation of residence time;
(vi) A computation of combustion efficiency
and destruction efficiency;
-------
(vii) A computation of scrubber efficiency
in removing halogens;
(2) The results from each trial burn shall be submitted
to the Regional Administrator.
(c) Monitoring
The owner/operator shall monitor and, record the - following
in each trial burn and; each operational burn:
(1) Combustion temperature;
(2) Carbon monoxide and oxygen concentrations in the
exhaust gas on a continuous basis, and
(3) The rate of hazardous waste, fuel, and excess air
fed to the combustion system at regular intervals of
no longer than 15 minutes.
(d) Combustion Criteria
(1) The incinerator shall operate at greater than
1000° C combustion temperature, greater than 2 seconds
retention time, and greater than 2 percent excess oxygen.
during incineration of hazardous waste, unless the
waste is hazardous because it contains halogenated
aromatic hydrocarbons, in which case the incinerator shall
operate at greater than 1200° C combustion temperature,
greater than two seconds retention time, and greater
than 3 percent excess oxygen during incineration of the
hazardous waste.
S7
-------
(2) The incinerator shall be operated at a combustion
efficiency equal to or greater than 99.9 percent, as
defined in the following equation:
x 100
Cco
Where:
CE = combustion efficiency
Cco2 = concentration of CO2 in exhaust gas
Cc = concentration of CO in exhaust gas
Incinerators that burn waste that is hazardous only
because it is listed in Section 250. 14 (b) CD are
exempt from this requirement.
Mote to (b) (1) and (2) : Incinerators ma; operate at
other conditions of temperature, retention- H.um, and
combustion efficiency if the facility owner/operator
can demonstrate that an equivalent degree o£ combustion
will be provided under alternate combustion criteria
to the conditions prescribed above.
(3) The incinerator shall be operated vita a functio line
device to cut off automatically waste feed to the
incinerator when significant changes occur- in flame
combustion temperature, excess air, or scrubber water
pressure.
(e) Destruction and Emission Control Criteria
(1) The incinerator shall be designed, constructed, ind
operated to maintain a destruction efficiency of 99.91
percent as defined in the following equation:
-------
/Win - W<
\ win
DE =f"in - out\X 100
Where:
DB - destruction efficiency
W. » mass feed rate of principal toxic components of
waste going into the incinerator (g/min)
Woat = mass emissions rate of principal toxic components
in waste in the incinerator combustion zone (g/min).
Incinerators that burn waste that is hazardous only because
it is listed in Section 250 .14(b) (1) are exempt from this
requirement.
(2) An incinerator used to thermally degrade hazardous
waste containing more than 0.5 percent halogens shall be
equipped with emission control equipment capable of removing
99 percent of the halogens from the exhaust gases.
(3) The incinerator shall be operated in a manner that
assures that emissions of particulate matter do not exceed
270 milligrams per dry standard cubic meter (0.12 grains
per dry standard cubic foot) at zero excess air. Compliance
with this requirement may be achieved by having particulate
emissions which, when corrected to 12 percent C02 by the
formula below, are less than 180 milligrams per standard
cubic meter (0.08 grains per dry standard cubic foot).
-------
Where:
PE_ = PE X Cs
c m
C X 1.5
m
= corrected particulate emissions, mg/m3 (gr/dscf)
= measured particulate emissions, mg/m3 (gr/dscf)
Cs s* stoichiometric CO2 concentration, ppm
CQ » measured CO2 concentration, ppm
(4) The incinerator shall be designed, constructed,, and
operated so that fugitive emissions of unburned hazardous
waste and combustion products are controlled.
-------
5.2. Rationale for Proposed Incineration Regulations
Regulation
(b) Trial Burns
(1) The owner/operator shall conduct a trial burn for each hazardous
waste which is significantly different in physical and chemical
characteristics from any previously demonstrated under equivalent conditions.
The trial burn shall include as a minimum the following determinations:
(i) An analysis of the hazardous waste for
concentrations of halogens and principal
hazardous components;
(ii) An analysis of the ash residues and
scrubber effluent for the principal
hazardous components;
(iii) An analysis of the exhaust gas for the
concentrations of the principal
hazardous components, hydrogen halides,
CO, C0_, 0-, and total particulates;
(iv) An identification of sources of fugitive
emissions and their means of control;
(v) A measurement of combustion temperature
and computation of residence time;
(vi) A computation of combustion efficiency and
-------
destruction efficiency;
(vii) a computation of scrubber efficiency
in removing halogens;
(2) The results from each trial burn shall be submitted to the
Regional Administrator.
Rationale
This regulation requires test burns to be conducted to demonstrate
that the incinerator will comply with all of the regulations under
250.45-1. Measurements and analysis of the waste f*od, combustion
gases, and scrubber. effiuenfrrwiiirallow the ^teterminatron- of the
degree of destruction of the waste. Also operating conditions
^>
adequate to destroy the waste such as temperature, residence time,
air flow and other variableScan be determined and be made part of
the permit conditions.
EPA is preparing a guidance document on incineration of hazardous
wastes which will address the aspects of test burns and monitoring
methodology. Also specific guidance will be given to permitting
officials to make a determination of what is a significantly different
waste and decide if a test burn will be required.
Regulation
(c) Monitoring
The owner/operator shall monitor and record the following in each
-------
trial burn and each operational burn:
(1) Combustion temperature;
(2) Carbon monoxide and oxygen concentrations in the
exhaust gas on a continous basis, and
(3) The rate of hazardous waste, fuel, and excess air
fed to the combustion system at regular intervals
of no longer than 15 minutes.
Rationale
Monitoring for carbon dioxide and carbon monoxide allows incinerator
operators to determine the combustion efficiency the extent to which
an introduced organic waste is being oxidized) . This combustion
efficiency can be determined by the following formula:
Cc°2 x 100
The higher the amount of carbon dioxide and the less the amount of carbon
monoxide, the higher will be the combustion efficiency.
Destruction efficiency is a comparison of the amount of a waste or
chemical substance introduced to incineration compared with the amount
emitted as in the following formula:
C input - C emit ted x 100
^ input
For selected wastes this is information obtained during test bums. On
-------
a daily basis, however, it is impractical to monitor every chemical
i*«-
substance in.hazardous waste fed into the incinerator and every possible
product that may result. Monitoring carbon dioxide and carbon monoxide
and comparing the two allows an indication of destruction efficiencies
since it compares the amount an organic waste has been partially (CO)
and completely (CO-) oxidized.
Although an organic waste may be less oxidized than to carbon Mwoxide
and water (ketones, alcohols acids), the amount of carbon monoxide
will indicate that the waste requires more activation energy or oxygen
atoms to reach complete oxidation and destruction of any intermediates.
Hence, the hydrocarbon bonds need not be monitored.
Excess oxygen allows owners and operators another means for insuring
that sufficient oxygen is available for thermal oxidation.
Pursuant to the authority of Section 6 (e) (1) the Toxic Substances
Control Act (TSCA) precedent setting regulations for the disposal
of polychlorinated bipehenyls were prescribed. These requirements
included benchmarks for PCS incinerator operations. The following was
promulgated in 40 CFR 761.40 (a)(7).
"At a minimum continous monitoring and recording
of combustion products and incineration operations
shall be conducted for the following parameters
whenever the incinerator is incinerating PCBs:
(i) 02 (ii) CO; (iii) C02".
This above precedent for the monitoring of CO, C02, and 02 is also
-------
needed for incinerating hazardous wastes other than PCBs since many will
be more toxic and more difficult to incinerate.
The requirement to monitor and record the rate of hazardous waste feed,
fuel and excess air to the incinerator every 15 minutes assures that these
inportant operating variables will be controlled and a permanent record
established for enforcement.
The PCB Disposal and Marking regulation, 40 CFR 761.40 (a) (3),
promulgated under authority of section 6 (e) (1) of the Toxic
Substances Act requires:
"The rate and quantity of PCB's (liquid) which
are fed to the combustion system shall be measured
and recorded at regular intervals of no longer
than 15 minutes."
This precedent for measuring operating parameters is needed since
many hazardous wastes are more toxic and more difficult to incinerate.
Regulation
(d) Combustion Criteria
(1) The incinerator shall operate at greater than 1000° C combustion
tenperature, greater than 2 seconds retention time, and greater than
2 percent excess oxygen during incineration of hazardous waste, unless
the waste is hazardous because it contains halogenated aromatic hydrocarbons,
in which case the incinerator shall operate at greater than 1200° C
combustion temperature, greater than two seconds retention time, and
greater than 3 percent excess oxygen during incineration of the hazardous
-------
waste.
Rationale
An incinerator must be properly designed to provide adequate mixing
of the waste and combustion air to obtain complete oxidation of the
waste. Temperature, residence time and turbulance are interrelated in
the combustion process.
Incinerator operating conditions for a two second retention time
at or near 1000° with adequate excess air has proved to be sufficient
for more than 99.9 percent destruction of most organic pesticides studied.
Most test burn data collected by EPA has been on the incineration of
pesticides (MRI, 1978). EPA in 1974 defined a pesticide incinerator
in regulations for pesticide disposal as an installation capable of
controlled combustion of pesticides at a temperature of 1000°C (1832°F)
and a two second retention or dwell time in the combustion zone, or
some lower temperature and sufficient swell time to assure complete
conversion of the specific pesticide to inorganic gases and solid ash
residues.
The decomposition temperatures and products vary widely for the variety
of organic wastes amenable for destruction in hazardous waste incinerators
-------
Temperatures for "complete" combustion for those pesticides tested in
laboratory experiments by Mississippi State University and University
of Dayton Research Institute, and in pilot scale studies by the
Midwest Research Insitute are shown in table 4^ . The definition
of complete combustion varies from 99.9 to 99.99 percent, dependent
upon the sensitivity of the tests used by three groups of researchers.
Incinerators designed to destruct hazardous wastes should insure a
minimum of 1000°C and a minimum two second retention time, although
a design could be tailored for specific wastes with an adequate
margin of safety.
Halogenate aromatic hydrocarbons, as a class are the most thermally
stable organic compounds in commercial ^jse-today-, The:use of
Polychlorinated Biphenyls and polychlorinated biphenyls in high
teaperature heat resistant applications is the most common example
of this thermally stable group of organics. The PCB Disposal and
Marking regulations 40 CFR 751.40 (a) (2) (i), promulgated under the
Toxic Substance Act recognizes this:
"Maintenance of the introduced liquids for
a 2 second dwell time at 1200°C (1100°C) and
3 percent excess oxygen in the stock gas..."
Thus this regulation recognizes the need for more stringent destruction
conditions for this class of compounds.
-------
TABLE sT TEMPERATURES OF COMPLETE COMBUSTION OF PESTICIDES
DETERMINED IN LABORATORY EXPERIMENTS
Temperature of complete combustion
Pesticide
Aldrin
Recrystallized
19% granular
Atrazine
Reagent grade
Technical grade
80% wettable powder
80% wettable powder
Bromacil
Reagent grade
80% wettable powder
Captan
Technical grade
50% wettable powder
2,4-D (isooctyl ester)
Reagent grade
4 Ib/gal. formulation
DDT
Reagent grade
Reagent grade
Technical flakes
DNBP
Reagent grade
3 Ib/gal* formulation
DSMA
Reagent grade
3.2 Ib/gal. formulation
Dalapon
Reagent grade
85% wettable powder
°C
570
700
650
600
600
600
716
671
600
600
602
623
500
560
850
639
656
665
612
250
850
(°F)
(1058)
(1292)
(1202)
(1112)
(U12)
(1112)
(1321)
(1240)
(1112)
(1112)
(1116)
(1153)
(932)
(1040)
(1560)
(1182)
(1213)
(1229)
(1135)
(482)
(1562)
Source-'
MRI
MRI
HSU
MRI
MSU
MRI
HSU
HSU
MRI
MRI
MSU
MSU
UDRI
MSU
MSU
MSU
MSU
MSU
MSU
MSU
MSU
(continued)
-------
TABLE,
(continued)
f
Temperature of complete combustion
Pesticide
Dicamba
Reagent grade
4 Ib/gal • formulation
Dieldrin
Reagent grade
1.5 Ib/gal . formulation
Diunm
Reagent grade
801 wettable powder
jOt
Kepone®
Reagent grade
Halathion
Reagent grade
} 5 lb/gal« formulation
251 wettable -powder
Hirex
Reagent grade
Technical grade
Konagon™
Reagent grade
8.6 Ib/gal* formulation
Rtt
Reagent grade
95% water dispersible
Paraquat
Reagent grade
2 Ib/gal. formulation
°C
840
850
620
640
775
550
500
663
715
650
700
850
800
596
545
646
613
592
(°F)
(1544)
(1562)
(1148)
(1148)
(1427)
(1022)
(932)
(1225)
(1319)
(1202)
(1292)
(1562)
(1472)
(1105)
(1013)
(1195)
(1135)
(1098)
SourceJ/
MSU
MSU
MSU
MSU
MSU
MSU
UDRI
MSU
MSU
MRI
UDRI
MRI
MSU
MSU
MSU
MSU
MSU
MSU
(continued)
-------
TABLE £' ( cont inued)
Temperature of complete combustion
Pesticide
Pic lo ram (potassium salt)
Reagent grade
Recrystallized
11.6% solution
10% pellet formulation
Carbaryl
Reagent grade
10% dust
2,4,5-T (acid)
Reagent grade
4 Ib/gal. formulation
Toxaphene
Technical grade
20% dust
Trifluralin
Reagent -grade
4 Ib/gal • formulation
Vernolate
Reagent grade
6 Ib/gal. formulation
Zineb
Reagent grade
Technical grade (85%)
75% we tt able powder
75% wettable powder
Source: State-of-The
°C
550
900
640
400
724
678
717
731
300£/
710
879
842
447
508
840
800£/
690
800
Art-Report: Pes
Disposal Research. Wilkinson,
Kelso, G.L.; and Hopkins, F.C
(°F)
(1022)
(1652)
(1184)
(752)
(1335)
(1252)
(1323)
(1348)
(572)
(1310)
(1614)
(1548)
(837)
(946)
(1544)
(1472)
(1274)
(1472)
ticide
R. R. ;
. ; EPA-
Source£'
MSU
MRI
HSU
MRI
MSU
MSU
MSU
MSU
MRI
MRI
MSU
MSU
MSU
MSU
MSU
MRI
MSU
MRI
600/2-78-183
-------
Regulation
(2) The incinerator shall be operated at a combustion
efficiency equal to or greater than 99.9 percent, as
defined in the following equation:
CE = C02 x 1QO
C02 + Cco
Where:
CE = combustion efficiency
Cco = concentration of CO2 in exhaust gas
C s* concentration of CO in exhaust gas
co
Incinerators that burn waste that is hazardous only
because it is listed in Section 250.14(b)(11 are
exempt from this requirement.
-------
Rationale
As described in (el Monitoring above, the quantities of
CO and CO2 in the combustion gases are direct indicators of
the degree of combustion of hydrocarbons in an incinerator.
Combustion efficiencies in excess of 99.9 percent were
attained in the series of test burns performed by EPA in
commercial scale incinerators under contract 68-01-2966
see table 2, page 13 • Thus, 99.9 percent combustion
efficiencies are state-of-the-art and can be achieved
in day to day operations of incinerators.
Waste listed in 250.14(b)(l) are hazardous due to
•
thSrr infectious nature only. 250.14(b) specifies conditions
for incineration or sterilization of these waste by reference to
appendix VII which details treatment, storage and disposal
procedures for these wastes.
-------
Regulation
Note to (b) (1) and (2): Incinerators may operate at
other conditions of temperature, retention time, and
combustion efficiency if the facility owner/opera tor
can demonstrate that an equivalent degree of combustion
will be provided under alternate combustion criteria
to the conditions prescribed above.
Rationale
This note allows flexability in prescribed operating
conditions for wastes and incinerator types. Equivalency
must be determined for different temperatures and retention
times. Normally test burns will be required to determine
the destructuon efficiency of a given incinerator for the
waste or wastes that will be burned during the lifetime
of the incinerator.
Regulation
(31 The incinerator shall be operated with a functioning
device to cut off automatically waste feed to the incinerator
when significant changes occur in flame combustion temperature,
excess air, or scrubber water pressure.
73
-------
Rationale
Numerous damage incidents have occured at municipal
and chemical incinerators due to one of several operating
problems. For example, the flame may be extinguished but
wastes may continue to be fed into the hot combustion
chamber. These wastes entering the hot chamber may volatilize
some of the constituents, depending on the temperature of the
hot zone and the vapor pressure of the constituents. without
the flame the combustion process will be incomplete and
all of the wastes feed may not reach a high enough pressure
or a sufficiently high temperature for chemical oxidation.
Similiarly, when the temperature in the combustion
zone decreases -due -to -a lack -of -oxygen/ -a -flame out, excess
moisture, or other reason, the wastes introduced to the
combustion zone will not be completely oxidized, and products
of incomplete combustion will not necessarily result. Odors
from incineration of municipal waste may result when temperature
decreases to below 700°C. In the case of the incineration of
hazardous wastes, however, the loss of sufficient combustion
temperature can result in the formation of hazardous
partially oxidized by-products. Some of the most odorous
$
oxygenated organics include the aldehydes, ke tones, esthers,
and alcohols. If complete combustion is provided, CO2 and H2O
will be formed instead.
Waste feed cut-off, when temperatures in the combustion
zone decrease to a range where incomplete combustion by-products
-------
are formed would prevent emissions of these by-products
significantly. The proper temperatures for various wastes
nnlst be prescribed in the permit based upon the type of
design of the incinerator being permitted and the chemical
and physical characteristics of the wastes expected to be
burned.
The specific amount of air required for complete
combustion relates to the stoichiometry of the oxidation
of a given waste to its complete oxidation s tatei. If
a fan were to malfunction such that no air (and hence oxygen)
were supplied to the combustion zone, the amount of oxygen
present would be used swiftly until not enough was available
for complete combustion of the wastes. Similiar to flame
out and low temperature conditions, a lack of sufficient air
is conducive to formation of the products of incomplete
combustion. Again, automatic waste feed connected to the
fans or other source of excess oxygen will lessen the risk
to adverse effects of such a condition.
Wet or caustic scrubbers are important not only in
controlling acid gases from entering the environment but
also entering the stack where significant corrosion of the
stack may take place. For example should a scrubber malfunction
during the combustion of chlorinated organic waste such as
PVC, HCL will be introduced to both the stack and the
enviroment.
•75-
-------
Regulation
(e) Destruction and Emission Control Criteria
(1) The incinerator shall be designed, constructed, and
operated to maintain a destruction efficiency of 99.U9
percent as defined in the following equation r
DE =/win - outlX 100
Where:
DE =» destruction efficiency
W. = mass feed rate of principal toxic components of
waste going into the incinerator (g/min)
Wout " mass emissions rate of principal toxic components
in waste in the incinerator combustion zone (g/mxn.) .
Incinerators that burn waste that is hazardous only becaosa
it is listed in Section 250 .14(b) (1) are exempt from this
requirement.
-------
Rational
The test work performed by EPA under contract 68-01-2966
to demonstrate destruction of hazardous chemical wastes produced
destruction efficiencies of 99.99 percent in five commercial
scale different incineration units. See Table 2 for a
summary of the test work. The destruction efficiencies in
each of the tests was calculated using the proposed formula
above.
Thus, EPA has determined that 99.99 percent destruction
efficiency is state-of-the-art and can be routinely obtained
in commercial scale incinerator.
Regulation
(21 An incinerator used to thermally degrade hazardous
waste containing more than 0.5 percent halogens shall be
equipped with emission control equipment capable of
removing 99 percent of the halogens from the exhaust gases.
77
-------
Rational
Water and caustic scrubbers are capable of significantly
controlling particulate and gaeous combustion products
that would otherwise be released directly to the environment
through the incinerator stack. Hydrogen halides, (HCL, HF,HBr) ,
are extremely corrosive gases, which also are hazardous to
both human health and the environment at low concentrations.
Scrubbers effectively remove these acids from the gases,
in addition to removing other hazardous soluble combustion
products (i.e. «•*} . The Technology for removing 99 percent
of any of the hydrogen halides has been effectively demonstrated.
(See table .2 1. Pursuant to the authority of Section 6(e)(l) the
Toxic Substances Control Act (TSCA) , regulations for the
disposal of polychlorinated biphenyl were prescribed. These
requirements include bench marks for PCB incineration. "Water
scrubbers shall be used for HCL control during PCB incineration
and shall meet any performance requirement specified by the
Regional Administrator. Scrubber effluent shall comply with
applicable water quality Standards, EPA Water Quality Criteria,
and any other State and Federal laws and regulations. An alternate
method of HCL control may be used if the alternate method
has been approved by the Regional Administrator."
-------
Regulation
(3) The incinerator shall be operated in a manner that
assures that emissions of particulate matter do not exceed
270 milligrams per dry standard cubic meter (0.12 grains
per dry standard cubic foot) at zero excess air. Compliance
with this requirement may be achieved by having particulate
emissions, which, when corrected to 12 percent C(>2 by the
formula below, are less than 180 milligrams per standard
cubic meter (0.08 grains per dry standard cubic foot) .
Where:
= PE x cs
m
C X 1.5
m
PEC = corrected particulate emissions, mg/m3 (gr/dscf)
= measured particulate emissions, mg/ra3 (gr/dscf)
« stoichiometric CQ^ concentration, ppm
=» measured CO2 concentration, ppm
Rationale
For this correction C02 shall be measured in the
combustion zone. Stack testing shall be conducted
once a year to measure particulate emissions. Stack
-------
samples shall be collected using EPA Method 5.
Particulate emissions from a hazardous waste incinerator
may contain toxic metal particles as well as uncombusted
or partially combusted hazardous waste. In the
case where a wet scrubber is required to remove hydrogen
halide and other adverse combustion product gases,
the particulate emissions level is expected to be
controlled below the proposed standard. Currently
municipal incinerator particulate levels are regulated
at 180 mg/m by Federal Standards for units handling
over 50 tons/day. Therefore, the state-of-the-art
exists for control of particulate matter at the proposed
level.
Regulation
(4) The incinerator shall be designed, constructed, and
operated so that fugitive emissions of unburned hazardous
waste and combustion products are controlled.
Rationale
Fugative emissions are defined as those emitted from
other than a stack or vent. A stacjpor vent is
designed to allow air contaminants to be emitted
to the atmosphere at elevations that are conducive to
dispersion.
-------
Fugitive emissions often are a significant source of local
air contamination at ground level particularly when dispersion
X
takes place in a horizontal plane without mi»ing into the
thousands of cubic feet of air between the top of a stack
and human breathing level.
Fugitive emissions from hazardous waste incinerators can
of
be ft> particular concern since the constituents of the
emissions could include unburned waste materials and
by-products of the combustion process. Fugative emissions
can be adequately controlled by two methods. The first is
to seal all leaks in the incinerator system. The second method
to control fugative emissions is to operate the incinerator
at a negative pressure (.i.e. less than atmospheric pressure) .
The negative pressure will insure that any system leaks will
pass outside air into the system rather than combustion gases
flowing out.
ff
-------
Appendix I
The following are damage incidents of importance
to the development of a strategy to protect human
health and the environment from hazardous air
emissions.
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HAZARDOUS WASTE DISPOSAL
DAMAGE REPORT NO. 1
July 8, 1977
Waste Incineration Causes Air Pollution in Connecticut
In early 1974 reports of air and groundwater pollution cause by the in-
cineration of wastes were made. The Air Compliance Division of the Connecticut
Department cf Environmental Protection subsequently closed down two.organic
solvents recovery operations. Solvents Recovery in Southington, Connecticut
was contaminating the air with heavy metals from the incineration of solvent
sludges including lead and zinc, which in turn contaminated the soil and
groundwater 1n the area and the company's own well. Incineration was ceased
in early 1974. In Beacon Falls, Connecticut, a similar operation was closed
for reasons of air pollution.
REFERENCES
The information summarized above was recorded by Alice Giles, February 1975.
Her sources of information were:
1. Jeff Heidtmann, Hydrogeologist, Connecticut Department of Environmental
Protection.
2. Bill Hegener, Water Compliance Division, Connecticut Department of
Environmental Protection
A-I
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HAZARDOUS WASTE DISPOSAL
DAMAGE REPORT NO. 2
July 8, 1977
Air Pollution from Frequent Landfill Fires
1. Personal Damage - None documented
2. Environmental Damage - Contamination of the air from burning of magnesium
chips in the landfill.
3. Economic Damage - None documented
4. Cause of Problem - Improper disposal of magnesium chips and filings
5. Type and Quantity of Hazardous Waste. - An unknown quantity of magnesium
chips and filings were discarded via surface disposal for an unknown
number of years. Other wastes which also may have been dumped at the
site were not identified.
6. Source of Haste - Valley Metal Co., Centerbrook (town or village) in Essex,
Connecticut
7. Date of Incident - About 1970
5". -'Location'-' Essex, Connecticut
9. Status - Unreported
10. Remedial Action Taken - Unreported
11. Legal Action Taken - Unreported
12. Narrative - Valley Metal, Co., Essex, Connecticut disposed of magnesium
chips and filings in a privately owned dump site for an unspecified
period of time. The waste was probably co-mingled with other fill
material, however, no Information is available on the type and quantity
of such material. Around 1970 frequent intense fires and explosions
were reported. No information is available concerning remedial actions
or legal actions. It is not known whether disposal of the magnesium
wastes and/or fires and explosions are still occuring at the site.
REFERENCES
The above information was recorded by Alice Giles, OSW, EPA in February
1975. Her source of information was Bill Hegener, Water Compliance Division,
Connecticut Department of Environmental Protection.
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HAZARDOUS WASTE DISPOSAL
DAMAGE REPORT NO. 3
July 7, 1977
Springfield Township, Pennsylvania
}. Personal Damage - None documented
2. Environmental Damage - Contamination of air, and surface and groundwater
down gradient from the landfill. Contaminants include oily wastes
and nickel.
3. Economic Damage - Compacting bulldozer destroyed, unidentified nurber of
fish killed
4. Cause of Problem - Drums containing unidentified industrial wastes exploded
during compaction. Resulting fire burned for several days. Fish kill
is attributed to runoff from a recently oiled access road. Probable
groundwater contamination attributed to chemical wastes in the landfill.
5. Tvoe ami Quantity of Hazardous Waste - Occasionally tank-car quantities
and many barrels of unidentified chemical wastes were compacted and
buried with other fill materials for an unspecified period of time.
L-Sources of Waste—- Unidentified
Date of Incident—. IncidentlOC/cuxedJa^lW ^
8, Location - Mayer Landfill, Springfield Township, Delaware Co., Pennsylvania
9. Status - The site was closed and covered some time between 1971 and August
1975.
10. Remedial Action Taken - Leachate collection and subsequent transport to a
public treatment plant for treatment began either after the 1971 fire
of after the 1974 fish kill. Leachate collection may still be occurring
or may have been discontinued when_the landfill was closed.
11. Legal Action Taken - None documented
12. Narrative - For an unspecified period of time the Mayer Landfill located in
HBeTaware County, Pennsylvania, accepted all types of industrial wastes.
Quantities of industrial wastes ranged from drums to tank car loads.
Indications are that other types of fill materials were also accepted.
The industrial wastes were probably co-minoled with these fill materials
and compacted during disposal operations. At the time of th2 incident the
surface of the landfill was approximately 100 feet above the original
ground level. The area occupied by the landfill was not specified.
The landfill site lies in the floodplain of Crum Creek.
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In 1971 a drum exploded during compacting operations and caused a
fire that burned for several days. The air around the landfill was
polluted during the fire. The compacting bulldozer was destroyed.
There is no indication that any remedial action was taken by the lard-
fill operators, or by the state, local, federal government as a
result of this incident.
In 1973, and possibly earlier, it was noted that leachate from the
landfill occasionally flowed into Crum Creek. There was also some
evidence of groundwater contamination at the landfill site. A
leachate sample collected on December 6, 1973 showed 0.360 ppm Ni.
fish kill which occurred on June 4, 1974 was attributed to oil run-
off from oiling the road leading to the site.
At some time, probably in 1974, surface leachate collection was begun.
The leachate was treated at an unspecified public treatment plant.
The landfill was closed and covered some time before August 1975.
REFERENCES
All information contained in this summary was obtained from handwritten notes
from what was probably a telephone conversation on August 14, 1975 with Wayne
Lyn of the Solid Waste Commission of the Pennsylvania Department of
Environmental Resources. The EPA person who jotted down the information was
not identified.
This statement was not part of the conversation with Lyn. Comes from
unidentified EPA source.
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HAZARDOUS WASTE DISPOSAL
DAMAGE REPORT NO. 4
July 14, 1977
Air Pollution at Evaporation Ponds
1. Personal Damage - Noxious odors, eye and throat irritation
2. Environmental Damage - Contamination of air by fumes from ponding of
liquid organic waste
3. Economic Damage - Corrosive damage to homes
4. Cause of Problem - Fumes (organic vapors, acidic vapors, etc.) from the
surface of industrial liquid waste evaporation ponds
5. Type and Quantity of Hazardous Waste - For years, unspecified (but large
quantities) or a variety of industrial waste liquids have been dis-
posed of via evaporation in ponds. Many of the constituents in the
wastes are more volatile than water.
6- Source of Waste - Industrial and some municipal sources
7, Date of Incident -Numerous incidents occurring over a period of several
years.
1 Location - San Francisco Bay Area
9. Status - Operations continue
10. Remedial Action Taken - None specified
11. Legal Action Taken - Numerous citations, usually by local Air Pollution
Control Boards.
12. Narrative - Evaporation ponds have been used in certain areas of the
country for many years for disposal of liquid and semi-solid waste of
industrial origin. As an example of the kinds of air pollution asso-
ciated with many of the disposal activities, some experiences with ~
Industrial Tank, Inc., are given below.
Industrial Tank, Inc. operates several evaporation pond sites in the
San Francisco Bay Area. Three sites, the Martinez Site, the Antioch
Site, and the Benicia Site, are discussed here.
The Antioch site operated for many years. It is located in Contra
Costa County, California, and was originally .located in the
center of a Superior Oil tank farm. Its purpose was to receive
waste water containing substantial amounts of oil and recover as much
of the waste oil as possible. This recovered oil was then sold to
A'-
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various sources and used In oiling roadways. The site consisted en
a series of ponds through which the water-borne waste flowed. At «ome
point in the ponding procedure skimming equipment removed the port on
of the water which contained high concentrations of the oil. The
final pond acted as an evaporation pond for the sludge material cor -
tafned in the waste. This site operated in the manner described al ove
for an unspecified number of years during which time Superior Oil
abandoned the tank farm and sold part of the land to private individual*
who received zoning variances and developed the area into a reside? tial
community. Some time after the subdivision was build residents began
to complain of odor problems from the disposal activity. Many com-
plaints to the Air Pollution Control Board vere made. The citizens
filed a one million dollar law suit against industrial Tank's Anticch
site for personal damage including damage to the houses of the home
owners. These homes vere suffering damage such as paint discoloration
and peeling.
Apparently, the Antioch site had never received a permit to operate
a Class I landfill but had operated for several years with the tacit
approval of the California Water Quality Control Board. They did rou-
tinely send the analysis of water from observation wells around the
perimeter of the site to the Water Quality Control Board. When the
pressure from residents became Intense, the Water Quality Control
Board gave notice to the Antioch site that it should be closed. The
first notice came in July 1973 and was deferred until January 1974.
At this time the process of filling in the pond began. The method
for filling was to add municipal refuse to the liquid in the ponds
until they would be gradually filled with municipal refuse. The
process of closing the site began in January of 1974 and continued
for an unspecifred yerfotf erf ttnfer^ttrts' noT Known whether the
site has been completely closed at this time. During the process of
closing the site one fire occurred July 1974. It appears that
the fire may have been deliberately set. (This fire is the subject
of a separate Air Hazardous Waste Damage Report.)
The Martinez site is an active sice. It consists of four evaporation
ponds. Two (A and D) are used in a biological treatment method.
The other two (B and C) rely on evaporation as the disposal mechanism.
The biodegradation pond receives flock containing a large variety of
unidentified material from oil company effluents. It is generally
quite odorous. This flock 1s pumped into pond A and then periodi-
cally the more solid material Is pumped into pond 0 where it is
disced frequently. This allows for anaerobic degradation procedures.
The efficency of the aerobic biodegradation process is questionable.
The remaining two evaporation ponds accept a wide variety of liquid
organic waste. These Include acids, bases, flourides, solvents, ant
organic oils. Some of the organic oils are recovered and burned in
an incinerator owned and operated by Industrial Tank. The kinds anc
efficiencies of air pollution control equipment on this incinerator
were not identified. The pH of the waste materials is adjusted in
holding tanks prior to discharge to the ponds. The pH generally ranges
from 6.8 to 7 before discharge in ponds. Once the materials are con-
tained in the ponds the pH appears to gradually become more acidic.
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Some biological activity does take place. These ponds are largely
an anaerobic process since the lagoons are not aerated. Some of the
materials produced as the wastes degrade under anaerobic, reducing
conditions include hydrogen sulfide, organic sulfur compounds, nitro-
gen bases and possibly ammonium chloride. Occasionally blue smoke
can be observed over a pond. It has been postulated that this
occurs when ammonia evaporates from one pond, HC1 evaporates from
the adjacent pond, and the two are mixed by prevailing winds to form
ammonium chloride. This does not always account for the blue smoke
because the smoke has been observed when the v/inds are blowing the
wrong way. In addition to these kinds of materials which are pro-
duced while the material is in the pond, many of the materials dis-
charged to the ponds are volatile.
Numerous citations have been issued against the Martinez facility,
and there have been complaints from near by residents in Martinez
and Concord. In the summer time very bad odors commonly occur in
the evening and are detectable many miles away. The composition and
quantities of materials evaporating to the air from this site have not
been determined. Occasionally certain wastes are slipped into a pond
which cause severe odcr problems. These are generally the ones which
result 1n citations. There appears to be some degree of monitoring
by the San Francisco Bay Area Air Pollution Control Board; however, the
extent of this surveillance is unknown. Whatever the extent of the
surveillance, contaminants to the air continue to be released. This
site does have a permit to operate as a Class I hazardous waste
disposal site.
The Benecia site is a Class I hazardous waste disposal site and accepts,
excl usi vely- haztrdous^wastsss
some time be classified as Class I material. It does not accept any
municipal refuse. This site, as is the case in the Martinez site,
consists of a series of evaporation ponds. The principle difference
between the two sites is that the odorous wastes are treated and handled
at the Martinez site while the more non-odorous wastes are handled at
the Benecia site. The Benecia site also has a sludge treatment area.
The site was originally owned by J & J Disposal, Inc. and was subse-
quently purchased by Industrial Tank, Inc. To operate the site as a
Class I disposal site, Industrial Tank, Inc. built a retaining wall
along the bottom of the site. They accept plastic and acidic waste
materials;- "For example; they accept wastes from Du Pont Chemical's
titanium dioxide operation. The odor problems described for Martinez
apply to Benecia as well although the odor problems appear to be
slightly less.
REFERENCES
Case #21 of the table entitled "Public Health and Environmental Damage Assess-
ment Inventory," completed by Bob Testani, OSW, EPA, undated. The source of the
A1-7
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information was Dave Storm, California Department of Health.
2. Karen Slitfak, Environmental Engineering Division, TRW, Inc. July 14-T5,
1977. Report of Verbal Communications with Mr. Carl Schwartzer, Division
of Vector and Solid Waste Control, California Department of Health.
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VERBAL COMMUNICATION REPORT
Call From: Karen Slimak, TRW, Inc., Consulting to EPA (Contract 168-01-4644}
.all To: Mr. Carl Schwartzer
Vector and Solid Waste Control Division
California Department of Health
415-843-7900 X434
Date: Ouly 14-15, 1977
Subject: Air Pollution Incidents at Industrial Tank, Inc. Evaporation Ponds
The following information regarding the air pollution incidents associated with
Industrial Tank, Inc. was received from Mr. Carl Schwartzer via telephone con-
versation on July 14-15,.1977. Three sites operated by Industrial Tank were
mentioned. These are the Martinez site, the Benecia site, and the Antioch site.
The Martinez site is also known as the Baker site and the Vine Hill site; the
Vine Hill name denotes the processing equipment used to blend the various waste
raterfals and the Baker site refers to the evaporation pond area.
Antioch site (Contra Costa County, California);
- The Antioch facility is now either completely abandoned or in the process
of being filled in and abandoned.
-The site during active operation was designed as an oil recovery facility.
.There were several ponds.-in--a -series-. 4teste~ oi V «as-a^
pond and allowed to flow through the pond system during which time surface
skimming was accomplished with floatation equipment. One of the ponds was
designed as a drop out pond for the sludge from the oil. All materials
not skimmed from the surface were retained in the evaporation pond system.
The recovered oil (with its relatively high water content) was sold for
use as road oil.
- The Industrial Tank oil recovery facility operated for many years (exact
nwrber of years unspecified). The facility was initially surrounded by a
Superior Oil tank farm. Superior Oil subsequently sold the property, it
was rezoned for residential use and houses were built.
- Complaints from near-by residents began. They reached a peak in about
1972. At which time, a coalition of residents filed a one-million dollar
suit against Industrial Tank. Industrial Tank counter-sued for three
Billion dollars. There appeared to be some cooperation with local air
pollution inspectors. The inspectors passed out forms for the residents
to fill out rather than interviewing each comolaintant and filling out the
forms as required. Other efforts to harass the Industrial Tank facility
included daily calls to Industrial Tank and to the Air Pollution Control
Board concerning odors. This was apparently an activity of a few resi-
dents who took it upon themselves to call daily. The suits progressed
to the point where depositions started to be taken, but then the lawyer
for the citizens group dropped out. Eventually both suits v/ere dropped.
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- In 1973 the Mater Quality Control Board decided to close the landfill.
The site had apparently never received a Class I landfill permit but
harf been operating as a Class I site with the tacit approval of the .'ater
Quality Control Board. Periodically samples from observation wells [n
the vicinity were submitted to the Water Quality Control Board. The
notice for closure was received in July 1973 and deferred until January
1974 when waste oils were no longer accepted at the facility.
- The process of abandoning the site included gradually filling the po id
with municipal refuse.
- When one of the ponds was approximately one-third filled with municipal
refuse a fire occurred on the morning (1 a.m. through 5 a.m.) of Jul / 5.
The fire was apparently not started by spontaneous combustion of the fillj
material. Although the exact cause of the fire remains undetermined
possibilities include fire crackers, hot charcoal in trash, and malicious
mischief. The Fire Department determined that the fire started in the
comer where the most recent garbage dumping had occurred. The size of
the pond involved was approximately one-half acre with an undetermined
depth. The fire flared twice in the 1 a.m. to 5 a.m. time period.
Martinez site:
- This is an active facility. It consists of four evaporation ponds. Two
ponds are used for biodegradation of the materials from oil refineries.
It 1s placed in pond A where anaerobic degradation takes place and the
sludge from that pond is pumped into pond D where it is disced almost
continually to allow for aerobic degradation. Probably the efficiency of
biodegradattoir fr toir bttSuse IJrete^irfcontiechnalsm for -periodic removal
of accumulated salt although there is a conveniently available area for
draining the liquid. The two remaining ponds (B and C) receive wastes
for evaporation. Anaerobic degradation occurs here.
• This site has received several citations from the local Air Pollution
Control Authority. The frequency of citations and of complaints increases
in the summer time when there are very bad odors. Some evenings the
odors can be detected for many miles. The City of Concord is considering
a suit against the facility.
• Occasionally a blue smoke can be observed over the pond. This is possibly
ammonium chloride formed by the reaction of ammonia and hydrogen chloride
gases from adjacent ponds. This does not always explain the appearance
of the blue smoke because it has been observed when the winds were blowing
the wrong way to allow for mixing of the two gases.
There is some H«S odor occasionally. Other odors are from chlorinated
hydrocarbons. *
The pH of the material discharged into the pond is between 6.8 and 7 (this
is to allow for protection of the pipes which convey the wastes to tho
pond}; the pH probably increases in acidity with time. The ponds are
largely anaerobic. (Reducing atmosphere produces H2$ and sulfate and also
produces sulfide, organic sulfur compounds and nitrogen bases.) At the
surface of the pond contact with air would allow the conversion of a
material containing C0£ to sodium bi-carbonate.
4-/O
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-Materials accepted include acids, bases, flourides, solvents, organic
oil. Some organic oils are recovered and burned, in an incinerator.
-Recently they have- installed a chlorinator for decomposition of cyanide
containing waste.
-Quite a Targe percentage of the waste materials are significantly more
volatile than water.
Benecia site (Salona County, California):
-The site accepts exclusively hazardous wastes, sludges, and other solids,
No Class II materials such as municipal refuse are disposed of at the
site.
-The site is a very poor location. It was originally operated by J.& J
Disposal, but was shut down fay the Water Quality Control Board. It was
purchased by Industrial Tank who subsequently built a retaining wall
along the lower edge of the facility at a cost of $750,000. The area
is monitored periodically for signs of leachate from the landfill.
-Materials accepted include plastics, acids, and all of Du Font's hydro-
chloric acid waste from its titanium dioxide operations.
- Currently their are few water related problems with the site; however,
these have been dry years and possible problems may occur during wet
years. The subsoil doesn't seem to fit some geological requirements.
- Son* of" the samr*types~oT wffst&s arraccepted at both the Benecia and
the Martinez facilities. The more odorous are treated in specially
ventilated holding tanks, neutralized and routed to evaporation ponds.
The more non-odorous material is disposed at the Benecia site.
- There is a sludge treatment process at the site.
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HAZARDOUS WASTE DISPOSAL
DAMAGE REPORT NO. 5
July 14, 1977
Fire at Hazardous Waste Landfill
1. Personal Damage - None
2. Environmental Damage - Contamination of air from fire at landfill
3. Economic Damage - None reported
4. Cause of Problem - The cause of the fire is undetermined. Possibilities
include fire crackers, hot charcoal in refuse, malicious mischief.
5. Type and Quantity of Hazardous Waste - Primarily residue from waste oils.
Quantities are unknown.Other combustible material was contained
in municipal refuse.
6. Source of Waste - Unidentified; the waste came from several industrial
and municipal sources.
7. Date of Incident - July 5, 1974; la.m. - 5a.m.
8. Location - Antioch site of Industrial Tan*, Inc.
9. Status - Site Is Closed.
10. Remedial Action Taken - None directly related to the fire. The site was in
the process of being closed at the time of the incident.
11. Legal Action Taken - None identified
12. Narrative - The Antioch disposal site of Industrial Tank, Inc. was pri-
marily a waste oil recovery operation. It was a series of ponds
through which oily water was passed. Large sized skimming equi~-
rant was used to remove the oi4v-wa*er-44H>r use a* road oil) from the
surface of the pond. Up until 1973 this site apparently operated as
a Class I landfill with the tacit approval of the California Water
Quality Control Board. Although there is indication that there was
not formal approval of the operation of this site as a Class I landfill
observation wells were routinely monitored by Industrial Tank and die
results sent to the Water Quality Control Board on a routine basis,
This continued until 1973 when public pressure against the landfill
became quite vocal. At this time the state Water Quality Control
Board gave notice to Industrial Tank, Inc. that the site would hav••»
to be closed. The initial notice of July 1973 was deferred until
January 1974 when the site stopped accepting hazardous wastes.
The procedure for closing the site involved gradual additions of
municipal refuse to the site to absorb the water without causing
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overflowing of the pond. Once the pond area was completely filled
with garbage it would be covered and abandoned. By July 1974 one
pojid whose dimensions were approximately 1/2 acre in area and several
feet deep, was filled to approximately 1/3 capacity with municipal
refuse. A fire occurred in the early morning of July 5. (This pond
was originally designed as a drop out pond for sludge from the waste
oil. At the water surface there was some oil which was skimmed with
floatation equipment.) Fire burned from approximately 1 a.m. until
5 a.m. and flared at least twice during that tine. Possibilities
for the cause of the fire include fire crackers from the 4th of
July celebration, hot charcoal present in some of the trash
material, and malicious mischief from some of the near by residents.
The actual cause of the blaze was not determined although the
fire department did think that the fire started in the corner
of the pond where they had been dumping the garbage. The procedure
of filling the series*of ponds continued without modification
after the fire was put out. The exact time of final covering and
abandonment of the site is not known.
REFERENCES
1. Case 121 of the Table entitled "Public Health and Environmental Damage
Assessment Inventory," completed by Bob Testani, OSW, EPA, undated. His
information source was Dave Storm, California Department of Health. There
Is no record of the communications with Storm.
2. Report of Communication of Karen Slimak, Environmental Engineering Division,
TRH, Inc. with Mr. Carl Schwartzer, Division of Vector and Wastes,
California Department of Health on July 14, 1977.
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HAZARDOUS WASTE DISPOSAL
DAMAGE REPORT NO. 6
July 12, 1977
Air Pollution from Disposal and Recovery of
Lead Wastes, San Francisco, California
1. Personal Damage - Alkyl lead intoxication occurred at lead recovery faci
lity. Toll collectors on a bridge became ill from vapors escauina
from trucks hauling organic lead wastes. Hazard was created to workers
at another reprocessing plant and to surrounding firms.
2. Environmental Damage - Contamination of air from escaping alkyl lead vapors.
3. Economic Damage - None reported
4. Cause of Problem - Evaporation of organic lead vapors from disposal sites,
recovery facilities, and from transporting vehicles.
5. Type and Quantity of Hazardous Waste - The type is liquid, organic waste.
The quantity of waste is unknown other than that approximately 50
tons of organic lead waste has been produced annually in the San
Francisco Bay Area.
6, Source of Waste - Several unidentified manufacturers
7. Date of Incident - Problem has existed for several years
8. Location - San Francisco Bay Area
9. Status - Proper disposal and/or recovery of organic lead wastes is still
a problem. Wastes are stored in a holding basin by one manufacturer
awaiting further instructions.
10. Remedial Action Taken - This series of incidents has been handled in a
variety of ways; these include (a) temporary storage of the wastes
awaiting further Instructions, (b) a reprocessor returned the wastes
to the original disposal site.
11. Legal Action Taken - At least one recovery plant was closed down.
12. Narrative - The disposal of organic lead wastes from the manufacture of
alkyl lead has been a continuing problem for several years. Several
of the associated Incidents 1n the San Francisco Bay Area are related
below:
The annual production of organic lead waste from the manufacturing
process for alkyl lead in the Bay Area has amounted to about 50 ton;
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per year. Although the organic lead waste is now being stored in a
holding basin at the manufacturing plant while capability for re-
covering the lead 1*5 developed, the waste was previously disposed
of in ponds at one industrial waste disposal site. Those attempts
of lead recovery resulted in alky! lead intoxication of recovery
plant employees. A later attempt to reprocess the lead wastes at
another location created a hazard to employees at the plant, as
well as a hazard to surrounding firms, as a result of air-borne
alky! lead vapor.. Also, toll collectors on a bridge along the truck
route to the new reprocessing facility became 111 from the escaping
vapor. After this second recovery plant was closed, some hazardous
material remained on the property and created a health hazard. Finally,
after much delay without achieving proper control, this material was
returned to the original disposal site. Recently, with the detection
of significant levels of alkyl lead in the air in the vicinity of
another disposal facility, a new hazard has been identified. The
source of this air-borne lead has not yet been confirmed because it
cannot be accounted for at the disposal site.
In summary, material generated by one firm has been deposited in a
disposal site which is operated by a second party and owned by a
third. Responsibility for protection of the public under these con-
ditions has been weak.
REFERENCES
Case 17 of the table entitled "Public Health and Environmental Damage
Assessment Inventory". Information recorded by Bob Testam, OSW, EPA
on December 16, 1975. His information came from Don Andreas, Can form a
Department of Public Health via Tim Fields, OSW, EPA.
1973 Report to Congress, Disposal of Hazardous Wastes (SW-115) Appendix
A, p.41.
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HAZARDOUS WASTE DISPOSAL
DAMAGE REPORT NO. 7
July 12, 1977
Air Pollution Incident at Pond Disposal Site
1. Personal Damage - Nausea was reported
2. Environmental Damage - Contamination of air resulted from the evaporation
of volatile liquid wastes from pond surface
3. Economic Damage - At least one of the buildings downwind of the pond lost
an undetermined number of working manhours from its employees due to
the evacuation of the building.
4. Cause of Problem - Volatile odorous wastes evaporated from the surface of
a disposal pond
5. Type and Quantity of Hazardous Waste - The material consisted of between
4,000 and 16,000 gallons of volatile odorous liquid wastes from the
manufacture of allyl amines. Constituents included organohalogens
such as crotyl chloride (C=C-C-C1), amines, and Cg - Cg hydrocarbons.
6. Source of Waste - Shell Oil in San Francisco Bay area
7. Date of Incident - September 1975
8. Location - Richmond Disposal Site of Richmond Sanitary Service, Contra
Costa County, California, Parent company - West Contra Costa
Disposal, Inc.
9. Status - Pond was closed shortly after the incident due to water pollu-
£Tbn problems. Pond may have reopened for certain restricted uses
in May or June of 1977.
10. Remedial Action Taken - None
11. Legal Action Taken - Richmond Sanitary Services and Industrial Tank, Inc.
(hauler) were cited for air pollution violations by the San Francisco
Bay area Air Pollution Control. Other legal actions were considerec
and may have been carried out, these included criminal charges agairst
the hauler.
12. Narrative - There were four firms involved in this incident. Shell Oil
Company in the San Francisco Bay Area was the company who produced the
waste. Industrial Tank, Inc. was contracted by Shell Oil to dispose
of the waste, they were also the hauler of the waste. BKK Disposal
was the southern California company which rejected the waste at its
disposal site. Richmond Sanitary Services was the company which
ultimately disposed of the waste material in its evaporation pond.
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In September 1975, Shell Oil Company generated several thousand
gallons of volatile liquid waste at its ally! amine plant in San
Francisco Bay Area. The exact quantity of the waste is not known;
however, the amount is between 4,000 and 16,000 gallons (1-4
truck loads). These wastes were all volatile material. The
primary constituents were organohalogens such as crotyl chloride,
amines, and short-chain hydrocarbons. This composition was reported
by the manufacturer and was confirmed by analyses performed by the
California Department of Health.
Arrangements were made with Industrial Tank, Inc. for the hauling and
disposal of this waste material. The wastes were loaded into vacuum
trucks and presumably hauled to an Industrial Tank facility. Industrial
Tank, Inc. operates evaporation pond disposal sites in the Martinez and
Antioch areas. It was determined that the wastes were not suited
for pond disposal. The material was then transported in the vaccumn
trucks to BKKDisposal in West Covina, California. The BKK Disposal
site is a municipal refuse co-mixing operation typical of the southern
California area.
BKK disposal rejected the material at the gate on the basis of an
Initial examination. The waste very odorous. BKK was especially
sensitive to odorous waste at this time because it had been closed
down by the town of West Covina for from 1-2 days in just the previous
week. (At a later time the odors were proved not to be due to the BKK
landfill.)
Industrial Tank, Inc. returned the material to the San Francisco area
and sent it to the Richmond"disposal site of Richmond Sanitary
Services. The Richmond disposal site is primarily a sanitary landfill
which handles the sanitary trash business of West Contra Costa Disposal.
They also have one small evaporation pond. Richmond Sanitary Service
accepted the waste and ran it into their evaporation pond.
The material floated to the top of the pond and evaporated. During the
evaporation there was a visible plume (white mist typical of amines),
very bad odors, and complaints of nausea from persons downwind.
REFERENCES
Case 119 (original case $} from the table entitled "Public Health and
Environmental Damage Assessment Inventory" completed by Alice Giles and
Bob Testani, OSW, EPA, January 28, 1976. The source of the information con-
tained therein was Harvey Collins, Head, Vector Control, California Health
Department. There is no record of the contact(s) with Collins in the EPA
file.
A-/7
-------
REFERENCES (Con't)
2. 'Notes from a conversation between Dave Storm, California Department of
Health and an unidentified person, presumably from EPA. The notes are
undated.
3. Verbal communication report by Karen Slimak, Environmental Engineering
Division, TRW, Inc. concerning telephone conversation on July 11, 1977
with Dr. Robert Stevens of the California Department of Health.
Where conflicting information occurred among these three sources, the verbal
communication report was used.
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VERBAL COMMUNICATION REPORT
From: Karen Slimak, TRW, Inc., Consulting to EPA (Contract £63-01-4645)
Call To: Dr. Robert Stevens
California Department of Health
415-843-7900 X434
Date: July 11, 1977
Subject: Air Pollution Incident at Richmond Disposal Site
The following information regarding the above incident which occurred in September
1975 was received from Dr. Robert Stevens.
- Some number of truck loads of wastes were involved. Exact amount is not
known; between 4,000 and 16,000 gallons (1-4 truck loads)
- Wastes were produced by a Shell ally! amine plant
- Constituents (as reported by the manufacturer and as confirmed by analysis
of California Department of Health) included very volalite organohalogens
(e.g., crotyl chloride C=C-C-C1) amines, and C5-Cg hydrocarbons
- Industrial Tank Incorporated was contracted by Shell to dispose of the
wastes
- ITI has evaporation ponds in Martinez and Antioch, but determined that
the wastes were not suitable for ponding
- They shipped the material to BKK Disposal in West Covina, California.
This is a municipal refuse co-mixing operation typical of the Southern
California area.
- Dr. Stevens was at the BKK site in West Covina collecting samples the day
the trucks arrived.
- BKK rejected the material at the gate on the basis of initial examination,
the waste was very odiferous. BKK had been closed down by town of West
Covina for from 1-2 days the previous week because of the odor problems
(later odors proved not to be due to the landfill). Therefore BKK was
very sensitive to odor problems at the time.
- Industrial Tank then returned the material to the San Francisco area and
took it to Richmond Sanitary Services' Richmond Disposal Site. (Parent
company - West Contra Costa Disposal Incorporated)
- Richmond Sanitary Services handles the Sanitary trash business for the
parent company. They also have one small evaporation pond.
- Richmond Sanitary Services accepted the wastes and ran it into the evapora-
tion pond.
A-n
-------
- The material floated to the top and began evaporating
- There was a visible plume (white mist), no firs, very bad odors, and Com-
plaints of nausea from persons downwind. One or more buildings were
evacuated including a Social Security building.
- There were unconfirmed reports that the plume didn't rise readily bu\.
hovered above ground for several hours, moved in various directions Ly
prevailing wind before dissipation.
- There were reports that the plume was sighted 10-15 miles away in Atlameta,
- An air pollution citation was issued against Richmond Disposal and acainst
Industrial Tank Inc. One Industrial Tank official was almost jailed in
the Incident.
- No remedial action was taken because this was a one-time incident ano the
material evaporated.
- A1r pollution surveiHence increased after the incident and more require-
ments were placed on testing wastes and on procedures for accepting
wastes; volatiles were restricted
- Shortly after this incident the pond was closed because of leaks and
because it got too full
- ic nas possibly reopened In 1977.
- For more information on the complaints of nausea, etc. contact Bob Gaynor,
Bay Area Pollution Control District
415-771-6000
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HAZARDOUS HASTE DISPOSAL
DAMAGE REPORT NO. 8
duly 22, 1977
Bulldozer Operator Nauseated from Fumes
1. Personal Damage - Bulldozer operator became nauseated
2. Environmental Damage - Contamination of air when wastes were uncovered;
leaks from waste material into a local stream
3. Economic Damage - None documented
i
4. Cause of Problem - Fumes from wastes from lindane and benzene hexachloride
manufacture uncovered during site preparation for a baseball field
5. Type and Quantity of Hazardous Waste - About 400 tons of BHC waste
6. Source of Haste - Unidentified pesticide manufacturer _..
7,..Date of Incident - August 4, 1976
8. Location - Hamilton Township, Allegheny County, Pennsylvania^
(I Status ^_UndetejOQined
10. Remedial Action Taken - Undetermined
11. Legal Action Taken - None
12. Narrative - Apparently, an unidentified pesticide manufacturer produced
TTHdane/BHC on a site in Hamilton Township, PA. The operation ceased
in about 1966. Subsequently, the site was deeded to the town.
Recently, the town decided to construct a baseball field and a bull-
dozer operator became nausftatp^ whr>n h" imoarthpri wha%-was Tater shown
to be BHC waste.Pennsylvania Department of Conservation (PDC) esti-
mates over 400 tons of BHC waste is present. Further, there is a
confirmed leak from the waste into a local stream.
As of August, 1976 the State was undecided on the best course of
action. The town did not have the funds to effect clean-up. The two
options considered were containment of the waste on site with treat-
ment of the leaking material or excavation and removal to a hazardous
waste site. A PDC group was scheduled to survey the buried waste to
determine its extent.
-------
The PDC was provided with some specific information, obtained frc i
TRW» on treatment of BHC waste by conversion to trichloro-
benzene with calcium oxide. They may elect to use this method fo -
treatment of the discharge.
REFERENCES
1. Harold R. Day, Pesticide Haste Management Division, EPA. August IS, 19 5.
Memo to Harry M. Trask, Pesticide Waste Management Division, EPA.
2. Case #65 from the table entitled "Public Health and Environmental Damage
Assessment Inventory - Pennsylvania", completed by Bob Testani, OSW, EP> ,
September 7, 1976. Source of information was Bill Schremp, Region III,
EPA.
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HAZARDOUS WASTE DISPOSAL
DAMAGE REPORT NO. 9
July 19, 1977
Asbestos Air Pollution from Landfills
1. Personal Damage - Possible exposure of workers and their families to
high levels of asbestos
2. Environmental Damage - I'one documented
3. Economic Damage - None documented
4. Cause of Problem - Unsatisfactory methods of disposal of hazardous waste
containing asbestos from asbestos mine and mill
5. Type and Quantity of Hazardous Waste - Undetermined quantities of
chrysotile asbestos in disposal area
6. Source of Waste - Pacific Asbestos Company, Copperopolis, California,
Parent Company - H. K. Porter Corporation
7. Date of Incident - February - March, 1973
location-,^~CopperopQ 14s. California
9. Status - Unknown
10. Remedial Action Taken - None determined
11. Legal Action Taken - None determined
12. Narrative - The Pacific Asbestos Company operates a quarry - mill complex
adjacent to the community of Copperopolis, California. Processing
wastes are apparently disposed on site. The method for disposal is
unsatisfactory and has resulted in complaints of exposure to the
community of high levels of chrysotile asbestos.
At the request of the International President of the Cement, Lime, and
Qypsuc: Workers, the Industrial Union Department of the AFL/CIO con-
ducted an investigation of worker and conmunity resident exposure to
asbestos. A medical and environmental science team headed by Professor
Irving J. Selikoff visited the Copperopolis community and the Pacific
Asbestos plant on March 9-10 to assess the adequacy of the method of
disposal of material from the Pacific Asbestos plant as well as the
levels of exposure of residents in the community and workers in the
plant to chrysotile asbestos fibers.
-------
The results of this investigation are unknown. There is no
data on any remedial measures or any legal action taken.
REFERENCES
Case 18 from the table entitled "Public Health and Environmental Damage
Assessment Inventory", completed by Bob Testani, OSW, EPA, undated.
Source of Information was Alan Cranston, Committee on Labor and Public
-Welfare, U.S. Senate (letter, March 1, 1973), and S.W. Samuels, Director
Health Safety and Environmental Affairs, Union Department, AFL-CIO
(memorandum, February 21, 1973).
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HAZARDOUS WASTE DISPOSAL
DAMAGE REPORT NO. 10
July 20, 1977
Air Pollution from Waste Asbestos Piles
\t Personal Damage - Potential exists for asbestosis and mesothelioma among
workers at asbestos mill and nearby residents.
2. Environmental Damage - Contamination of air (ambient levels 3.6 ng/m above
background; emission levels 108 to 1739 ng/m3 above background) due
to disposal activities and wind erosion at asbestos waste pile. Leach-
ate from waste pile (Total solids: fSO mg/1; pH 11.1) contaminated
nearby stream.
3. Economic Damage - None identified
4. Cause of Problem - Asbestos emissions from waste storage pile as a result
of wind erosion and dumping activities. Periodic leachate from landfill
5. Tvoe and Quantity of Hazardous Waste - Approximately 1.5 million cubic
yards of asbestos containing wastes; the waste pile is 50 feet high
and covers 20 acres. Other waste constituents include calcium and mag-
nesium carbonate.
6. Source of Waste - Various asbestos-manufacturing process and milt'.-of-
magnesia manufacture.
7. Date of Incident - The Nicolet Landfill (and associated asbestos emissions)
began operation in about 1C70 and continued until about 1975; Certain-
teed Products Landfill began operations sometime after January 1, 1970
and discontinued operations in March, 1972.
8. Location - Ambler Borough, Montgomery County, Pennsylvania
9. Status - The present status is unreported; both sites were required to
complete closure and site abandonment procedures by May 1, 1?74.
However,.appeals delayed th1.s_deadllne_until September 1975. _As o.
January 1976 the site was neither covered nor removed.
10. Remedial Action Taken - As of early 1975, the Nicolet site was not fenced.
Equipment to filter out the asbestos and concentrate the waste has
been purchased. The resultant asbestos containing wastes will go to
the Montgomery County Landfill.
11. Legal Action Taken
- In 1973 Nicolet was ordered to cease and desist dumping, and to cover
and stabilize the dumps.
-------
- On February 19, 1974, Pennsylvania Department of Environmental
Resources ordered Nicolet Industries, Inc. and Certain-teed Produc s
Corporation to cease waste disposal operatons immediately and comp-y
with landfill closure requirements by May 1, 1974.
- On February 10, 1975, Pennsylvania Department of Environmental
Resources denied the Nicolet Industry permit for disposal and requ red
that Nicolet cease operation of its solid waste disposal facility rvy
August 1, 1975 and proceed with closure activities.
12. Narrative - In 1367 two Ambler, Pennsylvania companies, Keasley and
Mattison (K & M) began manufacturing milk of magnesia and asbestos
products and dumping wastes a short distance away at the intersection
of Butler Avenue and Morris Road near the main section of the borough.
The wastes then, as now, were primarily (-80%) magnesium carbonate and
calcium carbonate. The site contains about 100,000 tons of magnesium.
Asbestos concentration varies throughout the site depending on waste
type encountered, e.g., asbestos dust - up to 40%, asbestos pipe -
up to 122, waste water sludge - ~2%.
Dumping has occurred at the site for a total of about 90 years. Much
~of tho WIT** rilp_"ac due to K & M activities. In 1930 when Nicolet
Industries. Inc. purchased the insulation and general products divi-
slonsoTT & M~Efie7 Inherited the waste pile. In 1962 Certain-teed
Products Corporation bought out the pipe manufacturing operation of
K & M. Nicolet Industries, Inc. and Certain-teed Products Corporation
Products Corporation
has added about 2700 tons of crushed asbestos pipe each year. Nicolet
1 ndustries^ disposes- of lis^asiestosa.was±e«J n.. piles . ad^acen t. ta -the. .^
old pile at Butler Avenue and Morris Road.
The old pile contains approximately 1.5 million cubic yards of waste;
its dimensions are approximately 50 feet high by 20-25 acres. A resi-
dential development and the Wissahickon Creek are nearby.
The locations of the active sites are shown in Figure 1. Current waste
treatment and disposal processes include waste collection, settling
ponds, lagoons, and disposal piles.
Waste generated as a dust (4(J pferCeht asbestos) froffl the Sanaing of
monolithic board 1s collected in baghouses. The dust is transferred
from the baghouse to containers where the material is wetted, covered,
and transported to a settling pond about one kilometer away. The *aste
material 1s dumped Into a section of the settling poind, mixed into
a slurry, and pumped to the active disposal lagoon approximately 50
meters away. Other asbestos-containing waste generated at the plant
empties into a wastewater system and is channeled to the settling pond.
Waste generated from machining the pipe ends is collected in a baghouse
and recycled rather than being discarded as waste. Pipe scraps greater
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SITE #10
s
PLANT A
BUILDING H 2 ' R.R.
-H-H I I II I M-J-I I I I I 1 I I I 1 I I I II 11 I I I I II I.I I I I M I I 1-4-1 I I 1 I I I I |=N=N=
"•'.PLANT B..!- ••
MAPLE STREET
!•..' '-. • .-.' '• .. •". • '
'••'••.•;'• '. PLANT A BUILDING H\'. •' ' '..-.'•
•••'- . .•'-.., •'..'• •..;••'•••''"' ' • ••'•.
.•«..••••. ; ••••;• ; •.•••.:•.•.-
SITEW
$&u
VPIPE SCRAPS
DUMPED HERE
/•/ AWil**^^?.'
PLANT B'S
SITE* ACTIVE PILE
SETTLING**
PONDS
LEGEND:
S SAMPLER
M METEOROLOGICAL
STATION
SEWAGE
PLANT
sLAGOON
/W
NW— -&—SE
270°/
W
/ i
sw
180°
x S
/ /
jt/ 'igure 1. Sources of asbestos emissions In Ambler. Pennsylvania.
.•^^^|yv-fjj^c
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than 30 cm (ca. 12 inches) in diameter are not recycled, and this waste
is transported to the disposal pile. A large amount of asbestos-
containing sludge is created in the wastewater treatment operatic*..
Tank trucks transport the slurrfed sludge to the disposal lagoon;
each truck carries approximately 23,000 liters (ca. 6000 gallons) per
load and empties into the lagoon at a rate of about 10 to 12 true :-
loads per 6-week period.
After water evaporates from the disposal lagoon, portions of the lagoon
have a dry, cracked crust. The top layer is light in color, has i
relatively low density, and is fibrous. The fibers appear to be jound
securely enough so that they are not released by wind action alons.
The sides of the disposal site are about 46 cm higher than the le/el
of the lagoon and form a roadway approximately 4.5 meters wide. Solid
material is deposited and spread on this roadway when it becomes neces-
sary to build up the sides of the lagoon.
When enough water has evaporated, the semidry waste is shoveled from
the lagoon and piled onto the adjacent disposal area. A bulldozer then
crushes the discarded pipe; the semidried sludge is mixed with the
crushed pipe, and the mixture is spread uniformly on the disposal pile.
The crushing operation is performed for approximately 1-1/2 days of
an 8-week period.
There are actually two adjoining disposal sites. Site A is approxi-
mately 20 meters high, 90 meters wide, and 150 meters long (ca. 60
feet high, 300 feet wide, and 500 feet long), while Site B is approxi-
mately 6 meters high, 90 meters wide, and 210 meters long. -
A waste disposal site located southwest of Plant A at the Nicolet
facility has been inactive for about 4 years and covers approximately
40,000 m* (ca. 10 acres) (Figure 1). The type of waste material de-
posited at the site differs from the material currently being disposed
of at the other two sites. Trees, grass, shrubs, and weeds cover ap-
proximately 75 to 90 precent of surface area, but little vegetation
grows on the north bank of the pile, which borders one side of a play-
ground and is close (within 15 meters) to occupied dwellings. This
bank is approximately 180 meters long, approximately 15 meters hi< h,
and has a slope of about 60 degrees.
Over a period of years, starting in 1971, both Nicolet and Certain-teed
have been challenged on state laws concerning solid waste management.
Investigation has also determined that the landfill is causing a dis-
charge of pollutants into the Ulssahickon Creek.
On December 2, 1971, Nicolet Industries applied for permission to con-
tinue dumping (Permission required by Solid Waste Management Act of
1968). Pending approval, Nicolet continued to dump. On March 2, 1972
Certain-teed applied under the same Act. However, they discontinued
dumping upon application.
-------
Pressure to close the landfill due to high levels of asbestos air
emissions began in about 1973. Concern was voiced by Dr. Irving
Selikoff, Mt. Sinai Environmental Sciences, Jack Farmer, EPA, and
others. An air monitoring program conducted by the U.S. Environ-
mental Protection Agency in October, 1973, indicated ambient back-
ground levels of asbestos to be 6 ng/ra3. An asbestos level of 9.6
ng/m3 was found at a playground near the largest waste pile. Values
obtained near active disposal piles range from 114 to 1745 ng/m3.
It has been reported that citizens have been removing material from
the piles for driveways.
In 1973 the Pennsylvania Department of Environmental Resources (DER)
ordered Nicolet to cease and desist dumping, to cover and stabilize
the dumps. The firm reapplied for a solid waste management permit.
In February 1974, a disposal permit was denied by the Pennsylvania
Department of Environmental Resources; Nicolet Industries and Certain-
teed were directed to cease disposal activities immediately and
cover and abandon the site by May:1974. In February 1974, a second
application was denied and disposal operations were directed to cease
in August 1975. As of November 1975 the Pennsylvania DER reported that
Certain-teed Products was complying with the court order regarding
dumping. Nicolet had complied in part, with one phase of their
operations still producing asbestos wastes. Nicolet was exploring
alternative remedies; however, the asbestos piles had been neither
planted or removed.
Although the initial pressure which resulted in the permit denials
was due to asbestos air emissions, justification for permit denial
and site-^losare-was ^giveir^as-water"- p®Htftit)-n-a«6rto leachate-eonta*
urination of an adjacent stream. The DER orders did not mention the
air emissions problem!
A similar asbestos waste pile exists at Hyde Park, Vermont. The pile
dimensions were approximately 400 feet high, approximately 26CO feet
long, approximately 1000 feet wide as of September 1973. At that
time the site contained 20 million metric tons of tailings. The site
had been in use for 15 years at that time. Percentages of chrysotile
asbestos in samples of debris from the tailings pile ranged from 12.7
to 21.1. Ambient concentrations (away from the site) ranged from 3 to
13,600 ng/n»3; average concentration was about 1300 ng/m3- Windblown
emissions from the tailings pile averaged 500 ng/m3. In this case
emissions from mining, milling, and roadways probably contributed
significantly to ambient concentrations.
REFERENCES
1. William K. Mandel. The Evening Bulletin. December 3, 1973. "Asbestos
H111 is Hit as Health Hazard".
2. Leon T. Gonshor, Regional Coordinator, Pennsylvania DER. February 20,
1974. Letter to Daniel Synder, Region III Administrator, EPA.
-------
3. Leon T. Gonshor, Regional Coordinator, Pennsylvania DER. February 20,
1975. . Letter to Daniel Synder, Region III Administrator, EPA.
4. Alice Giles, Undated. Internal EPA summary of Ambler Incident, OSW, EPA.
5. U.S. Environmental Protection Agency, 1974. Background Information on
National Emission Standards for Hazardous Air Pollutants - Proposed
Ammendraents to Standards for Asbestos and Mercury. Office of Air Quality
Planning and Standards, Research Triangle Park, North Carolina (EPA -
450/2-74-009a).
6. William G. Seeburger, American Cancer Society, Philadelphia, Pennsylvania.
January 15, 1976. Letter to Enery C. Lazar, Office of Solid Waste
Management, EPA.
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BD-26
Resource Conservation and Recovery Act
Subtitle C-Hazardous Waste Management
Section 3004 - Standards Applicable
to Owners and Operators of Hazardous Waste
Treatment, Storage, and Disposal Facilities
DRAFT
BACKGROUND DOCUMENT
Section 250.45-2 Standards for Landfills
U.S. Environmental Protection Agency
Office of Solid Waste
December 15, 1978
-------
TABLE OF CONTENTS
I. Intorduction
II. Rationale for Regulation
[II. Identification and Analysis of Regulatory Options
IV. Identification of Chosen Standards and Associated
Rationale
V. References
VI. Appendix I - Case Histories
-------
This document provides background information and
support for regulations which have been designed to protect
the air, surface water, and groundwater from potentially
harmful discharges and emissions from hazardous waste treatme ,t,
storage, and disposal facilities pursuant to Section 3004 of
the Resource Conservation and Recovery Act of 1976. It is
being made available as a draft for comment. As new information
is obtained, changes may be made in the regulations, as well
as in the background material.
This document was first drafted many months ago and has
been revised to reflect information received and Agency
decisions made since then. EPA made changes in the proposed
Section 3004 regulations shortly before their publication in
the Federal Register. We have tried to ensure that all of
those decisions are reflected in this document. If there
are any inconsistencies between the proposal (the preamble
and the regulation) and this background document, however,
the proposal is controlling.
Comments in writing may be made to:
Timothy Fields, Jr.
U.S. Environmental Protection Agency
Office of Solid Waste
Hazardous Waste Management Division (WH-565)
401 M Street, S.W.
Washington, D.C. 20460
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I. Introduction
Section 3004 of the Resource Conservation and Recovery
Act of 1976 (RCRA) mandates that the EPA Administrator
promulgate regulations establishing standards applicable to
owners and operators of facilities for the disposal of
hazardous wastes as may be necessary to protect human health
and the environment. Among other things, these standards
are to include requirements respecting (1) the disposal of
all such waste received by the facility pursuant to such
operating methods, techniques, and practices as may be
satisfactory to the Administrator, and (2) the location,
design, and construction of such hazardous waste disposal
facilities.
This document will be concerned specifically with the
secure landfilling method of hazardous waste disposal. For
the purpose of this discussion, a landfill is a facility
which is engineered for the secure disposal of hazardous
wastes involving the placement of such waste into the land
surface, and involving covering of the hazardous waste so
that human health and the air, groundwater and surface water
is protected.
According to definitions given in Subtitle A, Section
1004 of RCRA, hazardous waste storage facilities must not
leak or else the intended storage activity constitutes
disposal. The pertinent definitions from the RCRA are as
follows:
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"The term 'storage,1 when used in connection with
hazardous waste, means the containment of hazardous waste,
either on a temporary basis or for a period of years in such
a manner as not to constitute disposal of such hazardous
waste."
"The term 'disposal' means the discharge, deposit,
injection, dumping, spilling, leaking, or placing of any
solid waste or hazardous waste into or on any land or water
so that such solid waste or hazardous waste or any constituen
thereof may enter the environment or be emitted into the air
or discharged into any waters, including groundwaters."
When used in this Subpart, the following terms have the
meanings given in the Act:
"Administrator" - Sec. 1004(1)
"disposal" - Sec. 1004(3)
"Federal Agency" - Sec. 1004(4)
"hazardous waste management" -Sec. 1004(7)
"open dump" -Sec. 1004(14)
"person" - Sec. 1004(15)
"resource recovery" -Sec. 1004(22)
"sanitary landfill" - Sec. 1004(26)
"sludge" - Sec. 1004(26A)
"solid waste" - Sec. 1004(27)
"solid waste management" - Sec. 1004(28)
"solid waste management facility: - Sec. 1004(29)
"State" - Sec. 1004(31)
"storage" - Sec. 1004(33)
"treatment" - Sec. 1004(34)
2-
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Other terms used in this Subpart have the following
meanings:
"Act" means the Resource Conservation and Recovery
Act of 1976, Public Law 94-580.
"Active Fault Zone" means a land area which
according to the weight of the geologic evidence,
has a reasonable probability of being affected by
movement along a fault to the extent that a
hazardous waste facility would be damaged and
there by pose a threat to human health and the
environment.
"Active Portion" means that portion of a facility
where treatment, storage, or disposal operations
are being conducted. It includes the treated area
of a landfarm and the active face of a landfill,
but does not include those portions of a facility
which have been closed in accordance with the
facility closure plan and all applicable closure
standards.
"Aquifer" means a geologic formation, group of
formations, or part of a formation that is capable
of yielding useable quantities of groundwater to
wells or springs.
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"Attenuation" means any decrease in the maximum
concentration or total quantity of an applied
chemical or biological constituent in a fixed time
or distance traveled resulting from a physical,
chemical, and/or biological reaction or transformation
occurring in the zone of aeration or zone of
saturation.
"Cell" means a portion of waste in a landfill
which is isolated horizontally and vertically from
other portions of waste in the landfill by means
of a soil barrier which meets criteria specified
in Section 2^45-2 (b) (14).
"Chemical Fixation" means the treatment process
involving reactions between the waste and certain
chemicals, resulting in solids which encapsulate,
immobilize or otherwise tie up hazardous components
in the waste so as to minimize the leaching of
hazardous components and render the waste nonhazardous
or more suitable for disposal.
"Close Out" means the point in time at which
facility owners/operators discontinue operation by
ceasing to accept hazardous waste for treatment,
storage, or disposal.
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"Closed Portion" means that portion of a facility
which has been closed in accordance with the
facility closure plan and all applicable closure
requirements in this Subpart.
"Closing Date" means the date which marks the end
of a reporting quarter or reporting year.
"Closure" means the act of securing a facility
pursuant to the requirements of Section 250.43-7.
"Closure Procedures" means the measures which must
be taken to effect closure in accordance with the
requirements of Section 250.43-7 by a facility
owner/operator who no longer accepts hazardous
waste for treatment, storage, or disposal.
"Container" means any portable enclosure in which
a material can be stored, handled, transported,
treated, or disposed.
"Contamination" means the degradation of naturally
occuring water, air, or soil quality either directly
or indirectly as a result of man's activities.
"Cover Material" means soil or other material that
is used to cover hazardous waste.
-------
"Direct Contact" means the physical intersection
between the lowest part of a facility (e.g., the
bottom of a landfill, a surface impoundment liner
system or a natural in-place soil barrier, including
Ofd
leachate detection/removal systems) and a water
table, a saturated zone, or an underground drinking
water source, or between the active portion of a
facility and any navigable water.
"Disposal Facility" means any facility which
disposes of hazardous waste.
"Endangerment" means the introduction of a substance
into groundwater so as to:
(i) cause the maximum allowable contaminant
levels established in the National Primary
Drinking Water standards in effect as of the
date of promulgation of this Subpart to be
exceeded in the groundwater; or
(ii) require additional treatment of the groundwater
in order not to exceed the maximum contaminant
levels established in any promulgated National
Primary Drinking Water regulatons at the
point such water is used for human consumption;
or
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(iii) Reserved (Note: Upon promulgation of revisions to the Primary
Drinking Water Standards and National Secondary Drinking Water Standards
and National Secondary Drinking Water Standards under the Safe Drinking
Water Act and/of standards for other specific pollutants as may be
appropriate).
"EPA Region" means the States and other jurisdictions in the ten EPA
Regions as follows:
Region I - Maine, Vermont, New Hampshire, Massachusetts,
Connecticut, and Rhode Island.
Region II -New York, New Jersey, Commonwealth of Puerto Rico,
and the U.S. Virgin Islands.
Region III - Pennsylvania, Deaware, Maryland, West Virginia,
Virginia, and the District of Columbia.
Region IV - Kentucky, Tennessee, North Caorlina, Mississippi,
Alabama, Georgia, South Carolina, and Florida.
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Region V
Region VI
Region VII
Region VIII
Region IX
Region X
Minnesota, Wisconsin,
Illinois, Michigan,
Indiana, and Ohio.
New Mexico, Oklahoma,
Arkansas, Louisiana, and
Texas.
Nebraska, Kansas, Missouri,
and Iowa.
Montana, Wyoming, North Dakota,
South Dakota, Utah, and
Colorado.
California, Nevada,
Arizona, Hawaii, Guam,
American Samoa, and the
Commonwealth of the
Northern Mariana Islands.
Washington, Oregon,
Idaho, and Alaska.
"Facility" means any land and appurtenances,
theron and thereto, used for the treatment,
storage, and/or disposal of hazardous waste.
"Final Cover" means cover material that is applied
upon closure of a landfill and is permanently
exposed at the surface.
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"Five-Hundred-Year Flood" means a flood that has a
0.2 percent or one in 500 chance or recurring in
any year. In any given 500 year interval, such a
flood may^occur, oR moee -^A* o<4£-
"Flash Point" means the minimum temperature at
which a liquid or solid gives off sufficient vapor
to form an ignitable vapor-air mixture near the
surface of the liquid or solid. An ignitable
mixture is one that, when ignited, is capable of
the initiation and propagation of flame away from
the source of ignition. Propagation of Flame
means the spread of the flame from layer to layer
independent of the source of ignition.
"Groundwater" means water in the saturated zone
beneath the land surface.
"Hazardous Waste" has the meaning given in Section 1004(5!
of the act as further defined and identified in
Subpart A.
"Hazardous Waste Facility Personnel" means all
persons who work at a hazardous waste treatment,
storage, or disposal facility, and whose actions
or failure to act may result in damage to human
health or the environment.
8
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"Hazardous Waste Landfill" means an area in which
hazardous waste is disposed of in accordance with
the requirements of Secion 250.45-2.
"Hydraulic Gradient" means the change in hydraulic
pressure per unit of distance in a given direction.
"Incompatible Waste" means a waste unsuitable for
commingling with another waste or material,
because the commingling might result in:
(i) Generation of extreme heat or pressure,
(II) Fire,
(iii) Explosion or violent reaction,
(iv) Formation of substances which are shock
sensitive friction-sensitive, or otherwise
have the potential of reacting violently,
(v) Formation of toxic (as defined in Subpart A)
dusts, mists, fumes, gases, or other chemicals,
and
(vi) Volatilization of ignitable or toxic chemicals
due to heat generation, in such a manner that
the likelihood of contamination of groundwater,
or escape of the substances into the environment,
is increased, or
(vii) Any other reactions which might result in
not meeting the Air Human Health and Environment
Standard.
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"Leachate" means the liquid that has percolated
through or drained from hazardous waste or other
man emplaced materials and contains soluble,
partially soluble, or miscible components removed
from such waste.
"Leachate Collection and Removal System" means a
system capable of collecting leachate and/or
liquids generated within a hazardous waste landfill,
and removing the leachate and/or liquids from the
landfill. The system is placed or constructed
above the landfill liner system.
"Leachate Detection System" means a gravity flow
drainage system installed between the top and
bottom liners of a surface impoundment capable of
detecting any leachate that passes through the top
liner.
"Leachate Detection and Removal System" means a
system capable of detecting the presence of leachate
and/or liquids beneath the bottom liner system of -
a landfill, and is capable of periodically removing
leachate and/or liquids if found or known to be
present.
10
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"Leachate Monitoring System" means a system beneath
a facility used to monitor water quality in the
unsaturated zone (zone of aeration) as necessary
to detect leaks from landfills and surface impound-
ments. (For example, a pressure-vacuum lysimeter
may be used to monitor water quality in the zone
of aeration.)
"Liner" means a layer of emplaced materials
beneath a surface impoundment or landfill which
serves to restrict the escape of waste or its
constituents from the impoundment or landfill.
"Monitoring" means all procedures used to syste-
matically inspect and collect data on operational
parameters of the facility or on the quality of
the air, groundwater, surface water, or soils.
"Monitoring Well" means a well used to obtain
water samples for water quality analysis or to
measure groundwater levels.
"Navigable Waters" means "waters of the United
States, including the territorial seas". This
term includes, but is not limited to:
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(i) All waters which are presently used, or
were used in the past/ or may be susceptible
to use in interstate or foreign commerce,
including all waters which are subject to
the ebb and flow of the tide, intermittent
streams, and adjacent wetlands. "Wetlands"
means those areas that are inundated or
saturated by surface or groundwater at a
frequency and duration sufficient to support,
and that under normal circumstances do
support, a prevalence of vegetation typically
adapted for life in saturated soil conditions
Wetlands generally include swamps, marshes,
bogs, and similar areas such as sloughs,
paririe potholes, wet meadows, prairie
river overflows, mudflats, and natural
ponds.
(ii) Tributaries of navigable waters of the
United States, including adjacent wetlands;
(iii) Interstate waters, including wetlands; and
(iv) All other waters of the United States, such
as intrastate lakes, rivers, streams, mud-
flats, sandflats, and wetlands, the use,
12-
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degradation or destruction of which would
affect or could affect interstate commerce,
including, but not limited to:
(A) Intrastate lakes, rivers, streams,
and wetlands which are or could be
used by interstate travelers for
recreational or other purposes;
(B) Intrastate lakes, rivers, streams,
and wetlands from which fish or shell-
fish are or could be taken and sold in
interstate commerce; and
(C) Intrastate lakes, rivers, streams, and
wetlands which are used or could be used
for industrial purposes by industries
in interstate commerce.
(v) All impoundments of waters of the United
States otherwise defined as navigable waters
under this paragraph.
"Non-Point Source" means a source from which
pollutants emanate in an unconfined and unchannelled
manner, including, but not limited to, the following
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(i) For non-point sources of water effluent, this
includes those sources which are not controllabl
through permits issued pursuant to Sections 301
and 402 of the Clean Water Act. Non-point
source water pollutants are not traceable to
a discrete identifiable origin, but result
from natural processes, such as nonchannelled
run-off, precipitation, drainage, or seepage.
(ii) For non-point sources of air contaminant
emissions, this normally includes any land-
fills, landfarms, surface impoundments, and
basins.
"On-site" means on the same or geographically
contiguous property. Two or more pieces of
property which are geographically contiguous
and are divided by public or private right(s)-
of-way are considered a single site.
"Owner/Operator" means the person who owns the
land on which a facility is located and/or the
person who is responsible for the overall opera-
tion of the facility.
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"Partial Closure Procedures" means the measures
which must be taken by facility owners/operators
who no longer accept hazardous waste for treatment,
storage, or disposal on a specific portion of the
site.
"Permitted hazardous waste management facility
(or permitted facility)" means a hazardous waste
Treatment, storage, or disposal facility that
has received an EPA permit in accordance with
the requirements of Subpart E or a permit from
a State authorized in accordance with Subpart F.
"Point Source" means any discernible, confined,
and discrete conveyance, including, but not
limited to, the following:
(i) For point sources of water effluent, any
pipe, ditch, channel, tunnel, conduit, well,
discrete fissure, container, rolling stock,
concentrated feeding operation, vessel, or
other floating craft from which pollutants
are or may be discharged; and
(ii) For point sources of air contaminant
emissions, any stack, duct, or vent from
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which pollutants are or may be discharged.
"Post-Closure Care" means the monitoring and
facility maintenance activities conducted after
closure.
"Publicly Owned Treatment Works" or "POTW" means
a treatment works as defined in Section 212 of
the Clean Water Act (CWA), which is owned by a
State or municipality (as defined by Section
502(4) of the CWA). This definition includes
any sewers that convey wastewater to such a
treatment works, but does not include pipes,
sewers, or other conveyances not connected to a
facility providing treatment. This term also
means the municipality as defined in Section
502(4) of the CWA, which has jurisdiction over
the indirect discharges to, and the discharges
from, such a treatment works.
"Reactive Hazardous Waste" means hazardous
waste defined by Section 250.13(c)(l) of
Subpart A.
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"Recharge Zone" means an area through which water
enters an aquifer.
"Regional Administrator" means the Regional
Administrator for the Environmental Protection
Agency in which the facility concerned is
located, or his designee.
"Run-off" means that portion of precipitation
that drains over land as surface flow.
"Saturated Zone (Zone of Saturation)" means that
part of the earth's crust in which all voids are
filled with water.
"Spill" means any unplanned discharge or release
of hazardous waste onto or into the land, air or
water.
"Soil Barrier" means a layer of soil of a
minimum of 1.5 meters (5 feet) in thickness
with a permeability of 1 x 10~7 cm/sec or less
which is used in construction of a landfill or
a surface impoundment.
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"Sole Soruce Aquifers" means those aquifers
designated pursuant to Section 1424(e) of the
Safe Drinking Water Act of 1974 (P.L. 93-523)
which solely or principally supply drinking
water to a large percentage of a populated area.
"Treatment Facility" means any facility which
treate hazardous waste.
"True Vapor Pressure" means the pressure exerted
when a solid and/or liquid is in equilibrium with
its own vapor. The vapor pressure is a function
of the substance and of the temperature.
"Unsaturated Zone (Zone of Aeration)" means the
zone between the land surface and the nearest
saturated zone, in which the interstices are
occupied partially by air.
"United States" means the 50 States, District of
Columbia, the Commonwealth of Puerto Rico, the
Virgin Islands, Guam, American Samoa, and the
Commonwealth of the Northern Mariana Islands.
"Underground Drinking Water Source" (UDWS) means:
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(1) an aquifer supplying drinking water for
human consumption, or
(ii) an aquifer in which the groundwater contains
less than 10/000 mg/1 total dissolved solids;
or
(iii) an aquifer designated as such by the
Administrator or a State.
"Underground Non-Drinking Water Source" means an
underground aquifer which is not a UDWS.
"Volative Waste" means waste with a true vapor
pressure of greater than 78 mm Hw at 25°C.
"Water Table" means the upper surface of the
zone of saturation in groundwaters in which the
hydrostatic pressure is equal to atmospheric
pressure.
It should be noted that certain aspects pertaining to
the secure landfilling of hazardous wastes which come under
the heading of General Facility Standards and apply to all
treatment,storage and disposal facilities, will be addressed
in other gackground documents. These include:
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(1) General Site Selection
(2) Security
(3) Contingency Plan and Emergency Procedures
(4) Training
(5) Manifest System, Recordkeeping and Reporting
(6) Visual Inspections
(7) Closure and Post-Closure
(8) Groundwater and Leachate Monitoring
(9) Financial Requirements
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II. Rationale for Regulation
The case for hazardous waste management legislation has
been well stated in a recent EPA publication (1):
Some of the primary findings of EPA's Report to
Congress on Hazardous Waste Disposal, which was mandated
by Section 212 of the Solid Waste Disposal Act as
amended, are that current hazardous waste management
practices are generally unacceptable, and that public
health and welfare are unnecessarily threatened by the
uncontrolled discharge of such waste materials into the
environment, especially upon the land. It was also
concluded that usage of the land for hazardous waste
disposal is increasing due to the implementation of air
and water pollution controls, and the limitation of
disposal methods such as ocean dumping.
The Clean Air Act (as amended), the Federal Water
Pollution Control Act (as amended), and the Marine
Protection, Research, and Sanctuaries Act (as amended),
are curtailing the discharge of hazardous pollutants
into the Nation's air and water. The basic objective
of the latter is to prohibit the dumping of some
materials, and strictly regulate the dumping of all
materials (except dredge material controlled by Army
Corps of Engineers). Increasing volumes of sludges,
slurries, and concentrated liquids will therefore find
their way to land disposal sites.
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Few economic incentives exist to encourage waste
generators to utilize environmentally acceptable disposal
methods. Current methods frequently result in con-
tamination of ground waters from leachates; surface
waters from run-off and leachate; and air from evaporation,
sublimation, or dust dispersal.
EPA files contain many examples of environmental damage
from improper land disposal of hazardous waste.
An EPA ground water monitoring project entitled, "The
Prevalence of Subsurface Migration of Hazardous Chemical
Substances At Selected Industrial Waste Disposal Sites," has
investigated the likelihood of groundwater contamination at
hazardous waste land disposal sites. In this study, ground-
waters at 50 land disposal sites located East of the
Mississippi River and which received large quantities of
industrial waste were sampled and analyzed. The sites
selected are representative of typical industrial land
disposal facilities, and are situated in a wide variety of
geologic environments. No previous contamination of ground-
water with hazardous substances had been reported before
sampling, and waste disposal had been in progress for a
minimum of 3 years. At 43 of the 50 sites migration of one
or more hazardous constituents was confirmed according to
project criteria. Twelve hazardous inorganic constituents
were detected above background concentrations. The five
2Z
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most frequently occurring were selenium, barium, cyanide,
copper, and nickel in that order. Organic substances that
were identified included PCB's, chlorinated phenols, benzene
and derivitives, and organic solvents.
At 26 sites, hazardous inorganic constituents in the
water from one or more of the monitoring wells exceeded the
EPA drinking water limits. Of the hazardous substances,
selenium most frequently exceed drinking water limits,
followed by arsenic, chromium, and lead.
Conclusions drawn from the study are:
1. Groundwater contamination at industrial land
disposal sites is a common occurrence.
2. Hazardous substances from industrial waste land
disposal sites are capable of migrating into
and with groundwater.
3. Few hydrogeologic environments are suitable for
land disposal of hazardous waste without some
risk of groundwater contamination.
4. Continued development of programs for monitoring
industrial waste land disposal sites is necessary
to protect groundwater quality.
5. Most old industrial waste disposal sites, both
active and abandoned, are located in geologic
environments where groundwater is particularly
susceptible to contamination.
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6. Many waste disposal sites are located where the
underlying aquifer system can act as a pipeline
for discharge of hazardous substances to a
surface-water body.
Numerous incidents of damage which resulted from
improper land disposal are contained within EPA files.
Grasshopper bait, a pesticide containing arsenic
trioxide, was being buried on a farm near Perham, Minnesota
between 1934 and 1936. In 1972, 36 years later, a well was
drilled near the burial site to supply water for employees
in a newly built office facility. Eleven of the thirteen
employees of the facility became ill from arsenic poisoning.
Two required hospitilization and treatment. One lost the
use of his legs for about six months due to severe neuropathy,
Analysis of well water revealed arsenic levels of 21,000 ppb.
(The USPHS drinking water standard is 50 ppb). The area of
disposal was located twenty feet from the well. Estimated
costs for solving the problem range from $2500 to $25,000.
In May 1974, three dead cattle were discovered on a
power company's recently acquired farm property near Byran,
Illinios, and pathological examination established that the
cattle had died of cyanide poisoning. Further investigation
revealed that the approximately 5-acre area, which is part
of a large property set aside for a nuclear power plant, had
been for several years a repository of large quantities of
toxic industrial wastes. The former owner of the property
2.4
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used it to dispose of industrial waste his hauling company
collected. The power company hired a consultant to study
the environmental damage on the property and to recommend
clean-up procedures. The subsequent study documented extensive
harm to wildlife and vegetation. Nearby soils and surface
and groundwaters were heavily contaminated with cyanide and
chromium. It is not yet known when farm crops can safely
be harvested on the affected property again.
Until approximately June 1970, Beech Creek, Waynesboro,
Tennessee, was considered pure enough to be a source of
drinking water. At that time, waste polychlorinated biphe^nyls
(PCB) from a nearby plant began to be deposited in the
Waynesboro city dump site. Dumping continued until April
1972. Apparently the waste, upon being off-loaded at the
dump, was pushed into a spring branch that rose under the
dump and then empties into Beech Creek. Shortly after
depositing of such wastes began, an oily substance appeared
in the Beech Creek waters. Dead fish, crawfish, and waterdogs
were found, and supported wildlife also was being affected
(e.g., two raccons were found dead). Beech Creek had been
used for watering stock, fishing, drinking water, and
recreation for decades. Presently, the creek seems to be
affected for at least 10 miles (16.09 kilometers) from its
source and the pollution is moving steadily downstream to
the Tennessee River. Health officials have advised that the
creek should be fenced off to prevent cattle from drinking
the water. •*
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The City of Aurora, Illinois operated a dumpsite until
1965, at which time it was leased to a disposal company to
operate as a sanitary landfill. From 1961 until 1972,
residential, commercial, and industrial wastes were disposed
of at the site. During the early months of 1966, nearby
residents began complaining of odor problems with their drinking
water. By the summer of 1966, a total of nine wells had been
polluted by leachate; seven of them were totally unfit for any
kind of use. All seven wells substantially exceeded USPHS
standards for chlorides, total solids, and biological
contaminants. Tests by the Illinois Department of Public
Health and Illinois Geological Survey confirmed that the landfill
was the source of the pollution. The owners of the contaminated
wells sued the disposal company and were awarded $54,000
damages in a directed verdict. This was to cover legal expenses
and the costs of hooking up with the city of North Aurora's
waterlines. The cost to the State for its investigation was
estimated to be $52,000.4
The Cedar Hill dump, in King Counjpty, Washington has
been in operation for about ten years. For the last three
years, it has operated as a sanitary landfill accepting
industrial and hospital wastes in addition to municipal refuse
from the Seattle area. Leachate from the landfill, high in
iron and zinc, has been contaminating Mason Creek which passer;
below the site. The creek runs into Issa Creek and through
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the City of Issaquah, about two miles downstream from Cedar
Hill. Contaminants in the leachate have fostered the growth
of a slime mold (sphaerotilus) in the creek which has been
killing salmon eggs and fry at the Issaquah State Fish
Hatchery. The fungus covers the eggs and clogs the gills of
the fry/ depriving them of oxygen. Estimated losses at the
Hatchery since 1973 amount to $280,000. Leachate run-off
and infiltration at the landfill continue and could eventually
affect nearby Sammamish Lake.
A landfill, in Lehigh County, Pennsylvania opened in
1967 on the site of an abandoned quarry, accepting trash and
industrial wastes from Lehigh and Northampton Counties.
Among the wastes dumped at the landfill was a wide variety
of industrial organics. In October, 1970, a supplier of
n
water for about 50 homes in North Whitehall Township, filed
a complaint with the Pennsylvania Department of Environmental
Resources for contamination of their water supplies by
leachate from the landfill. Analysis of water from wells in
a
March 1971 reveled the presence of 20 ppm trichloroethylene,
as well as phenols and ethyl acetate. Although the landfill
company reportedly stopped accepting liquid wastes in 1970,
traces of organic contaminants still persist in the water.
The water, though somewhat degraded, is considered potable
and is used for drinking.
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The city of Rockford, Illinois operated a landfill in
a former sand and gravel pit from 1947 to 1972. The landfill
received residential, commercial, and industrial wastes.
Leaching of chemicals into the groundwater caused nine
wells — four industrial, four residential, and a public
supply well — to be contaminated. The industrial wells
were abandoned in 1966, the residential wells in 1970, and
public supply well in 1972. Contaminants found in levels
over the USPHS standard were: total dissolved solids (800
ppm), iron (1.8 ppm), and manganese (0.71 ppm). The recommended
USPHS drinking water standards for these substances are as
follows: 500 ppm, 0.3 ppra, and 0.05 ppm. The industrial
and residential wells affected were replaced by connecting
to the city water system and a new well was drilled to
replace the abandoned public well. The total costjp of
connecting the industrial and residential sites to city
water, replacing the public water supply well, and placing a
better cover on the landfill was estimated at $127,500.
These expenditures did not include investigative and adminis-
trative costs, and did nothing to clean up the water.*
A landfill in Allegheny County, Pennsylvania, began
waste disposal operations in Monroeville Borough in 1932.
Besides municipal solid waste, the landfill accepted heavy
metal-containing industrial sludges and at one time an
estimated 15,000 gallons/day of waste water from steel mills.
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Contamination of the groundwater and a tributary of Turtle
Creek by an estimated 50,000 gallon/day of leachate initiated
a lengthy court battle in December, 1970, involving the land-
fill, area residents, Monroeville Borough, Allegheny County,
and the State of Pennsylvania. The landfill was ordered
closed in March 1973. Subsequently, it reopened after
installation of a leachate system. Nevertheless, as of
March 1975, area residents continued to complain of untreated
leachate bypassing the treatment plant, odors emanating from
the site, insufficient cover material being used, and other
alleged violations.
A landfill in Egg Harbor Township, New Jersey, has been
the depository of large quantities of organic and inorganic
industrial wastes. In 1973, this landfill was ordered by
the State not to accept any more industrial wastes since
laboratory analysis of samples from nearby observation wells
established the existence of a groundwater pollution
problem involving several chemical contaminants. Lead con-
centrations in the observation wells have been analyzed up
to 18 ppm. (The U.S. Public Health Service mandatory drinking
water standard for lead is 0.05 ppm.) A .municipal water supply
well field, situated within 0.6 miles (1 kilometer) of the
area of contamination, has not been affected; however, it
is being regularly monitored because of the obvious threat.^
A chemical company in Will County, Illinois, disposed
of unidentified solid chemical wastes in a landfill on its
-------
property for a number of years. In February 1974, area
residents complained of a reddish discharge into the Des
Plaines River from a tributary stream which drained off the
chemical company property . Monitoring tests on the runoff
from the site taken at the stream showed (in ppm) : Fe 2600,
Mn 1360, Ni 2.4 and sulfates 2200. BOD was over 10,600 ppm
and COD above 46,670 ppm. The runoff wiped out several acres
of foilage and vegetation downslope from the disposal area.
As a result of regulatory action by the State, the following
corrective actions were taken by the company: A treatment
lagoon was clay-lined, the drainage pattern changed, the area
reseeded, and the leachate collected in tank trucks and
treated on-site.4
Improper disposal of hazardous wastes by and on the
property of Hooker Chemical and Plastics Corporation in
Montague, Michigan, probably began in the 1950 's and continued
until early 1970. Various drummed wastes, including
hexachlorocyclopentadiene (C 5, 6} residues, fly ash, and
brine sludge were deposited in several dump sites on the
company's property. In addition, brine sludge combined with
sediments from an equalization basin was disposed in a 15
acre on-site lagoon. The disposal areas and equilization
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for nearby residents were irreparably contaminated, along with
as much as 1.2 million cubic yards of soil. Furthermore,
White Lake, which discharges directly into Lake Michigan, has
become polluted via inflow of contaminated groundwater.
A
A chemical manufacturing company has
been dumping As-containing wastes since 1953 at the LaBounty
Dump Site along the Cedar River in South Charles City, Iowa.
This chemical fill covers approximately 8.5 acres and contains
an estimated 27,000,000 cubic feet of chemical sludge and
underlying and surrounding soil. In addition to various
o
forms of arsenic, the site also contains phenols, orttfhi-
troalinine, nitrobenzene, etc.
The situation poses a serious threat because the under-
lying fractioned limestone bedrock is where 70 percent of
Iowa residents obtain their drinking and irrigation water.
At one point (date ? ) toxic# chemicals from LaBounty were
found in the drinking water at Waterloo, 50 miles downstream
on the Cedar River.
T"Ht company
flpfltugbury was ordered to close shop and cease all dumping
at LaBounty by the Iowa D.E.Q. in December 1977. The order
also requires:
(1) program of soil borings to locate, then remove
As contamination;
(2) removal must begin by July 1, 1979;
(3) locate new dumpsite and have operative by July 1,
1979.
The estimated cost of removal of these toxic wastes is
about $20 million.
3V
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The preceding damage incidents are just a few of the
over 420 confirmed hazardous waste damage cases contained
in damage assessment files of the EPA. This does not
include numerous unestimated potential damage incidents
across the U.S. which are still unknown or unconfirmed by
EPA at present.
32-
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The preceding damage incidents are just a few of the
over 420 confirmed hazardous waste damage cases contained
in damage assessment files of the EPA. This does not
include numerous unestimated potential damage incidents
across the U.S. which are still unknown or unconfirmed by
EPA at present.
III. Identification and Analysis of Regulatory Options
Option 1 - Performance standards on the design and
operation of a hazardous waste landfill.
Advantages
Regulations are easily enforced. Compliance
could be checked by simple observation of
the landfill facility.
Disadvantages
Innovation is stifled. Improved technology
cannot be implemented without changes in
the regulations.
Comprehensive regulations would be difficult
to devise in the short time EPA has.
Difficult to justify most design and operating
standards without good data base.
Compliance with design and operating standards
will not ensure environmental protection.
Option 2 - Hazardous waste landfills shall use the best
available and/or practical technology to
ensure the protection of the public health
and environment.
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Option 2 is modeled from EPA effluent
discharge requirements of the Federal
Water Pollution Control Act. These require-
ments are based on the quality of effluent
discharges from existing facilities in
the United States. Effluent discharge re-
quirements vary with industry type. Estab-
lishment of these discharge requirements
is initiated by making an inventory of existing
industries with effluent discharges and
determining the quality of each facility's
discharge. An exemplary group of facilities
is then selected for each industry type.
This exemplary group is composed of those
facilities having the highest quality dis-
charge. Generally, the average discharge
quality of each examplary group is adopted
by the EPA as the effluent discharge standard
for that industry type. These standards are
considered to represent the "best practicable
control technology." In some cases, a quality
lower or higher than the examplary group
average has been adopted as the standard.
New facilities are usually required to practice
the "best available technology." The "best
available technology" generally represents
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the highest existing discharge quality for
a given industry type. A similar type or
inventory could be conducted for existing
hazardous waste chemical landfills. The
criteria for selecting an exemplary group
of landfills might be the amount of leakage
detected from the bottom of the facility.
The "best practicable liner technology" and
the "best available liner technology" could
then be established based on leakage found
at "examplary" landfills. The standard could
then be the use of specific liner types based
on their performance at existing facilities,
i.e., their ability to not leak. The standard
could perhaps vary for different hazardous
waste types.
Advantage^
Once the "best available and/or practical"
technology is defined enforcement is relatively
simple. Compliance can be checked by obser-
vation.
If the "best available and/or practical"
technology is adequately defined, it is assured
that a facility is doing everything possible
to protect the public health and environment.
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Disadvantages
Defining the "best available and/or practical"
technology will require a data base EPA does
not yet have and will not have the time to
acquire.
Even if the "best available and/or practical
technology is used at a landfill, the
protection of the public health and environment
is not ensured.
Option 3 - No performance standards on the design and
operating of a hazardous waste landfill.
In this case, hazardous waste landfills will
be required to comply with emission standards
by any methods they wish to devise. Guide-
lines concerned with operating and design
practices may be supplied to permitting agencies
to be used in determining the suitability of a
landfill design for the disposal of hazardous
wastes.
Advantages
There is flexibility in the manner in which the
landfill operates. New techniques and design
are not discouraged.
Guidelines could be readily amended to adapt v.o
changing technology.
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Protection of the environment is ensured if
the emission standards are met.
Disadvantages
Guidelines do not have the force of law. They
are used at the discretion of permitting
officials and may be applied unevenly.
Option 4 - Performance standards on the design and operation
of a hazardous waste landfill with provision for
deviating from the prescribed standards.
Advantages
Eliminates inflexibility associated with
specific performance type standards, encourages
innovation.
Easily enforceable and less discretionary.
Specific and clearly defines duties which are
not subject to broad interpretations.
Standards carry the force of law.
Disadvantages
Comprehensive standards difficult to devise
in a short period of time.
Difficult to justify most design and operating
standards without good data base.
State Regulations
California
California has developed regulations concerning hazardous
waste land disposal. These regulations specify that hazardous
wastes may only be disposed of in Class I landfills. Standards
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for Class I landfills are listed in Section 2510 of the
regulations. The design and operation standards are limited
to specifying a liner impermeability and requiring drainage
control structures. Environmentally safe operation is en-
sured by permitting only secure facilities as Class I sites.
The strategy followed in California is most similar to Option.
3.
Minnesota
The Minnesota Pollution Control Agency has recently
compiled a set of proposed regulations concerning the manage-
ment of hazardous wastes. These regulations do not include
any design and operation standards and so, are similar to
Option 3. There is a set of specifications requiring certain
information be included with a permit application. The prime
mechanism for ensuring environmental protection lies in
permitting only those facilities which are secure.
New York
The New York State Department of Enviornmental Conservation
has developed draft regulations dealing with solid waste manage-
ment facilities. The New York regulations specify many aspects
of the design and operation of hazardous waste landfills anc
so follow the strategy outlined in Option 1. Though variances
can be granted these standards rigidly specify many of the
operating features of a landfill. Regulation 360.8(b)(l)
(VII), which concerns the cover and compaction of solid wastes,
is an example of this type of standard.
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An important feature of the New York regulations is
regulation 360.8(b)(2) which specifies that all standards
which apply to sanitary landfills must also apply to hazard-
ous waste landfills. One problem may be that though the wastes
disposed of in a hazardous waste landfill by definition have
a greater potential to cause environmental damage, there may
be operational practices desirable in a sanitary landfill
but not necessary in a hazardous waste landfill. The use of
a daily cover may be one example.
Pennsylvania
The Pennsylvania Department of Environmental Resources
has recently drafted a set of proposed regulations for the
management of solid waste.
These regulations are in large part design and operation
oriented as is Option 1. Phase II of Section 75.38 specifies
design and operating practices necessary to obtain a permit.
In addition, paragraph (1) of Section 75.38, Phase II requires
that hazardous waste landfills comply with the standards set
for sanitary landfills, with certain exceptions. The design
and operation regulations discuss many of the practices
associated with secure landfilling such as the use of daily
covers, final covers and liners.
Texas
Section 104 of the Industrial Solid Waste Management
Regulation Order No. 75-1125-1 addresses the problem of
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hazardous waste disposal. The four regulations of this
section are all performance standards and design and operate ng
practices are not specified. Environmental protection is
Su«ed
cnitornriit by permitting only secure facilities and my monitor: ng
to check compliance with performance standards. The Texas
strategy is analogous to Option 3.
Summary and Discussion
The application of the four options is disucssed in
terms of their suitability as a Federal regulatory framework
to control the landfilling of hazardous waste. The advantage
and disadvantages of each approach are discussed as are the
rationale for choosing or not choosing a particular approach.
«<*
Option 2 was determinedAto be a viable alternative for
establishing landfill design and operating standards. The
Agency recognizes that the state-of-the-art of predicting
landfill discharges is poor, and thus the prudent course
is to prescribe maximum containment while allowing for
deviation with proof of non-degradation. The strategy used
for regulating landfills in these proposed rules is that
they should be designed, constructed and operated so as to
achieve the maximum containment of wastes. The rationale
for this strategy is two fold. Maximizing containment
minimizes the escape of waste constituents and thus provide;
protection of human health and the environment. Although
EPA recognizes that some escape of wastes may not present a
hazard to the environment, the Agency does not know how to
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predict what designs will allow what release rates, nor
does the Agency know what release rates are acceptable.
Accordingly, landfills are required to be designed, con-
structed and operated such that discharges do not occur
unless the facility owner/operator can demonstrate that
the groundwater human health and environmental standard
(EPA drinking water standards) is not exceeded via some
alternative design.
Therefore, developing standards along or based on
discharge requirements was not further considered.
Evaluation of landfilling practices on a case-by-case
basis (Approach 3) is the ideal regulatory approach in
terms of insuring that the permit is tailored to the site
and takes into account site and waste specific parameters.
This approach advantageously requires that the permitting
official carefully scrutinize and assess each permit
application, on its own merits, in an effort to determine
the appropriate permit requirements.
A major drawback of Approach 3 is the excessive economic,
manpower, and time requirements needed for implementation.
Another problem is that if EPA does not promulgate specific
standards then there will be no means by which to assess or
compare the equivalency of State hazardous waste programs
to the Federal program. It may be difficult for a State
-------
to even develop a comparable hazardous waste program without
Federal standards to use as guidance.
Guidelines for controlling the landfilling of non-
hazardous waste are used by some States as guidance to aid
in evaluating permit applications for the landfilling of
hazardous waste. Nonhazardous landfilling guidelines are
often grossly inappropriate and inadequate for this purpose.
Three of the five States evaluated here use guidelines
developed specifically for controlling the landfilling of
hazardous waste. The guidelines specify minimum requirements,
of either a process or performance type, and are incorporated
into the permit. These guidelines, although lacking the
force of law, are included in all permits except when certain
site or waste-specific parameters dictate that a modification
to the guideline(s) be made. Depending on the parameter in
question, the guideline may be made more stringent, less
stringent, or deleted. If made less stringent or deleted,
the owner or operator of the facility may be required to
demonstrate that the objective of the original guideline will
still be achieved.
Professional judgement must frequently be exercised
when modifying a guideline. This requires a considerable
amount of expertise on the part of the permitting official.
Finding and hiring individuals of the appropriate caliber may
be a major limiting factor (of this approach) at both Federal
and State levels.
42.
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The apparent popularity of Approach 3 with the States
surveyed does not necessarily mean it was selected because
it was the best approach. It is possible that selection
of Approach 3 may have been based on it being the only
available choice, rather than the best choice.
Approach 3, in spite of its popularity, was not selected
by EPA as a framework for regulating landfilling. Excessive
resource requirements and the lack of a means for assessing
and comparing State programs to the Federal program make
this approach impractical on a national scale.
Approach 1 involves the use of specific performance
standards applicable to all landfills. Such standards specify
the minimum requirements a facility must meet in order to
obtain a permit. Performance standards include material
restrictions; and location, design and operating requirements.
Standards of this type essentially tell a facility owner/
operator: (1) what materials (hazardous wastes) are or are
not acceptable for certain treatment, storage, and disposal
practices, and (2) where to locate and how to design and
operate a site. Performance standards find favor with
facility owners/operators that are seeking regulatory
guidance on material restrictions and site location, design
and operation.
However, strict standards specify a desired result
without specifying how to achieve it. Standards of this
type are favored by facility owners/operators that have
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the necessary treatment, storage, and disposal expertise
and want only to know what end result is desired by the
regulatory agency.
As a result of its "cookbook" nature, Approach 1 would
be easier to implement on a national scale -and would utilize
less resources than Approach 3. This approach also provides
a basis for assessing the equivalency of State programs.
A major disadvantage of Approach 1 is its inflexibility.
Even when an alternative method can be demonstrated to meet
or exceed the objective of a set standard, there are no
provisions for deviating from that standard. Because of
this inflexibility, Approach 1 discourages the development
of new and innovative technologies by industry.
Only one of the States surveyed used this approach to
regulate the landfilling of hazardous waste. Its unpopu-
larity is thought to result primarily from its inflexibility.
The solution to this problem is to incorporate flexibility
into an otherwise rigid standard; especially a standard
that might not be suitable for all existing or future
technologies. Because Approach 1, as presented, has no
provision for flexibility, it was rejected for use as a
regulatory framework. In lieu, a hybrid approach, Approach 4,
was developed, and selected for use as a regulatory framework.
In developing Approach 4, emphasis was placed on maxi-
mizing the beneficial attributes of Approaches 1 and 3, and
minimizing their inherent disadvantages.
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In an effort to eliminate the inherent inflexibility
associated with developing design and operating standards,
many of the standards, where appropriate, are accompanied
by notes. The notes which are performance oriented, provide
deviation from the standard provided the facility owner or
operator can demonstrate to the EPA Regional Administrator,
prior to receiving a permit, that the proposed alternative
method(s) meets the objective(s) of the standard. The
Regional Administrator, therefore, has the discretion to
permit the use of alternate but equivalent technologies on
a case-by-case basis. This approach affords maximum flexi-
bility, where possible, by allowing industry to either follow
the standard or demonstrate the efficacy of an equivalent
method.
Not all of the standards are accompsnied by notes,
hence, some lack flexibility. Several of the proposed
standards do not have notes because the Agency made a
decision, based on the best data available, that it was
not possible to deviate from the standard and still meet
the human health and environmental objective (of the
standard). Some of the landfilling standards are not
accompanied by notes because they specify a desired result,
e.g., preventing direct contact between the landfill and
navigable water.
Implementation of Approach 4 on a national scale will
impact upon economic and manpower resources to a much lesser
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extent than Approach 3. This is because Approach 4 is
"cookbook" in nature, and when deivation from a standard
is proposed, the burden of proof is upon the facility owner
or operator. This attribute will keep judgmental decisions
to minimum, thereby lessening the need for a workforce of
the caliber required in Approach 3.
Approach 4 was selected for use as a framework to
regulate the landfilling of hazardous waste because it:
(1) lends flexibility in the form of notes *o what would
otherwise be rigid standards, (2) provides a means by which
permit applications can be more easily evaluated, and
(3) provides an objective basis for comparing the Federal
program to State programs.
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IV. Identification of Chosen Standards and Associated Rationale
The purpose of the hazardous* landfill standards are to reduce
the potential for damage to human health and the environment which
can arise from improper disposal of hazardous waste.
The regulatory format which the Agency has chosen to implement
in the regulation is one of specific design and operating standards,
combined with notes which provide a basis for deviation from the
standard. It is one which the Agency feels best protects the
human health and the environment. It combines most all the advan-
tage of the options discussed in Section III by sepecif ically
delinenting what is required of owners and operators regarding
landfilling of hazardous waste, while at the same time, providing
some flexibility through the mechanism of the note. However,
not all of the standards are accompanied by notes. For some
standards the Agency believes that it is not possible for the
facility owner/operator to deviate from the standard and still
protect human health and the environment.
tU>lH •&£.<%. ^S5oa*foJ TEA-Vlw^e;
The following regulations* have been proposed under Section
250.45-2, standards for hazardous waste landfills:
(a) Site Selection
(1)A landfill shall be located, designed constructed, and
operated to prevent direct contact between the landfill and
navigable water.
Navigable water should not be allowed to interact
with hazardous waste deposited in a landfill, since it
could allow the waste to escape to the environment.
Additionally water, contacting the landfill could erode
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or otherwise deteriorate the structure. A regulation
prohibiting direct contact between a landfill and
navigable water would help prevent such problems. Thfe
prescedent set by the State of New Jersey and most
other States, which have or are preparing hazardous
waste disposal regulations, establishes the fact that
such procedures are recognized good practice. The
potential consequences of not having such a regulation
(listed below in detail) provide the rationale for this
regulation.
(1) Precedent set by the State of New Jersey.
A portion of New Jersey's hydrologic criteria
for site location includes a recommendation
to prohibit the establishment of facilities
in places where disposal of wastes could
bring contact with surface water or navigable
water.
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(2) Consequences of not having such a regulation.
A. Direct contact would hasten the movement
of hazardous wastes into surface and/or
groundwater and away from the site.
B. Navigable water contacting the landfill
has the potential to:
i) Infiltrate the landfill, form a
leachate, create a hydraulic head
which can eventually breach the
landfill liner.
ii) Carry dissolved and undissolved
hazardous constituents away from the
site.
iii) Damage the landfill structure.
C. Direct contact will preclude the existence
of an unsaturated zone under and around
the landfill. This automatically
eliminates any natural attenuation or
buffering capacity that could exist in
such an unsaturated zone. Additionally,
the time to detect and rectify a problem
before environmental damage can occur is
reduced if not eliminated.
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(2) A landfill shall be located designed, and construe ed
so that the the bottom of its liner system or natural n-
place soil barrier is at least 1.5 meters (5 feet)
above the historical high water table.
NOTE; The bottom of any liner system or natural in-
place soil barrier may be located less than 1.5 meters
(5 feet) above the historical high water table,
provided the facility ower/operator can demonstrate,
to the Regional Adminstrator, at the time a permit*
isxSubpart E, that no direct contact will occur between
the landfill and the water tableland a leachate
monitoring system as required by Section 250.43-8
can be adequately maintained in the lesser space.
The objective of this regulation is to ensure
that a sufficient distance exists between the bottom
of the landfill and historical high water table that
will allow for the emplacement of leachate monitoring
equipment, if necessary, and to act as a buffer and
provide reaction time for responding to an unaccept-
able discharge should one be detected.
The rationale for such a regulation is very similar
to rationale (2) (A) and (C) of regulation (a) (1) of
this section. Essentially the above regulation is
attempting to ensure that a buffer zone or zone of
natural attenuation exists between the landfill and
groundwater. The presence of such a zone may make the
difference between what would be a minor, reversible
pollution problem 9a£ a major irreversible one. The
separation between the bottom of the landfill and aquiter
prevent the aquifer from becoming contaminated
-50
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immediately in the event of a leak. Thus, if a
monitoring system immediately beneath a landfill detects
a leak some time will be available for implementing
contingency plans before the aquifer becomes contaminated.
The 1.5m buffer zone also provides for unpredictable
fluctuations of the historical high water table,
reducing the possibility of direct contact between ground-
water and the bottom of the landfill. The exact distance
needed is site specific and should be established on
a case by case basis. Therefore the note, which is part
of this regulation, prescribes the criteria for deviating
from the standard. In allowing the owner/operator to
demonstrate that no contact will occur between the
landfill and the UDWS and maintaining adequate leachate
detection capabilities between the landfill liner and
the UDWS, the Agency has allowed for achievement of
equivalent waste containment while encouraging techno-
logical innovation and advancement of current state-of-
the-art treatement, storage and disposal practices.
A review of several state's regulations reveals a
varialicre, between states, concerning the distance between
a landfill and groundwater. New York requires 5 feet
(1.5m) to groundwater and a liner, of unspecified
thickness, with a permeability of 1 x 10~7 cm/sec.
Illinois requires 10 feet (3m) of 1 x 10"8 cm/sec
(permeability) clay between a landfill and groundwater.
Other states, such as Oklahoma require different depths
-------
to groundwater depending upon whether or not there is
leachate collection and the type of leachate collection
system employed. The minimum depth to groundwater for
a landfill with a compound leachate collection system
(in Oklahoma) is less than 3 meters (10 feet) of "relatively
impermeable soil". Guidelines developed by Texas
state that the bottom of the landfill area should be
well above the historical high groundwater table,
suggesting a maximum of 50 feet but allowing this
number to be reduced to 1/10 of that value (5 feet)
if the site is located in massive relatively impermeable
clay formations. Other States which specify a minimum
depth to the water table are Minnesota and Iowa which specify
5 feet, and Washington and Pennsylvania both specifying 4
feet to the groundwater table.
Although 1.5 meters is conservative when compared with
other States' requirements, when it is used in con-
junction with other requirements in this section, it
provides adequate protection. Essentially,
regulation (b) (6) (iv) requiring that bulk liquids
semi-solid and sludge not be landfilled; regulation
(b) (11) requiring a 10 ft. (3m) thick liner of
1 x 10~7 cm/sec permeability (in addition to the 1.5m
above groundwater requirement) and regulation (b) (13)
requiring leachate collection, provide considerable
52.
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protection of groundwater by themselves. The additional
requirement of a 1.5m buffer zone is more important
in terms of providing a margin of safety rather than
being the main barrier to pollution of the groundwater
by leachate.
(3) A landfill shall be at least 150 meters (500 feet)
from any functioning public or private water supply,
or livestock water supply.
NOTE: A landfill may be less than 150 meters (500 feet)
from any functioning public or private water supply or
livestock water supply, provided the owner/operator can
demonstrate to the Regional Administrator, at the time
a permit is issued pursuant to Subpart E, that:
(i) No direct contact will occur between the landfill
and any functioning public or private water supply
livestock water supply;
(ii) No mixing of the landfill leachate (including)
groundwater or surface water contaminated with
leachate) with the public or private water supply
or livestock water supply will occur; and
(iii) A groundwater monitoring system as required by
Section 250.43-8 has been installed and is being
adeqately maintained.
A review of several States' regulations reveals
a dichotomy in the approach used to develop buffer zone
regulations. Most states prefer regulating on a site-
53
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specific basis, the premise being that the distance
needed between a landfill and water supply well is
dependent upon site specific variables, such as soil
permeability, groundwater flow and direction, groundwater
quality and use, etc.
At least two states, Texas (State Department of
Health Resources), and Wisconsin (Department of Natural
Resources), prefer to specify a distance, 500 feet
(150m) and 1250 feet (375m) respectively. The States'
rationale behind specifying a number is that it
provides a tangible point of reference and facilitates
enforcement. Being cognizant that a specified distance
may not be applicable in some situations, both States
maintain a flexible attitude and allow for concessions
to be made. For example, Wisconsin requires that special
construction techniques be used for constructing wells
within 1250 feet (375m) of a landfill. Texas allows
wells within 500 feet (150m) of a landfill if certain
site parameters can provide the equivalent of 500 feet
protection.
The regulatory approach taken by EPA, inclusion
of a note allowing deviation from the standard, incor-
porates the advantages of having a tangible reference
point with the versatility of allowing for concessions
to be made under special circumstances.
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Although the conservative value of 150m was chosen,
when it is used in conjunction with other requirements
in this section, it provides adequate time for detecting
and responding to a problem when one is detected.
Essentially, a distance of 150m is relied upon in
terms of providing a margin of safety and is not
expected to serve as the main barrier to pollution of
a water supply well.
(b) Construction and Operation
(1) A landfill shall be located, designed, con-
structed, and operated to minimize erosion,
landslides, and slumping.
Erosion, landslides and slumping are
three geophysical forces that can potentially
disrupt the environmental integrity of a
landfill. The main objective of the above
regulation is to ensure that such a disruption
does not occur.
Being cognizant of the fact that few
potential landfill sites will be free of such
forces, the regulation was written to allow
flexibility, i.e., if an ideal site could not
be found, then engineering against such
geophysical forces would be acceptable. It
is germane to point out that locating a
BS
-------
landfill in an area known to be subject to
extensive erosion, landslides, and/or slumping
will require that site improvements be made
and/or special operational techniques be employed.
The potential consequences of not
locating or designing against erosion,
landslides and slumping are listed below:
Erosion
Erosion can deteriorate the structure of a
landfill and increase the likelihood of water
entering the site. Subsequent infiltration
and development of hydraulic head can hasten
the vertical migration of hazardous con-
stituents from the site. Additionally, once
surface water has entered the landfill,
erosion can effect removal of wUStftftfsoil
cover material (which may be contaminated)
and deposited wastes via suspension or
solution. The ultimate result is polluted
surface water runoff which requires collection
and treatment.
Landslides
Landslides, along with floods and erosion art
common changes due to weather, the nature of
soils, and gravity. Each, however, can
-------
produce a change in a site, thereby directly
affecting the rate at which contaminants
reach the environment.
A landslide near or within a landfill
can disturb its structural integrity. All
environmental media could be adversely
affected in the event of a landslide dis-
rupting the containment system of a secure
landfill.
Areas subject to or having had landslides
are undesirable locations for siting a
landfill because the loose unconsolidated
soil that characterizes such an area would
lack the necessary structural integrity
needed to safely support a landfill.
Slumping
The slumping or subsidence of land beneath a
landfill can:
A. breach the landfills containment system;
B. bring the bottom of the landfill and
groundwater into closer proximity if not
in direct contact; and
C. cause depressions in the surface of the
landfill in which surface water can
accumulate.
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C21 A landfill shall be located, designed,
constructed and operated. So that its
liner system or natural in-place soil barrier
is compatible with the wastes to be land-
filled.
Among the first considerations in
selcting a site for disposal of hazardous
wastes, should be the compatibility of the
structural components of the site with the
wastes to be deposited. The possible re-
actions between the soil liner and a waste
can detrimentally affect the ability of a
disposal site to isolate a waste and prevent
its escape to the environment.
In addition to possible soil reactions,
reaction of the waste with the filled material
can result in serious consequences. In
particular, disposal in landfill areas can
result in decomposition of the filled material,
with generation of toxic gases and possible
ingnition of flammable gases produced in the
landfill. A careful evaluation of disposal
area compatibilities is essential to ensure
adequate protection of the human health and
the environment.
.59
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Natural in-place soil, barriers (liners)
consists of clay and fine grained soils.
However, some natural liners are not com-
patible with some hazardous wastes. For
example, some natural impermeable soils may
fail when exposed to strong acids. Also,
artificial liners and synthetic membranes may
fail if not properly installed or constructed,
or when exposed to some hydrocarbon solvents.
Table __1 summarizes some of the advantages
and disadvantages of several liner types.
It is evident that the compatibility of
the waste with the liner should be the first
consideration in selecting a site for disposal.
Any structural damage to the liner due to
incompatible reactions between the waste and
liner of the cell can result in escape of the
hazardous constituents to the environment,
which could adversely affect the human
health and wildlife as well as interact
with other incompatible substances in the
vicinity. The leakage or rupture of con-
tainerized hazardous wastes can also result
in structural damage through interaction of
the escaped material with the liner or with
other escaping wastes. Another potential
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TABLE 1
AND) DISADVANTAGES .OF. SEVERAL
o
--* _ .a-fTjJtJ
Clayey Soil
Bontonitc Clay
Low-cost synthetic membranes
High-cost synthetic membranes
Paved acpHo.lt with a tar cove:.:
Paved asphalt with a synthetic
membrane
1.2 m (4 ft) layer of common
clay
Clay barrier with synthetic
Advantageo
-coaiid'j clamant..: piCvitlo
ic-viucvtG gfound-water protection
Very low permeability provides
ground-water protection
Most raerr-branes have good tensile
strength,- low temperature flexi-
bility and resistance to a num-
ber of chemical wastes, highly
impermeability
Extra thickness provides ex-
cel", ::'it resistance* to a p'wher
of chemical wastes , highly
impermeability
Provides.firm structural support'
'Provider; structural integrity
and resistance to chemical
attack
Low permeability specifications
provide ground-water protection
Sti'uctural ir.to'jrity and self-
sealing properties of clay pro-
vide a very high decree of
ground-water protection
Not available in all geographic
regions. Exposure to certain
acids and chemicals nay causa
failure
Failure may occur when exposed
to acids and certain chemicals
Not recommended for retention.
of hydrocarbons and solvents.
Data on long-term integrity is
lacking
Not recommended for retention
of hydrocarbon and solvents.
Data or, long-term integrity is
lacking. High-cost may cauca
use to be economically infeasi-
ble
Vulnerable tc attack by certain
hydrocarbon solvents
Vulnerable to attack by certain
hydrocarbon solvents. Use ai
cnrf.Ain synthetic membranes could
clcvatu cost
Exposure to certain acids nay
c/..isc! failure:. Not available in
all geographic areas
Expose to certain acids over a
lei. .'.-teiia period may c:;use r;,~l:-<:c
Clay is not available in all goo-
graphic' regions. Use or certain
synthetic u'.erobrane coulci clovCita
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consequence of such interaction is the
formation or release of other hazardous
substances to the air and water media.
Stone, et alf in their report entitled
"Evaluation of Hazardous Waste Emplacement in
Mined Openings", discussed the interaction of
several rock types of different mineral
constituents with aqueous solutions of
varying pH. It was pointed out that in a
given pH range some rocks release complexing
agents which hold toxic metals in solution,
while other exhibit thixotropic properties,
and others dissolve or react and undergo
unfavorable structural alterations, perhaps
allowing the release of hazardous wastes to
the environment.
These considerations are representative
of the kinds of interaction which are possible
between a waste and a landfill liner. However,
there are many other parameters regarding
liner-waste incompatibility besides pH which
need to be considered in the evaluation of
any disposal area for hazardous waste. Mere
hindrance of hydraulic continuity is not a
sufficient basis for determining the geological
acceptability of a disposal site because of
the many possible reactions of waste and the
liner.
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It is therefore imperative that the
hazardous waste to be disposed is compatible
with the disposal area and that such a de-
termination be made before a waste is dispose
so that incidents involving fires, explosions.
formation of toxic fumes, and release of
contaminants to the environment can be avoided.
(3) The exact location of each l^ardous waste
and the dimensions of each cell with respect
to permanently surveyed bench marks shall be
recorded. The contents of each cell shall
also be recorded. These records shall be
handled as specified in 250.43-5(b).
The exact location and contents of a
particular landfill, with respect to surveyed
bench marks, would provide beneficial and
easily obtainable information. Surveyed
bench marks will be required for laying out
e»p€**i6*4
the design of the landfill, prior to 9*&b£ag.
With the dimensions and bench marks determined
for a particular landfill, a simple grid
system could be utilized to record exact
locations and contents of wastes.
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Permanent records containing the exact
location and the contents of each landfill
will provide a means for tracking down sources
of contamination in case of any damage incident
resulting from the landfill operation.
By knowing the exact location, quality, and
quantity of a hazardous waste responsible
for groundwater, surface water, or air con-
tamination, the potential for further damage
and methods of correction may be developed.
Besides facilitating remedies for damage
incidents, recording the exact location and
contents for a landfill would also aid in
resource recovery efforts for a particular
hazardous waste should it become economically
feasible. Disposal in a landfill may prove
to be only storage with time, should the
particular waste become desirable to be re-
covered. This factor supports part of the
basic philosophy of the RCEA legislation,
that being resource recovery through treatment
or re-use of wastes.
Permanent records for location and
contents of landfills would also ensure that
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incompatible wastes have no chance of coming
in contact with one another. They would
protect filled and covered cells from being
structurally disturbed from subsequent
inadvertent landfilling in the immediate
area.
(4) Wastes, containerized or non-containerized,
that are incompatible shall be
disposed of in separate landfill cells.
The wastes accepted at hazardous waste
disposal facilities are usually hazardous by
themselves. However, if a waste were to come
in contact with another waste which is
incompatible with it, the consequences often
create a more acutely hazardous situation
than that posed by the reactants themselves.
Furthermore, wastes can contact other incom-
patible materials during handling at a facility-
resulting in the same consequences. The lack
of accurate information about the wastes, and
the often indiscriminate handling of the
wastes contribute to the high risk of contact
of potentially incompatible substances at
hazardous waste landfills.
The chemical reactions which result from
such contact can cause secondary consequences
such as injury, intoxication,
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or death of workers, members of the public,
wildlife, and domestic animals. They can
also cause property and equipment damage,
and contamination of air, water and land.
Persons involved in the handling and
disposal of hazardous wastes should not create
a situation whereby potentially incompatible
wastes can come in contact with one another
and result in: (1) heat generation, (2)
pressure generation, (3) fire, (4) explosion
or violent reaction, (5) formation of substances
which are shock sensitive, friction sensitive,
or otherwise have the potential of reacting
violently, (6) dispersal of toxic dusts and
mists due to an explosion or violent reaction,
(7) formation of toxic fumes, gases, or other
toxic chemicals, (8) volatilization of
flammable or toxic chemicals due to heat
generation, and (9) solubilization of toxic
substances. These incompatible reactions are
those that are considered most important to
be controlled through the mandatory separation
of incompatible wastes
inorder to protect human health and the
environment from their occurrences.
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Many incidents have already occurred,
some of which are documented in Appendix I,
In each of the cases listed, incidents
occurred during normal handling operations
and were the results of lack of accurate
information about the waste (Case History
No. 5)jindiscriminate disposal practices
(Case Histories No. 1,3,4,6,7), and in-
discriminate mixing during other handling
operations (Case Histories No. 2,5). These
incidents have shown that the above mentioned
reactions are those that are most significant
in the consideration of potentially incompatible
hazardous waste and their separation.
Many documented cases provide the
supporting rationale for the re-
quirement for preventing contact of incom-
patible wastes and the contact of wastes
with other incompatible materials within
the landfill. The appropriate control method
may prove to be both site and waste specific
A variety of waste-control approaches
for hazardous waste disposal have been adopted
by the States. The California Department of
Health restricts disposal of incompatible
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wastes in order to insure that they will
not come into contact with one another
to cause fire or explosion, to generate
toxic fumes, or to create substances which
are an even greater hazard. California's
guidelines for handling of hazardous waste
list incompatible wastes according to the
potential consequences of their intermingling
(See Table 2 ). Disposal standards require
separation of these materials at storage and
disposal sites. The Texas Water Quality
Board has modeled its waste-classification
regulation upon the California listing.
Maryland regulations identify designated
hazardous substances in three classes based
upon the gravity of risk to human health
and the environment. Class I substances
pose "a grave risk," Class II substances
present a "major risk," while Class III
substances are those that will pose a
"substantial threat" under "certain conditions".
The basis for classification is drawn
principally from the requirement of the Water
Pollution Control Act, the Safe Drinking
Water Act, the Toxic Substances Control Act,
and RCRA.
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Table 2
List, of Potenti;:!ly Incompatible Wastes
The nixing of a Group A waste uith a Croup B waste c^v have the
consequence as noted.
Croup 1-A
Acetylene sludge
Alkaline caustic liquids
Alkaline cleaner
Alkaline corrosive liquids
Alkaline corrosive "battery fluid
Caustic wastewater
Lice sludge and other corrosive
alkalies
Line wastewater
Lice and water
Spent caustic
Group 1-B
Acid sludge
Acid and water
Battery acid
Chemical cleaners
Electrolyte, acid
Etching acid liquid or solvent
Liquid cleaning compounds
Pickling liquor and other corrosi
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>lco>ol3 ^n^ con cent "rated waste Irx Groups
«3:c
Calcium
Li c h i. urn
Kecal hydrides
Sodium.
S02CI2, SOC12>
water-reactive wastes
FoteuStal consequences : Fire, expil , lor. , or heat generation; generation of
flacnable or toxic gases.
Croup 5-A £rJL^2.JlT^l
Alcohols Concentrated Group I-A or 1-B vas-Ce:
Aldehydes Group 3-A wastes-
Kalcta«.ated hydrocarbons
Eitrated hydrocarbons and other
reactive organic compounds
acd solvents
Basatusated hydrocarbons
j^coTLsequer.ces: Fire, explosion or violent reaction.
Crou? S-A Group 6-3
Spent tyar.xde and sulfide Group 1-B wastes-
solsticns
lotent!zd consec-jences: Ceneratioa of toxic hydrogen cyanide or
sulfids gas.
Croup 7-A
Chlorates ar.d other srronS oxidizers Acetic acid aad ocher organic
Chioriia Concer-.tr:!tccl Etlneral acids
Croup 2-E -vai-ter-.
Croup 3-A vastcs
5~A wa;;Ce5 an<1 °thcr fI--
and co^-bus-able wastes.
: F!re. explosion, or violent: r^.ctfon.
w, regulations and "guidelines" for handling of hazardous
waste", California Department of Health, February 1975.
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(5) Each container of liquid hazardous waste
shall be surrounded by an amount of sorbent
inert material capable of absorbing all of
the liquid contents of the container.
The principal rationale behind this
regulation is in line with a basic philosophy
of landfilling hazardous waste, that philosophy
being to operate a landfill so that no hydraulic
head (hydrostatic pressure) is produced. By
keeping free liquids out of a landfill, the
potential for leachate production is reduced
and thus, environmental damage resulting from
that leachate is minimized. According to
Darcy's Law, which pertains to the movement
of water through a permeable medium, unless
there is some hydraulic head produced there
can be no flow out of the landfill. This is
the desire containment condition favored in a
secure hazardous waste landfill. When little
or no leachate is produced, no hydraulic head
develops, and because of Darcy's Law, the
containment condition is realized.
Also, this regulation indirectly en-
courages the practice of pretreatment tech-
niques prior to landfilling and the development
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of other acceptable methods of disposal
of liquid wastes besides landfilling in
containers. With Agency policy describing
landfilling as the least environmentally
acceptable method of liquid waste disposal,
this regulation supports this philosophy by
requiring the use of sorbent material around
buried containers, thus increasing the cost
of filling liquid wastes.
The sorbent materials serve to contain
the waste liquid should its container be
ruptured after burial. It must be realized
that a container once it is buried in a
landfill will not contain that waste forever.
All buried containers will rupture or leak
sooner or later and by providing sorbent
material to hold the liquid waste leachate
production would be reduced. A sorbent
material such as lime may also
act to neutralize the liquid waste if it
is releasted.
The seepage of appreciable amounts of
liquid waste or leachate may also cause a
rise in the water table and the development
of a groundwater mound. As the mound increases
in size, the unsaturated zone becomes pro-
gressively thinner and thus the opportunity
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for natural attenuation is reduced. S&ftbent
material, again would retain liquid waste
lost from ruptured containers and reduce the
formation of this groundwater mound and the
subsequent reduction in natural attenuation.
(6) The following hazardous waste shall not be
disposed in a landfill:
(i) Ignitable waste, as defined in Section 250.13 (a)
of Subpart A;
(ii) Reactive waste, as defined in Section 250.13(c)
of Subpart A;
(iii) Volatile waste;
NOte: See Note in Section 250.45(P).
(iv) Bulk liquids, semi-solids, and sludges.
Note: Bulk liquids, semi-solids, and sludges may be
disposed of at a landfill provided such waste
is pretreated and/or stabilized (e.g., chemically
fixed, evaporated, mixed with dry inert absorbant),
or treated and/or stabilized in the landfill
(e.g., mixed with municipal refuse at acceptable
ratios) to reduce its liquid content or increase
its solid content so that a non-flowing consistency
is achieved to eliminate the presence of free
liquids prior to final disposal in a landfill.
72.
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(i) Ignitable wastes, as defined in Section 250.13(a)
of Subpart A.
The landfilling of wastes with a flash point of less than
60°C (140°F), defined as ignitable wastes, is considered
an unsafe practice with potential threats to public health
and the environment. The objective of this regulation is
to reduce the potential for fires and the related adverse
affects (e.g., explosions, air emissions).
During and after the disposal of flammable waste, there are
many available external and internal energy sources which can
raise temperatures of wastes to their flash points. Electrical
energy in the form of sparks generated by landfill machinery
and thermal energy resulting from the heat of neutralization
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(pH change) or from the decompostion of organic waste, are
examples of potentially problematic heat sources.
Another concern is the fact that disposal sites often contain
waste that initially are not hazardous, but which when burned,
become so. Certain plastics for example, give off noxious fumes
and a beryllium dust may become airborne by means of the fire.
(It is important to identify flammable waste so that these wastes
can be segregated from otherwise benign wastes.)
A pure liquid with a flash point less than 60°C (140°F) is
a hazardous waste. The 60°C (140°F) breakpoint is suggested
because temperatures of this order can be encountered during the
disposal of wastes, particularly in hot climates. Heats of
chemical reaction, solar radiation, or organic degradation
can elevate ground temperatures well above 38°C (100°F). Further
evidence in support of a 60°C flash point include:
(1) The heat generated as wastes are mixed, including heat
of neutralization, heat of reaction, and heat of mixing, all are
exothermic but difficult to estimate the temperature of these
reactions;
(2) The heat from dark objects absorbing sunlight in landfills
can approach 49°C (120°F) in parts of the U.S.
(3) The heat from biodegration in landfills can reach 60°C.
(4) Tempertures in composting operations can reach 70°C (158°F).
A flash point of 60 C (140 F) provides for an adequate
margin of safety under such circumstances.
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The possibility of landfilling certain wastes with a flash
point less than 60°C (140°F), under certain situations could
be considered safe. The notes accompaning this standard allows for
deviation, thus landfilling of such a waste(s) may be
acceptable if it can be shown that the disposal method (s)
employed will not violate the human health and environmental
standards and are approved by the Regional Administrator
base on best available technology.
(ii) Reactive wastes, as defined in Section 250.13(c) of
Subpart A.
The disposal of reactive wastes, as defined in Subpart
A, in a hazardous waste landfill is considered an unsafe
practice with respect to public health and the environment.
A waste is reactive, according to Subpart A (250.13(c)(1),
if it has any of the following properties:
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Reactive Waste - A solid waste is a reactive waste if it:
(1) is normally unstable and readily undergoes violent
chemical change without detonating; reacts violently with
water, forms potential explosive mixtures with water, or
generates toxic gases, vapors or fumes when mixed with
water; or is a cyanide or sulfide bearing waste which can
generate toxic gases, vapors or fumes when exposed to mildly
acidic or basic conditions.
(ii) is capable of detonation or explosive reaction but
requires a strong initiating source or which must be
heated under confinement before initiation can take place,
or which reacts explosively with water.
(iii) is readily capable of detonation or of explosive
decomposition or reaction at normal temperatures and pressures.
(iv) is a forbidden explosive as defined in 49 CFR 173.51, a
Class A explosive as defined in 49 CFR 173.53, or a Class E
explosive as defined in 49CFR 173.58.
Such wastes include pyroboric substances, explosives,
autopolymerizable material and oxidinizing agents. If it
is not apparent whether a waste is a reactive waste under
this section, then the methods cited in Section 25C.13(c) (2>
of Subpart A or equivalent methods can be used to determine
if the waste is a reactive waste.
It is the intent of this regulation to minimize and/or elin inate
the potnetial for the occurrence of incidents which may result
in serious damange and/or a^,«^ «i
* nog* adversely affect the public healt and
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the environment.
According to the above criteria for reactive wastes, it can be
readily seen that disposal of such waste may have the potential
to cause serious and irreparable damage. There are numerous
damage reports contained in the EPA files which document damage
and..injuries resulting from disposal of reactive wastes.
EPA recognizes that under certain situations and approved
operating procedures, reactive wastes, as defined above, may
be disposed of in a hazardous waste landfill in an acceptably
safe manner, provided the methods employed will not violate
human health and environmental standards (250.42-1,2,3) and
are approved by the Regional Administrator, based on best available
technology (See note Section 250.45(c)).
(iii) Volatile wastes
SOTE: See note in 250.45 (c)
The objective of not allowing highly volatile wastes to be
landfilled is to assure that hazardous waste disposal facilities
(landfills) are operated such that the ambient air quality beyond
the facility owner's property, due to emissions from the facility,
does not adversely affect human health or the environment.
Further discussion concerning standards regulating air quality
from non-point emission sources can be found in the background
document for the Control of Air Emissions.
•f
Landfilling of highly Volatile waste has the potential to create
serious air pollution problems and for the occurance of incidents
which may result in serious damage to and/or adversely affect
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the public health and the environment. There have been numerous
damage incidents involving volatile wastes which are documented in
EPA files. The majority of these incidents have occured as
result of improper handling due to the lack of accurate information
on the specific *(aste and, the often indiscriminate handling
and disposal of such wastes. These factors contribute to
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the exceedingly high risk with the disposal of highly volatile
wastes. Substances with high vapor pressures can cause, either
alone or irrconjunction with another substance, chemical reactions
and reaction consequences which are often more reactive than the
reactant(s) themselves ^intense heat generation, pressure generation,
fire, explosion, violent reaction, formation of latent reactive
substances, dispersal of toxic substances, formation of toxic fumes,
gases and other toxic chemicals and solubilization of toxic substances)
These primary consequences can lead to secondary consequences
such as injury, intoxication, or death of workers, members of the
public, domestic animals and wildlife. Property and equipment
damages as well as contamination of air, water and land can also
be caused by the primary consequences. Examples of sepcific
damage incidents resulting from disposal of volatile hazardous
wastes can be found in the background document for the standards
for the Control of Air Emissions.
The severity of these adverse consequences and the swiftness with
which they can occur emphasize the necessity for adequate
precautionary measures regarding the managment and disposal
of highly volatile wastes.
o
A maximum vapor pressure of 78 mm of Hg at 25 C has been established,
above which wastes could not be landfilled. Rationale supporting
this number can be found in the background document, Standards
n
for the Control of Air Emissions.
The Agency recognizes that wastes with a vapor pressure below
Hg at 25°C may be landfilled in a manner which would not
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adversely affect human health and the environment. The note
accompanying this standard allows such deviation to occur if
the owner/operator can demonstrate that non-point sources do
not contribute any air contaminants to the atmosphere such t> at
concentrations do not exceed limits based on those promulgated
in 28 CFR 1910.1000 pursuant to the Occupational Safety and
C
Health Act of 1970 (See 250.45(Jf) and Annex 2 of Subpart D) .
Comprehensive laboratory and field investigations by the
owner/operator of a landfill will be requisite to demonstrating
that certain volatile waste can be disposed of in an environmentally
acceptable manner.
(iv) bulk liquids, semi-solids and sludges.
Note: Bulk liquids, semi-solids, and sludges may be
disposed of at a landfill provided such waste
is pretreated and/or stabilized (e.g., chemically
fixed, evaporated, mixed with dry inert absorbant),
or treated and/or stabilized in the landfill
(e.g., mixed with municipal refuse at acceptable
ratios) to reduce its liquid content or increase
its solid content so that a non-flowing
consistency is achieved to eliminate the presence
of free liquids prior to final disposal in
a landfill.
The landfilling of bulk liquids, semi-solids and sludges are
considered contrary to the regulatory strategy put forth by
g-pji
the fffllt. This strategy supports maximum containment of hazardous
wastes and maximum protection of the public health and the
environment.
£0
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Containment is directly affected by the liquid content of the
waste materials. Increasing the liquid fraction will generally
decrease the potential of containment.
Darcey's Law, which can be applied to define the rate of flow
of groundwater, can also be applied to estimate how rapidly
liquid contaminants move downward from the land surface to the
saturated zone. Parameters which .will affect rate of flow are
the hydraulic conductivity of the material, fluid viscosity,
material porosity, natural attenuation and the hydraulic
head (hydrostatic pressure) created by the liquid. The rate
of travel of a fluid is directly proportional to the amount
3
of hydraulic head, i.e., the greater the hydraulic head,
the greater the velocity of a liquid through a material, with
all other parameters being kept equal. The disposal of
bulk liquids, semi-solids and sludges into hazardous waste
landfills will create a positive hydraulic head greater than
what would be created by only direct precipitation. This
would result in a situation where leaching of hazardous waste
would be encouraged and cause a greater potential for
ground water contamination.
The disposal of bulk liquids, semi-solids and sludges in hazardous
waste landfills with, or being constructed with, leachate collection
systems is also discouraged. The purpose of a leachate collection
system is to collect and remove any leachate which happens to be
generated from the disposal of hazardous wastes (which have only
a small percentage of water by weight) and from direct
precipitation. This is done to ensure maximum containment
B(
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of the hazardous waste. The leachate which has been collect id
is a hazardous waste which is treated and discharged with
appropriate NPDES permit or disposed of in the landfill. Recycling
of the leachate through a landfill should accelerate the
degradation of the organic fraction; however, the conservative
mineral salts will be retained within the landfill mass. Some
of these salts conceivably may be converted to low solubility
compounds. Soluble salts, however, will continue to be
susceptible to discharge from the landfill as the leachate
volumes exceed the capacity of the barrier underlying the
landfill.
In order to keep liquids and sludges out of hazardous waste
landfills they must be treated and/or stabilized prior to or
in the landfill to a non-flowing consistency, or they must be
containerized and surrounded by sorbent material when buried.
Most landfills are designed without taking into account the
nature of the waste that they are to contain. Modification
or treatment of wastes prior to land burial can, in some cases,
retard the production of leachate that would adversely affect
the quality of ground waters and surface waters.
The appropriateness of a waste-modification method depends u.xsn
its technical effectiveness in preventing the leaching of
toxic components and upon economic factors.
(7) Diversion structures (e.g., dikes, drainage ditche^
shall be constructed such that surface water runoff
will be prevented-from entering the landfill.
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Note: Diversion structures may not be necessary
provided the owner/operator can demonstrate tc the
Regional Administrator, at the time a permit is issued
pursuant to Subpart E, that the landfill facility is located
so that the local topography will prevent surface water
runoff from entering the facility.
Precipitation can create large amounts of surface water runoff
which can enter or even flood a landfill. Landfills which are
3u«tou*±>*3
below*grade are particularly vunerable since they can serve
as sinks for the collection of rainfall or snowmelt runoff. This
water would damage the physical structure of a landfill through
erosion or carry away wastes in solution or suspension. Sufficient
water may collect to allow overflow of hazardous materials to the
surface water environment. Furthermore any water which is
allowed on the surface of a landfill may percolate downward
through wastes creating leachate and contributing to the static
head within the site. To abate these potential environmental
threats, every effort should be made to minimize runoff into
landfills. This may be achieved by the construction of dikes
or drainage ditches capable of diverting runoff water from
the landfill. The diversion capacity of preventive structures
should be based on a prediction of maximum storm frequency
for the active life of the facility.
(8) Surface water which has been in contact with the
active portions of a landfill shall be collected and
treated or disposed of as hazardous waste in accordance
with requirements in this Subpart unless it is analyzed
53
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and found not to be a hazardous waste as identified or iste
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(9) Where gases are generated within the landfill, a gas
collection and control system shall be installed to control
the vertical and horizontal escape of gases from the landfill^.
Gas collection and control system shall not be required
provided the owner /opera tor can demonstrate, to the Regional
'Administrator, at the time a permit is issul® pursuant to
Subpart E, that gases will not be generated in the landfill
or that gases generated will not be in violation of the
air contaminant limits specified in the "Note" associated
with Section 250. 4 5 (c) and will not creat a flammable or
explosive atmosphere.
Landfills may contain or produce explosive, toxic or
asphyxiating gases which may accumulate on site or migrate
off-site. Products of waste decomposition, oxidation,
volatilization, sublimation, or evaporation may include gases
such as methane and hydrogen (explosive and asphyxiating) ,
carbon monoxide and carbon dioxide (asphyxiating) , chlorine
(toxic) , and various gases of chemical wastes (explosive,
asphyxiating, or toxic) .
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Presence of any of these gases at a landfill, in suf-
ficient concentration, can pose a serious threat to the
health and welfare of site employees, users, and oc-
cupants of nearby structures. Explosions, asphyxiations,
and poisonings resulting in injury and death have resulted
from disposal site gases. In addition, property damage,
groundwater contamination, and vegetation kills on-site
and on adjacent lands have been caused by hazardous
waste disposal gases. Techniques need to be implemented
at landfills to avoid/ prevent, or control the formation
and migration of these gases.
There is need for the use of methods to prevent
gas migration offsite and to prevent accumulation in on-
site structures in harmful quantities. Frequently
these measures are site-specific, and may include; control
of incoming waste materials which may cause problems"
location of the site away from occupied structures on-
site to prevent migration? construction of barriers
to gas migration at the landfill boundry? and the use
of vents. Barriers to vertical migration consist of
covering the landfill with low permeability soils or
other materials. However, since all materials are
somewhat permeable these barriers should be used in
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conjunction with vents. Vents may consist of gravel or
open trenches and the use of porous or slotted pipes with or
without pumps to stimulate gas flow either for dispersion
into the atmosphere, or for concentration, destruction, or
utilization, usually by combustion.
As previously mentioned, gas generation at hazardous
waste landfills is frequently a site-specific situation which
is generally dependent on the disposal of waste materials
which may, by themselves or in combination with other wastes,
cause gas generation and related problems. Therefore, this
regulation is flexible enough to allow owners/operators of
hazardous waste landfills not to install gas collection and
control systems if they can demonstrate that gases will not
be generated from wastes materials disposed in the landfill.
Owners and operators may also choose to demonstrate that
any gases generated would not contribute any air contaminant
to the atmosphere in excess of limits set in 250.45 (c) of Subpart D.
(10) A minimum of 15 centimeters (6 inches) of cover material
shall be applied daily on active hazardous waste landfill.
Active portions which will not have additional wastes placed
on them for at least one week shall be covered with 30 centimeters
(12 inches) of cover material.
NOTE: An owner/operator may use covers of different thicknesses
and/or apply them at different frequencies if he can demonstrate
to the Regional Administrator, at the time a permit is issure
pursuant to Subpart E, that the possibility of fire or explosion
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or the harboring, feeding, and breeding of land burrowing animals
and vectors will be controlled to an equivalent degree.
Cover material serves many purposes: (1) helps in
disease vector and rodent control; (2) helps contain odor,
litter, erosion, and air emissions; (3) enhances aesthetics;
(4) lessens the chance and spread of fires; (5) reduces
infiltration of rainwater and thereby decreases potential
leachate generation and surface and groundwater contamination;
and (61 enhances the site appearance and utilization after completioi
Hazardous waste landfill operations plans should specify
what soils are to be used as cover material, where they are
to be obtained, and how they are to be placed over the waste
in order to meet the Aforementioned purposes. Cover materials
A
used at a landfill is classes as daily, intermediate, and
final; the classification depends on the thickness of soil
used and by the length of time the cover is to exposed
to the elements. In general, if the cover is to be exposed
for more than 1 week but less than 1 year, intermediate
cover should be used. If the cover is to be exposed less
than one week, daily cover is sufficient, and if the cover
is to be exposed longer than one year final cover should
be used.>
MFinal cover material should be well compacted.
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DAILY COVER. The important control functions of
daily cover are odor, vector, litter, fire, and moisture.
Generally, a minimum compacted thickness of six inches
of soil will perform these functions if it is applied
at the end of each operating day. Using greater than
six inches would waste soil cover and cause the landfill
to be filled up more quickly decreasing its usable life.
At the end of the operating day, the working face should
also be covered, thus leaving no waste exposed. Subsequent
grading may be desired to prevent ponding of rainwater
and subsequent infiltration into the fill.
INTERMEDIATE COVER. Functions of intermediate cover
are the same as daily cover but include gas control and
possibly service as a roadbase. It is applied in the
same manner as daily cover, but the minimum compacted depth
recommended is one-foot (3C cm.). Periodic grading and
maintenance may be necessary to repair erosion damage, to
prevent ponding of water, and to fill cracks and depressions
caused by moisture loss and settlement of the fill. The
30cm dept for intermediate cover was determined to be
sufficient to withstand the added stresses of prolonges erosions
and infiltration for a period of one year and still maintain
adequate protective cover over the fill.
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While.the quantity of cover soil applied is
important, the quality of the material is even more
important. No one soil, type appears to fulfill the
requirement for impermeability. Clean sands are
readily permeable, silts are difficult to manipulate,
and clays have a tendency to shrink and crack if they
lack moisture content. A mixture of these soils,
however, can provide an adequate cover material. See
the background document for Closure and Post-Closure
Care (Section 250.43-7) for the development of suitable
soils for cover.
The Agency realizes that the application for cover
materials at the above specified frequencies and thick-
ness may not be applicable at all landfills in every
waste disposal situation. Therefore if owners/operators
of hazardous waste landfilJScan demonstrate successfully
that the possibility of fire or explosion, harboring,
feeding and breeding of land burrowing animals and
disease vectors; or that the human health and environ-
ment: are controlled and protected to an equivalent degree,
then covers of different thickness and/or frequencies
may be employed.
(11) In areas wnere evaporation exceeds precipitation
by 20 inches or more and where natural geologic
conditions allow, a landfill shall have a natural
in-place soil barrier on the entire bottom and
sides of the landfill. This barrier shall be
at least 3 meters (10 feet) in thickness and
consist of natural in-plan** soil which has a.
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permeability of less than or equal to 1 X 10~
cm/sec, and meets the requirements of Section
250.45(b) (14).
Note: A natural in-place soil barrier using natural
in-place soils of different thicknessess and
permeabilities may be used, provided the barrier
has a thickness greater than or equal to 1.5
meters (5 feet), and provided that the owner/
operator of the landfill can demonstrate to the
Regional Administrator, at the time a permit is
issued prusuant to Subpart E, that it will provide
equivalent containment of leachate.
(12) An owner/operator of a landfill using the dfsign
in paragraph (b)(11) or any similar design which
does not have a leachate collection system shall
demonstrate to the Regional Administrator, at the
time a permit is issued pursuant to Subpart E,
that liquids will not accumulate in the landfill
to the extent that they may be discharged to the
surface or to groundwater.
Any contaminant deposited on the ground surface is
in position where it can easily enter the geologic
'environment of soils and unconsolidated or solid rocks,
as long as they contain pore spaces or other openings.
Liquid contaminants and solid contaminants that undergo
leaching by water from precipitation can infiltrate
where the soils are sufficiently permeable, to
percolate downward through the unsaturated material to
the water table:
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The relative inaccessibility of the groundwater
for monitoring dicatate emphasis on preventative control
measures to protect usable drinking water supplies.
Normal groundwater monitoring procedures involve
limited sampling locations in the presumed direction
of flow. Selection of monitoring locations and
definition of flow direction techniques are not fool-
proof. A very real possibility of "missing" ground-
water pollution through normal monitoring and sampling
techniques, therefore, exists. Furthermore, corrective
techniques for groundwater pollution, once identified,
are not well established. It is this situation which
supports concentration on protection of groundwater via
preventive techniques and requirements; i.e., criteria
for contaminant containment.
The factors that relate to the containment
characteristics of the site include soil thichkness,
soil permeability, sieve analysis, liquid limit,
Unified Soil Classification, and depth to water table.
The containment time will vary with changes in the
thickness of clay, depth to water, and hydraulic
conductivity of the material above the water table.
MJ
It is preferred*Wiquids be combined with absorbent
material, although it is unlikely that all free liquids
can be absorbed.
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Leachate produced by water migrating through
the deposited hazardous waste presents a treat of both
ground and surface water contamination. Under moist
climatic conditions, when precipitation exceeds
evaporation, the production and migration of leachate
is encouraged. For this reason, landfills using this
natural design (without leachate collection) must be
located in areas where evaporation exceeds precipitation
annually by 20 inches. An excess of 20 inches of
evaporation was chosen because such a number limits the
use of this natural design to areas known to be very
/utJuaillf
dry wititydeep water table levels. Generally, these
areas include parts of Arizona, New Mexico, Texas,
Utah, Nevada, California, Colorado, and isolated areas
of Wyoming and Montana. (See figure * ). If this
standard was written without ths 20 inch excess
£t'.t., oa. e^poC-A^io*. &xceeis •p*ec.'f»M">'0
evaporation limit/the area in which this design could
be used would include the majority of the continental
U. S. west of the Mississippi River which fl*
The types of information concerning soil properties
sought by State regulatory agencies reflects a preference
for tight clay soils with no sand or gravel seams and a
hydraulic conductivity of less than 1 x 10" cm/sec.
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RESERVED
For Figure __i
Map U.S. showing general areas where evaporation exceeds
precipitation by 20 inches.
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The regulatory philosophy prevailing in the U.S.
today favors maximum containment, and the States are
using two different types of regulatory approaches to
achieve this.
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Some States specify minimuin vertical distances to
the water table, minimum permeabilities, minimum
overburden thickness, and the soil or rock material
criteria that must be met at sites. Other States
regulate sites according to containment time
characteristics.
There is a strong preference in many States for
the use of natural in-place materials for lining sites
and, generally, states specify lining as a condition
for a permit. Hazardous waste land disposal facilities
in California are required to have in-place soil liners
with a permeability of 1 x 10~8 cm/sec regardless of
the soil thickness. Illinois requires 10 feet of
1 x 10" 8 cm/sec of in-place clay-rich soil for landfill
liners. Pennsylvania is somewhat less stringent, but
more explicit in their landfill liner requirements;
where natural soil conditions allow, 2 feet (or a
thickness determined by permitting official) of
1 x 10~7 cm/sec of clay-rich soils shall be required.
The strictest landfill requirements are those in the
State Ohio, which requires 25 feet of in-place clay-
rich soils with a permeability of 1 x 10"° cm/sec.
Other States, Texas, New York, Minnesota and New Jersey,
specify liner permeabilities of less than or equal to
1 x 10"^ cm/sec.
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The criteria chosen by the EPA are most like
the State of Illinois' liner thickness and permeability
requirements. The requirements, however, have been
scaled to apply on a national level. This is due to
the lack of extensive clay-rich soil deposits available
in the U. S. with permeabilities of less than or equal
to 1 x 10~8 cm/sec.
The intent of this standard was to allow the use
of a landfill design in areas where natural in-place
soils would be sufficient to meet the specified contain-
ment requirements without leachate collection. There-
fore, they must be located in very dry climates.
Sites meeting the necessary geologic and climatic
condition for maximum waste containment without leachate
collection could also pose a problem of accumulating
liquids which might overflow to the surface or create
leaks to the groundwater due to excessive hydraulic
head, with the unlikely occurrance of unnaturally.heavy
rains. Thus, the owners/operators must demonstrate
that such a situation will not occur if the s-ite is to
be used for the landfilling of hazardous wastes.
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The availability of natural sites that will
satisfy the above requirements may be difficult
to find. In such situations the EPA standards provide
needed flexibility by allowing other combinations
of soil thickness that will achieve equivalent con-
tainment and/or allowing usage of synthetic membranes
and leachate collection systems, specified under
250.45-2(b)(13) of this section.
(13) In areas where climatic and natural geologic conditions
do not allow meeting the requirements of paragraph
(b)(11), a landfill shall have either one of the
following liner systems covering the entire bottom
and sides of the landfill:
(i) Design I
The liner system shall have a slope of at least 1
percent at all points to one or more leachate collection
sumps, (which meet the specifications in paragraph
(b)(17)), so that leachate formed in the landfill will
flow by gravity into the leachate collection sump(s)
from which the leachate can be removed and treated or
disposed of as specified herein. The liner system
shall consist of:
(A) A soil liner which is at least 1.5 meters
(5 feet) in thickness and composed of natural
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in-place soil or emplaced soil which has a
permeability less than or equal to 1 x 10-7
cm/sec and meets the requirements of paragraph
(b)(14); and
(B) A leachate collection and removal system overlying
the soil liner which is at least 30 centimeters
(12 inches) in thickness and composed of permeable
soil capable of permitting leachate to move
rapidly through the system and into the leachate
collection sump(s).
(ii) Design II
The liner system shall have a slope of at least 1
percent*all points and be connected at all low points
to one or more leachate collection sumps (which meet
the specifications of paragraph (b)(17)), so that
leachate formed in the landfill will flow by gravity
into the leachate collection sump(s) from which the
leachate can be removed and treated or disposed of as
specified herein. The landfill liner system shall
consist of:
(A) A leachate detection and removal system, placed
on the natural base of the landfill, which shall
consist of a minimum of 15 centimeters (6 inches)
of permeable soil capable of permitting leachate
to move rapidly through the system and into the
leachate collection sumps;
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(B) A membrane liner system overlying the leachate
detection and removal system composed of a
15 centimeter (6 inch) layer of clean permeable
sand or soil overlaid with a synthetic
membrane liner which meets the specifications
in paragraph (b) (1%) and which is overlaid with
a 15 centimeter (6 inch) layer of clean permeable
sand or soil;
(C) A soil liner overlying the membrane liner system
which is at least 1 meter (3 feet) in thickness
and composed of soil which has a permeability
less than or equal to 1 x 10~7 cm/sec and meets
the requirements of paragraph (b)(14) ; and
(D) A leachate collection and removal system
overlying the soil liner which is at least 30
centimeters (12 inches) in thickness and composed
of permeable soil capable of permitting
leachate to move rapidly through the system
and into the leachate collection sumps.
Note: A landfill may use a different liner system than
the two-described above provided the owner/
operator can demonstrate to the Regional Administra -
tor, at the time a permit is issued pursuant to
Subpart Er that the alternate liner system
includes a liner and a leachate collection and
removal system that provides equivalent or
greater leachate containment, collection, and
removal.
too
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The objective of this standard is to provide
maximum protection for human health and the environment
at landfill sites where climatic and natural geologic
conditions do not allow use of the liner design
specified in 250.45-2(b)(11), and also to provide
flexibility in design and construction of liner
systems.
In establishing the rationale for standard
250.45-2(b)(11) the need for protecting the natural
groundwater system beneath the landfill was discussed
at length and therefore will not be addressed here.
However, the emphasis on the protection of groundwater
and underground drinking water sources through maximum
waste containment is basic to the landfill designs
discussed here.
The standard as stated above allows for the use
of either of two basic disigns for the construction of
a landfill liner system in conjunction with a leachate
collection system(s). These designs are designated,
Design I and Design II.
101
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Design I requires a soil barrier (liner) of at
least 1.5 meters in thickness composed of natural in-
place soil or imported amended, recompacted or reworked
soils with a permeability of 1 x 10" cm/sec. The
in-place soil or emplaced soil liners must also meet
the requirements of 250.45-2(b)(14).
The liner type, thickness and permeability criteria
specified in this standard for this design follows the
strong preference in many States for the use of natural
materials for lining sites. Hazardous waste disposal
sites in Oklahoma must have a clay liner at least
1.5 meters (5 feet) thick, while New Jersey will permit
the use of natural and/or man-made materials for lining
as long as a maximum hydraulic conductivity of 1 x 10"7
cm/sec can be maintained. Other States with hazardous
waste regulations and/or guidelines which specify
liner thickness and permeability in conjunction
with leachate collection and removal are Texas, New
York, Minnesota, Ohio, and Pennsylvania. All of the
above States require a maximum permeability of 1 x 10~7
cm/sec for soil liners". Soil liner thickness addressed
by these States range from 1.5 meters (5 feet) to not
specifying a thickness for liner material. The EPA
has chosen to specify liner thickness to ensure
adequate waste containment and to provide for leachate
attentuation within the soil liner.
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Design II is a more complex design involving
a double liner system with leachate collection and
removal. The liner system for Design II consists
of a 1 meter (3 feet) soil liner with a permeability
of 1 x io~7 cm/sec., which meets the requirements
of 250.45-2(b)(14). The soil liner overlies a
synthetic membrane liner which meets the specifications
in 250.45-2(b)(17) and is protected on both sides
with a minimum of 14 cm (6 inches) of clean sand or
soil. In addition to the leachate collection and
o
removal system required to be constructed on tip of
the liner systems of Design I and Design II, a leachate
detection and removal system will be required beneath
the membrane liner of Design II.
The Agency believes that use of Design II will
afford the greatest degree of waste containment and
groundwater protection of the designs described in
these standards. It combines the attneuation and
self-sealing properties of a soil/clay liner with
the synthetic membrane's capacity for resistance
to a number of chemical wastes and very low permeability,
The use of synthetic membranes, by themselves is not
an acceptable practice. The Agency feels that there
is, at present, inadequate information available on the
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long-term reliability of synthetic membranes, used by
themselves, for waste containment in landfills. Once
a landfill liner is constructed and in place and waste
W
materials are disposed of within the fill, and ..the
liner system fails to contain the waste; the retrieval
and repair of that liner is extremely costly and
hazardous if not an impossible task due to the nature
and volume of the wastes within the fill. Thus
Af*/
deleterious effects to the groundwateri result.
The construction of an impermeable liner should
be closely supervised. In particular, the installation
of a manufactured liner requires (1) prior removal of
all sharp stones and similar objects to prevent
puncture and (2) application of a protective soil
cover after the liner is in place to prevent damage
from landfill machinery. Table 3 summarizes
the advantages and disadvantages of several liner
types. EPA has adopted standards which stipulate
that liners may be natural or (when natural conditions
are not favorable) man-made, or a combination-of both;
and must have a thickness of at least 1.5 meters
(5 feet) when used in conjunction with leachate
collection, and have a permeability of less than
or equal to 1 x 10~7 cm/sec.
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Natural clayey Soil
Bentcmlto Clay
Low-cost synthetic membranes
High-cost synthetic membranes
Paved asphalt with a tar cover
Paved asphalt with a synthetic
membrane
1.2 m (4 ft) layer of common
clay
Clay barrier with synthetic
membrane
Soltr-saallm; alantonte provide
adequate gfound-water protection
Very low permeability provides
ground-water protection
Most membranes have good tensile
strength, low temperature flexi-
bility and resistance to a num-
ber of chemical wastes, highly
impermeability
Extra thickness provides ex-
cellent resistance to a
of chemical wastes , highly
impermeability
Provides.firm structural support'
•Provides structural integrity
and resistance to chemical
attack
low permeability specifications
provide ground-water protection
Structural integrity and self-
seating properties of clay pro-
vide a very high degree of
ground-water protection
Hot AvalXabLo in ai-X
regions. Exposure to certain
acids and chemicals may cause
failure
Failure may occur when exposed
to acids and certain chemicals
Not recommended for retention
of hydrocarbons and solvents.
Data on long-term integrity is
lacking
Not recommended for retention
of hydrocarbon and solvents.
Data on long-term integrity is
lacking. High-cost may cause
use to be economically infoasi-
ble
Vulnerable to attack by certain
hydrocarbon solvents
Vulnerable to attack by certain
hydrocarbon solvents. Use of
certain synthetic membranes could
elevate cost
Exposure to certain acids may
cause failure. Not available in
all geographic areas
Expose to certain acids over a
long-term period may cause failure.
Clay is not available in all goo-
graphic' regions. Use of certain
synthetic membrane could elovate
cost
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As discussed above liners may be natural or man-
made, or a combination of both. Natural impermeable
barriers consist of clay and fine-grained soils; man-
made liners range from asphaltic compositions to
concrete compositions to various synthetic polymeric
membranes. The selection of liners may be determined
by the type of leachable material to be disposed. Some
liners are not compatible with some hazardous wastes.
For example, ethylene propylene rubber would probably
fail when used with a waste containing hydrocarbons.
In addition, natural impermeable soils may fail when
exposed to strong acids.
Texas has established guidelines for the use of
soil barriers or liners at sites receiving hazardous
wastes. Man-made liner material should be at least
30 mils thick, be of reinforced material, and be used
in conjunction with soil protection to minimize the
possibility of puncturing the liner.
Pennsylvania regulations stipulate that the
disposer must submit data indicating the miscibility
of any proposed liner membrane relative to an exposure
of not less than 100 hours with the wastes to be
disposed. Disposal sites constructed without man-
made liners must have renovating soil between the
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waste and any sidewill. The State will determine
the thickness of the renovating soil layer based upon
the groundwater and surface water contamination potential
of the wastes. The State agency also specifies that
the leachate-collection system be designed to handle
the amount of leachate generated over the active life
of the site and up to 10 years after its closure.
Containment is of course directly affected by
the liquid content of the waste materials. Increasing
the liquid fraction will generally decrease the potential
of containment. Natural attenuation by the soil
and rock through which the waste pass will also
affect the quality of the leachate reaching the
ground and surface water. In general, attenuation
mechanisms become more effective as hydraulic conducti-
vity decreases in a given section of soil. It is
EPA policy to eliminate the disposal and generation
with subsequent collection and removal of all free-
liquids in hazardous waste landfills. This is to be
required in order to minimize the creation of a
hydraulic head which would result in an increase in
hydraulic conductivity and have deleterious effects
to the liner.
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As discussed, leachate produced by water migrating
through the deposited hazardous waste presents the
threat of both ground and surface water contamination.
Leachate travels to the bottom of a landfill under
normal circumstances. For this reason, additional
protection and control can be achieved by the
installation of a leachate collection and removal
system. If leachate were detected, the collection
system would allow it to be pumped out. The collection
system should be monitored regularly for the quantity
and quality of leachate produced.
This standard requires that febwefc^landfills be
designed to include a leachate collection and removal
system to be constructed on t^p of the liner system
in order to intercept and remove leachate generated
within the fill. A minimum acceptable leachate
collection and removal system, is specified in these
standards. Since the leachate collection and removal
system is located on top of the liner system,
the liner must have a slope at all points of at least
1 percent and drain to one or more leachate collection
sumps. Leachate must be able to flow by gravity to
the sumps from which the leachate can be removed
and treated or disposed properly. A minimum of
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30 cm (12 inches) of highly permeable soil or gravel,
O-
which will allow leachate to move rapidly to the
collection sump(s) must be placed over the soil liner.
Perforated pipes could also be added within the soil/
gravel layer to enhance the collection and movement
of liquids. The purpose and need for such a system
in a landfill where free liquids are generated has
been previously discussed. A system such as the one
described here is a very minor part of the total
cost of a secure landfill and the benefit of its
use to the containment of waste and protection of
groundwater can not be over emphasized.
Although leachate collection and treatment is
called for by the majority of State regulatory agencies,
the method of treatment is rarely prescribed.
"Disposal Site Design and Operation Information,"
prepared by the California State Water Resources
Control Board, summarizes the technical difficulties
States may encounter in this respect by observing
that "Treatment of this high organic and mineral
content liquid is difficult. Discharge to a sewerage
system usually is not possible because landfills
normally are long distances from the nearest connection
points. Use of evaporation ponds is practical only
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if the quantity of leachate collection is less than
the evaporation potential of the ponding areas.
Recycling of the leachate through a landfill should
accelerate the degradation of the organic fraction;
however, the conservative mineral salts will be retained
within the landfill mass. Some of these salts conceivably
may be converted to low solubility componds. Soluble
salts, however, will continue to be susceptible to
discharge from the landfill as the leachate volumes
exceed the capacity of the barrier underlying the
landfill." ®
The federal effluent standards program applies
to all generators of hazardous waste that dispose of
material to surface waters. Storage, treatment, or
disposal in lagoons, landfills, or spreading grounds
is not covered. Some States have included discharges
to the ground in their effluent program. EPA has
not yet developed surface water effluent guidelines
for the commercial hazardous waste management facility,
but some States, New York and Washington, for example,
are developing effluent standards on a case by case
basis for the commercial treater of hazardous waste.
(14) The soils used in a soil liner and natural in-place
soil barrier shall meet the following minimum criteria:
no
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(i) Be classified under the Unified Soil Class-
ification System CL, CH, SC, and OH (ASTM Standard
D2487-69f
(ii) Allow greater than 30 percent passage through
a No. 200 sieve (ASTM Test D1140),
(iii) Have a liquid limit equal to or greater than
30 units (ASTM Test D423),
(iv) Have plasticity equal to a greater than 15
units (ASTM Test D424),
(v) Have a pH of 7.0 or higher (Annex 5), and
(vi) Have a permeability not adversely affected
by anticipated waste.
NOTE: Soil not meeting the above criteria may be used
provided the owner/operator can demonistrate to the
Regional Administrator, at the time a permit is issued
pursuant to Subpart E, that such soil will provide
equivalent or greater structural stability and waste
containment and attenuation, and will not be adversely
affected by the anticipated waste.
The objective of requiring landfill soil liners
and natural in-place soil barriers to meet the criteria
listed above is to provide for maximum structural
stability, containment and attenuation (retention)
of the hazardous waste constituents, and provide soils
that will not be adversely affected by the anticipated
waste.
in
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The specifications concerning soil properties
used by State regulatory agencies reflect a preference
for tight, fine grain clay soils with no sand and
gravel seams. The California Department of Health's
soil criteria, as specified in "Draft Minimum Standards
for Hazardous Waste Management," are used in varying
detail by other states. Of these criteria, soil types
of CL, CH, OH or sometimes SC per the Unified Soil
Classification System, passage of not less than 30
percent (by wt.) through a standard US. No. 200
sieve, a liquid limit of not less than 30 units using
ASTM Test D423, plasticity index of not less than
15 units based on ASTM Test D424, are addressed in
regulations or guidelines for Hazardous Waste Manage-
ment by Illinois, Oklahoma, Texas, New York, Pennsylvania
and Minnesota.
Essentially the soil types selected are characteristic
of inorganic clays, organic clays, clayey sands,
sixty clays, sandy clays, lean clays and fat clays,
all of which are fine grained soils.
Fine-grained soils are characterized by extremely
large specific surface, i.e., area per unit weight.
Clays have both internal as well as external surfaces.
Their specific surface can reach 800m^ per gram.
Ill-
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Because of greater specific surfaces, finer soil
materials have greater attenuating characteristics
than courser material. In general, there is less
migration of leachate as soil texture becomes finer.
Thus, where possible, it is advantageous to locate
surface impoundments in thick, relatively impermeable
formations such as massive clay beds. Where this is
not possible, then the soils with a high clay and
silt content (i.e., fine-grained soils) should be
sought According to the Unified Soil Classification
System, the boundary between coarse-grained and fine-
grained soils is taken to be the 200-mesh sieve
(0.074 mm), 'jir) 30 percent of the soil (by weight
passing through such sieve.
Thus, the percentage of the soil passing through
200-mesh sieve is one of the indicators of the presence
or absence of the clay or silt, to be used to determine
the suitability of the soil to serve as a barrier to
hazardous waste movement into the environment.
The objectives for requiring a liquid limit not
less than 30 units and plasticity index not less than
15 units, are to assure the consistency, workability
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and firmness (i.e., compressibility, dry strength,
shearing resistance, etc.) of the soils intended as
liners or barriers to the passage of hazardous wastes
and Ifctt leachates from landfills.
The "liquid limit," "plasticity limit" and
"plasticity index" are the most useful indicators
of the engineering behavior of clay soils. The
above limits, also termed Atterberg limits, are
defined by the water content required to produce
specific degrees of consistency that are measured
in the laboratory.
The "liquid limit" (upper plastic limit) is the
point at which soil becomes semifluid. In operational
terms, the liquid limit is defined as the water content
at which a trapezoid grove of specific shape, cut in
moist soil held in a special cup is closed after
25 taps on a hard rubber plate (ASTM Test D423).
The "plastic limit" (lower plastic limit) is
defined as the water content at which soil begins
to crumble on being rolled into a thread 1/8 inch
3 mm) in diameter (ASTM Test D424). It represents
the lowest water content at which soil can be deformed
readily without cracking.
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The "plastic index," a difference between the
liquid and plastic limits, is the range of water content
of the soil at which plastic behavior occurs. It is
also an indicator of the plasticity or "clayeyness"
of the soil.
It has been observed (A. Casagrande) that many
properties of clays and silts, such as their dry
strength, their compressibility, their reaction to
the shaking test, and their consistency near the plastic
limit, can be correlated with the Atterberg limits by
means of the so-called plasticity chart. According
to the chart, clays with liquid limits less than
30 are considered to be of "low" plasticity. Those
with liquid limits between 30 and 50 exhibit "medium"
plasticity and those above 50 exhibit "high" plasticity.
The plasticity index is useful in estimating the dry
strength and compressibility of the soil. The soils
with plastic index less than 10 have low compressibility.
Those with plastic index between 10 and 20 exhibit
medium compressibility and those above 20 high com-
pressibility.
Since the consistency of the soil, its workability,
compressibility and dry strength are critical for
construction and environmentally sound operation of
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hazardous waste landfills, both "liquid limit" and
"plastic index" are important factors in determination
of the soil suitability for such construction.
The requirement under (v) that soil liners have
a pH of 7.0 or higher iMttSgaBSS, because of the
attenuation ability of soils at higher pH values
and the ability of high pH soils to inhibit the
reaction of wastes with a low pH (acid) . The Texas
Department of Water Resources has also set a similar
pH requirement of no less than 7 for soils to be used
as liners or natural in-place soil barriers.
It is required under (vi) that the premeability
of soil liners should not be adversely affected by
the anticipated wastes. The rationale for this
is the fact that clay liners, although suitable
for the majority of hazardous wastes, are not compatible
with certain wastes. For example, natural impermeable
soils may fail when exposed to strong acids and strong
alkaline waste may cause clay liners to swell. There-
fore, the wastes that are not compatible with soil
liners should not be deposited into such landfills.
The rationale concerning waste compatibility with
the liner is given in (b)(4) of this section.
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(15) Synthetic membrane liners shall meet the following
criteria:
(i) Be of adequate strength and thickness
to insure mechanical integrity and have a minimum
thickness of 20 mils;
(ii) Be compatible with the waste to be landfilled;
(iii) Be resistant to attack from soil bacteria
and fungus;
(iv) Have ample weather resistance to withstand
the stress of extreme heat, freezing, and thawing;
(v) Have adequate tensile strength to elongate
sufficiently and withstand the stress of installation
or use of machinery and equipment;
(vi) Be of iniform thickness, free from thin
spots, cracks, tears, blisters, and foreign
particles;
(vii) Be placed on a stable base; and
(viii) Have a permeability less than or equal to
— 12
1 x 10 cm/sec or it's equivalent .
Liners should be of adequate strength and thickness
to insure mechanical integrity of the liner. The
failure to provide liners of adequate mechanical
strength and thickness could result in liner failure
(e.g., rupture, puncture, laceration, and development
of cracks) with subsequent seepage of hazardous wastes
into the environment.
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The thickness of synthetic membranes used as
liners and their mechanical strength are closely
related, i.e., the thicker the liner, the higher
mechanical strength which can be anticipated.
For the purpose of these regulations a minimum
thickness of 20 mils was chosen for membrane thickness
in hazardous waste landfills. This thickness was
A 1
chosen because the agencww believes that when
used in conjunction with other criteria specified
in Design II (see rationale for 250.45-2 (b)(13)
Design II) and the specified minimum criteria for the
use of synthetic membranes, that adequate waste
containment and ground water protection will be realized
Among the first consideration in selecting
a liner for hazardous waste landfill is the compati-
bility with the hazardous wastes to be contained.
The possible reactions between the liner and wastes
can detrimentally affect the ability of the landfill
to contain such wastes and prevent their seepage to
the environment.
The compatibility criteria for synthetic membranes
used as liners are similar to those specified in the
rationale for 250.45-2 (b)(14)(i).
I IB
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The exposure of synthetic membranes used in landfills
to soil bacteria and fungi; has been known to, and
could, adversely affect the durability and impermeabi-
lity of such liners. For this reason, synthetic
membranes which have properties which resist such
attack should only be used.
Synthetic membranes used as liners should have ample
weather resistance to withstand the stresses associated
with wetting and drying, freezing and thawing as
dictated by the geographical location of the landfill
site.
Synthetic liner materials without adequate tensile
strength may rupture during installation or be affected
by continous use of machinery and equipment required
for the operation of the landfill. Liner material
should also resist laceration, abrasion and puncture
from matter contained in the waste it will hold,
all of which could decrease the durability of the
liner.
The physical quality of the membrane liner is also
of concern. Thin spots, cracks, tears, blisters,
foreign particles and pin holes resulting from its
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manufacture and/or subsequent handling prior to
installation could adversely affect durability and
permeability of the liners.
The installation of a manufactured liner requires prior
preparation of the base. The base should be stable
so that settling or other movement after liner
installation does not tear or weaken the liner
through stretching. The improper installation of
even the best material will defeat the purpose of
the lining.
The Agency recognizes that the state-of-the-art of
predicting landfill discharge is poor, and thus
the prudent course is to prescribe maximum containment
of hazardous waste.
Maximum containment minimizes the escape of hazardous
waste constituents, and thus provides protection of
human health and the environment.
To better attain containment of hazardous waste
constituents in landfills there is a definite need
for flexible impervious lining materials of long
life. Data available on flexible polymeric membranes
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(CPE, PVC, Hypalon, EPDM, ER) have indicated their
(?)
permeability is less than lOfcl^ cm/sec. However,
since these flexible synthetic materials are composed
of resin and a very slowly extractable plasticizer,
there will be changes over long periods of time,
with gradual stiffening of the material due to loss
of this plasticizer. For example, even if all the
plasticizer were removed from PVC, a process which
is estimated to take more than 100 years, the basic
resin still has 30 to 50 percent elongation. Over
time the permeability of these materials is also
believed to be reduced from its initial state.
However, exposure test of these various polymeric
membranes to conditions similar to those encountered
in hazardous wastes landfills for periods exceeding
flE
1 year, have so far, showed no effect on permeability,
For these reasons the Agency feels that there is, at
present, inadequate information available on long-term
reliability of synthetic polymeric membranes used as
liners, by themselves, for waste containment in
landfills (Refer to 250.45-2 (14) for recommended
landfill design using synthetic membranes).
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The Agency has received comment on the ability, availability,
and reliability of standard tests to measure a permeability
as low as 1 x 10""^-2 cm/sec. Although this does
present some difficulty in terms of long test periods
and careful laboratory technique, a method is presented
in ASTM, Test 3079.
Test methods are also being developed under EPA
contract. Also,the standard is written as 1 x 10~12
cm/sec or its equivalent.
This was done so that the permeability of the membrane
liner does not necessarily have to be expressed in
cm/sec but in any units as long as the permeabilities
1 2
are equivalent to 10 cm/sec or less.
(16) A landfill overlying an underground drinking water
source shall have groundwater monitoring systems
and a leachate monitoring system as specified in
250.43-8.
One of the most severe causes of groundwater contamination
in the USA is leakage of wastes from unlined and lined
hazardous waste landfills. Pollution problems such
as these can be reduced if landfills are lined by
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impermeable clay, or clay and/or synthetic membrane
liners. However, all liners are prone to failure,
due to incompatibility with contained wastes, mechanical
failure, improper installation, etc., resulting
in hazardous waste seepage into the environment.
The objective of the above regulation is to detect
and correct any liner failure or goundwater contami-
nation before more serious problems can develop.
Monitoring requirements for hazardous waste surface
impoundments over usable aquifers, under 250.43-8 specify
monitoring in zone of saturation, applicable to all
facilities constructed after the effective date of
this regulation.
The objectives and rationale for requiring monitoring
in the zone of saturation are the same as specified
in the background document for Groundwate andLeachate
monitoring section 250.43-8 of Subpart D.
(17) A leachate collection sump (as required in the
liner systems specified in paragraph (b)(13) shall
be designed and constructed:
•2-3
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(i) of materials both compatible with and
impermeable to the leachate formed in the
landfill;
(ii) so that the sump is accessible for removal
of leachate if the sump pump becomes inoperative
and/or the stand pipe for removal of leachate
become damaged; and
(iii) with a volume equal to our greater than
three-months expected volume of leachate but
no less than 1000 gallons.
(18) The owner/operator shall remove leachate from a
leachate collection sump as frequently as necessary
to maintain gravity flow in the leachate collection
and removal system and shall check the leachate
collection sump at least monthly to assure compliance
with this requirement.
The purpose of these standards is to specify minimum
criteria for collection and removal of leachate from
the hazardous waste landfill. This is done to minimize
any hydraulic pressure which would be created in
the landfill due to excess liquids (leachate) (see
£* v
pages 80-fl / rationale/y250.45-2 (b) (6) (iv)J which could
cause the liner to fail.
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Leachate is drained from the hazardous waste landfill
via gravity to the collection sump. . Because of the
hazardous nature of the leachate and the possibility
that it could remain in the sump up to one month
before removal, the sump must be constructed of
materials which would prevent the escape of leachate
before removal. Therefore, the sump must be constructed
using materials which are both impervious to and
compatible with the leachate.
Because hazardous waste landfill*, are designed and
(**W«#I ge*k)
constructed below the surface of the ground/^leachate
collection sumps are required. The sump pump as=
access (stand pipe) for mechanical or physical removal
l^adfriuirt-fS We*»3\H uio«fc«rt eo-^«»* so+Kfli C.£
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(19) Landfill liner systems and natural in-place soil
barriers shall not be placed over earth materials
exhibiting a permeability of greater than 1 x 10~^
cm/sec.
The object of this standard is to restrict the siting
of hazardous waste landfills in areas where soil
permeability will not restrict the flow of waste
constituents to groundwater or ODWS in the event
of a liner failure. This provision provides an extra
margin of safety at such facilities where the release
of unknown quantities wastes of unknown quality might
present a hazard to public health and the environment.
A precedent for such a standard exist in the State
of New York which restricts hazardous waste facilities
from being located in areas exhibiting a soil permeability
greater than 1 x 10"5 cm/sec. This Agency is establishing
a permeability not to exceed 1 x 10 cm/sec because
of the availability of such soil on a National
level, and that such a permeabilityfin conjunction
with containment criteria,will be adequate to meet
the objectives of the human health and environmental
objectives of these regulations.
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Closure
(1) At closure, the owner/operator of a landfill
shall place a final cover over the landfill. This
final cover shall consist of at least 15 centimeters
(6 inches) of soil with a permeability less than
or equal to 1 x 10 cm/sec which meets the criteria
of Section 250.45-2 (b) (14) , underlying 45 centimeters
(18 inches) of soil capable of supporting indigenous
vegetation. The top 15 centimeters (6 inches) of
this cover shall be topsoil.
NOTE: A final cover using different thicknesses
and permeabilities may be used provided the owner/
operator can demonstrate to the Regional Administrator
that it will provide equivalent control of infiltration
of water, equivalent control of sublimation or evaporation
of harmful pollutants into the air, and equivalent
erosion control. The owner/operator must also demon-
strate that the final cover will support indigenous
vegatation.
The selection of clay as the recommended cover material
was partially based on a report by Geraghty and
Miller, "Site Location and Water Quality, Protective
Requirements for Hazardous Waste Management Facilities ?"
b U-S. g~PA , " SfturUef Inn^l/ dfSiA o*J o^oavko* ".
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In table 3 , various soil types are
ranked according to their performance of certain cover
functions. Clay is given a rating of "excellent"
for the prevention of emergence of flies, minimization
of moisture, minimization of gas venting and control of
blowing paper and providing a pleasing appearance.
For the support of vegetation it is rated "fair to good."
It received "poor" ratings for the prevention of burrowing
and tunneling by rodents and venting decomposition.
However, other soil types did not receive as many
"excellent" ratings for the performance of the various
functions.
The cover depth requirement for clay is designed to
provide a impermeable clay cap which will resist
erosion, inhibit infiltration of rainwater and prevent
sublimation of harmful pollutants into the air.
A cover of top soil is necessary in order to sustain
vegetative growth and to maintain the clay cap.
More than 2 feet of cover may be necessary depending
on the soil type and the anticipated use of the
completed landfill. For example, if trees are to be
planted a minimum of three feet or more of soil
capable of supporting vegetation will be necessary
/2.S
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TABLE- 3
SUITABILITY OF VARIOUS SOIL TYPES FOR
USE AS LANDFILL COVER MATERIAL*'
Soil Type—
Clayey-Silty Clayey-Silty
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to prevent the roots from breching the impermeable
clay cap and entering the hazardous waste.
A permeability of less than 1 x 10~7 cm/sec was
selected, based in part on a Corps of Engineers study,
"Cover Materials for Solid and Hazardous Waste."
Different Unified Soil Classification System soil
types are ranked according to their performance of
specific cover functions. The clays are ranked very
high, "inorganic clays of high plasticity, fat clays"
are ranked number one for effectiveness in impeding
water percolation and gas migration. Inorganic
clays of low to medium platicity, gravelly clays,
sandy clays, silty clays, and lean clays are ranked
second for effectiveness in impeding water percolation
and gas migration. Inorganic silts, micaceous or
diatomaceous fine sandy or silty soils and elastic
silts were ranked third for impeding water percolation.
Out of these possibilities, the 10~7 cm/sec figure
was chosen because it appears effective to minimize
infiltration and these types of soils are more easily
found than others which are less permeable.
Clays were chosen for the following reasons. They are
very fine in texture thereby making them more cohesive
and more impermeable even though they commonly contain
small to moderate amounts of silt and sand.
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Clay soils vary greatly in their physical properties,
which depend not only on the small particle size but
on the type of clay minerals and soil water content.
When dry, a clay soil can be almost as hard and tough
as rock and can support heavy loads. When wet, a cla\
soil swells and its permeability is very low.
Six inches was determined to be the minimum thickness
required to provide an impermeable cap over the fill
while not wasting valuable clay. Eighteen inches of
additional soil is necessary to, (1) prevent the
clay cap from drying out and cracking and (2) sustain
vegetative cover.
(2) Where trees or other deep-rooted vegetation are
to be planted on the completed fill, the final cover
shall consist of 15 centimeters (6 inches) soil
layer specified in paragraph (c)(1) underlying at
least 1 meter (3 feet) of soil capable of supporting
the deep rooted vegetation and indigenous vegetation.
NOTE: The upper layer soil thickness for deep-rooted
vegetation may be less than 1 meter (3 feet) provided
the owner/operator can demonstrate to the Regional
Administrator that the roots of the vegetation will
not penetrate the 6-inch clay cover.
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The 3 feet of soil requirement as well as the other
depteh of soil layer requirements are based on EPA's
recommendations for sanitary landfills, as described
in, "Sanitary Landfill Design and Operation." The
objectives for cover of sanitary landfills are the
same as for hazardous waste landfills, i.e., maintenance
of cover functions and the subsequent isolation of
wastes from the environment.
(3) The final grade of the final cover shall not
exceed 33 percent. Where final grades exceed 10 percent,
horizontal terraces shall be constructed. Terraces
shall be of sufficient width and height to withstand
a 24-hour, 25 year storm. A terrace shall be placed
at every 10 feet of rise in elevation when the slope
is less than 20 percent and at every 20 feet of rise
in elevation when the slope is greater than 20 percent.
NOTE: The final grade may be of different design
and slope provided the owner/operator can demonstrate
to the Regional Administrator that water will not
pool on the final cover and that erosion will be
minimized.
Grading is important in order to encourage runoff and
minimize infiltration and erosion. The general topo-
graphic layout of the completed landfill surface
-------
should be controlled by carefully locating waste
cells. The final cover should then be compacted and
graded to inhibit the ponding of water on the landfill
surface because any standing water will create hydrauli
head encouraging infiltration into the fill. These
values for grading were selected because they are
minimum grades necessary to inhibit ponding and also
minimize the effects of erosion by runoff. Preferably,
topsoil from the site should be stockpiled and reserved
for support vegetation indiginous to that area. The
topsoil should not be highly compacted since it will
be seeded.
Post-Close-Out
(1) During the post-closure period, which shall
continue at the landfill for a period of at least
20 years (see 250.43-7), the owner/operator of the
landfill:
(i) Shall maintain the soil integrity, slope,
and vegetative cover of the final cover and
all diversion and drainage structures;
(ii) Shall maintain the groundwater and leachate
monitoring systems and collect and analyze
samples from these systems in the manner and
frequency specified in Section 250.43-8;
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(iii) Shall maintain survey bench marks;
(iv) Shall maintain and monitor the gas collection
and control system where such a system is
installed to control the vertical and horizontal
excape of gases; and
(v) Shall restrict access to the landfill
as appropriate for its post-closure use.
NOTE: The owner or operator of a landfill may request
that certain post-closure requirements be discontinued
earlier than 20 years after closure. The facility
owner or operator shall submit information to the
Regional Administrator to indicate that such post-
closure care need not continue; (e.g., no leaks
have been detected, technology has advanced, alternate
disposal techniques are to be employed) ..
; .«**.
The Regional Administrator shall have the discretion
to discontinue one or more of these post close-out
requirements.
At hazardous waste landfills, where wastes are not
removed or rendered non-hazardous during site closure,
there remains a potential, long-term threat that
hazardous constituents could find their way off-site
-------
and pose a substantial threat to human health and
the environment. During the active operation of
a landfill these proposed standards for landfilling
have specified specific design and asperating
methods which, if compiled with, will substantially
minimize the potential for escape of hazardous waste
constituents. Some of these design and operating
methods must also continue during post-closure until
such a time that it can be demonstrated that the
landfill no longer presents a threat to human health
and the environment.
Soil integrity, slope and vegetative cover of the
final cover and all diversion and drainage structures
must be maintained in order to eliminate the possibility
of infilteration of surface waters which would increase
the hydraulic head within the landfill, which would
in turn increase the likelihood of hazardous constituents
entering the environment.
Ground^water and leachate monitoring systems must be
maintained to indicate as early as possible the
potential movement of contaminants, so as to predict,
as early as possible, the potential for endangerment
of the ground^water or the impact on specified ground-
-------
water quality. The fundamental objective of monitoring
landfill sites is to serve as a back up to the waste
containment structures and/or devices.
The maintenance of survey bench marks during the
post-closure period will enable the location of
specific waste types if it were to become necessary
and/or feasible to remove or further isolate such
waste or portion of the landfill. This could occur
if waste constituents were found in samples analyzed
from the groundwater and/or leachate monitoring
systems above background concentrations. Also,
the location of wastes in the landfill could be
beneficial if it were determined or technology developed
for a particular waste to be re-used or recycled.
Gas collection and control systems, in those landfills
where installed, must also be maintained during the
post-closure period. Gases have the potential to
generate in the landfill for long periods of time
therefore the venting and control of such
gases must be maintained to reduce the risk of fire
and explosion and to reduce air contamination.
-------
At landfills, because of the presence of hazardous
waste, site access must be restricted. However,
the degree of restriction will be determined by the
proposed post-closure use as approved by the Regional
Administrator.
If the owner/operator of the landfill felt that certain
aspects of or all of the post-closure care and maintenca
for a particular site need not continue for 20 years,
he must demonstrate that such care is not necessary
to protect human health and the environment (e.g.,
no leaks have been detected, technology has advanced,
alternative disposal or treatment techniques are to
be employed). The Agency feels that such an avenue
for deviation must be available for flexibility in
regulation to stimulate the development of treatment
and disposal technology. Also flexibility is needed
because not all disposal sites present the same potential
threat to human health and the environment.
(2) No buildings intended for habitation shall be
constructed over landfills where radioactive wastes
as defined in Subpart A have been disposed.
Radioactive wastes are very persistant and contact
with them is extremely dangerous. Excavation is
-------
required for the construction of a building and
this would create the possibility of exposure of the
radioactive material to the environment creating a
hazard to public health and the environment.
The radiation associated with landfilled radioactive
hazardous waste, is low level, but capable of causing
chronic effects resulting from extended exposures.
The exposure would be greatest immediately over the
landfill and could be extensive if a building were
constructed over the landfill where people were
likely to spend considerable amounts of time.
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REFERENCES
1. T. Fields, Jr., and A.W. Lindsay, Landfill Disposal
of Hazardous Wastes: A Review of Literature and Known
Approaches, Report EPA/530/SW-165, Washington, D.C.
U.S. Environmental Protection Agency (September 1975) .
2. Hazardous waste disposal damage reports. Environments 1
Protection Publication SW-151. (Washington), U.S.
Environmental Protection Agency, June 1975. 8p.
3. U.S. Environmental Protection Agency, Office of Solid
Waste Management Programs. Disposal of hazardous
wastes; report to Congress. Environmental Protection
Publication SW-115. Washington, U.S. Gov't Printing
Office, 1974. HOp.
4. Office of Solid Waste Management Programs. SW-131s.
Unpublished data.
5. California State Water Resources Control Board.
Waste Discharge Requirements for Non-Sewerable
Waste Disposal To Land, Disposal Site Design and
Operation Information, March 1976.
6. Perloff, William H and William Baron, Soil Mechanics,
The Ronald Press Company, 1976.
7. Haxo, Henry E., Robert S. Haxo and Richard White. Liner Materials
Exposed to Hazardous and Toxic Sludges, First Interim Report. EPA-
600/2-77-81. U.S. Environmental Protection Agency. June 1977.
8. Staff, Charles E. Preventing Pollution from Sanitary Landfills
with Impermeable Membranes. Information Service Bulletin #022677.
Staff Industries Inc., Upper Montclair, N.J.
9. U.S. Environmental Protection Agency. Sanitary Landfill Design
and Operation. SW-65t* , 972. p.14
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Appendix I - Case Histories
1, Formation of Toxic Gas in Sanitary Landfill
In Los Angeles County, a tank truck emptied several
thousand gallons of cyanide waste onto refuse at a
sanitary landfill. Another truck subsequently deposited
several thousand gallons of acid waste at the same
location. Reaction between the acid and the cyanide
evolved large amounts of toxic hydrogen cyanide gas.
A potential disaster was averted when a local chlorine
dealer was quickly called to oxidize the cyanide with
chlorine solution.
2. Formation of Toxic Gas in Excavated Site
A load of acidic aluminum sulfate was inadvertently
discharged into an excavation already containing some
sulfide waste. Hydrogen sulfide was released and
the truck driver died in his cab at the landfill
site.
3. Formation of Toxic Gas at a Landfill
At a sanitary landfill near Dundalk, Maryland, a
2,000-gallon liquid industrial waste load containing
iron sulfude, sodium sulfide, sodium carbonate and
sodium thiosulfate, along with smaller quantities
of organic compounds was discharged into a depression
-------
atop an earth-covered area of the fill. When it
reached eight to ten feet below the point of discharge,
the liquid started to bubble and fume blue smoke.
The smoke cloud quickly engulfed the truck driver
and disabled him. Several nearby workers rushed to
his aid and were also felled. During the clean-up
operation, one of the county firefighters also collapsed,
All six of the injured were hospitalized and treated
for hydrogen sulfide poisoning. It was not determined
whether the generation of hydrogen sulfide was due
to the instability of the waste or the incompatibility
of the waste with some of the landfill materials
although the pH of the waste was measured to be
13 before it left the plant.
4. Fire, Dispersal of Toxic Dusts from Leaky Containers
At a dump in Contra Cost County, California, a large
number of drums containing solvents were deposited
in a landfill. In the immediate area were leaky
containers of concentrated mineral acids and several
bags containing beryllium wastes in dust form.
The operators failed to cover the waste at the end
of the day. The acids reacted with the solvents
during the night, ignited them and started a large
chemical fire. There was possible dispersion of
-------
beryllium dust into the environment. Inhalation,
ingestion or contact with beryllium dust by personnel
could have led to serious health consequences.
5. Volatilization of Toxic Chemicals Due to Heat Generation
from Ruptured, Buried Containers
A load of empty pesticide containers was delivered
to a disposal site in Fresno County, California.
Unknown to the site operator, several full drums of
an acetone methanol mixture were included in the load.
When the load was compacted by a bulldozer, the
barreled waste ignited, engulfing the bulldozer in
flames. The operator escaped unharmed, but the
machine was seriously damaged. The ensuing fire,
which also involved dispersion of pestidice wastes,
was extinguished by firemen. The firemen were
examined to ensure they had not been harmed by
exposure to pesticide dusts.
I. Formation of Water Soluble Toxic Substances from
Ruptured Drums
In Riverside County, California, several drums of
phosphorus oxychloride, phosphorus thiochloride
and thionyl choloride were improperly dropped off
at a dump. Later during a flood, the drums were
-------
unearthed, ruptured, and washed downstream. They
released hydrogen chloride gas and contaminated
the water.
7. Fire at a Disposal Site
A disposal site in central California accepted a
load of solid dichromate salts and dumped it in
a pit along with pesticide formulations and empty
pesticide containers. For several days thereafter,
small fires erupted in the pit due to the oxidation
of the pesticide formulations by the dichromate.
Fortunately, the site personnel were able to extinguish
these fires before they burned out of control. There
were no injuries, or property or equipment damage.
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Resource Conservation and Recovery Act
Subtitle C - Hazardous Waste Management
Section 3004 - Standards Applicable to Owners and Operators
of Hazardous Waste Treatment, Storage, and
Disposal Facilities.
Draft
BACKGROUND DOCUMENT
Section 250.45-3 Standards for Surface Impoundments
U.S. Environmental Protection Agency
Office of Solid Waste
December 15, 1978
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This document provides background information and support
for regulations which are designed to protect the air,
surface water/ and groundwater from potentially harmful dis-
charges and emissions from hazardous waste treatment, storage,
and disposal facilities pursuant to Section 3004 of the Resource
Conservation and Recovery Act of 1976. It is being issued as
a draft to support the proposed regulation. As new information
is obtained, changes may be made in the regulations as well as
in this background material.
This document was first drafted many months ago and has
been revised to Jkeflect information received and Agency
decisions made since then. EPA made changes in the proposed
Section 3004 regulations shortly before their publication
in the Federal Register. We have tried to ensure that all
of those decisions are reflected in this document. If there
are any inconsistencies between the proposal (the preamble
and the regulation) and this background document, however,
the proposal is controlling:
Comments in writing may be made to:
Timothy Fields, Jr.
U.S. Environmental Protection Agency
Office of Solid Waste
V
Hazardous Waste Management Division (WK-565)
401 M Street, S.W.
Washington, D. C. 20460
I
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I. Introduction
A. RCRA Mandate and Authority
B. Definition of Area being Regulated and
Other Koy Words.
II. Rationale.for Regulation
A. Actual Damage Incidents
III. Identification of Existing Regulatory Methods
IV. Analysis of Regulatory Options
V. Identification of Chosen Regulation and
Associated Rationale.
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I. Introduction
A. RCRA Mandate and Authority
Section 3004 of the Resource Conservation and Recovery
Act of 1976 (RCRA) madates that the EPA Administrator
promulgate regulations establishing standards applicable to
owners and operators of facilities for the treatment, storage
and disposal of hazardous wastes as may be necessary to
protect human health and the environment. Among other things,
these standards are to include requirements respecting 1) the
treatment/ storage or disposal of all such waste received by
the facility pursuant to such operating methods, techniques,
and practices as may be satisfactory to the Administrator,
and 2) the location, design, construction operation and
maintenance of such hazardous waste treatment, storage, or
disposal facilities.
B. Definition of Area being Regulated and Other Key Words
For the purpose of the regulation. "Surface Impoundment"
means a natural topographic depression, artificial excavation,
or dike arrangement with the following characteristics:
(i) it is used primarily for holding, treatment, or disposal
of waste; (ii) it may be constructed above, below, or partially
in the ground or in navigable waters (e.g., wetlands); and
(iii) it may or may not have a permeable bottom and/or sides.
Examples include holding ponds and aeration ponds.
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The other pertinent definitions are as follows:
(1) "Active Fault Zone" means a land area which,
according to the weight of the geologic evidence, has a
reasonable probability of being affected by movement along
a fault to the extent that a hazardous waste facility would
be damaged and thereby pose a threat to human health and
the environment.
(2) "Administrator - See Section 1004(1).
(3) "Aquifer" means a geologic formation, group of
formations, or part of a formation that is capable of
yielding useable quantities of groundwater to wells or
springs.
(4) "Attenuation" means any decrease in the maximum
concentration or total quantity of an applied chemical or
biological constituent in a fixed time or distance traveled
resulting from a physical, chemical, and/or biological reaction
or transformation occurring in the zone of aeration or zone
of saturation.
(5) "Close out" means the point in time at which
facility owners/operators discontinue operation by ceasing
to accept hazardous waste for treatment, storage, or disposal.
-------
(6) "Closure" means the act of securing a facility
pursuant to the requirements of Section 250.43-7.
(7) "Closure Procedures" means the measures which
must be taken to effect closure in accordance with the
requirements of Section 250.43-7 by a facility owner/
operator who no longer accepts hazardous waste for treat-
ment, storage, or disposal.
(8) "Coastal High Hazard Area" means the area subject
to high velocity waters, including, but not limited to,
hurricane wave wash or tsunamis as designated on Flood
Insurance Rate Maps (FIRM) as zone VI-30.
(9) "Contamination" means the degradation of naturally
occurring water, air, or soil quality either directly or
indirectly as a result of man's activities.
(10) "Direct Contact" means the physical intersection
between the lowest part of a facility (e.g., the bottom of
a landfill/ a surface impoundment liner system or a natural
in-place soil barrier, including leachate detection/removal
systems) and water table, a saturated zone, or an underground
drinking water source, or between the active portion of a
facility and any navigable water.
-------
(11) "Disposal Facility" means any facility which
disposes of hazardous waste.
(12) "Endangerment" means the introduction of a substance
into groundwater so as to:
(i) cause the maximum allowable contaminant,levels
established in the National Primary Drinking
Water standards in effect as of the date of
£uiopGL>t-£
promulgation of this -S^-f-r-t to be exceeded in
the groundwater; or
(ii) require additional treatment of the gr/(oundwater
in order not to exceed the maximum contaminant
levels established in any promulgated National
Primary Drinking Water regulations at the point
such water is used for human consumption; or
(iii) Reserved (Note: Upon promulgation of revisions
to the Primary Drinking Water Standards and
National Secondary Drinking Water Standards under
the Safe Drinking Water Act and/or standards for
other specific pollutants as may be appropriate^) •
(13) "EPA" means the U.S. Environmental Protection Agency.
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(14) "EPA Region" means the States and other
jurisdictions in the ten EPA Regions as follows:
Region I - Maine, Vermont, New Hampshire,
Massachusetts, Connecticut, and Rhode Island.
Region II - New York, New Jersey, Commonwealth of
Puerto Rico, and the U.S. Virgin Islands.
Region III - Pennsylvania, Delaware, Maryland,
West Virginia, Virginia, and the District of
Columbia.
Region IV - Kentucky, Tennessee, North Carolina,
Mississippi, Alabama, Georgia, South Carolina, and
Florida.
Region V - Minnesota, Wisconsin, Illinois, Michigan,
Indiana, and Ohio.
Region VI - New Mexico, Oklahoma, Arkansas, Louisiana,
and Texas.
Region VII - Nebraska, Kansas, Missouri, and Iowa.
Region VIII - Montana, Wyoming, North Dakota, South
Dakota, Utah, and Colorado.
Region IX - California, Nevada, Arizona, Hawaii,
Guam, American Samoa, and the Commonwealth of the
Northern Mariana Islands.
Region X - Washington, Oregjfon, Idaho, and Alaska.
8
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(15) "Facility" means any land and appurtenances,
thereon and thereto, used for the treatment, storage,
and/or disposal of hazardous waste.
(16) "Final Cover" means cover material that is
i>
applied upon closure of a landfill and is permanently
exposed at the surface.
(17) "Five-Hundred-Year Flood" means a flood that
has a 0.2 percent or one in 500 chance of recurring in
any year. In any given 500 year interval, such a flood
may not occur, or more than one such flood may occur.
(18) "Floodplain" means the lowland and relatively
flat areas adjoining inland and costal areas of the
mainland and off-shore islands, including, at a minimum,
areas subject to a one percent or greater chance of
flooding in any given year.
(19) "Freeboard" means the vertical distance between
the average maximum level of the surface of waste in a
surface impoundment, basin, open tank, or other containment
and the top of the dike or sides of an impoundment, basin
open tank, or other containment.
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(20) "Fugitive Emissions" means air contaminant
emissions which are not planned and emanate from sources
other than stacks, ducts or vents or from non-point
emission sources.
(21) "Groundwater" means water in the saturated
zone beneath the land surface.
(22) "Hazardous Waste" has the meaning given in
Section 1004(5) of the Act as further defined and
identified in Subpart A.
(23) "Hazardous Waste Facility Personnel" means all
persons who work at a hazardous waste treatment, storage
or disposal facility, and whose actions or failure to
act may result in damage to human health or the environment,
(24) "Hazardous Waste Landfill" means an area in
which hazardous waste is disposed of in accordance with
the requirements of Section 250.45-2.
(25) "Hydraulic Gradient" means the change in
hydraulic pressure per unit of distance in a given
direction.
10
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(26) "Incompatible waste" means a waste unsuitable
for commingling with another waste or material, because
the commingling might result in:
(i) Generation of extreme heat or pressure,
(ii) Fire,,
(iii) Explosion or violent reaction,
(iv) Formation of substances which are shock
sensitive friction-sensitive, or otherwise
have the potential of reacting violently,
(v) Formation of toxic (as defined in Subpart A)
dusts, mists, fumes, gases, or other
chemicals^ and
(vi) Volatilization of ignitable or toxic chemicals
due to heat generation, in such a manner that
the likelihood of contamination of groundwater,
or escape of the substances into the environment,
is increased, or
(Vii) Any other reactions which might result in not
meeting the Air Human Health and Environmental
Standard. (See Appendix I for more details.)
11
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(27) "Leachate" means the liquid that has percolated
through or drained from hazardous waste or other man
emplaced materials and contains soluble, partially soluble,
or miscible components removed from such waste.
(28) "Leachate Detection System" means a gravity flow
drainage system installed between the top and bottom liners
of a surface impoundment capable of detecting any leachatfe
that passes through the top liner.
(29) "Liner" means a layer of emplaced materials
beneath a surface impoundment or landfill which serves
to restrict the escape of waste or its constituents from
the impoundment or landfill.
(30) "Monitoring" means all procedures used to
systematically inspect and collect data on operational
parameters of the facility or on the quality of the air,
groundwater, surface water, or soils.
(31) "Monitoring Well" means a well used to obtain
water samples for water quality analysis or to measure
groundwater levels.
12
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(32) "Navigable Waters" means "waters of the United
States, including the territorial seas". This term includes
but is not limited to:
(i) All waters which are presently used, or
were used in the past, or'may be susceptible
to use in interstate or foreign commerce,
including all waters which are subject to the
ebb and flow of the tide, intermittent streams,
and adjacent wetlands. "Wetlands" means those
(X/
areas that are inundated or saturated by surface
or groundwater at a frequency and duration
sufficient to support, and that under normal
circumstances do support, a prevalence of vegetation
typically adapted for life in saturated soil
conditions. Wetlands, generally include swamps,
marshes, bogs, and similar areas such as sloughs,
prairie potholes, wet meadows, prairie river
overflows, mudflats, and natural ponds.
(ii) Tributaries of navigable waters of the United
States, including adjacent wetlands;
(iii) Interstate waters, including wetlands; and
(iv) All other waters, of the United States, such
as intrastate lakes, rivers, streams, mudflats,
sandflats, and wetlands, the use, degradation
13
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or destruction of which would affect or could
affect interstate commerce, including, but
not limited to:
(A) Intrastate lakes, rivers, streams,
and wetlands which are or could be
used by interstate travelers for
recreational or other purposes;
(B) Intrastate lakes, rivers, streams,
and wetlands from which fish or shellfish
are or could be taken and sold in
interstate commerce; and
(C) Intrastate lakes, rivers, streams, and
wetlands which are used or could be
used for industrial purposes by industries
in interstate commerce.
(v) All impoundments of waters of the United States
otherwise defined as navigable waters under this
paragraph.
(33) "Non-Point Source" means a source from which
pollutants emanate in an unconfined and unchannelled manner,
including, but not limited to, the following:
U
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(i) For non-point sources of water effluent, this
includes those sources which are not controllable
through permits issued pursuant to Sections 301
and 402 of the Clean Water Act. Non-point
source water pollutants are not traceable to
a discrete identifiable origin, but result from
natural processes, such as nonchannelied'run-off,
precipitation, drainage, or seepage.
(ii) For non-point sources of air contaminant emissions,
this normally includes any landfills, landfarms,
surface impoundments, and basins.
(34) "Owner/Operator" means the person who owns the
land on which a facility is located and/or the person who
is responsible for the overall operation of the facility.
(35) "Partial Closure Procedures" means the measures
which must be taken by facility owners/operators who no
longer accept hazardous waste for treatment, storage, or
disposal on a specific portion of the site.
(36) "Permitted Hazardous Waste Management Facility
(or Permitted Facility)" means a hazardous waste treatment,
storage, or disposal facility that has received EPA permit
15
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in accordance with Subpart E^x Ca C^ ^ -v^^T 1} tn~S (^j <-
-
(37) "Point Source" means any discernible, confined,
and discrete conveyance, including, but not limited to,
the following:
(i) For point sources of water effluent, any
pipe, ditch, channel, tunnel, conduit, well,
discrete fissure, container, rolling stock,
concentrated feeding operation, vessel, or
other floating craft from which pollutants
are or may be discharged; and
(ii) For point sources of air contaminant emissions,
any stack, duct, or vent from which pollutants
are or may be discharged.
(38) "Post-Closure Care" means the monitoring and
facility maintenance activities conducted after closure.
(39) "Reactive Hazardous Waste" means hazardous waste
defined by Section 250.13 (c) (1) of Subpart A.
(40) "Recharge Zone" means an area through which
water enters an aquifer.
16
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(41) "Representative Sample" means a sample having
average characteristics of all groundwater in the aquifer
beneath the facility.
(42) "Run-off" means that portion of precipitation
that drains over land as surface flow.
(43) "Saturated Zone (Zone of Saturation)" means that
part of the earth's crust in which all voids are filled
with water.
(44) "Spill" means any unplanned discharge or release
of hazardous waste onto or into the land, air or water.
(45) Soil Barrier" means a layer of soil of a minimum
of 1.5 meters (5 feet) in thickness with a permeability of
1 x 10 cm/sec or less which is used in construction of a
landfill or a surface impoundment.
(46) "Sole Source Aquifers" means those aquifers
designated pursuant to Section 1424 (e) of the Safe Drinking
Water Act of 1974 (P.L. 93-523) which solely or principally
supply drinking water to a large percentage of a populated
area.
17
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(47) "Storage Facility" means any facility which
stores hazardous waste, except for generators who store
their own waste on-site for less than 90 days for subse-
quent transport off-site, in accordance with regulations
in Subpart B.
(48) "Treatment Facility" means any facility which
treats hazardous waste.
(49) "True Vapor Pressure" means the pressure exerted
when a solid and/or liquid is in equilibrium with its own
vapor. The vapor pressure is a function of the substance
and of the temperature.
(50) "24-Hour, 25-Year Storm" means a storm of 24-hour
duration with a probable recurrence interval of once in
twenty-five years as defined by the National Weather Service
in Technical Paper Number 40, "Rainfall Frequency Atlas of
the United States", May 1961, and subsequent amendments, or
equivalent regional or State rainfall probability information
developed therefrom.
(51) "Unsaturated Zone (Zone of Aeration)" means the
zone between the land surface and the nearest saturated zone
18
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in which the interstices are occupied partially by air.
(52) "United States" means the 50 states, District of
Columbia, the Commonwealth of Puerto Rico, the Virgin Islands,
Guam, American Samoa, and the Commonwealth of the Northern
Mariana Islands.
(53) "Underground Drinking Water Source" (UDWS) means:
(i) an aquifer supplying drinking water for
human consumption, or
(ii) an aquifer in which the groundwater contains
less than 10,000 mg/1 total dissolved solids;
or
(iii) an aquifer designated as such by the
Administrator or a State.
(54) "Underground Non-Drinking Water Source" means an
underground aquifer which is not a UDWS.
(55) "Volatile Waste" means waste with a true vapor
o
pressure of greater than 78 mm Hg at 25 c.
(56) "Water Table" means the upper surface of the
zone of saturation in groundwater in which the hydrostatic
pressure is equal to atmospheric pressure.
19
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(57) "Wetlands" means those areas that are inundated
or saturated by surface water or groundwater at a frequency
and duration sufficient to support, and under normal
circumstances do or would support, a prevalence of vegetation
typically adapted for life in saturated or seasonally
saturated soil conditions. Wetlands generally include
swamps, marshes, bogs, and similar areas, such as sloughs,
potholes, wet meadows, reiver outflows, mudflats, and
natural ponds.
20
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II. Rationale for Regulation
A. Actual Damage Incidents
The treatment and disposal of hazardous wastes in
a properly located/ designed, constructed, operated and maintained
surface impoundments could be an acceptable, environmentally sound
waste management practice. However, numerous incidents of damage
have occured because of the inproper location, design, construc-
tion, operation or maintenance of such facilities.
A few examples of such incidents are described below:
o A copper reclamation company operating in a mid-Atlantic
State from 1965 to 1969 bought industrial wastes from other plants,
extracted copper, and then stored the remaining liquids in 11
cement lagoons. Three of these lagoons developed open seams on
the bottom from which toxic pollutants seeped into an adjacent
creek, which became lifeless. Also, the plant grounds became
reddish green with sulfuric acid wastes. The county and State,
after prolonged litigation, finally had an injunction issued to
have all wastes properly treated. Rather than face this expense,
the company abandoned the site, leaving the lagoons filled with
3 1/2 million gallons of toxic wastes, and leaving rusting drums
of toxic materials strewn about the property. In April 1970,
heavy rains threatened to wash much of the toxic wastes in the
lagoons into the Delaware River via the adjacent creek. When
overflow reached 25 gallons a minute, county officials were
forced to have the disposal site sandbagged and a dirt dike
built to prevent further overflow. Had the lagoons continued to
21
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overflow/ the Trenton water supply downstream would have been
rendered unusable. Because of this danger, and a steady under-
ground seepage from three of the lagoons, the State was forced
to assume the expense of cleaning up the site. At a cost of
$400,000 the wastes were neutralized and the ocean dumped in
1971. Although the waste no longer poses a threat to surrounding
areas, the original plant site is still contaminated and devoid
of vegetation.
o Four private wells in an eastern state were contaminated
with phenols in late 1972. The phenols had leached from unlined
disposal lagoons of a fiberglass manufacturing operation. in
January 1973, the phenol concentration in one of the wells was
1.64 ppm. (The U.S. Public Health Service recommended drinking
water standard for phenols is 0.001 ppm). As a remedial measure,
the leaking lagoons have been emptied and lined disposal lagoons
have been installed. Recently, one of the affected wells still
2
had a phenol concentration of 0.138 ppm.
o On September 27, 1972, heavy rains broke the earthen dike
of a former refinery waste lagoon which is currently owned by
Pleasant Township. The released sludge entered the Allegheny
River and killed about 450,000 fish with an estimated value of
$75,000 along a 60-mile stretch. Analysis of the discharge
entering the river at that time indicated the following: pH
1.7; COD 116,112 ppm; iron 507.3 ppm; sulfates 56.5 ppm. To
stop the leak, the town built up the lagoon bank and also has
been adding clean fill as available. Monitoring wells dug near
the lagoon show that the groundwater quality still is degraded.3
22
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o Chromium from a waste lagoon of a New Jersey company
contaminated a municipal well, at least one domestic well, and a
nearby stream in the 1960's. The company had been in operation for
about ten years before the problem was recognized in 1970, At
that time, a total chromium concentration of 150 ppm was measured
in one of the wells 700 feet away from the waste lagoon. The
source of contamination has been eliminated, but the plume of
polluted groundwater is still there. The former municipal
drinking water well is currently used for industrial purposes
4
only.
o Nitrate and nitrite contamination in several wells at the
Bangor Annex naval installation in Kitsap County, Washington, was
discovered in March 1971 during routine sampling. The Navy
then began a program of monitoring 39 wells, 33 of which are off
the Annex. As a result, it was found that the shallow perched
aquifer underlying the area contained RDX and TNT in concentrations
of 5«2 ppm and 13 ppm, respectively. The contaminants were also
found to have penetrated the soil underlying this aquifer to a
depth approximately 260 feet above the main aquifer. The con-
tamination source was an unlined settling basin used to discharge
wastewater from the washing of spent bomb casings, after removal
of the insoluble solids. As a remedial measure, the upper six
inches of residue was removed and incinerated in 1971, and the
basin backfilled with four feet of soil. An estimated 9,000
pounds of RDX still remain in the soil of the basins.
23
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The U.S.G.S. has released a final report on its study of the
problem which recommends that the site be covered with an imper-
meable material and drainage controlled on the upgradient side.
Currently, 11 wells are still monitored in an operation which has
cost the Navy $150,000, so far. Final costs are estimated to
approach a million dollars.
o On October 27, 1968, a waste storage lagoon on the plant
site of a Pennsylvania refining company broke, spilling waste
sludge containing oils, acid wastes, and alkyl benzene sulfonate
into the south branch of Bear Creek, killing an estimated 4.5
million fish valued at $108,000. Because the company was in poor
financial condition, only a little over $20,000 in fines were
q
levied to cover the damage.
c
o Arsenic Compounds, the by-products of pharmaceutical
manufacturing operations, were discharged into sludge lagoons
behind a Pennsylvania plant prior to 1966, when Rohm and Hass
Company purchased the facilities. By 1966, the groundwater in
the vicinity of the plant was contaminated with arsenic. The
groundwater in the area discharges into Tupehocken Creek which
downstream contributes to Philadelphia's water supply. Despite
persistent pumping of the groundwater to reduce the arsenic level
analysis of the creek water revealed an arsenic concentration of
0.094 ppm in February 1975. This is significantly higher than the
0.010 ppm arsenic analyzed upstream from the plant site. Arsenic
from the groundwater is also seeping into the Myerstown municipal
24
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sewer lines and entering the treatment plant. Arsenic has been
detected at a concentration of 0.285 ppm in the sewage effluent,
which now will require upgraded treatment to reduce this level.
It has not yet been determined who will have to bear the cost
for upgrading the treatment of the sewage effluent. Rohm and
Haas Company wishes to resolve the arsenic problem by having the
lagoons cleaned out and the wastes disposed of adequately. The
manner of technical implementation is presently under study.
Wastes currently being generated are stored in 55-gallon drums
with polyethylene plastic liners?
o On June 10, 1967, a dike containing an alkaline waste
lagoon for a steam generating plant at Carbo, Virginia, collasped
and released approximately 400 acre-feet (493,400 cubic meters) of
fly ash waste into the Clinch River. The resulting contaminant
slug moved at a rate of 1 mile per hour (1.6 kilometers per
hour) for several days until it reached Norris Lake in Tennessee,
whereupon it is estimated to have killed 216,200 fish. All food
organisms in the 4-mile (6.43-kilometer) stretch of river immediately
p
below Carbo were completely eliminated.
o On December 7, 1971, at a chemical plant site in Fort
Meade, Florida, a portion of a dike .forming a waste pond ruptured,
releasing an estimated 2 bill-ion gallons (7.58 billion liters)
of slime composed of phosphatic clays and insoluble halides
into Whidden Creek. Plow patterns of the creek led to
subsequent contamination of the Peace River and the estuarine
25
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area of Charlotte Harbor. The water of Charlotte Harbor took
on a thick milky white appearance. Along the river, signs of
life were diminshed, dead fish were sighted, and normal surface
fish activity was absent. No living organisms were found in
Whidden Creek downstream of the spill or in the Peace River at
a point 8 miles downstream of Whidden Creek, clam and crab
gills were coated with the milky substance, and in general
all benthic aquatic life was affected in some way.9
o A holding pond and tanks at a chemical manufacturing
plant in Saltville, Virginia, failed, spilling chlorine,
hypochlorites, and ammonia into the north fork of the Holston
River. River water samples showed concentration levels at 0.5
part per million hypochlorite and 17.0 parts per million of fixed
ammonia. Dead fish were sighted along the path of the flow in
the river.
o Annual production of organic lead waste from manufactur-
ing processes for alkyl lead in the San Francisco Bay area amounts
to 50 tons (45.4 metric tons). This waste was previously
disposed of in ponds at one industrial waste disposal site.
Attempts to process this waste for recovery resulted in alkyl
lead intoxication of plant employees affected, but employees
of firms in the surrounding area were exposed to an airborne
alkyl lead vapor hazard. Toll collectors on a bridge along
the truck route to the plant became ill from escaping vapors
from transport trucks. Currently, the manufacturers that
generate organic lead waste are storing this material in holdina
basins at the plants pending development of an acceptable
recovery process."
26
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The damage incidents described above plus at least twenty
other similar cases contained in the EPA files clearly indicate,
that improperly located designed/ constructed, operated or
maintained hazardous waste surface impoundments can pollute
usable aquifers, surface waters and the air, creating public
health and environmental hazard. Thus a need exists to regulate
the location, design, construction and operation of hazardous
waste surface impoundments.
The environmental media most endangered by surface impound-
ments are: the groundwater-specifically underground drinking
water sources; surface water and the air.
Regulatory methods/options for protecting underground
drinking water sources and surface waters described in the
following section of this document. Regulatory methods for
protecting the air quality at hazardous waste surface impound-
ments are discussed in separate background document - "Air
Human Health and Environmental Standard".
2 7
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III. Identification of Existing Regulatory Methods
Regulatory methods used by States with the most progressive
hazardous waste management for preventing groundwater and surface
water contamination by leakage or overflow of hazardous waste
surface impoundments are identified and briefly summarized below:
(1) Texas - According to Technical Guidelines No. 4 -
Ponds and Lagoons, published by the Texas Water Quality Board,
the pollution potential of a pond depends on the following factors:
(1) the composition and reactivity of the waste material- (2) the
physical state or form of the wastes; (3) the geological and
hydrological parameters of the site; and (4) construction,
operation and maintenance of the facility. Pertinent portions
of the Texas Water Quality Board guidelines are cited below:
Wastes - "The waste/wastes to be treated/disposed of should
be classified in accordance with the Texas Water Quality Board's
guideline on "Waste Classification". In addition, it is necessary
to determine, by testing, the effect of the wastes to be contained
within the pond on the soils or lining materials to be utilized
in the construction of the pond. The object of such testing is
28
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to determine if the wastes have any detrimental effect (causing
dissolution, increasing the permeability, etc.) on the soils or
lining material utilized as barriers to prevent the wastes or
leachates from the wastes from seeping from the pond. No waste/
wastes that has a significant detrimental effect on the materials
being used as barriers to movement of wastes from the pond should
be disposed of in the pond.
Due to the higher degree of mobility of the liquid wastes,
they present a somewhat greater hazard or pollution potential
than do the more viscous, high solids content sludges. Greater
care must be exercised when handling (loading or unloading) the
liquid wastes, since spills involving these materials would be
more likely to result in their rapid conveyance to area waters.
All ponds, regardless of their content, should always have
adequate freeboard. Ponds containing liquids, as opposed to
sludges, may be subject to stricter freeboard requirements due
to the possibility of wave action within the ponds being generated
by strong winds, thus possibly allowing wastewaters to be washed
over the pond dike."
Geology - "When possible, ponds should be located in thick,
relatively impermeable formations such as massive clay beds.
Where this is not possible, then soils with a high clay and silt'
content should be sought. Those earth materials classified under
the Unified Soil Classification as CL, CH, OH, and sometimes SC
29
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are normally suitable for use as liners or barriers to the passagj
of wastes or leachates. Each pond-site location, its construction
and operating procedures will be evaluated individually, but if
natural in-place soils or imported, amended, recompacted or
reworked soils 'are to be utilized as barriers or liners for the
ponds, then the following suggested parameters should be met:"
30
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TABLE I
Parameter Waste Classification
IA IB II III
In-place soil thickness or 4' 3' 3'
Compacted soil liner 31 2' 21
thickness
Permeability* (in cm/sec) IxlO-7 IxlO-7 IxlO-7
% Passing No. 200 Sieve 30 30 30
Liquid Limit 30 30 30
Plasticity Index 15 15 "15
Artificial liner thickness 30mil 20mil 20mil
*Pentieability is to be determined with the waste if liquid, and
with the liquid phase if semisolid."
Hydrology - "When possible, the bottom of the pond should
be well above the historical high groundwater table. Floodplains,
shorelands, and groundwater recharge areas should be avoided.
Significant hydraulic connection (surface or subsurface) between
the site and surface and/or groundwaters should be absent. Each
pond-site location will be considered/evaluated individually but
as a rule, the following suggested parameters should be met."
31
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TABLE II
Parameter Waste Classification
IA IB II III
Monitor Well Yes Yes Yes
Leachate Collection Yes -
Secondary Dikes+ Yes -
Freeboard 2' 1.5' 1.5'
Depth to Water Table* 50' 10' 10'
If site is below 50-year floodwater elevation
X Z Z
If site is above 50-year floodwater elevation
Z Z Z -
X = operator should provide surface water diversion dikes
with a minimum height equal to two (2) feet above the
50-year floodwater elevation around the perimeter of
the disposal site.
Z = operator should provide surface water diversion struc-
turers capable of diverting all rainfall runoff from
a 24-hour, 25-year storm.
+ Secondary dikes would normally not be necessary when the
primary dikes are well engineered, constructed and main-
tained.
*If pond is located in massive relatively impermeable for-
mation, these numbers could possibly be reduced to 1/10
of those values listed.
32
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Construction - "One of two common methods are recommended
for pond or lagoon constraction: (1) the "above - ground" pond/
lagoon; and (2) the "below - ground" pond/lagoon.
o "Above-ground" ponds/lagoons are recommended for use
in areas with high groundwater table conditions. If class
IA (hazardous) wastes are to be retained in above-ground
ponds and the primary dikes are poorly engineered or
unstable/inadequate, then secondary or back-up dikes
are to be constructed around the primary dikes in order
to prevent exit of wastes from the facility if the primary
dikes break. Other methods to prevent the escape of wastes
into area waters may also be used.
o "Below-ground" ponds/lagoons are recommended for use
in areas where the groundwater table is not close to the
surface. In below-ground ponds containing Class IA (hazardous)
wastes where waste level is above ground level, a secondary
or back-up dikes are to be constructed around the primary
dikes if the primary dikes are poorly engineered or unstable/
inadequate. These secondary dikes should be constructed
to insure that the area within is capable of retaining
a minimum of 1.25 times the volume of waste material retained
above ground level within the primary dikes. Again, methods
other than back-up dikes may be used to prevent escape of
wastes into area waters.
33
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"Above" - and "below-ground" ponds/lagoons are not required
to be lined if the underlying soil is relatively impermeable
(£lO-7 cm/sec) and of sufficient thickness to inhibit seepage
of wastes from the pond into the groundwater. If these conditions
are not met, then the ponds should be lined.
Dikes for all ponds are to be "keyed" into the underlying
soil to promote a good seal between the ground and the dike
bottom in order to prevent lateral migration/seepage of wastes
through the base of the dike."
Operation - "Regardless of the type of pond facility con-
structed it must be operated in such a manner so as to serve
its intended purpose without posing a water pollution threat.
Maintaining proper freeboard, accepting only those wastes which
are compatible with and not detrimental to the pond lining,
and taking care not to rupture the liner are just a few of
the things that the operator must be constantly concerned with.
Other potentially harmful or undesirable conditions such as
foul odors, oil slicks on pond surface, or fires, are to be
minimized or eliminated if possible."
The following suggestions are made regarding the maintenance
of storage pond dikes:
o Construction - "all earthen dikes should be constructed
of a clay-rich soil capable of achieving a coefficient of
permeability of at least 1.0 x 10- cm/sec or less when
compacted tO 95% standard proctor at optimum moisture content.
34
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Dikes should usually (subject to soil and equipment types)
be constructed in lifts a maximum of nine (9) inches thick.
The surface between lifts should be sacrificed to insure
a good seal between each lift.
o Stabilization and Maintenance - "In order to minimize
the erosion of earthen dikes by wind and water, it is suggested
that )there practical all earthen dikes be stabilized by
establishing a protective "cover" such as, but not limited
to, grass, shell, rock, etc., over the top and sides of the
exposed portions of the dikes. In addition, the dikes
should be periodically inspected for the purpose of detecting
and correcting any deterioration of the dikes. All needed
maintenance or corrective action necessary to restore the
dike to its original condition should be accomplished
expeditiously due to the possible serious consequences".
(2) Oklahoma - According to the guidelines published
by Oklahoma State Department of Health, Chapter IV.; "Ponds and
Lagoons", treatment and disposal of industrial wastes in properly
located, constructed, maintained and operated "ponds or lagoons"
is considered to be an acceptable, environmentally sound waste
35
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management practice. To assist operators in accomplishing the
treatment and/or disposal of wastes in ponds and lagoon in such
a manner as to preclude contamination of groundwater and surface
water supplies, the Oklahoma State Department of Health published
detailed guidelines for location/ constraction, operation and
maintenance of such facilities. Pertinent portions of these
guidelines are as follows:
Wastes - No waste/wastes that has a significant detrimental
effect on the materials being used as barriers to movement of
wastes from the pond/lagoon should be disposed of in such facilities.
It is, therefore, desirable to determine by testing the effect
of the wastes to be contained on the soils or lining materials
to be utilized in the construction of ponds or lagoons. Greater
care must be exercised when handling the liquid wastes because
they present a somewhat greater hazard of pollution potential
than do the more viscous, high solid content sludges (e.i. spills
involving liquids would more rapidly convey to area waters;
possibility of wave action within a pond/lagoon generated by
strong winds may result in stricter freebord requirements).
Geology - "Whenever possible ponds and lagoons should be
located in thick, relatively impermeable formations such as
massive clay beds. Where this is not possible, then soils with
a high clay and silt content should be sought." "The soil
characteristics shall be continuous for a distance of at least
^
ten (10) feet in all directions vertically and laterally of the
actual disposal area.
36
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a. Fine-grained soils generally falling into group
classification CH, OH, or CL per the Unified Soil
Classification System.
b. Maximum permeability coefficient of 10- cm/sec, or
less permeable.
c. Consideration will also be given to particle size
distribution, liquid limit and plasticity index, pH,
dispersion, etc.
If the natural or undisturbed soil at a proposed Industrial
Waste disposal site would not be adequate to contain the waste
deposited therein, an impervious liner of reconstituted natural
or specific clays or artificial materials may be used. The
following minimum criteria shall apply to such liners.
Clay liners
a. Be at least five (5) feet thick.
b. Be reconstituted and compacted on a substantially
stable base.
c. After compaction, have a maximum permeability coefficient
Q
of 10- cm/sec, or less permeable.
Artificial liners
a. Be non-reactive to waste materials.
b. Be placed on a stable-type base."
Hydrology - "Whenever possible the bottom of the disposal
area should be well above the historical high groundwater table.
Floodplains, shorelands, and groundwater recharge areas should be
37
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avoided. Significant hydraulic connection (surface and subsurface)
between the site and standing or flowing surface water should be
absent. Each disposal site will be considered/evaluated indivi-
dually but as a rule, the following suggested parameters should
be met:
Parameter Controlled Industrial Waste
Monitor Well Yes
Leachate Collection Yes
Secondary Dikes Yes
Freeboard 3'
Depth to Water Table 50'
In addition, it is generally desireable to provide for
temporary impoundment of all runoff that might be contaminated
by spills, dike failures, or other unusual problems. By providing
this extra level of protection, contamination runoff can be
restricted to the site proper, without the risk of such runoff
immediately entering creeks, rivers, etc."
Construction - "One of two common methods are recommended for
pond or lagoon construction: (1) the "above-ground" pond/lagoon,
and (2) the "below-ground" pond/lagoon.
o The "above-ground" method of pond and lagoon
i
construct*!*** is recommended for use in areeas with high
groundwater tayle conditions. Because the waste level in
Kuch ponds will obviously be at some distance above ground
level, a secondary or back-up dikes are recommended around
the primary dike in order to prevent exit of wastes from
the facility in the event the primary'dike is breached.
However, methods other than back-up dikes may be utilized
to prevent escape of wastes into area waters.
38
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o The "below-ground" pond and lagoon construction is
recommended for use in areas where the groundwater table
is not close to the surface. In situations where "Controlled
Industrial Wastes" (hazardous wastes) are retained above
ground level secondary or back-up dikes are recommended
around the primary dikes to prevent exit of the wastes
from the facility in the event the primary dike is breached.
Secondary dikes, for both types of pond/lagoon construction,
should be designed and constructed to insure that the area within
a secondary dike is capable of retaining a minimum of 1.25 times
the volume of waste material retained above ground level within
the primary dikes.
"Above" - and "below-ground" ponds/lagoons are not required
to be lined if the underlying'soil is relatively impermeable
7
( 10- cm/sec) and of sufficient thickness to prevent seepage of
wastes from pond or lagoon into the ground water. If these
conditions are not met, then the ponds are to be lined.
Dikes for all ponds are to be "keyed" into the underlying
soil to promote a good seal between the ground and the dike
bottom in order to prevent lateral migration/seepage of wastes
through the base of the dike."
Operation - "Regardless of the type of pond facility con-
structed it must be operated in such a manner so as to serve its
intended purpose without posing a water pollution threat.
39
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Maintaining proper freeboard, accepting only those wastes which
are compatible with and not detrimental to the pond lining,
and taking care not to rupture the liner are just a few of
the things that the operator must be constantly concerned with.
Other potentially harmful or undesirable conditions such as foul
odors, oil slicks on pond surface, or fires, should be minimized
or eliminated if possible.
(3) California - According to the regulations published
by the State Water Resources Control Board, both disposal sites
and wastes have been categorized. Wastes which consist o? or
contain toxic substances are classified as Group I wastes. "Hazar-
dous Wastes" are included in this group. The only classes of
disposal sites which can accept Group I wastes, including hazardous
wastes, are described below:
Class I - There must be no possibility of discharge of
pollutant substances to usable waters. Artificial barriers
may be used for control of lateral wastes movement only.
Usable groundwater may underlie the site, but only under
extreme cases and where natural geological conditions
prevent movement of the wastes to the water and provide
protection for the active life of the site. Inundation
and washout must not occur. All waste groups may be
received.
Limited Class I - A special case of Class I site is
established where a threat of inundation by greater than
a 100-year flood exists. A limitation is placed on the
40
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type and amount of Group 1 wastes that may be accepted.
Class II-l - These sites may overlie or may be adjacent
to usable groundwater. Artificial barriers may be used
for both vertical and lateral waste confinement in the
absence of natural conditions. Protection from a 100-year
frequency flood must be provided. Group 2 and 3 wastes
can be accepted and under special conditions, certain
Group 1 materials may be accepted.
Most hazardous waste impoundments (ponds/lagoons), therefore,
must be in areas where the natural geologic setting protects
groundwater quality. Artificial liners are not considered
adequate to provide groundwater protection from all Class I
wastes.
Regarding surface water protection, Class I sites may have
artificial barriers to control lateral waste movement. The
modifications made to enable lateral control of waste migration
must be in a manner acceptable to a regional board. The imper-
meable conditions established should meet all of the following
criteria if the barrier is comprised of soil, or provide
equivalent impermeable conditions if comprised of approved
synthetic materials:
p
a. Permeability of 10- cm/sec, or less permeable.
b. CL, CH or OH soils per Unified Soil Classification
System.
c. Not less than 30% by weight passes a No. 200 sieve
(U.S. Standard).
41
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d. Liquid limit of not less than 30 (ASTM Test D423) .
e. Plasticity index of not less than 15 (ASTM Test D424) .
f. Permeability is not adversely affected by chemical or
physical reaction with the anticipated wastes.
Sites made suitable for use by man-made physical barriers
shall not be located where improper operation or maintenance of
such structures could permit the waste, leachate, or gases to
contact usable ground or surface water. The integrity of waste
containment structures must be maintained. Excavations made as
part of the site operation should not result in removal of por-
tions of confinement barriers without prior evaluation of the
effect on containment features. Waste disposal facilities
utilizing mechanical equipment such as pumps must be designed
to prevent overflows due to malfunction of the equipment.
Inundation and washout must not occur. The State suggests that
freeboard should be established to prevent overflow under the
greatest anticipated 24-hour or 6-day rainfall and wind condi-
tons, whichever is more restrictive. Sites which meet all the
criteria for Class I sites except they are subject to inundation
by a tide or a flood of greater than 100-year frequency may be
considered by the regional board as a limited Class I disposal
site.
(4) Pennsylvania - Impoundments (ponds/lagoons) are regulated
by the Bureau of Water Quality Management within the Department of
42
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Environmental Resources. According to the regulations: "No person
or municipality shall operate, maintain or use or permit the operation,
maintenance or use of an impoundment for the production processing,
storage, treatment or disposal of polluting substances, unless such
impoundment is structurally, sound, impermeable, protected from
unauthorized acts of third parties and is maintained so that a
freeboard of at least two (2) feet remains at all times".
Except where impoundment is already approved under an existing
permit, a permit from the Department is required approving the
location, construction, use, operation and maintenance of the
pond or lagoon.
According to the general policy, the "impermeability" is
a coefficient of permeability. If natural deposits are used,
they must have a uniform thickness of greater than 2 feet and
must have a permeability of less than 1x10- cm/sec. If the
uniform thickness is greater than 4 feet and there is an upward
groundwater flow, the permeability may be increased to IxlO-6
cm/sec or less. Synthetic liners of membrane type must have a
minimum thickness of 20 mils and a natural permeability of less
than 1x10- cm/sec.
(5) New York - The State of New York has its own groundwater
quality standards and a facility discharging to groundwaterd must
have a permit. For a hazardous waste surface impoundments to obtain
such a permit, it must have an impervious lining and all leachate
-------
and runoff from the impoundment must be collected and treated
adequately. No formal guidelines or criteria for permitting
facilities have been adopted, and each impoundment is judged
individually*
(6) Maryland - By July I/ 1977, all hazardous waste surface
rx-b
impoundmej/s in Maryland will have to obtain an interim permit.
These permits will be issued on a case-by-case basis, though these
facilities will not be allowed to leak. The Maryland Department of
Natural Resources, which is in charge of hazardous waste surface
impoundments in Maryland, has no formal guidelines or criteria for
use in permitting these facilities. However, permitting officials
will use standards and/or guidelines already established by
other organizations for pond design. Such organizations include
the U.S. Soil Conservation Service and the American Society
of Civil Engineers.
(7) Oregon - Industrial waste surface impoundments in Oregon
are required to be permitted. To be permitted, an impoundment must
be designed so as to be watertight; thus, a liner is usually
required. The design adequacy of each impoundment is judged on a
case-by-case basis, and no formal guidelines are used.
(8) Ohio - Ohio does not have nay published regulations per-
taining to hazardous waste management facilities, nor is there a permit
program for such facilities. The Director of the Ohio Environmental
44
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Protection Agency, however/ can issue an order requiring facilities,
to take certain environmentally protective measures (i.e. clay
liners in ponds, etc.)
(9) Illinois - Has no uniform program requiring hazardous
waste surface impoundments linings.
45
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IV. Analysis of Regulatory Options
The damage incidents described in Part II of this document
clearly outlined the pollution potential associated with hazardous
waste surface impoundments. However, the treatment, storage or
disposal of hazardous wastes in properly located, designed,
constructed, operated and maintained surface impoundments could
be an acceptable, economical and environmentally sound waste
management practice.
Surface water pollution problems, relative to the hazardous
waste surface impoundments, are usually results of breaks in the
dikes or overtopping, with subsequent spilling over of hazardous
wastes to the surface waters. Such incidents have resulted in
water contamination, fish kills and degradation of the
stream.
The movement of hazardous wastes through surface impound-
ment into the groundwater can also cause human health and
environmental damage. The groundwater has little assimilation
capacity compared to the surface water. The rate of movement
of groundwater is extremely low relative to surface water.
Unlike streams, which can rebound from pollution conditions
in few years, ground water does not experience the flushing
action of a stream flow, nor does it experience the purifying
effects of air, light or aerobic biological activity. Instead
it flows very slowly, receives less dilution, has essentially
no oxygen to degrade pollutants under aerobic conditions, and
46
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flows through a medium where surface tension tends to hold
pollutants in a "plume" instead of dispersing them. Since the
potential for the groundwater to recover from a polluted condi-
tion is very low, a high degree of groundwater protection should
be provided by the regulations.
Generally, the pollution potential of hazardous waste
surface impoundments depend on a number of things such as:
1. Site location (e.g., geological, hydrological para-
meters of site, geographical location, etc.).
2. Composition, reactivity and physical state or form
of wastes to be contained.
3. Design and construction of the facility.
4. Operation and maintenance at the facility.
5. Closing procedures and post closure care.
All of these factors should be given careful consideration
if impoundments are to be utilized without creating a threat
to the public health and environment.
From the description of various state regulations in Part
jjl of this document, it is clear that there are several alter-
native regulatory options that can be adopted for regulation
of hazardous waste surface impoundments.
In accordance with EPA regulatory strategy, Part 250,
Subpart D of the regulations includes two types of performance
Standards (under Section 250.42), and design and operating
standards (Sections 250.43 through 250.45). The design
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and operating standards, which cover general facilities standards,
storage standards, and treatment and disposal standards, are
designed to protect public health and the environment and, therefore
to achieve compliance with the Health and Environmental Standards
under most situations. The Health and Environmental Standards
are meant to be overriding standards to supersede the design
and operating standards.
Under this regulatory structure, it is intended that the
design and operating standards will be the principal regulatory
criteria used to manage the treatment, storage and disposal
of hazardous wastes, where there is a reason to believe that
design and operating standards will not achieve compliance with
the Health and Environmental Standards, it is intended that the
both will be used as the basis for regulatory action.
Following the foregoing rationale, the design and operating
standards are designed to provide protection of public health
and the environment for most situations.
In achieving this purpose, however, this standard may, in
some instances, unnecessarily over-regulate some situations.
Additionally, being based on the current state-of-art of treatment
storage and disposal practices, the standards may preclude
technological inovation and advancement of the state-of-the-art.
In recognition of this problem, some of the design and operating
standards include notes, which prescribe the criteria for
deviation from such standards. In all cases, the basis for
deviation is achievement of equivalent containment or destruction
of the hazardous wastes. It is believed, that the above approach
48
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will prevent over-regulation without sacrificing public health
and environmental protection, and will permit application of
new technology which would not otherwise be permitted by the
specificity of the design and operating standards.
The Analysis of human health and environmental protection
provided by each standard is presented in Section V of this
background document.
49
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V. Identification of Chosen Regulation and Associated Rationale
(a) Site Selection.
SEandardid) Surface impoundments shall be located, designed,
constructed, and operated to prevent direct contact between
the surface impoundment and navigable water.
Rationale;Surface water should not be allowed to interact with
hazardous waste deposited in the surface impoundment, since
it could allow the wastes to escape to the environment.
Additionally, water contacting the surface impoundment struc-
ture could erode or otherwise deteriorate its structural inte-
grity. A regulation prohibiting direct contact between surface
impoundments and surface water would prevent such problems.
A. The precedents set by the State of Texas and Oklahoma
established the fact that such procedures are recognized good
practices. Portion of Texas, and Oklahoma's hydrologic criteria
for a hazardous waste "pond/lagoon" site location requires that
significant "hydraulic" connection (surface or subsurface)
between the site and standing or flowing surface water should
be absent.
B. Consequences of not having such a regulation are
listed below:
50
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(i) Direct contact (surface or subsurface) with surface
water would hasten the movement of hazardous wastes into surface
water and away from the site. This is especially significant for
surface impoundments since wastes contained in such facilities
are either liquids or semi-liquids with hazardous components
either in soluble or in readily soluble form.
(ii) Surface water contacting the surface impoundment has
a potential to:
(a) carry dissolved and undissolved hazardous components
away from the site,
(b) infiltrate the impoundment and damage its structural
integrity (e.g., damage liners, break dikes).
51
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Standard:(2) A surface impoundment shall be located, designed,
and constructed so that the bottom of its liner system or
natural in-place soil barrier is at least 1.5 meters (5 feet)
above the historical high water table.
Note: The bottom of any liner system or natural in-place
soil barrier may be located less than 1.5 meters
(5 feet) above the historical high water table
provided the owner/operator can demonstrate to
the Regional Administrator, at the time a permit
is issued pursuant to Subpart E, that no direct
contact will occur between the surface impoundment
and the water table, and a leachate monitoring
system as required in Section 250.43-8 can be
adequately installed and maintained in the lesser
space.
Rationale*, The objective of this regulation is to insure that a suffi-
cient distance exists between the bottom of any surface impound-
ment and groundwater that will prevent direct contact between
the impoundment and the aquifer; will allow for the emplacement
of the leachate monitoring system as required under Section
250.43-8, and provide reaction time for responding to an
unacceptable discharge should one be detected.
Essentially, the above regulation is intended to ensure
that a buffer zone of natural attenuation exsits between
the surface impoundment and groundwater. The presence of
such a zone may make a difference between what would be a
52
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minor/ reversible pollution problem and a major irreversible
one.
The separation between the bottom of the impoundment
and the aquifer will prevent the aquifer from becoming con-
taminated immediately in the event of failure of the liner
system*fetilur». Thus, if a leak is detected, some time will be
available for implementing contingency plans before the
aquifer becomes contaminated. It will also provide room
for the emplacement of the leachate monitoring equipment,
where required by design specifications. Furthermore,
the buffer zone provides for unpredictable fluctuations
of the groundwater level, reducing the possibility of
direct contact between the groundwater and impoundment liner
system, especially in the case of artificial liners.
The parameters for hazardous waste "ponds and lagoons"
in Texas and Oklahoma specify the depth to the groundwater
table as 50 feet unless the "pond and lagoon" is located in
a massive, relatively impermeable formation, where the dis-
tance could possibly be reduced to 5 feet. Other states
such as: Maryland, New York, Pennsylvania, Oregon and Ohio
have no formal guidelines or criteria in this area? however,
they seem to be more conservative in their approach.
It may be advantageous to require a greater distance to
the groundwater table as an added precaution. This would,
however, automatically exclude a number of potential and
53
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existing sites around the Gulf Coast and elsewhere, because
of naturally high groundwater conditions. Since surface im-
poundments are an essential part of industrial wastewater
treatment for the industry in these areas, standards prevent-
ing their use would cause a serious impact on industry. Ad-
ditionally, there is no definitive evidence that a separation
of 5 feet, or greater, is needed for human health and
environmental protection.
When the 5-foot requirement is used in conjunction with
design and construction criteria under Standard (c)(3) and
(c)(4), and other requirements of this section, it should satisfy
all above-stated objectives of the regulation and in the
same time provide more flexible approach.
Furthermore, the above regulation is accompanied with
a note which prescribes the criteria for deviating from the
standard. The basis for the deviation allowed is the
achievement of equivalent separation between the impoundment
and the water table, and the adequate installation of a leachate
monitoring system.
Consequences of not having such regulation are listed below
(i) Direct subsurface contact with groundwater
would hasten the movement of hazardous wastes
into groundwater. This is especially significant.
for surface impoundment, since waste contained
in such facilities are either liquids or semi-
liquids with hazardous components either in
soluble or in readily-soluble form.
54
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(ii) Direct contact with groundwater will preclude the
existence of an unsaturated zone under and around
the surface impoundment. This automatically eliminates
any natural attenuation or buffering capacity that
could exist in such an unsaturated zone. Additionally,
the time to detect and correct a problem before
environmental damage can occur is reduced if not
eliminated.
(iii) Direct contact with groundwater will preclude in-
stallation of leachate monitoring equipment required
under (c)(3) of this Section, thus preventing early
detection of the liner system failure.
The precednets set by the State of Oklahoma and Texas
established the fact that such procedures are recognized good
practices. Portion of Texas' and Oklahoma's hydrologic
criteria for hazardous waste "pond/lagoon" site location
requires that significant "hydraulic" connection (subsurface)
between the site and groundwater should be absent.
55
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Standard;(3) A surface impoundment shall be located at least 150
meters (500 feet) from any functioning public or private water
supply or livestock water supply.
Note: A surface impoundment may be located less than
150 meters (500 feet) from any functioning
public or private water supply or livestock
water supply provided the owner/operator can
demonstrate to the Regional Administrator, at
the time a permit is issued pursuant to Subpart E,
that:
(i) No direct contact will occur between the
surface impoundment and any functioning
public or private water supply or livestock
water supply;
(ii) No mixing of the leachate (including
groundwater or surface water contaminated
with leachate) with the public or private
water supply or livestock water supply
will occur.; and
(iii) A groundwater monitoring system as required
by Section 250.43-8 has been installed and
is being adequately maintained.
Rationale;Because groundwater is a major source of drinking water, and
drinking water can have a direct effect upon public health, a
buffer zone between the surface impoundment sites and water
supply wells is desirable. A buffer zone of 150 m (500 feet)
between impoundment site borders and drinking water supplies
provides a margin of safety that will allow for detecting and
responding to a groundwater problem before neighboring drinking
water supplies can be affected. 56
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A review of several state regulations, in respect to
the general site selection^reveals a difference in their
approach used to develop buffer zone regulations. Most
states prefer to regulate on the site specific basis, the
premise being that the distance needed between the surface
impoundment and water supply well is dependent.
At least two states, Texas (State Department of Health
Resources) and Wisconsin (Department of Natural Resources),
prefer to specify a distance, 500 feet (150 m) and 1250 feet
(375 m), respectively. The states' rationale behind specify-
ing number is that it provides a tangible point of reference
and facilitates enforcement. Being cognizant that a specified
distance may not be applicable in some situations, both states
maintain a flexible attitude and allow for concessions to
be made. For example, Wisconsin requires special construction
techniques to be used for construction wells with 1250 feet
(375 m) of a site; Texas allows wells within 500 feet (150 m)
if certain site parameters can provide the equivalent of
500 feet (150 m) of protection.
The regulatory approach taken by EPA similarly incor-
porates the advantages of having a tangible reference point,
57
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with the versatility of allowing for concessions to be made
under special circumstances.
Although the conservative value of 150 m (500 feet) was
chosen, when it is used in conjunction with other require-
ments in this section, it provides adequate time for detect-
ing and responding to a problem when one is detected.
Essentially, a distance of 150 m (500 feet) is relied
upon in terms of providing a margin of safety and is not
expected to serve as the main barrier to pollution of a water
supply well.
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Standard?(4) Surface impoundments shall be located or designed,
constructed, and operated to minimize landslides, slumping,
and' erosion.
Rationalel Erosion, landslides and slumping are three geophysical
forces that can potentially disrupt the enviromental
integrity of a surface impoundment. The main object of the
above regulation is to ensure that such a disruption does not
occur.
Being cognizant of the fact that few potential sites
will be free of such forces, the regulation was written to
allow flexibility, i.e., if an ideal site could not be found
then engineering against such geophysical forces would be
acceptable. It is germane to point out that locating sur-
face impoundment in an area known to be subject to extensive
erosion, landslides, and/or slumping will require that site
improvements be made and/or operational techniques be employed,
59
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The potential consequences of not locating or designing
against erosion, landslides and slumping are listed below:
1. Erosion
Erosion can deteriorate the structural stability of
the pond or lagoon. Exposed portions of earthen dikes
are especially susceptible to erosion. Subsequent
infiltration or breaching of the dikes can hasten the
movement of hazardous constituents from the site. The
ultimate result is polluted surface runoff which requires
collection and treatment to prevent surface water
contamination.
2. Landslides
Landslides, along with floods and erosion, are common
occurrences caused by weather, the nature of soils, and
gravity. Each, however, can produce a change in a
site, thereby directly affecting the rate at which
contaminants reach the environment.
60
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A landslide near or within a site can disturb its
structural integrity. All environmental media could
be adversely affected in the event of a landslide,
thus disrupting the containment system of a surface
impoundment. Areas subject to, or having had landslides
are undesirable locations for siting surface impound-
ments because the loose unconsolidated soil that
characterizes such an area would lack the necessary
structural integrity needed to safely support such
facilities.
3. Slumping
The slumping or subsidence of land beneath a surface
impoundment can:
A. Disturb structural integrity of the impoundment,
B. Breach the containment system of such facilities,
C. Bring the bottom of the surface impoundment and
groundwater into closer proximity if not direct
contact.
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(b) Hazardous waste Suitable for Surface Impoundments
Standard*.(!H A surface impoundment shall not be used to contain
hazardous waste which is:
(i) Detrimental to any material being used as a
barrier to the waste movement from the surface
impoundment,
(ii) Ignitable waste, as defined in Section 250.13 (a)
of Subpart A,
(iii) Reactive waste, as defined in Section 250.13 (c)
of Subpart A, or
(iv) Volatile waste.
Note: (Relative to ii, iii, and iv) see Note associated
with Section 250.45(c).
Rationale*.The pollution potential of a surface impoundment depends,
among other things, on the specific characteristics of the
wastes to be contained. The possible reactions between the
materials being used as barriers to movement, and contained
hazardous wastes can detrimentally affect the ability of
surface impoundment to islolate wastes and prevent
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their escape to the environment.
The impermeable barriers (liners, in-place soil, dikes)
consist either of clay and fine-grained soils, or artifical
materials (concrete, plastics, etc.). However, some
materials are not compatible with some hazardous wastes.
For example, some natural impermeable soils may fail when
exposed to strong acids; synthetic membranes and asphalts
are vulnerable to attack by certain hydrocarbon solvents.
Table 1 summarizes some of the advantages and disadvantages
of several liner types.
The reactions between the contained wastes and liner or
dike construction materials can increase permeability or
cause dissolution of these materials and can result in the
escape of the hazardous substances to the environment, with
the subsequent adverse effects on human health and the
environment. It is, therefore, imperative that the hazard-
ous wastes to be contained are compatible with construction
materials, and that such determination is made before wastes
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TABLE 1
ADVANTAGES AND DISADVANTAGES OF SEVERAL LINERS
Alternatives
Advantages
Disadvantage s
Natural Clayey Soil
Self-sealing elements provide Not available in all geographic
adequate ground-water protection regions. Exposure to certain
acids and chemicals may cause
failure
Bentonite Clay
Very low permeability provides
ground-water protection
Failure may occur when exposed
to acids and certain chemicals '
Low-cost synthetic membranes Most membranes have good tensile Not recommemded for retention
Paved asphalt with a tar
cover
Paved asphalt with a syn-
thetic membrane
1.2 m (4 ft) layer of
common clay
Clay barrier with synthetic
membrane
strength, low temperature flex-
ibility and resistance to a
number of chemical wastes
Provides firm structural sup-
port
Provides structural integrity
and resisitance to chemical
attack
Low permeability .-ipeci f ications
provide ground-water protection
Structural integrity and self-
scaling properties of clay pro-
vide a very high degree of
ground-water protection
of hydrocarbons and solvents.
Data on long-term integrity is
lacking. High-cost may cause
use to be economically infeas-
ible
Vulnerable to attack by certain
hydrocarbon solvents
Vulnerable to attack by certain
hydrocarbon solvents. Use of
certain synthetic membranes coulj
elevate cost
Exposure to certain acids may
cause failure. Not available in
all geographic areas
Expose to certain acids over a
long-term period may cause fail-
ure. Clay is not available in
all geographic regions. Use of
certain synthetic membrane could
elevate cost
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are deposited/ so that such incidents are avoided.
The containment of hazardous wastes that are highly
reactive, ignitable, or volatile, in surface impoundments,
may generate hazardous emissions endangering workers or
neighbors of a facility, and potentially disrupt the
environmental soundness of the operation. The explosions
could disrupt the structural integrity of the impoundment
and cause subsequent leaks of hazardous wastes into the area
groundwater and surface water. The impermeability of some
artificial liners {e.g., synthetic liners) could be adverse-
ly affected by the fire and result in hazardous leaks into
the groundwater and surface water. The containment of high-
ly volatile hazardous wastes in surface impoundments could
result in unregulated discharges into the air. The
fires could also cause unregulated discharges into the en-
vironment. For example, burning of hazardous organic wastes
65
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containing halogens or heavy metals will result in formation
of toxic gaseous components and their transmission into the
air. The potential fires and explosions, with subsequent
environmental problems, could be also a result of containment
of hazardous wastes that are highly reactive with air and
water. It is, therefore, imperative that such practices
are avoided.
The rationale for selection of vapor pressure greater
than 78 mm Hg at 25°C (under (iv)}, is given in a separate
background document - (3) Air Human Health and Environmental
Standard.
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Standard!(2? Hazardous waste which is incompatible (see Appendix I)
shall not be emplaced together in a surface
impoundment.
RationalerMixing of hazardous wastes that are not compatible with
each other in hazardous waste surface impoundments can
result in many environmental problems, such as: violent
reactions, excessive heat or pressure generation and potential
fires and explosions, and subsequent dispersion of hazardous
components into the air, or formation of hazardous gaseous
fumes and their transmission into the air. For example,
mixing of cyanide and sulfide containing alkaline wastes
with acidic wastes will release toxic HCN and H2S vapors
into the environment; uncontrolled mixing of concentrated
acidic and akaline wastes could result in violent reactions
and excessive heat generation and subsequent environmental
problems. Mixing of hazardous wastes containing highly
reactive components (e.g., oxidation-reduction agents and
organics, etc.) could result in explosions and fires. The
major objective of the above regulation is to ensure that
such disruptions do not occur.
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Standard;(3) All hazardous waste shall be tested, prior to
placement in a surface impoundment, for com-
patibility with the intended liner materials
to determine whether it will have any detrimental
effect (e.g., cause cracks, dissolution, decrease
mechanical strength, or increase permeability) on
the soils or lining materials used to prevent
leakage from the surface impoundments.
Rationale? The conceptual objectives and rationale for this regula-
tion are described in a rationale given for regulation (b) (l)
(i) of this section; i.e., to assure that the hazardous
wastes to be contained are compatible with soils and lining
materials used for construction of hazardous waste surface
impoundment.
The possible reactions between the soils and/or lining
materials can detrimentally effect the ability of the impound-
ment to isolate wastes and prevent their escape into the
68
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environment, it is, therefore, evident that the compatibility
of wastes with potential lining materials should be the
first consideration in design and construction of the surface
impoundment. No waste having a significant detrimental
effect on the materials used as barriers to movement of the
wastes from the impoundment (e.g., causing dissolution,
increasing permeability), and consequently resulting in
seepage of such hazardous wastes into the environment,
should be deposited in such facilities.
The liner materials have been characterized to some
extent in the literature, particularly in information that
is available from various manufacturers, fabricators, sup-
pliers, installers and trade associations. Manufacturers
and fabricators do make available information concerning the
physical, chemical and mechanical properties of specific
materials that they either manufacture or formulate. However,
the literature is fairly sparse as far as meaningful informa-
tion regarding engineering and performance data, on which to
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base engineering analysis for a specific liner/waste
situation.
Liner studies presently being undertaken by Matrecon,
Inc, under a contract to EPA have shown that certain liner
materials, are incompatible with certain waste types.13
For example, clays can only hold strongly acidic and caustic
wastes for a short time period; aromatic hydrocarbons wastes
will dissolve, or cause most membrane liners and asphaltic
materials to swell. However, the above study does not test
all liner/waste situations, nor does it test the durability
of all liner adhesive and seaming techniques, nor the dura-
bility of liners under various climatic conditions.
The fact that the individual waste characterisitcs vary
necessitates testing of different lining materials with the
hazardous wastes of interest, to determine maximum perfor-
mance characteristics. Factors to be considered should
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include liner's deterioration upon contact and after prolonged
contact with hazardous wastes of interest, and alterations
of the liner material's permeability with time. For the
ultimate success of surface impoundments for the containment
of hazardous wastes, and to assure environmentally sound
performance, it is, therefore, necessary to require testing
for compatibility of hazardous wastes with the intended liner
materials, either during the design stage, or prior to disposi-
tion of hazardous wastes into an existing impoundment, if the
waste is different from that of previously deposited in such
impoundment.
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(c) Design and Construction
Standard:(l) A surface impoundment shall be designed and con-
structed so as to be capable of preventing discharges
or releases to the groundwater or navigable water.
Rationale;The objective of the above regulation is to assure that
the surface impoundments are designed and constructed in a
manner that will assure their environmenatlly sound operation
during the expected life of the facility.
Surface impoundments, in general are the most common
industrial and/or hazardous waste management facilities.
These versatile installations could serve many basic
purposes, including:
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* settling and removal of suspended solids,
* holding and impoundment of wastewater,
* holding and impoundment of settled solids,
* equalization,
* aeration,
* neutralization,
* biological treatment,
* disposal through evaporation.
Their relative simplicity and low operating cost makes
them a preferred technology for handling of various in-
dustrial wastes, including hazardous wastes. Treatment,
storage and disposal of hazardous wastes in properly located,
designed and constructed surface impoundments can be an
acceptable, environmentally sound hazardous waste management
practice.
By their nature, surface impoundments, with the exception
of disposal ponds/lagoons, are temporary structures
7.3
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with variable lengths of service life. However, regardless
of the expected service life, the environmental soundness
of each impoundment depends directly on the materials used
for construction, i.e., compatibility with the hazardous
wastes to be contained; durability upon prolonged contact
with the hazardous wastes of interest; and alteration of
permeability over time. Since the above characteristics
may vary with each construction material and each material/
waste situations, all construction materials should be selected
such that their durability and permeability is not adversely
affected by prolonged contact with the hazardous wastes of -
interest and remains unchanged during the expected service
life of the facility.
The potential consequences of improper design and con-
struction of surface impoundments are the failure of hazardous
waste containment and subsequent leaks of hazardous components
into the environment or shortening of the expected service
life of the facility.
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Standard'(2) Where natural geologic conditions allow/ a surface
impoundment shall have a natural in-place soil barrier
on the entire bottom and sides of the impoundment.
This barrier shall be at least 3 meters (10 feet) in
thickness and composed of natural in-place soil which
meets the specifications of paragraph (c)(4).
Note: An owner/operator of a surface impoundment may
use a natural in-place soil barrier of different
thickness and different specifications if the
owner/operator can demonstrate to the Regional
Administrator, at the time a permit is issued
pursuant to Subpart E, that equivalent or greater
waste containment can be achieved. However, under
no circumstances shall the thickness of the natural
in-place soil barrier be less than 1.5 m (5 feet),
or its permeability be greater than 10" cm/sec.
RationaletThe hydraulic conductivity and the
thickness of the soil liner are factors
addressed by the States that have
existing regulations or guidelines for
hazardous waste surface impoundments.
Oklahoma requires 10 feet in-place soil thick-
ness of £1X10 cm/sec, of clay-rich soil for
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"ponds and lagoons;" Texas specifies 4 feet of - 1X10"^
cm/sec, in-place underlying soils for "ponds and lagoons."
In Pennsylvania, the natural deposits underlying the
potential "pond/lagoon" sites must have at least 2 feet
> -7
of - 1X10 cm/sec, clay-rich soil.
The criteria chosen for the EPA regulation followed the
precedent in Oklahoma's requirements, which provide the
greatest groundwater protection of the above state regula-
tions/guidelines. The rationale is given below:
Movement of contaminants through the underlying strata
is governed by hydraulic factors, including the relative
permeability of the underlying material, the depth to the
cf
zone.satruation (water table), and the location and areal
extent of recharge (positive head)-. Physical, chemical,
and biological properties of the geologic materials may
effect a reduction of contaminant levels (natural attenuation)
Any contaminant deposited on the ground surface is in
a position where it can easily enter the geologic environ-
ment of soils, and unconsolidated or solid rocks, as long
as they contain pore spaces or other openings. Liquid con-
taminants and solid contaminants that undergo leaching by
water from precipitation can infiltrate whenever the soils
are sufficiently permeable, and percolate downward through
the unsaturated material to the water table.
The factors that relate to the release characteristics
of the site include soil thickness, soil permeability, depth
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of water table, and other soil characteristics specified
under (c)(4). The release time will vary with changes in
the thickness of clay, depth to water table/ and hydraulic
conductivity of the material above the water table.
The regulatory philosophy prevailing in the United States
today favors maximum containment instead of slow release into
the environment.
Containment is of course directly affected by the
liquid content of the waste materials. Increasing the
liquid fraction will generally decrease the potential of
containment. Since the wastes contained by surface impound-
ments are primarily liquids or sludges with high water
content, the potential for containment is much lower,
when compared to landfills, which could regulate the liquid
content in wastes or the amount of percolation. Therefore,
the use of the most stringent requirements for surface impound-
ments are fully justified.
Objections, however, can be raised as to the availability
of natural sites that will satisfy the above requirements.
In that respect, the "note" under (c)(2), of this section,
provides needed flexibility by allowing other combinations
of soil thickness and permeabilities that will achieve
equivalent containment, and by providing an alternative
design specified under (c)(3) of this section.
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Surface impoundments designed in accordance to (c) (2) ,
are subject to leachate monitoring, as specified in 250.43-8.
The primary objectives of leachate monitoring under the natural
in-place soil » is to prevent contamination of usable aquifers
through early detection of any failure of natural containment,
and to allow initiation of necessary corrective procedures
before the contaminants reach the groundwater. The rationale
for leachate monitoring requirement is given in a separate
background document - (12) "Groundwater and Leachate Monitoring'
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Standard!(3) Where geologic conditions do not allow use of the
design in paragraph (c)(2), a surface impoundment
shall have a liner system covering the entire
bottom and sides of the impoundment. This liner
system shall consist of top liner, a bottom liner
and leachate detection system which meet the
following specifications:
(i) The top liner shall consist of emplaced
soil at least 30 centimeters (12 inches) in
thickness which meets the criteria in
paragraph (c)(4), or an artificial liner
which meets the criteria in paragraph (c)(5).
(ii) The bottom liner shall consist of natural
in-place soil or emplaced soil which meets
the criteria in paragraph (c)(4) and is at
least 1.5 meters (5 feet) in thickness/ or
an artificial liner which meets the criteria
in (c) (5) .
(iii) The leachate detection system shall be a
gravity flow drainage system installed
between the top and bottom liners and shall
be capable of detecting any leachate that
passes through the top liner. Provisions
shall be made for pumping out any leachate
that passes through the top liner and for
removal of noxious gases that occur in the
system.
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Note: An owner/operator may use a different design
if he can demonstrate that an equivalent or
greater degree of waste containment is achieved.
The Regional Administrator shall take into
account the length of time the surface impound-
ment has been in existence, projected facility
life, and artificial liner, natural in-place soil
or emplaced soil permeability and thickness
when arriving at a decision regarding whether an
equivalent degree of containment exists. in the
case of existing facilities, the facility owner/
operator may conduct leachate (zone of aeration)
monitoring to determine whether any significant
increase in the background levels of chemical
species has occurred. If no significant increase
is observed, the design shall be considered to
provide the same or greater degree of performance
Rationale; The objective of the above regulation is to provide
maximum protection for human health and the environment at the
sites where natural soil conditions do not allow use of the
design in (c)(2), (i.e., are not suitable for "natural
containment"), and to provide maximum flexibility in design
and construction.
In accordance with the above regulation, the top (facilit
liner could be constructed of natural or specific reconstituted
or rework soils which meet the criteria under (c)(4), or of
the artificial materials which meet the criteria under (c) (5)
of this section.
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The primary function of the top liner is to serve as
a barrier between the hazardous wastes and the environment.
Because the top liner will be in direct contact with
contained wastes, compatibility is the primary criterion
for its selection (see (b)(1)(i) of this section). Both
soil and artificial liners are permitted as a top (facility)
liner. This allows for needed flexibility to match liner
with hazardous wastes to achieve maximum compatibility and
environmental protection.
The use of artificial liners for hazardous waste surface
impoundments is considered to be a good engineering practice.
Texas, Oklahoma, Pennsylvania and other states permit the
usage of artificial liners as long as they are compatible
with subject wastes. Although clay liners are preferable
for landfills, the specific nature of impoundments makes
artificial liners acceptable. The surface impoundments
are normally temporary containing devices for hazardous
wastes. In the event a liner failure is detected, the
wastes can be removed, and the liners replaced or repaired
before a usuable aquifer is adversely affected. On the
other hand, however, the long-term effect of wastes on
permeability and integrity of membrane liners is generally not
known.
Accordingly, artificial liners are allowed only in situations
where they are used for temporary containment of wastes
(i.e., in ponds where the wa-stes are removed upon closure).
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The bottom liners, based on the intended purpose of
the surface impoundment, and on the local conditions, could
consist of natural in-place soils, reconstituted or reworked
clays or artificial materials.
The primary function of the bottom liner is to serve
as a barrier between hazardous wastes, in the case of
their migration/seepage through the top (facility) liner,
and the zone of aeration. Since the EPA regulations do
not specify permeability of the underlying strata under
the facility liner system (zone of aeration), the soils
could be highly permeable. in this situation, if a bottom
liner did not exist and a leak in the top liner occurred,
hazardous wastes would probably infiltrate into the
ground water very rapidly.
The incorporation of the impermeable bottom liner into
the design/construction criteria serves as an additional
protection of usable aquifers. Because of the above fact
and the closer proximity to the groundwater, the imper-
meability and mechanical integrity of the bottom liner is
more critical than that of the top liner.
The selection of the bottom liner should be based
primarily on the compatibility with expected wastes and
intended use of the surface impoundment (i.e., temporary
or permanent containment of wastes). The clay liners
would be preferable as bottom liners. An advantage of
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clay liners over synthetic liners is that clay remains a semi-
fluid material when wet and is, therefore, self-sealing
should the barrier be penetrated. Furthermore, the long-
term effect of the majority of hazardous wastes on artificial
membranes is not known at the present. This information is
critical, especially if the wastes are to remain in the
impoundment after its closure. Therefore, if the artificial
liner is used as a bottom liner, wastes and the liner must
be removed from the surface impoundment prior to its closure
(see (e)(1)) of this section. If the wastes are to remain
in the surface impoundment permanently, the facility
essentially becomes a secure landfill and must have liners
which comply with the landfill regulations under 250.45-2 of
this section.
The requirement of a minimum thickness of 1.5 m (5 feet)
for all soil bottom liners is consistent with regulations
under (c)(2) of this section.
The above regulation requires installation of a leachate
detection system installed between top and bottom liners.
Since the purpose of the leachate detection system is to detect
any failure of the top liner, the monitoring of the aeration
zone, specified under Section 250.43-8, is not required.
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Noxious gases may accumulate under the top liner
as a result of biological activities or chemical
reactions. Air is also frequently trapped under the
membrane liner during construction in loose porous soils
and depressions are formed under the membrane. As the
membrane begins to conform to its bearing surface, air
begins to accumulate and to appear as bubbles under the
liner. Once the problem is corrected, the air bubbles will
not normally reappear. However, in some situations decaying
organics or chemical reactions will release gas under the
liner on a continuing basis. If the situation is encountered
permanent vents should be provided to constantly vent the
generated gas, to prevent operating problems or permanent
damage of the liner.
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Standard?(4) Soils used for surface impoundments liners or
natural in-place soil barriers shall:
(i) Be classified under the Unified Soil
Classification Systems as CL, CH, SC, or OH,
{ASTM Standard D2487-69);
(ii) Allow more than 30 percent passage through
a No. 200 sieve (ASTM Test D1140);
(iii) Have a liquid limit equal to or greater
than 30, (ASTM Test D423);
(iv) Have a plasticity index equal to or greater
than 15, (ASTM Test D424);
(v) Have a pH of 7.0 or higher, (See Appendix IV);
(vi) Have a permeability equal to or less than
1X10"7 cm/sec. (ASTM Test 2434); and
(Vii) Have a permeability not adversely affected
by the waste to be placed in the impoundment/
Note: Soil not meeting the above criteria may be used
provided that the owner/operator can demonstrate to
the Regional Administrator, at the time a permit is
issued pursuant to Subpart E, that such soil will
provide equivalent or greater structural stability
and waste containment properties and will not be
adversely affected by the waste to be placed in the
impoundment.
p aj-4 nnaleJEThe above regulation is applicable to both natural in-place
soil barrier,specified under Cc)(2) of this section and to the
soil liners specified under (c)(3).
The specifications concerning soil properties used by
State regulatory agencies reflect a preference for tight
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clay soils with no sand or gravel seams and a hydraulic
conductivity of less than 1X10~ cm/sec. Overall, the
California Department of Health "Draft of Minimum Standards
for Hazardous Waste Management" incorporates the principal
soils criteria used in varying detail by other States sur-
veyed. The California regulations and the proposed EPA
regulations for PCB disposal stipulate: (1) hydraulic con-
— 8
ductivity of 1X10 cm/sec, or less; (2) CL, CH or OH
soils as per the Unified Soil Classification System;
(3) passage of not less than 30 percent by weight through
a standard U.-S. No. -200 sieve; (4) a liquid limit of not
less than 30 units using ASTM Test D423; (5) plasticity
index of not less than 15 units based upon ASTM Test D424;
and (6) a soil permeability that must not be adversely affected
by chemical or physical reaction with anticipated wastes.
The rationale for requirement under (i); i.e., a pass-
age of not less than 30 percent of soil (by weight) through
86
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200-mesh sieve, is related to the suitability of the soils
to serve as liners or barriers to the passage of hazardous
wastes or leachates.
Where possible, it is advantageous to locate surface
impoundments in thick, relatively impermeable formations
such as massive clay beds. Where this is not possible,
then the soils with a high clay and silt content (i.e.,
fine-grained soils) should be sought. According to the
Unified Soil Classification System, the boundary between
coarse-grained and fine-grained soils is taken to be the
200-mesh sieve (0.074 mm), or percentage of the soil
(by weight) passing through such sieve. Thus, the percentage
of the soil passing through 200-mesh sieve is one of the
indicators of the presence or absence of the clay or silt,
to be used to determine the suitability of the soil to serve
as a barrier to hazardous waste movement into the environment.
The draft hazardous waste surface impoundment regula-
tions have followed the precedent established by the EPA PCS
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regulations and the California and Texas regulations; the
passage of not less than 30 percent by weight through a
standard U.S. No. 200-sieve.
The rationale for the requirements under (ii) , i.e.,
liquid limit not less than 30 and (iii) i.e., plasticity
index not less than 15, are related to the consistency,
workability and firmness (i.e., compressibility, dry
strength, shearing resistance, etc.) of the soils intended
as liners or barriers to the passage of hazardous wastes
I
of leachates from surface impoundments.
The "liquid limit", "plasticity limit" and "plasticity
index" are the most useful indicators of the engineering
behavior of clay soils. The above limits, also termed as
Atterberg limits, are defined by the water contents required
to produce specific degrees of consistency that are measured
in the laboratory.
The "liquid limit" (upper plastic limit) is the point
at which soil becomes semifluid. In operational terms, the
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liquid limit is defined as water content at which a
trapezoid groove of specific shape, cut in moist soil
held in a special cup is closed after 25 taps on a hard
rubber plate (ASTM Test D423).
The "plastic limit" (lower plastic limit) is defined
as the water content at which soil begins to crumble on
being rolled into a thread 1/8 inch (3 mm) in diameter
(ASTM Test D424). It represents the lowest water content
at which soil can be deformed readily without cracking.
The "plastic index", a difference between the liquid
and plastic limits, is the range of water content of the
soil at which plastic behavior occurs. It is also an
indicator of the plasticity of "clayeyness" of the soil.
It has been observed (A.Casagrande) that many pro-
perties of clay and silts, such as their dry strength,
their compressibility, their reaction to the shaking test,
and their consistency near the plastic limit, can be
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correlated with the Atterberg limits by means of the
so-called plasticity chart. (In this chart, the ordinates
represent the plasticity index and the abscissas the cor-
responding liquid limit). According to the above chart,
clays with liquid limits less than 30 are considered to be
of "low" plasticity. Those with liquid limits between 30
and 50 exhibit "medium" plasticity and those above 50
exhibit "high" plasticity. The plasticity index is useful
in estimating the dry strength and compressibility of the
soil. The soils with plastic index less than 10 have low
compressibility. Those with plastic index between 10 and
20 exhibit medium compressibility, and those above 20 high
compressibility.
Since the consistency of the soil, its workability,
compressibility and dry strength are critical for con-
struction and environmentally sound operation of hazardous
waste surface impoundments, both "liquid limit" and "plastic
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index" are important factors in determination of the soil
suitability for such construction.
The draft hazardous waste surface impoundments regula-
tion followed the precedent established by the EPA PCB
;
regulation, and California and Texas regulations, in respect
to both "liquid limit" and "plasticity index."
The draft hazardous waste surface impoundment regulations
have followed the precedent established by the EPA PCB regulations
and the California regulations on soil criteria in all areas
except permeability and pH.
The requirement under (iv) that soil liners have a
pH of 7.0 or higher was added because of the higher attenuation
ability of soils at higher pH values, and the ability of high
pH soils to inhibit the reaction of wastes with low pH with
the soils.
The impoundment regualtions under (v) specify 10~7 cm/sec.
— Q
rather than 10 ° cm/sec, because more state regulations use
7 cm/sec.; almost all reviewers outside the Agency support
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10 cm/sec.; and because there is no definite evidence
that 10 cm/sec, is necessary for human health and
environmental protection.
The Texas and Oklahoma parameters for soil liners in
hazardous waste "ponds and lagoons" (in-place natural
soils and recompacted or reworked soil liners) are similiar
to the California specification, with the exception of the
soil permeability. Both Texas and Oklahoma require soil
permeability for hazardous waste "ponds/lagoon" liners to
be less than an equal to 1X10 cm/sec. In Pennsylvania,
the natural deposits underlying the potential "pond or
lagoon" site also must have permeability of less than or
equal to 1X10 cm/sec.
The permeability criteria chosen for the EPA regulations
follow the precedents established by Texas, Oklahoma and
Pennsylvania. California's requirement for 10-8 cm/sec.
appears more protective. However, in conjunction with the
design and construction criteria under (c)(2) and (c)(3),
and the other regulations in this section, this number
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(10 cm/sec.) should be adequate to provide satisfactory
groundwater and surface water protection.
In addition to the criteria listed under (i) to (v) of
this regulation, it is required under (vi) that the per-
meability of soil liners should not be adversely affected
by the anticipated wastes.
The rationale for the above regulation is the fact
that clay liners, although suitable for the majority of
hazardous wastes, are not compatible with certain wastes.
For example, natural impermeable soils may fail when ex-
posed to strong acids; and strong alkaline waste may cause
clay liners to swell. Therefore, the wastes which are not
compatible with soil liners should not be deposited into
such surface impoundments. The rationale concerning waste
compatibility with the liner is given in (b)(1) of this
section.
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Standard*(5) Artificial liners for surface impoundments (e.g.,
concrete, plastic) shall:
(i) Be of sufficient strength to insure mechanical
integrity ;
(ii) Have a minimum 'thickness of 30 mils;
Rationale :Liners should be of adequate strength and thickness to
insure mechanical integrity of the liner. The failure to
provide liners of adequate mechanical stength and thickness
could result in liner failure (e.g., rupture, puncture,
laceration, development of cracks, etc.) with subsequent
seepage of hazardous wastes into the environment.
Thickness of artificial liners, especially membrane
liners, and their mechanical strength are closely related
(i.e. the thicker the liner, the higher mechanical strength
could be anticipated). The criteria chosen for EPA regu-
lation followed the precedent in Texas requiremnts established
for hazardous waste "ponds and lagoons".
Standard > (iii) Be compatible with the waste to be placed in
the impoundment;
Rationale i Among the first consideration in selecting a liner for
hazardous waste surface impoundment is the compatibility
with the hazardous wastes to be contained. The possible
reactions between the liner and wastes can detrimentally
affect the ability of the impoundment to contain such wastes
and prevent their seepage to the environment.
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The compatibility criteria for artificial liners
and rationale are same as specified under (b)(1)(i)
of this section.
Standard ; (iv) Have a permeability less than or equal
to 1X10 cm/sec.
Rationale .'The permeability criteria for artificial liners and
rationale are same as specified under (c)(4) of this section
for clay liners.
Standard ', (v) Have an expected service life at least
25 percent longer than the expected time
of facility usage;
Rationale * Estimates of the predicted life-time of liner materials
are usually available from the literature, various manufactur-
ers, fabricators, suppliers, installers and trade unions.
However, accurate information concerning the long-term
effect of subject wastes on specific liners is generally not
95
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known. The hazardous wastes after prolonged contact could
have a detrimental effect on liner durability and permeabil-
ity. Continuous use of artificial membranes after their
predicted life time would considerably increase the po-
tential for liner failure and subsequent groundwater con-
tamination. Lacking the actual field test data, the pro-
jected life of the liner for the specific liner/waste
situation can only be assumed. To compensate for the lack
of specific data, the EPA regulation has incorporated a
safety factor, allowing use of the specific liner for no
more than 3/4 of its projected^life.
Standard;(vi) Be placed on a stable base;
Rationale/The installation of a manufactured liner requires prior
preparation of the base. The base should be stable so that
settling or other movement after liner installation does not
tear or weaken the liner through stretching. The improper
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installation of even the best material will defeat the
purpose of the lining.
Standard : (vii) Satisfactorily resist attack from ozone,
ultraviolet rays, soil bacteria, and
fungus;
Ration a le>The exposure to ozone, ultraviolent rays, soil bacteria
and fungus could adversely affect the durability and im-
permeability of membrane liners.
S t and ard t(viii) Have ample weather resistance to with-
stand the stress of freezing and thawing;
Rationale,t Liners should have ample weather resistance to withstand
thelstresses associated with wetting and drying, freezing
and thawing as dictated by the geographic location of
the impoundment site.
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Standard '.(ix) Have adequate tensile strength to elongate
sufficiently and withstand the stress of
installation and/or the use of machinery
or equipment;
•
Rationale r The liner materials without adequate tensile strength
may rupture during installation or be affected by continuous
use of machinery and equipment required for the operation of
the pond or lagoon.
Standard I (x) Resist laceration, abrasion and puncture
from any matter that may be contained in
the fluids it will hold;
Rationale/The sharp objects and abrasive materials present in
contained waste could lacerate, puncture or decrease dur-
ability of the liner.
S tandard.i (xi) Be of uniform thickness, free of thin
spots, cracks, tears, blisters, and
foreign particles;
Rationale; Thin spots, cracks, tears, blisters, foreign particles
present in the liner materials, and variable thickness of
the liner could adversely affect durability and permeability
of the liners.
Standard'Xxii) Be easily repaired.
Rationale* The liner material should be capable of being repaired
easily so that if a puncture does occur, it can be remedied.
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Standardj(6) To prevent their rupture, all artificial liners
in a surface impoundment where mechanical equip-
ment is used for operation (e.g., sludge dredging
and collecting) shall have a protective cover of
selected clean earth material, not less than 45
centimeters (18 inches) thick, placed directly on
top of the liner.
Rationale! All artificial liners are prone to rupture or damage
caused by mechanical equipment, such as sludge dredging and
collecting equipment, if such machinery/equipment is used
for operation. To prevent such problems, it is recommended
that all surface impoundments lined with artificial liners,
and using mechanical equipment, should have a protective
cover of selected clean earth material, not less than 45
cm (18 inches) thick, placed directely upon the liner.
The usage of protective covers for artificial liners,
if needed because of operating conditions, is generally
considered to be a good engineering practice, although the
recommended thickness may vary (i.e., with type of liner,
manufacturer specification, usage, etc.). The thickness
recommended in the above regulation is based on liner
manufacturer recommendations, discussions with experts, and
what has generally been found effective in actual practice.
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Standard^ (7) A surface impoundment shall have a groundwater
monitoring system and a leachate monitoring system
that meet the specifications in Section 250.43-8.
Rationale Tne one cause of groundwater contamination in the United
States is leakage of wastes from unlined holding surface impound-
ments. In nearly all cases, unlined impoundments or impoundments
constructed in permeable soils leak. The pollution problems
such as these can be alleviated if surface impoundments are
constructed in impermeable clay soil or lined with clay and/or
artificial liners. (See (c)(2) and (c)(3)). However, all
liners are prone to failure, due to incompatibility with
contained wastes, mechanical failure, prolonged usage exceeding
projected life (artificial liners), or effective life of clay
liners; improper installation, etc., resulting in hazardous
waste seepage into the environment.
The objective of the above regulation is to detect and
correct any liner failure or groundwater contamination before
more serious problems can develop.
Monitoring requirements for hazardous waste surface
impoundments over usable aquifers, under 250.43-8 specify
monitoring in zone of saturation, applicable to all facili-
ties constructed after the effective date of this regulation.
The objectives and rationale for requiring monitoring
in the zone of saturation are the same as specified under
250.43-8 of 3004.
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Standard;(8) All surface impoundment dikes shall be designed and
constructed in a manner that will prevent discharge
or release of waste from the facility, both horizon-
tally and vertically.
Rationale;1*16 primary function of any surface impoundment dike is
the containment of a definite volume of waste within the
impoundment area/ and to serve as a barrier between the contained
wastes and the environment. To serve its intended purpose, the
surface impoundment dikes should be designed and constructed
so as to prevent hazardous waste seepage into the environment.
The method of constructing surface impoundment usually
consists of building the dike around the selected area, either
without excavation - for "above-ground" construction, or
around the excavated area - for "below-ground" impoundments.
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The waste level in surface impoundment, depending on
design and construction, could be at ground level, below,
or above the ground level, the latter being the case with
all "above-ground" structures. If the waste level remains
at all times at ground level or below, the risk of wastes
flowing out of the surface impoundment, in the event the
dike is breached at the ground level, is greatly reduced.
However, if the waste level would normally be maintained
some distance above the ground level, and the dike is
breached, hazardous wastes will flow freely out of the
impoundment and into the area drainage system. Therefore,
the design and construction criteria should be more stringent
in this case.
To serve its intended purpose, the earthen dikes should
be constructed from impermeable soils (see requirements
under (c) (9)), to prevent migration or seepage from the
impoundment, and be structurally stable to serve its intended
purpose during the anticipated service life without cracking
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or breaking. In addition, all dikes should have an adequate
seal between the dike bottom and underlying soils.
The dike height and width is usually determined by the
intended use of the surface impoundment (e.g., volume to be
retained, method of delivery, etc.). The dike height should
be adequate to contain anticipated/projected volume of the
wastes and allow sufficient freeboard above the impoundment
peak operating water level. (See freeboard requirements
under (d)(2) of this section.)
The dike slope depends chiefly on the size of the im-
poundment and on materials available for their construction.
Surface impoundment dikes are usually designed and constructed
with slopes between (6) horizontal to (1) vertical, and
(2) horizontal to (1) vertical. Normally, good pond soil would
support slopes of (3) horizontal to (1) vertical. The wind
and water erosion effect, and the protection to be provided,
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are another important design and construction criteria for
dikes. All soils, regardless of the slope, need protection
in zones subject to turbulence and agitation (e.g., created
by wind induced wave action, inlet and outlet increased
hydraulic activity, aerator agitation, etc.). Generally,
the larger ponds and lagoons in windy areas are more suscept-
ible to erosion (and require more protection). The steeper
the side slope, the less area there is for protective
covering.
The consequences of failure to provide adequate design
and construction for hazardous waste surface impoundments
are listed below:
The hazardous wastes could seep through permeable dikes
both horizontally and vertically, enter the area groundwater
and surface waters and .cause con.taininatj.on, or the .hazardous
wastes could migrate/seep laterally through the base of dike
and enter the environment.
The surface water pollution problems are usually the
result of breaks in the dikes or overtopping, with subsequent
spill over of hazardous wastes to the surface waters, re-
sulting in contamination, fish kills, and degradation of the
stream. The seepage of hazardous wastes through the impoundment
dike into the groundwater can also cause public health and
environmental problems. As indicated elsewhere, the groundwater
has little assimilation capacity compared to the surface water
It is therefore imperative to assure that all surface impoundment
dikes are designed and constructed in a manner that will preclude
seepage of wastes from the facility into the groundwater.
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The guidelines for "pond and lagoon" construction
in Texas and Oklahoma recommend construction of secondary
or back-up dikes (if necessary due to poorly engineered or
unstable/inadequate primary dikes)/ capable of retaining
1.25 times the volume retained above the ground level within
the primary dike, for all "pond/lagoons" retaining wastes
above the ground level; or methods other than back-up dikes
may be utilized to prevent waste escape into the area water.
The proposed EPA regulations do not specifically require
construction of secondary or back-up dikes for new surface
impoundments, under the presumption that the properly designed
and constructed primary dikes alone would be capable to
prevent waste escape from the facility. However, for existing
facilities, the construction of impermeable secondary (back-up)
dikes could be a good alternative for solving a pollution
problem resulting from poorly engineered, unstable, or inadequate
primary dikes.
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Standard^9) A11 earthen dikes at the facility shall be construc-
ted of clay-rich soil with a permeability less than
or equal to 1X10 cm/sec.
RatipnalegThe conceptual objectives and rationale for this regu-
lation are similar to those given for regulation (c)(8) of
this section; i.e., to prevent seepage of hazardous wastes
through impoundment dike and enter the environment. if the
impoundment dikes are constructed from permeable soils,
contained hazardous fluids would penerate through them and
enter into the area groundwater or surface water.
To achieve the above objective, it is recommended that
all earthen dikes are constructed of a clay-rich soil
with permeability less than or equal 1X10~7 cm/sec. The
permeability criterial for dike construction are similar
to those specified under (c)(2) and (c)(4).
It is believed that the above permeability will provide
adequate protection against the hazardous waste seepage
through dikes, both horizontally and vertically. The
precedent set by the State of Texas established the fact
that this procedure is a recognized good practice. A portion
of Texas' construction criteria for ponds and lagoons requires
earthen dikes to be constructed of a clay-rich soil with
permeability less than or equal to 1X10~7 cm/sec, where compacted
to 95% standard proctor at optimum moisture content.
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Standard^10) A11 earthen dikes shall have an outside protective
cover (e.g., grass, shale, rock) to minimize erosion
by wind and water.
Ration a le.'The structural stability of the dike must be maintained
for an environmentally sound operation of the surface impound-
ment. In order to minimize the erosion of earthen dikes by
wind and water and subsequent deterioration of their structural
stability, it is recommended that all earthen dikes should
be stabilized by a protective cover.
The potential consequences of failure to provide ade-
quate protection against erosion by wind and water is deter-
ioration of structural stability, causing breaching of the
dike and subsequent release of hazardous wastes to the
environment.
Surface impoundment dikes are usually constructed with
side slopes between six horizontal to one vertical and two
horizontal to one vertical. The final slope selected will
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depend on the dike material and water-erosion protection to
be provided. All soils, regardless of slope, will require
some type of protection in zones subject to turbulence and
agitation. Such zones can be created by wind-induced wave
action, inlet and outlet increased hydraulic activity and
aerator agitation. Examples of turbulent zones are areas
around the discharge areas at recirculation pumping station
and areas around the influent and effluent connections.
If the wind is always in one direction, wave-action
erosion protection usually can be limited to those areas
that receive full force of the wind-driven waves. Protection
should always extend from at least one foot below the minimum
surface to at least one foot above the maximum water surface.
Protection against hydraulic turbulence should extend several
feet beyond the area subject to such turbulence.
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Erosion protection can be provided by cobble stones,
broken or cast-in-place concrete, wooden bulkheads, asphalt
strips, etc. Whatever is used should recognize the need to
control shoreline and aquatic growth. The steeper the side
slope, the less area there is for such protective coverings
and aquatic or shoreline growth. Large ponds in windy
areas require heavier erosion protection.
Exterior slopes of the dike are also subject to erosion
by wind and rain and require stabilization by a protective
cover (e.g., grass, rocks, etc.).
The precendents set by the State of Texas, and indicated
elsewhere *^' , establish the fact that requirement of
protective cover for soil dikes is a recognized good
practice, as quoted: "Stabilization and Maintenance — In
order to minimize the erosion of earthen dikes by wind and
water, it is suggested that where practical all earthen dikes
be stabilized by establishing a protective cover such as, but
not limited to, grass, shell, rock, etc., over the top and
sides of the exposed portions of the dikes."
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St andard'.dl) Those surface impoundments which are intended to be
closed without removing the hazardous waste shall meet
the landfill requirements under Section 250.45-2.
Rationale? In accordance with applicable closure standards under (e)
of this section, there are two acceptable approaches to a
close-out of surface impoundments.
The first approach requires removal of hazardous wastes
and/or hazardous waste residuals and liners from the surface
impoundment, with subsequent disposal, as requried in Subparts
B, C, and D.
The second approach is to close surface impoundment with-
out removal of hazardous wastes, and/or hazardous residuals,
and/or liners from the impoundment.
In the later case, the surface impoundment becomes a
hazardous waste landfill, and, therefore, a subject to the
landfill regulations, under 250.45-2.
The objective of the above regulation, is to assure, that
those surface impoundments which are intended to be closed
without removal of hazardous wastes, and/or hazardous residuals
are located, designed and constructed in a manner which will
satisfy both, the surface impoundment regulations and
regulations under 250.42-2.
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(d) Operation and Maintenance
Standard?(1) A surface impoundment shall be operated and main-
tained so that discharges or releases to groundwater
and navigable water do not occur.
Ration ale'-The primary objective and rationale for the above re-
gulation is to assure that all hazardous waste surface im-
poundments are operated and maintained in such a manner as
to preclude any human health and environmental problems.
Regardless of the type of surface impoundment construct-
ed, it must be operated in such a manner as to serve its
intended purpose without posing any water pollution or air
pollution threat. Maintaining proper freeboard, accepting
only those wastes which are compatible with and not detri-
mental to the impoundment lining, taking care not to rupture
liner, keeping records of the contents of each impoundment
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at all times to prevent unregulated mixing of incompatible
wastes, are just a few things that the operator must be
constantly concerned with to assure an environmentally
sound operation at all times.
Routine maintenance of all facilities at the surface
impoundment site, such as roads, ditches, fences, freeboard
markers, etc. and especially dikes, is essential to maintain
a clean, orderly, safe and environmentally acceptable operation,
All needed maintenance or corrective action necessary to
restore the dike or liners to their original condition should
be accomplished expeditiously due to the possibility of more
serious consequences.
The failure to operate and maintain hazardous waste
surface impoundments properly can result in various environ-
mental problems. For example, failure to provide sufficient
freeboard could result in waste overflowing from the impound-
ment with subsequent movement into the surface waters, or
infiltration into the groundwater if surrounding soil is
permeable. Wastes that are incompatible with liner materials
could cause their deterioration, dissolution or otherwise
increase their permeability, and can result in unregulated
discharges into the groundwater. The rupture of the liner
could cause hazardous waste migration/seepage into the
groundwater. The failure to maintain dikes can cause their
deterioration and result in breaching with subsequent movement
of hazardous wastes into the environment.
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Standard*(2) The freeboard maintained in a surface impoundment
shall be capable of containing rainfall from a
24-hour, 25-year storm but shall be not less than
60 centimeters (2 feet).
Rationale.;The objective of the above regulation is to prevent
spillover of hazardous waste from the impoundment with the
subsequent possibility of ground or surface water contamination.
The failure to provide sufficient freeboard could
cause hazardous wastes to overflow or be washed over the
dike by wave-action or hydraulic turbulence, and consequently
migrate into the area waters. The overflows are one of
the primary sources of surface water pollution problems
relative to hazardous waste impoundments. If surrounding
soils are premeable, hazardous wastes washed over the dike
could also infiltrate into the groundwater.
Because of the higher degree of mobility, liquid wastes
present a somewhat greater environmental hazard than do
solids or viscous high solid content sludges. Greater
care, therefore, must be exercised when handling the liquid
wastes, since the possibility of wave action being generated
by strong winds and/or hydraulic turbulence is more probable
in such facilities, and hazardous spills involving liquids
would more rapidly enter the environment.
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The States of Texas and Pennsylvania require a minimum
of two feet of freeboard for all hazardous waste "ponds and
lagoons;" Oklahoma specifies three feet of freeboard. The
3-foot requirement could provide additional safety, but in
addition to increasing cost of construction, it could also
adversely affect mechanical stability of the dike.
The most critical factor in establishing freeboard
requirements is the amount of the rainfall in the subject,
area. The freeboard requirements in arrid areas may be
less strict because the possibility of impoundment over-
flowing as a result of the rain storm or prolonged rain-
fall is negligible.
The proposed regulation requires freeboard to be
adequate either to contain rainfall from a 24-hour 25-year
storm or to be at least two feet (60 cm), the former
figure being in correspondence with 250,43(c) of Section 3004
of the RCRA, applicable to all hazardous waste facilities.
Although the more conservative value (2 feet) was chosen
for minimum freeboard requirement, when used with the above
rainstorm protection figure, and other requirements in this
section (i.e., erosion control, dike inspection and maintenance
etc.), it should provide adequate protection against associated
environmental problems.
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Standard?(3) Records shall be kept of the contents and location
of each, surface impoundment. These records shall
be maintained as specified in Section 250.43-5 (b).
RationaleI The objective of the above regulation is to prevent
unregulated mixing of noncompatible wastes and to prevent
all subsequent health hazard and environmental problems.
The maintenance of such records should preclude accidental
mixing of noncompatible wastes in hazardous waste ponds and
lagoons. Additionally/ in the event ground water or surface
water contamination is detected, such records will assist
in identifying the source of contamination.
Mixing of hazardous wastes that are not compatible
with each other in hazardous waste surface impoundments, if
performed under uncontrolled conditions, can create human
health and environmental hazards resulting from violent
reactions, excessive heat or pressure generation, potential
fires and explosions and subsequent dispersion of hazardous
components into the air, or formation of hazardous gaseous
115
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fumes and their transmission into the air. In addition,
such reactions, or products of such reactions could adverse-
ly affect the impermeability of the liner or dike and re-
sult in unregulated discharges into the groundwater or
surface waters.
The precedents set by the State of Texas and Oklahoma
established the fact that this procedure is a recognized
good practice. Both the Texas and Oklahoma specifications
for hazardous waste "ponds and lagoons" require maintenance
of records on the quantity and quality of the waste treated
or disposed of in the pond/lagoon.
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Standard*(4) Tne integrity of the natural in-place soil barrier
or the liner system installed in a surface impound-
ment shall be maintained until closure of the
impoundment. The liner system or natural in-place
soil barrier shall be repaired immediately upon
detection of any failure (e.g., liner puncture).
Rationales The purpose of liners or natural in-place soil barriers
in hazardous waste surface impoundments is to assure con-
tainment of hazardous wastes and prevent their seepage into
the area groundwaters. The potential consequence of not
maintaining the integrity of liners is the failure to
contain hazardous wastes, and subsequent seepage into the
groundwaters. The objective of the above regulation is
that such disruption does not occur.
The integrity of the installed liners could be en-
dangered by the following:
* hazardous waste/liner incompatibility,
* improper installation,
* any matter in hazardous waste (sharp objects,
etc.) with potential to rupture, puncture or
lacerate liners,
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* use of machinery or equipment/
* adverse weather conditions (subsequent freezing and
thawing),
* attack from ozone, ultraviolet rays, soil bacteria
and fungus.
Any detected failure of the natural in-place soil barrier
or liner failure should be corrected immediately, to prevent
contamination of usable aquifers by hazardous waste. if a
specific chemical, element, or compound known to be present in
the surface impoundment is detected by a monitoring system,
the impoundment should cease the operation immediately, and
the problem should,-be either -immediately correctedr -or the
facility closed following the requirements under (e) of this
section. If the failure of a liner system remains undetected
or is not corrected promptly, hazardous waste could migrate
from the surface impoundment and contaminate the underlying
aquifer.
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Standard t (5) Surface impoundment dikes shall be visually
inspected daily, as specified under Section
250.43-6, for the purpose of detecting and
correcting any deterioration. Any maintenance
or corrective action necessary to restore the
dike to its original condition shall be accom-
plished expeditiously.
Rationale * The primary objective of the above regulation is to
minimize the possibility of the impoundment dike failure
through routine visual inspection, proper maintenance of
dikes, and prompt corrective measures upon detection of
any dike failure.
The primary function of any surface impoundment dike
is the containment of a finite volume of pumpable liquids
and sludges within the impoundment area and to serve as a
barrier between the contained wastes and the environment.
To serve its intended purpose, the dike should be imper-
meable and structurally stable to prevent hazardous waste
seepage or relaease into the environment.
The structural integrity and impermeability of dikes
can be adversely affected by improper operation or erosion.
As a result, a portion of the dike could be washed away,
develop cracks, or break, thus allowing hazardous waste to
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be released into the environment. The breaching of dikes is
known to be one of the primary sources of surface water
pollution problems, relative to hazardous waste surface
impoundments. Furthermore, if the surrounding soils are
highly permeable, hazardous wastes released from the
impoundment could also infiltrate into the area groundwater.
Therefore any maintenance or corrective action necessary
to restore the dike to its original condition should be
accomplished expeditiously to avoid more serious consequences
(i.e., groundwater and surface water contamination).
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Standard;(6) Any system provided for detecting the failure of
a liner system or natural in-place soil barrier
shall be visually inspected daily, as specified
in Section 250.43-6, to insure that it is operating
properly for the purpose intended.
Rationale * The objective of the above regulation is to minimize the
possibility of failure of the leachate detection system
through routine inspection.
All liners are prone to failure due to their incom-
patibility with contained wastes, mechanical rupture, pro-
longed usage exceeding projected life of the liner, etc.
The reactions between the liner and hazardous wastes could
result in dissolution of the liner or increase its per-
meability. If the liner failure is not detected, hazardous
wastes can escape from the surface impoundment and migrate/
seep into the groundwater, or eventually, to the surface
water.
The primary function of leachate detection system is
to detect any such failures. The proper operation of such
a system is, therefore, essential for environmentally sound
operation of the impoundment. Because any leachate detection
system is prone to mechanical failure after prolonged use,
the requirement for routine inspection is fully warranted.
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(e) Closure and Post-Closure
Standard;(1) Upon final close-out, all hazardous waste and
hazardous waste residuals shall be removed from
the surface impoundment, if the impoundment does
not meet the landfill requirements under Section
250.45-2, and disposed of as hazardous waste
pursuant to the requirements of this Part.
Rationale' The proper close-out of surface impoundments is essential
for protection of human health and the environment. The hazardous
wastes and/or hazardous residuals remaining in the impoundment
after facility closure may become a source of environmental
problems due to failure of hazardous waste containment, and
subsequent leaks of hazardous components into the environment
in those facilities which were not designed to contain wastes
for an extended period of time.
By their nature, surface impoundments, with exception
of disposal ponds/lagoons, are temporary structions, designed
for variable lengths of the service life; the environmental
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soundness of each impoundment depending directly on the
materials used for construction, i.e., compatibility with
the hazardous wastes to be contained; durability upon
prolonged contact with the hazardous waste of interest;
and alteration of permeability with time. Since the above
characteristics may vary with each construction and each
material/waste situation, EPA regulations for surface
impoundments require construction materials to be compatible
with wastes of interest, and that the durability and
permeability of such materials remains unchanged during the
expected service life of the facility.
However, the long-term effect of the majority of
hazardous wastes on artificial membranes, is not known at the
present. This information is critical, especially if the
wastes are to remain in the impoundment after its closure for
the unspecified length of the time. The hazardous wastes
after prolonged contact could have a detrimental effect on
liner durability and permeability. Therefore, the continuous
contact of hazardous waste with liners after their predicted
life time, as may be the case after the facility closure, would
considerably increase the potential for liner failure and sub-
sequent groundwater contamination.
Based on the above facts, the EPA regulation requires
removal of all hazardous wastes and hazardous waste residuals
from-those surface impoundments which do not meet the criteria
for landfills under 250.42-2, e.i. those, which are not designed
and constructed to contain hazardous wastes for an extended-
unspecified period of the time.
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Therefore, the continuous contact of hazardous waste with liners
after their predicted life time, as may be the case after the facility
closure, would considerably increase the potential for liner failure
and subsequent groundwater contamination.
Based on the above facts, the EPA regulation requires removal
of all hazardous wastes and hazardous waste residuals from those surface
impoundments which do not meet the criteria for landfills under
250.42-2, e.i. those, which are not designed and constructed to contain
hazardous wastes for an extended-unspecified period of the time.
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Standard/^2) Upon final close-out of a surface impoundment which
meets the criteria for landfills under Section
250,42-2, all hazardous waste and hazardous waste
residuals shall be:
(i) Removed and disposed as hazardous waste
pursuant to the requirements of this Part/
or
(ii) Treated in the impoundment pursuant to the
note following Section 250.45-2(b) (6)(iv),
and then the impoundment shall be closed
according to the closure requirements for
landfills under Section 250.45-2(c).
Rationalej The proper closure of surface impoundments is essential
for protection of public health and the environment. The
hazardous waste and/or hazardous waste residuals remaining
in the impoundment after the closure may become a source of
environmental problems, if facility fails to contain remaining
hazardous wastes. Therefore, those surface impoundments, which
were not designed to contain wastes for an extended period
of time, (e.i. after facility closure), may become source
of groundwater and surface water contamination.
The objective of the above regulation is to prevent
environmental problems resulting from the improper closing
procedures, by allowing retention of hazardous wastes and
hazardous waste residuals only in those impoundments which
were designed and constructed to contain hazardous components
permanently - e.i. those which in addition to the surface
impoundments criteria meet also the criteria for landfills
under 250.42-2.
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For those impoundments which meet the criteria for
landfill, EPA regulatory approach permits two basic closing
procedures:
(i) Removal of hazardous wastes/hazardous
residuals and disposal in accordance
with all applicable requirements of this
Part, or
(ii) Treatment of hazardous waste/hazardous
residuals remaining in the impoundment in
accordance with the landfill criteria under
250.45-2 (b) (6) (iv), and closure of the im-
poundment in accordance with landfill closure
requirements under 2.50.45-2 (c) . After the.
closure, facility becomes also subject to
all post-closure requirement specified for
landfills under 250.45-2(d).
The primary rationale for this approach is to provide
maximum protection for human health and the environment and in
the same time provide needed flexibility in respect to the
closing procedures.
The rationale for closure and post-closure requirements
for surface impoundments closed in accordance to (ii) of this
standard are given in a separate background document - No. 17
Landfills.
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Standard;(3) Emptied surface impoundments shall be filled with
an inert fill material and seeded with a suitable
grass or ground cover crop, or converted to some
other acceptable use that meets the requirement
under Section 250.43-7.
Ration ale ^The objective of the above regulation is to assure,
that the surface impoundments, after the removal of
hazardous wastes/hazardous residuals are closed in
environmentally acceptable manner, and in the same time
converted to some acceptable use. The regulation is
preventing the abandonment of the emptied site or sloppy
closure. By specifying inert fill materials, the re-
gulation is preventing conversion of-the site to"an open--
dump or unsecured land disposal facility.
The primary rationale for this approach is to provide
maximum protection for public health and the environment
and in the same time provide needed flexibility in respect
to the closing procedure.
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Standard '(4) Those surface impoundments which were closed as
landfills shall meet all post-closure require-
ments for landfills under Section 250.45-2(d).
Rationale*The objective of the above regulation is to assure,
that those surface impoundments which were closed as
landfills, e.i. without removal of hazardous wastes and
hazardous waste residuals, meet all post-closure require-
ments specified for landfills under Section 250.45-2(d).
The rationale for post-closure requirements for
landfills is given under separate background document
(see No. 18 - Landfills).
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REFERENCES
1. Personal communication. H. Page Fielding, Delaware
River Basin Commission, to Alice Giles, Office of
Solid Waste, April, 1975.
2. New Jersey Department of Environmental Protection files,
Trenton, New Jersey.
3. Bureau of Water Quality Management files, Pennsylvania
Department of Environmental Resources, Harrisburg,
Pennsylvania.
4. New Jersey Department of Environmental Protection files,
Trenton, New Jersey.
5. Tracy, J.V., and N.P. Dion. Evaluation of groundwater
contamination from cleaning explosive-projectile
casings at the Bangor Annex, Kitsap County, Washington,
Phase II. U.S. Geological Survey, Water-Resources
Investigations 62-75, Open-File Report, 1976. 44 p.
6. Personal communication. Frank Williams and John Davidson,
Pittsburgh Regional Office, Bureau of Water Quality
Management, Pennsylvania Department of Environmental
Resources, to Robert Weems, Office of Solid Waste,
Spring, 1975.
7. Personal communication. Edward Simmons, Harrisburg
Regional Solid Waste Director, Bureau of Land Protection,
Pennsylvania Department of Environmental Resources,
to Robert Weems and Alice Giles, Office of Solid Waste,
Spring, 1975.
8. U.S. Environmental Protection Agency, Office of Solid
Waste. Disposal of hazardous waste; report to Congress.
Environmental Protection Publication SW-115. Washington,
U.S. Government Printing Office, 1974. 110 p.
9. Ibid.
10. Ibid.
11. Ibid.
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12. Gerathy and Miller, Inc. "Sice Location and Water
Quality Protective Requirements for Hazardous Waste
Management Facilities", EPA Contract 68-01-4636.
13. Matrecon, Inc. "Evaluation of Liner Materials Exposed
to Hazardous and Toxic Sludges", Draft Interim
Report, 1976, EPA Contract 68-03-2173.
14. Upgrading Lagoons, EPA Technology Transfer Publication.
15. Upgrading Wastewater Stabilization Ponds to meet new
Discharge Standards. Synposium Proceedings, Utah
Water Research Laboratory, College of Engineering,
Utah State University, November 1974.
130
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Resource Conservation and Recovery Act
Subtitle C - Hazardous Waste Management
Section 3004 - Standards Applicable to. Owners
and Operators of Hazardous Waste
Treatment, Storage, and Disposal
Facilities.
DRAFT
BACKGROUND DOCUMENT
Section 250.45-4 Standards for Basins
U.S. Environmental Protection Agency
Office of Solid Waste
December 15, 1978
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This document provides background information and support for
regulations which are designed to protect the air, surface water,
and groundwater from potentially harmful discharges and emissions
from hazardous waste treatment, storage, and disposal facilities
pursuant to Section 3004 of the Resource Conservation and Re-
covery Act of 1976. It is being issued as a draft to support
the proposed regulation. As new information is obtained, changes
may be made in the regulations as well as in this background
material.
This document was first drafted many months ago and has been re-
vised to reflect information recieved and Agency decisions made
since then. EPA made changes in the proposed Section 3004 reg-
ulations shortly before their publication in the Federal Register,
We have tried to ensure that all of those decisions are reflected
in this document. If there are any inconsistencies between the
proposal (the preamble and the regulation) and this background
document, however, the proposal is controlling.
Comments in writing may be made to:
Timothy Fields, Jr.
U.S. Environmental Protection Agency
Office of Solid Waste
tf
Hazardous Waste Management Division (WX-565)
401 M Street, S.W.
Washington, D.C. 20460
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I. Introduction
A. RCRA Mandate and/or Authority for the Regulation
B. Definition of the Area being Regulated and other
Key Words Used in Background Document
II. Rationale for the Regulation
A. Actual Damage Incidents
B. Potential Damage Resulting from the Absence of
Regulation
III. Identification of Regulatory Options
A. Specific Standards Mandated by RCRA
B. Existing Federal, State, or local regulations
that could be adopted
C. Others
IV. Analysis of Regulatory Options
V. Identification of Chosen Regulation and Associated
Rationale
IV
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I. Introduction
A. RCRA Mandate and/or Authority for the Regulation
Section 3004 of the Resource Conservation and Recovery
Act of 1976 (RCRA) mandates that the EPA Administrator promul-
gate^ regulations establishing standards applicable to owners
and operators of facilities for the treatment, storage, and
disposal of hazardous waste^, as may be necessary to protect
human health and the environment. Among other things, these
standards are to include requirements respecting:
1. the treatment, storage or disposal of all such
waste received by the facility pursuant to such
operating methods, techniques, and practices as
may be satisfactory to the Administrator, and
2. the location, design, construction, operation and
maintenance of such hazardous waste treatment,
storage, or disposal facilities.
B. Definition of the Area Being Regulated and Other
Key Words Used in Background Document
For the purpose of this regulation "basin" means any
uncovered device constructed of artificial materials, used to
retain waste as part of a treatment process, usually with a
capacity of less than 100,000 gallons. Examples of basins
include open mixing tanks, clarifiers, and open settling tanks
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The other pertinent definitions — key words used in
background document are as follows:
(1) "Administrator" - See Sec. 1004(1)
(2) "Aquifer" means a geologic formation, group of
formations, or part of a formation that is capable
of yielding useable quantities of groundwater to
wells or springs.
(3) "Close Out" means the point in time at which
facility owners/operators discontinue operation
by ceasing to accept hazardous waste for treat-
ment, storage, or disposal.
(4) "Closed Portion" means that portion of a facility
which has been closed in accordance with the
facility closure plan and all applicable closure
requirements in this Subpart.
(5) "Closure" means the act of securing a facility
pursuant to the requirements of Section 250.43-7.
(6) "Closure Procedures" means the measures which must
be taken to effect closure in accordance with the
requirements of Section 250.43-7 by a facility
owner/operator who no longer accepts hazardous
waste for treatment, storage, or disposal.
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(7) "Contamination" means the degradation of natrally
occurring water, air, or soil quality either
directly or indirectly as a result of man's
activities.
(8) "Disposal Facility" means any facility which disposes
of hazardous waste.
(9) "Endangerment" means the introduction of a substance
into groundwater so as to:
(i) cause the maximum allowable contaminant levels
established in the National Primary Drinking
Water standards in effect as of the date of
promulgation of this Subpart to be exceeded
in the groundwater; or
(ii) require additional treatment of the groundwater
in order not to exceed the maximum contaminant
levels established in any promulgated National
Primary Drinking Water regulations at the point
such water is used for human consumption; or
(iii) Reserved (Note: Upon promulgation of revisions
to the Primary Drinking Water Standards and
National Secondary Drinking Water Standards
under the Safe Drinking Water Act and/or
standards for other specific pollutants as
may be appropriate).
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(10) "EPA" means the U.S. Environmental Protection
Agency.
(11) "EPA Region" means the States and other
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jurisdictions i the ten EPA Regions as follows:
Region I - Maine, Vermont, New Hampshire,
Massachusetts, Connecticut, and Rhode Island.
Region II - New York, New Jersey, Commonwealth of
Puerto Rico, and the U.S. Virgin Islands.
Region III - Pennsylvania, Delaware, Maryland, West
Virginia, Virginia, and the District of Columbia.
Region IV - Kentucky, Tennessee, North Carolina,
Mississippi, Alabama, Georgia, South Carolina,
and Florida.
Region V - Minnesota, Wisconsin, Illinois, Michigan,
Indiana, and Ohio.
Region VI - New Mexico, Oklahoma, Arkansas, Louisiana,
and Texas.
Region VII - Nebraska, Kansas, Missouri, and Iowa.
Region VIII - Montana, Wyoming, North Dakota, South
Dakota, Utah, and Colorado.
Region IX - California, Nevada, Arizona, Hawaii, Guam,
American Samoa, and the Commonwealth of the Northern
Mariana Islands.
Region X - Washington, Oregon, Idaho, and Alaska.
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(12) "Facility" means any land and appurtenances,
thereon and thereto, used for the treatment,
storage, and/or disposal of hazardous waste.
(13) "Freeboard" means the vertical distance between
the average maximum level of the surface of waste
in a surface impoundment, basin, open tank,
or other containment and the top of the dike
or sides of an impoundment, basin, open tank,
or other containment.
(14) "Fugitive Emissions" means air contaminant
emissions which are not planned and emanate from
sources other than stacks, ducts, or vents or
from non-point emission sources.
(15) "Groundwater" means water in the saturated
zone beneath the land surface.
(16) "Hazardous Waste" has the meaning given in
Section 1004(5) of the Act as further defined
and identified in Subpart A.
(17) "Hazardous Waste Facility Personnel" means all
persons who work at a hazardous waste treatment,
storage, or disposal facility, and whose actions
or failure to act may result in damage to human
health or the environment.
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(18) "Incompatible Waste" means a waste unsuitable for
commingling with another waste or material, because
the commingling might result in:
(i) Generation of extreme heat or pressure,
(ii) Fire,
(iii) Explosion or violent reaction,
(iv) Formation of substances which are shock
sensitive friction-sensitive, or otherwise
have the potential of reacting violently,
(v) Formation of toxic (as defined in Subpart A)
dusts, mists/ fumes, gases, or other
chemicals, and
(vi) Volatilization of ignitable or toxic chemicals
due to heat generation, in such a manner that
the likelihood of contamination of groundwater,
or escape of the substances into the environment,
is increased, or
(vii) Any other reactions which might result in
not meeting the Air Human Health and Environ-
mental Standard. (See Appendix I for more
details.)
(19) "Leachate" means the liquid that has percolated
through or drained from hazardous waste or other man
emplaced materials and contains soluble, partially
soluble, or miscible components removed from such
waste.
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(20) "Leachate Monitoring System" means a system
beneath a facility used to monitor water quality
in the unsaturated zone (zone of aeration) as
necessary to detect leaks from landfills and
surface impoundments. (For example, a pressure-
vacuum lysimeter may be used to monitor water
quality in the zone of aeration.)
(21) "Liner" means a layer of emplaced material
beneath a surface impoundment or landfill which
serves to restrict the escape of waste or its
constituents from the impoundment or landfill.
(22) "Monitoring" means all procedures used to system-
atically inspect and collect data on operational
parameters of the facility or on the quality of
the air, groundwater, surface water, or soils.
(23) "Monitoring Well" means a well used to obtain water
samples for water quality analysis or to measure
groundwater levels.
(24) "Navigable Waters" means "waters of the United
States, including the territorial seas." This
term includes, but is not limited to:
(i) °A11 waters which are presently used, or
were used in the past, or may be susceptible
to use in interstate or foreign commerce,
including all waters which are subject to the
ebb and flow of the tide, intermittent
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and adjacent wetlands. "Wetlands" means
those areas that are ymundated or saturated
by surface or ground water at a frequency
and duration sufficient to support, and that
under normal circumstances do support, a preva-
lence of vegetation typically adapted for life
in saturated soil conditions. Wetlands generally
include swamps, marshes, bogs, and similar areas
such as sloughs, prarie potholes, wet meadows,
prarie river overflows, mudflats, and natural ponds
(ii) Tributaries of navigable waters of the United
States, including adjacent wetlands;
(iii) Interstate waters, including wetlands; and
(iv) All other waters of the United States, such
as intrastate lakes, rivers, streams, mudflats,
sandflats, and wetlands, the use, degradation
or destruction of which would affect or could
affect interstate commerce, including, but not
limited to:
(A) Intrastate lakes, rivers, streams and
wetlands which are or could be used by
interstate, travelers for recreational
or other purposes:
(B) Intrastate lakes, rivers, streams, and
wetlands from which fish or shellfish
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are or could be taken and sold in
interstate commerce; and
(C) Intrastate lakes, rivers, streams, and
wetlands which are used or could be used
for industrial purposes by industries in
interstate commerce.
(v) All impoundments of waters of the United States
otherwise defined as navigable waters under
this paragraph.
(25) "Non-Point .Source" means a source from which pollutants
emanate in an unconfined and unchannelled manner, in-
cluding, but not limited to the following:
(i) For non-point sources of water effluent, this
includes those sources which are not controllable
through permits issued pursuant to Sections 301
and 402 of the Clean Water Act. Non-point source
water pollutants are not tracable to a discrete
identifiable origin, but result from natural
processes, such as nonchannelled run-off, pre-
cipitation, drainage, or seepage.
(ii) For non-point sources of air contaminant
emissions, this normally includes any
landfills, landfarms, surface impoundments,
and basins.
(26) "Owner/Operator" means the person who owns the land o
which a facility is located and/or the person who is
responsible for the overall operation of the facil'
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(27) "Partial Closure Procedures" means the measures
which must be taken by facility owners/operators
who no longer accept hazardous waste for treatment,
storage, or disposal on a specific portion of the
site.
(28) "Permitted hazardous waste management facility
(or permitted facility)" means a hazardous waste
treatment, storage, or disposal facility that
has received an EPA permit in accordance with
the requirements of subpart E or a permit from
a State authorized in accordance with Subpart F.
(29) "Reactive Hazardous Waste" means hazardous waste
defined by Section 250.13(c)(l) of Subpart A.
(30) "Regional Administrator" means the Regional
Administrator for the Environmental Protection
Agency Region in which the facility concerned is
located, or his designee.
(31) "Run-off" means that portion of precipitation that
drains over land as surface flow.
(32) "Saturated Zone (Zone of Saturation)" means that
part of the earth's crust in which all voids are
filled with water.
(33) "Spill" means any unplanned discharge or release of
hazardous waste onto or into the land, air or water,
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(34) "'Soil Barrier" means a layer of soil of a minimum
of 1.5 meters (5 feet) in thickness with a permea-
bility of 1 x 10~ cm/sec or less which is used
in construction of a landfill or a surface impound-
ment.
(35) "Sole Source Aquifers" means those aquifers designated
pursuant to Section 1424(e) of the Safe Drinking Water
Act of 1974 (P.L. 93-523) which solely or principally
supply drinking water to a large percentage of a pop-
ulated area.
(36) "Storage Facility" means any facility which stores
hazardous waste, except for generators who store
their own waste on-site for less than 90 days for
subsequent transport off-site, in accordance with
regulations in Subpart B.
(37) "Surface Impoundment" means a natural topographic
depression, artificial excavation, or dike arrange-
ment with the following characteristics: (i) it is
used primarily for holding, treatment, or disposal
of waste; (ii) it may be constructed above, below, Or
partially in the ground or in navigable waters (e.a
wetlands); and (iii) it may or may not have a pre-
meable bottom and/or sides. Examples include hold!
ponds and aeration ponds.
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(38) "Treatment Facility" means any facility which treats
hazardous waste.
(39) "True Vapor Pressure" means the pressure exerted
when a solid and/or liquid is in equilibrium with its
own vapor. The vapor pressure is a function of the
substance and of the temperature.
ytar
(40) "24-hour, 25- -feeur Storm" means a storm of 24-hour
duration with a probable recurrence interval of
once in twenty-five years as defined by the National
Weather Service in Technical Paper Number 40, "Rain-
fall Frequency Atlas of the United States", May 1961,
and subsequent amendments, or equivalent regional or
State rainfall probability information developed there-
from.
(41) "Unsaturated Zone (Zone of Aeration)" means the zone
between the land surface and the nearest saturated
zone, in which the interstices are occupied partially
by air.
(42) "United States" means the 50 States, District of
Columbia, the Commonwealth of Puerto Rico, the
Virgin Islands, Guam, American Samoa, and the
Commonwealth of the Northern Marinana Islands.
(43) "Underground Drinking Water Source" (UDWS) means:
(i) an aquifer supplying drinking water for
human consumption, or
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(ii) an aquifer in which the groundwater contains
less than 10,000 mg/1 total dissolved solids;
or
(iii) an aquifer designated as such by the Adminis-
trator or a State.
(44) "Underground Non-Drinking Water Source" means an
underground aquifer which is not a UDWS.
(45) "Volatile Waste" means waste with a true vapor
pressure of greater than 78 nun Hg at 25°C.
(46) "Water Table" means the upper surface of the zone
of saturation in groundwaters in which the hydro-
static pressure is equal to atmospheric pressure.
II. Rationale for the Regulation
A. Actual Damage Incidents
There are no known damage incidents associated with -tefee>
basins in EPA files. However, there are several damage cases
involving surface impoundments which are closely related to
basins.
B. Potential Damage Resulting from the Absence of
Regulation
The environmental media potentially endangered by the
hazardous waste basins are: -tefee surface water, groundwater, and
the air.
Surface Water
Surface water pollution problems relative to basins are th
potential for overflow, spills, or cracking, breaking, or other
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damage of the basin walls with subsequent movement of hazard
ous waste to surface water, resulting in gross contamina-
tion, fish kills, and degradation of the receiving water.
Because surface water is an important source of drinking
water^and an agricultural and industrial water supply,
contamination of the surface water will have a direct impact
on the public health and the environment.
Groundwater
The migration/seepage of hazardous waste from a basin
to the groundwater due to overflow, spills, or cracking,
breaking or other damage to the basin structure, could cause
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severe human health and environmental problems. Because^fefce
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groundwater will have a direct impact on the public health,
and the environment.
Groundwater normally has little assimilation capacity
compared to surface waters. The rate of movement of ground-
water is extremely slow, relative to surface waters. Unlike
streams, which can recover from polluted conditions in a few
years, groundwater does not experience the flushing action
*A
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Air
Treatment of hazardous waste that is highly reactive,
ignitable, incompatible, or volatile in basins may generate
hazardous emissions into the airland endanger public health
and the environment. Wastes may react violently with water
and air, or may react with each other, causing fires, explo-
sions, and/or formation of toxic gaseous components and
their release into the air.
III. Identification of Regulatory Options
A. Specific Standards Mandated by RCRA
Subpart D establishes performance standards applicable
to operators and owners of facilities that treat, store, or
dispose of hazardous waste identified or listed under
Subpart A and/or designated as hazardous waste by the gener-
ator of the waste pursuant to Subpart B.
In accordance with EPA regulatory strategy, Subpart D
includes two types of performance standards: Health and
Environmental Standards (under Section 250.42), and design
and operating standards (Sections 250.43 through 250.45).
The design and operation standards, which cover general
facilities standards, storage standards, and treatment and
disposal standards, are designed to protect public health
and the environment and, therefore, to achieve compliance
with the Health and Environmental Standards under most
situations. The Health and Environmental Standards super-
cede the design and operating standards in certain circum-
stances.
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Under this regulatory structure, it is intended that
the design and operating standards will be the principal
regulatory criteria used to manage the treatment, storage
and disposal of hazardous wastes. Where there is a reason
fh
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In accordance #6^ the definition, "basin" means any uncovered
device^ constructed of artificial materials, used to retain waste
as part of a treatment process, usually with a capacity of less
than 100,000 gallons.
Based on the definition, basins are always only hazardous
waste structures temporarily used for treatment and/or contain-
ment of hazardous wastes, and are never used for permanent
disposal^ or long term storage.
Basins are usually engineered structures, with sides and
bottom constructed from artificial materials (e.g., concrete,
steel, synthetic materials, etc.) serving as primary barriers
to movement of waste^ from such structures. Basins can be
either lined or unlined. However, liners serve only as a pro-
tection against corrosion of construction materials or waste
incompatibility with such materials.
Because of the small size and method of construction, most
corrosion problems, cracks, or other damage that can cause
hazardous waste migration/seepage from the basin could be
detected through visual inspection.
Based on the above, hazardous waste basing should be sub-
ject to all Human Health and Environmental Standards and General
Facility Standards, and to the standards applicable to treatment
facilities, but should not be subject to the standards applicable
to storage and disposal facilities.
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B. Existing Federal, State or Local Regulations
That Could Be Adopted
Review of existing Federal, State, or local regulations
revealed an absence of existing regulations that can be used
as a precedent for regulation of hazardous waste basins.
However, because of their similarity with surface impoundments,
in respect to the environmental impact on groundwater,
surface water, and air, some aspects of the "surface impoundments"
standards are applicable to "basins".
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IV. Analysis of Regulatory Options
The environmental media most endangered by basins are:
groundwater, surface water, and the air. Regulatory options
for protecting each of these media from pollutants from
basins are discussed below.
Section 3004 requires that EPA develop facility per-
formance standards as necessary to protect human health and
the environment .however, it does not specify the nature of
#
those standards. Therefore, EPA was faced with a dilemma
inherent in the standard-setting process. On the one hand,
standards may be drafted calling for a certain level of
environmental quality which is /nM£>wn to be protective. This
type of standard (e.g., ambient air quality, water quality,
etc.) is difficult for government to enforce and difficult
to determine which actions cause a particular level of
degradation in environmental quality. Additionally, it is
I,
difficult to prescribe "safjK levels" of thousands of toxic
substances that might be found in hazardous waste.
On the other hand, performance (technology-based)
standards may be drafted to prescribe limits on waste management:
activities aimed at preventing human health and environmental
damage. The problem with such perscriptive restrictions on
waste management action is that such standards tend to
freeze the development of technology at the level of the
standard. There is little incentive to develop new and
better techniques to achieve a particular environmental goal
MIL
if use of particular techniques are required by EPA regulations
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A third method of standard setting to achieve environ-
mental protection is to d^y/ectly regulate the amount. of
pollutant which is allowed to be released into the environ-
ment from a given source (e.g., effluent limitations, new
source performance standards) . This has the advantage of
encouraging the development of new technology to meet those
standards, while providing environmental protection that is
more enforceable than standards based on environmental
quality. Unfortunately, this regulatory approach is far
i
more applicable to discrete sources of pollution (smokestack
or outfall pipe) than it is to the overall land and ground-
water degradation relative to improper hazardous waste
management, with respect to basins.
In view of the drawbacks to each of these types of
standards, EPA proposed an innovative combination of these
types of standards. This approach is intended to accomplish
the high degree of protection of public health and the
environment provided for the Act, provide sufficient guidance
necessary for industry compliance and government enforcement,
and encourage technological innovation.
In accordance with the EPA regulatory approach, the
human health and environmental protection strategy used in
regulation of basins should require compliance with control
A.-///
technology standards, #f respect to:
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1. Design and construction
2. Hazardous waste characteristics.
3. Operation and maintenance.
4. Closing procedures.
v/M
All these factors, jejr^respect to the human health and
environmental protection provided, and analysis of whether
each option meets the RCRA mandate are discussed below.
1. Design and Construction
The primary objective of design and construction standards
for basins should be to assure that the basins are designed/
constructed in a manner that will prevent discharge of
hazardous waste into the environment during the life of the
facility. The environmental media to be protected are
navigable waters and the groundwater. (Because basins are
always uncovered structures, the design and construction
standards have no impact on discharge into the air.)
In dealing with hazardous wastes, appropriate material
of construction is a critical factor for environmentally
safe operation of basins. Sufficient strength and thickness
to assure mechanical integrity and to prevent seepage, and
compatibility with hazardous waste and treatment chemicals
to be contained under expected treatment conditions (i.e.,
temperature, etc.) are the critical factors to be considered.
The potential consequence of improper selection of construc-
tion materials is of containment, and subsequent leaks of
hazardous waste^ into the groundwater or surface waters in
the area.
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One method of standard setting to achieve groundwater
and surface water protection would be to prescribe materials
to be used for basing construction. The problem with this
//te-
regulatory options is that it would require^listing of all
permitted construction materials for each hazardous waste/
treatment situation. Considering the number of possible
combinations, it is very difficult tq provide such a compre-
hensive list. In addition, such^ regulation would freze the
development of technology at the level of the standard.
Another regulatory approach would be to prescribe a
certain level, which is known to be protective, for ground
water and surface water quality directly affected by a
specific basin. This type of standard would be, however,
difficult for government to enforce. Also, it would be
difficult to determine which actions cause a particular
level of degradation in groundwater and surface water quality.
Additionally, it would be difficult to prescribe "safe
levels" of contaminants that may be found in hazardous
wastejf contained in basins.
A third method of standard setting would be, to directly
regulate the amount of pollutant allowed to be released into
the groundwater and surface water from a given basin. This
type of standard would be, however, difficult for government
to enforce, since the majority of hazardous waste discharges
from basins are the result of uncontrolled conditions or
accidents (|e\j). , seepage due to cracking, corrosion, or
dissolution, increased permeability, spillage, etc.).
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In view of the drawback of each regulatory approach,
the combination of all three approaches seems to be most
reasonable. This method of standard setting would require
basins to be constructed of impermeable materials of suffi-
cient strength and thickness to insure mechanical integrity
and to prevent the discharge of wastes to surface waters or
groundwater. It should also be required that the materials
X&
used for construction of basins are compatible with.hazardous
os*4 A
waste and treatment chemicalsounder expected operating
conditions (i.e., temperature, etc.)/ or are protected by a
liner compatible with such waste or treatment chemicals
and/or treatment conditions.
In addition/ it should be required that all hazardous
wastes are tested prior to disposition in a basin to deter-
mine whether they will have any detrimental effect (e.g.,
cause dissolution, corrosion, increase permeability, decrease
mechanical strength) on materials used for construction of
such basins.
This approach would accomplish the high degree of pro-
tection of public^ health and the environment provided for
by the Act^ provide sufficient guidance for industry
compliance and government enforcement, and at the same time
encourage technological innovation.
2. Hazardous Waste Characteristics
LiltA
The primary objective of regulation ^XArespect to the
hazardous waste characteristics^/is to prevent public
health and environmental problems related to the retention
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of hazardous wastes in basins. The environmental media to
be protected are: the surface water, groundwater, and the
air.
The incompatibility of hazardous wastes and treatment
chemicals or reagents with materials used for construction
dl
could potentially disrupt the structural integrity of.facil-
ity, allowing the escape of hazardous components into the
groundwater and surface waters. The main objective of the
regulation should be that such disruption does not occur.
Treatment of hazardous wastes that are highly reactive,
ignitable, volatile, or incompatible with each other in
basins may generate hazardous waste emissions into the air
and endanger public health and the environment. The main
objective of the regulation should be to prevent such environ-
mental problems.
One method of standard setting, to achieve groundwater,
surface water and air protection would be, to provide a list
of hazardous wastes and/or hazardous waste combinations
which can be retained in basins, based on waste characteristics
and compatibility with intended construction materials. The
major drawback of this regulatory approach is that EPA
o-
presently lacks a supportive dat£ base to prepare such a
comprehensive list. Furthermore, such a list would prevent
placement of hazardous wastes that are not listed into the
basinsgfwithout changes in the regulations.
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Another approach would be^to prescribe certain levels,
s*
which are know to be protective^for groundwater, surface
water and air quality directly affected by a specific basin.
A third method of standard setting would be to directly
regulate the amount of pollutants allowed to be released
into the groundwater, surface water, and into the air from a
given basin. While both regulatory approaches provide
needed public health and environmental protection, they
would be difficult for government to enforce.
S-*
In view of the drawback of each regulatory approach,
the combination of all three approaches seems to be most
reasonable. This method of standard setting should require
that the basins are not to be used to contain waste, which
is:
(a) detrimental to the basins' construction
materials;
(b) reactive, as defined in Subpart A;
(c) ignitable, i.e., as defined in Subpart A;
(d) volatile; i.e., those having a vapor pressure
greater than 78 mm Hg at 25°C.
The regulation should also require that hazardous
wastes which contain incompatible chemical groups shall not
be mixed together in basins.
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This approach would accomplish the high degree of pro-
tection of public health and the environment mandated by the
Actf provide sufficient guidance for industry compliance and
enforcement, and at the same time encourage technological
innovation.
3. Operation and Maintenance
The primary objective of operation and maintenance
standards for basins should be to assure that the basins are
operated and maintained in a manner that will prevent public
health and environmental problems. The environmental media
to be protected are surface waters and the groundwater.
Because basins are always uncovered struct$i^es/ the operation
and maintenance of basins has no impact on the discharges
into the air. (The air pollution potential associated with
waste characteristics and treatment chemicals, and the
regulatory options are discussed under Part 2 of this section.)
The primary purpose of basins (in addition to the
intended treatment objectives) is to provide containment of
*
hazardous wasters during fehe treatment and^prevent discharges
of hazardous wasteji into the surface or groundwater in the
area.
Waste incompability with construction materials,and
improper operating conditions and maintenance^ are among the
primary contributing factors effecting structural integrity
and i/ipermeability of basins. For example, wastes with
"*¥ J
corrosive properties would^attaqfl construction materials,
causing corrosion problems. Mechanical abrasion from any
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matter contained in wastes could cause erosion problems.
Certain wastes could cause gradual dissolution of certain
construction materials. Improper operation and adverse
weather conditions not anticipated in design/construction
(frequent freezing and thawing, etc.) could deteriorate
a/)d Ma
structural integrity of construction materialsMcause
cracking and other damage, which could allow migration or
seepage of hazardous wasted from the basin and subsequent
environmental problems.
Most of the corrosion and erosion problems, the mater-
ial cracking and other damages could be detected early
through visual inspection, before more serious environmental
problems could develop. Since the majority of basins have
/4J ..
capacity uoually less than 100,000 gal. (380 mj), their
visual inspection would be technically feasible. Ground-
water degradation can be detected through groundwater
monitoring.
The uncorrected corrosion and erosion problems, crack-
ing or other structural damage of basin construction materials
could result in hazardous waste^ release or seepage from the
basin and subsequent movement to the environment. It is
therefore imperative that any damage detected is repaired
immediately.
One method of standard setting to achieve groundwater
and surface water protection would be to require only visual
inspection, regardless of the size of the basin, or the
potential of the basin for discharge to the underground ^
Drinking water "
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source. While visual inspection may be effective in some
instances, it would require emptying basins periodically.
<3L
Such,.practice may be costly, or may interfere with existing
A
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continu/^ ££ treatment processes, if basins are of such an
operation.
Another approach would be to require only groundwater
monitoring systems. While groundwater monitoring would
detect groundwater contamination, it would not provide early
t&LS/)//)0
detection of problems and/or a voujing^to Initiate any mea-
sures to correct such problems. Furthermore, groundwater
monitoring will not prevent surface water contamination, and
may be too costly for small basins.
In view of the drawbacks of each regulatory approach,
the combination of both apporaches seems to be most effec-
tive means of regulation. This method of standard setting
should require that:
o basins are monitored or visually
inspected for leaks, corrosion, cracks
or other damages, and that any damage
detected is repaired immediately.
It should also be required that:
o All basins which have the potential
for discharge to underground drinking
water sources have groundwater monitor-
ing systems.
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o Basins do not have to have groundwater
monitoring systems if the facility owner/
operator can demostrate that a leak could be
detected by visual inspection or other means.
This approach will accomplish a high degree of public
health and environmental protection provided for by the Act.
It will also provide sufficient guidance for industry compli-
ance and government enforcement, and at the same time encourage
technological innovation.
4. Closing Procedures
The primary objective of "closing" standards for basins
should bef/to assure that basins are closed in a manner that
will preclude public health and environmental problems after
facility closure. The environmental media to be protected
are surface waters and the groundwater.
Any hazardous waste^ remaining in the basins after
facility closure may become a source of groundwater and sur-
face water contamination due to failure of containment and
subsequent leaks.
The hazardous waste^, after prolonged contact, may have
a detrimental effect on the construction material, its dura-
bility and impermeability. The continuous contact of hazard-
ous waste^ with such materials, after their predicted life
time, as may be the case after the facility closure, would
considerably increase potential for groundwater and surface
water contamination.
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Jc
Therefore, a regulation requiring removal of all
hazardous wastes from basins after facility closure is
essential for protection of public health and the environ-
ment.
The improper handling of hazardous wastey, after their
removal from basins, can also become a source of environ-
mental problems and should be regulated.
Based on the above, the standard respecting the closure
of basins should require that, upon final closure, all
hazardous wastejf and hazardous waste residues are removed
from basins and disposed of as required in Subparts B, C,
and D.
This approach will accomplish the high degree of
protection of public health and the environment mandated by
the Act.
V. Identification of chosen Regulation and Associated
Rationale
(a) A basin shall be constructed of impermeable materials
of sufficient strength and thickness to ensure mech -
anical integrity and to prevent the discharge of waste
to navigable wat^ers or groundwater.
The primary objective of the above regulation is to
assure that all basins containing hazardous waste are con-
structed in a manner that will assure containment of hazard-
ous waste;* during treatment operations throughout the pro-
jected life of the facility, without posing any threats to
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human health and the environment. To satisfy the above
objectives, all basins containing hazardous waste^ should be
constructed of materials that have an adequate strength and
thickness to withstand the stress/^p the operation, and jfrf
XX^y.same time are capable pj&A prevent fene seepage of hazard-
ous wastes into the environment.
In dealing with hazardous waste^, appropriate materials
of construction are required to provide reasonable service
life for equipment and environmentally safe operation.
Coated and lined basins may frequently be used to meet
material requirements, e.g., carbon steel lined with lead,
rubber, glass, plastic, or other corrosion resistant materials.
Xature of the hazardous waste^ and treatment chemicals,
expected length of service, temperature of operation, desired
physical strength, liquid flow rate and mechanical abrasion
are among the factors to be considered in material selection.
Because of the complexity of the problem, only general
guidance can be provided.
The potential consequence of improper selection of con-
struction materials is the failure of hazardous waste contain-
ment, and subsequent leaks of hazardous components into the
groundwater or surface waters, or shortening of the expected
service life of the facility.
(b) A basin shall not be used to contain hazardous waste
which is:
(1) Detrimental to the basin's construction materials;
(2) Ignitable waste, as defined in Section 250.13(a)
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of Subpart A;
(3) Reactive waste, as defined in Section 250.13(c)
of Subpart A; or
(4) Volatile waste.
Note: With respect to (b) (2, 3 and 4), see Note associated
with Section 250.45(c).
The incompatibility of hazardous waste^ and treatment
chemicals or reagents with materials used for construction
under operating conditions could cause corrosion of facility,
allowing the escape of hazardous components into the environ-
ment. The main objective of the above regulation is to assure
that such disruption does not occur.
Treatment of hazardous wastes that are highly reactive,
&
ignitable, or volatile, in basins may generat/K hazardous
emissions endangering workers or neighbors of a facility, and
potentially disrupt the environmental soundness of the opera-
tion. Explosions could disrupt the structural integrity of
the basin and cause subsequent leaks of hazardous wastes into
sia&s~4y
.fehe -ai'ea^ groundwater and surface water. The impermeability
of some construction materials or liners could be adversely
affected by chemical reac^^ons or fire and result in hazardous
leaks into the groundwater and surface water. Reactions and
fires could also cause discharges into the air. For example,
^f
burning of hazardous organic waste^ conaining halogens or
heavy metals will result in formation of toxic gaseous com-
ponents and their transmission into the air. The potential
fires and explosions, with subsequent environmental problems,
could be also a result of containment of hazardous waste^ that
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highly reactive with air and water. It is, therefore,
imperative that such practices are avoided.
The rationale for selection of vapor pressure greater
a-
than 78 mm at 25°C (under (iv)), is given in^separate back-
ground document - (3) Air Human Health and Environmental
Standard.
(c) Hazardous waste which is incompatible (See Appendix I)
shall not be placed together in a basin.
Mixing of hazardous wastes that are n/Qg/ compatible
with each other in basins can result in many environmental
problems, such as: violent reactions, excessive heat or
pressure generation and potential fires and explosions and
subsequent dispersion of hazardous components into the air,
or formation of hazardous gaseous fumes and their transmission
into the air. For example, mixing of cyanide and sulfide
containing alkaline wastes with acidic wastes will release
toxic HCN and H2S vapors into-the environment; uncontrolled
mixing of concentrated acidic and alkaline wastes could result
in violent reactions, excessive heat generation, and subsequent
environmental problems. Mixing of hazardous wastes containing
highly reactive components (e.g., oxidation-reduction agents and
' ~
disruptions do not occur.
(d) A hazardous waste shall be tested prior to placement
i/-
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The conceptual objective and rational for this regulation
is to assure that the hazardous waste^ to be contained a*-e /j
compatible with materials used/tor construction of basins.
The possible reactions between the waste^ and construction
materials can detrimentally effect the ability of basins to
isolate wastes and prevent their escape into the environment.
It is, therefore, evident that the compatibiltiy of wastes
with construction materials should be the first consideration
rfa
in,, design and construction of basins. No waste having a
significant detrimental effect on the materials used as
barriers to movement of the wastes ^qj/m the basin (e.g. ,
causing dissolution, increasing permeability) , and conse-
*)
quently resultin in seepage of such hazardous wastes into
the environment, should be deposited "in such facilities.
The fact that the individual waste characteristics vary,
necessitates testing of different construction materials with
the hazardous waste of interest, to determine maximum performance
characteristics. Factors to be considered should include deter-
ioration upon the contact and prolonged contact with hazardous
wastes of interest, and alterations of the material's permeabil-
ity with time. For the ultimate success of basins for the
containment of hazardous wastes, and to assure environmentally
sound performance, it is, therefore, necessary to require
*
testing of hazardous wastes with the intended construction
materials for compatibility, either during the design stage, or
prior to disposition of hazardous wastes into an existing basin,
if a waste is different from that^/ previously deposited in
such facility.
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(e) The materials used for construction of basins shall be
compatible with the hazardous waste and treatment
chemicals to be used under expected operating conditions
(i.e., temperature, pressure) or shall be protected by
a liner compatible with the hazardous waste and treat-
ment chemicals to be used under expected operating con-
ditions.
In dealing with hazardous wastes, appropriate materials,
of construction are required to provide reasonable service
life for equipment and the environmentally safe operation.
Material of construction must be chosen very carefully, to
protect personnel, the environment and economic equipment life.
Coated and lined basins may frequently be used to meet material
requirements, e.g., carbon, steel lined with lead, rubber, glass
plastic, or other corrosion resistent materials. Nature of the
hazardous wastes and treatment chemicals, expected length of
service, temperature of operation, desired physical strength,
liquid flow rate, and mechanical abrasion are among the factors
to be considered in material selection. Because of the complex-
ity of the problem, only general guidance can be provided.
The incompatibility of hazardous waste and treatment
chemicals or reagents with materials used for constuction under
operating conditions could cause corrosion problems or poten-
£-
tially disrupt the structural integrity of^facility, allowing
the escape of hazardous components into the environment. The
main objective of the above regulation is to assure that such
disruption does not occur.
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The potential consequences of improper selection of
construction materials are listed below:
1. Corrosion
Besides the influent waste stream itself, the chemical
reagents often possess corrosion properties (for example, the
lime used to precipitate metals from an acidic waste streams
or to neutralize acidic wastes). In dealing with acids and
alkalines, appropriate materials of construciton are required
to provide reasonable service-life for equipment. For example,
lead is attacked by hydrochloric acid, but can be used with
concentrated sulfuric acid (75-95%). Chromic acid (oxidizing
agent) generally corrodes all metals, but will not deteriorate
glass, polyethylene, or PVC. In many cases the specific con-
centration of the reagent is important. The presence of moisture
in wastes could be another critical factor. Elevated tempera-
tures generally increase corrosivity, also.
The above discussion addresses only some of the problems
concerning corrosion. In general, corrosion may cause rapid
deterioration of construction materials, resulting in equipment
failure or subsequent hazardous waste leaks into the environment.
2. Salting and Scaling
Salting and scaling is the formation of an insulating
layer at the heat transfer sufaces, causing a considerable loss of
heat transfer efficiency. It is commonly encountered in evapor-
ation basins and can potentially lead to their failure and sub-
sequent environmental problems. Scaling and salting may be
reduced or prevented by preliminary treatment of liquid streams,
careful choice of materials of construciton, and by operational
control.
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J7
3. Pressure
Unanticipated high pressure can disrupt the structural
intergrity of the facility and cause the escape of hazardous
materials into the environment.
4. Liquid flow rate and mechanical abra/^^bn
The mechanical abrasion from any matter that may be con-
tained in the waste, and flow rates higher than anticipated in
>/r^/*/»ir. // sift duJac/gd euKf/e,/- SCst/so//
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Jf
monitoring. Since the majority of basins have^ capacity ucually
less than 100,000 gal. (380 nv*) , their visual inspection would
be technically feasible. Furthermore, since basins are only
temporary structures/ and wastes are never expected.to remain
in basins after facility closure, the requirement of leachate
monitoring instead of visual inspection, would place and un-
necessary burden on industry.
Furthermore, the objective of this regulation is to assure
that any damage detected through visual inspection is repaired
immediately before more serious problems could develop.
The uncorrected corrosion and erosion problems, cracking
or other structural damage of basing construction materials
could result in hazardous wastes release or see^page from the
basins and subsequent movement to the environment. It is
therefore imperative, that all basins, after any problem is
detected, are emptied and repaired if this is technically
feasible. The structure should not be used until all repairs,
or renovation work is completed. If the basin cannot be repairec
such that it would assure environmentally sound operation, it
must be replaced by.other structure^
(g) A basin shall have a groundwater monitoring system meeting
the specifications of Section 250.43-8.
Note: A basin does not need a groundwater monitoring system if
the facility owner/operator can demonstrate to the
Regional Administrator, at the time a permit is issued
pursuant to Subpart E, that any leaking can be detected
by visual inspection or other means.
The objective of the above regulation is to detect and correct
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any failure, or groundwater contamination, before more serious
problems can develop.
Monitoring requirements for basins/ which have the potential
for discharge to UDWS, specify monitoring in zone of saturation,
applicable to all facilities constructed after the effective date
of this regulation.
The objectives and rational for requiring monitoring in
the zone of saturation are the same as specified under 250.43-8
(h) At final closure, all hazardous waste and hazardous
waste residues shall have been removed from a basin and
disposed of as hazardous waste pursuant to the require-
ments of Subparts B, C, and D.
The proper close-out of basins is essential for protection
of human health and the environment. The hazardous wastes and/or
hazardous residuals remaining in the basins after facility
closure may become a source of environmental problems due to
failure of hazardous waste containment, and subsequent leaks of
hazardous components into the environment in those facilities
which were not designed to contain wastes for an extended period
of time.
By their nature, basins are temporary hazardous waste con-
tainment structures designed for variable lengths of service
life.
S*'
The environment soundness of each basin depends directly
upon the materials used for construction, i.e. compatibility
with the hazardous wastes to be contained, durability upon pro-
longed contact with the hazardous wastes of interest, and
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alteration of permeability with the time.
The hazardous wastes after prolonged contact could have
a detrimental effect on durability and permeability of construct-
ion materials. Therefore, the continuous contact of hazardous
wastes with such materials after their predicted life time, as
may be the case after facility closure, would considerably increase
the potential for failure, and subsequent groundwater and/or
surface water contamination.
Based on the above facts, the regulation requires removal
of all hazardous wastes and hazardous waste residuals from
basins, upon their final closure, and disposal of removed
hazardous waste/hazardous residuals in accordance with the
requirements in Subpart B, C, and D.
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Resource Conservation and Recovery Act
Subtitle C - Hazardous Waste Management
Section 3004 - Standards Applicable to Owners and
Operators of Hazardous Waste Treatment,
Storage, and Disposal Facilities.
DRAFT
BACKGROUND DOCUMENT
Section 250.45-5 Standards for Landfctrms
U. S. Environmental Protection Agency
Office of Solid Waste
December 15, 1978
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This document provides background information and support
for regulations which are designed to protect the air, surface
water, and groundwater from potentially harmful discharges
and emissions from hazardous waste treatment, storage, and
disposal facilities pursuant to Section 3004 of the Resource
Conservation and Recovery Act of 1976. It is being made
available as a draft for comment. As new information is
obtained, changes may be made in the regulations, as well
as in the background material.
This document was first drafted many months ago and
has been revised to reflect information received and Agency
decisions made since then. EPA made changes in the proposed
Section 3004 regulations shortly before their publication
in the Federal Register. We have tried to ensure that all
of those decisions are reflected in this document. If
there are any inconsistencies between the proposal (the
preamble and the regulation) and this background document,
however, the proposal is controlling.
Comments in writing may be made to:
Timothy Fields, Jr.
U.S. Environmental Protection Agency
Office of Solid Waste
Hazardous Waste Management Division (WH-565)
401 M Street, S.W.
Washington, D.C. 20460
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TABLE OF CONTENTS
I. Introduction
II. Rationale for Regulation
III. Existing Federal or State Regulations/Guidelines
IV. Analysis of Landfarming Regulatory strategies
V. Identification of Chosen Regulatory Option
and AssociatedRationale
VI. References
VII. Appendices
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I . Introduction
A. RCRA Mandate for the Regulation:
The Congress of the United States, via Section 3004
of Subtitle C of the Resource Conservation and Recovery
Act (RCRA) of 1976 (P.L. 94-580) , mandated that the
Administrator of the Environmental Protection Agency
promulgate regulations establishing performance standards
applicable to owners and operators of hazardous waste
treatment/ storage, and disposal facilities as may be
necessary to protect human health and the environment.
These standards are to include, but not be limited to,
requirements respecting (1) location, design, and con-
struction, and (2) operating methods, techniques, and
practices of these facilities.
Compliance with this mandate necessitates the develop-
ment and promulgation of regulations that will protect
human health and the environment from the adverse effects
of air, land, and water pollution that may result from
hazardous waste disposal.
"Disposal," in the sense that it is defined in
Section 1004(3) of the Act, includes the landf arming of
hazardous wastes. Though standards for landf arming are not
\V \
J
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improper landfarming disposal methods may pose a threat to
human health and the environment and therefore such prac-
tices should be regulated. Landfarming is an environmentally
acceptable method for disposing of some hazardous waste,
provided certain operating and design parameters are adhered
to. This document discusses the rationale used in developing
the proposed standards for landfarms (40 CFR Part 250.45-5
Subpart D).
B. Key Definitions:
The following are key definitions pertinent to
the standards applicable to landfarms. Except for the
term "disposal", which is defined in Section 1004(3) of the
. \ Act, all definitions were developed from other sources.
^ *" "Attenuation" means any decrease in the maximum concentra-
tion or total quantity of an applied chemical or biological
constituent in a fixed time or distance traveled resulting
from a phy.ical, chemical, and/or biological reaction or
A
transformation occurring in the zone of aeration or zone of
saturation.
"Contamination" means the degradation of naturally occuring
water, air, or soil quality either directly or indirectly as
a result of man's activities.
"Direct Contact" means the physical intersection between
lowest part of a facility (e.g., the bottom of a landfill
-------
surface impoundment liner system or a natural in-place soil
barrier/ including leachate collection/removal systems) and
a water table/ a saturated zone, or an underground drinking
water source, or between the active portion of a facility
and any navigable water.
"Disposal", means the discharge, deposit, injection, dumping,
spilling, leaking or placing of any solid waste or hazardous
waste into or on any land or water so that such solid waste
or hazardous waste or any constituent thereof may enter the
environment or be emitted into the air or discharged into
any waters, including groundwaters.
"Facility" means any land and appurtenances, thereon and
thereto/ used for the treatment, storage, and/or disposal of
hazardous waste.
"Fertilizer" means any substance containing one or more
recognized plant nutrient(s) which is used for its plant
nutrient content, and which is designed for use or claimed
to have value in promoting plant growth.
"Flash Point" means the minimum temperature at which a
liquid or solid gives off sufficient vapor to form an
ignitable vapor-air mixture near the surface of the liquid
or solid. An ignitable mixture is one that, when ignited,
3
-------
is capable of the initiation and propagation of flame away
from the source of ignition. Propagation of flame means the
spread of the flame from layer to layer independent of the
source of ignition.
"Food Chain Crops" means tobacco; crops grown for human
consumption; or crops grown for pasture, forage or feed
grain for animals whose products are consumed by humans.
"Groundwater" means water in the saturated zone beneath the
land surface.
"Hazardous Waste" has the meaning given in Section 1004(5)
of the Act as further defined and identified in Subpart A
"Incompatible Waste" means a waste unsuitable for comming-
ling with another waste or material, because the comminglino
might result in:
(i) Generation of extreme heat or pressure
(ii) Fire,
(iii) Explosion or violent reaction,
(iv) Formation of substances which are shock-
sensitive, friction-sensitive, or otherwis
have the potential of reacting violently
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(v) Formation of toxic (as defined in Subpart A)
dusts, mists/ fumes, gases or other chemicals,
and
(vi) Volatilization of ignitable or toxic chemicals
due to heat generation, in such a manner
that the likelihood of contamination of
groundwater, or escape of the substances
into the environment, is increased, or
(vii) Any other reactions which might result in
not meeting the air human health and
environmental standard. (See appendix 3
for more details.)
"Landfarming of a Waste11 means application of waste onto
land and/or incorporation into the surface soil, including
the use of such waste as a fertilizer or soil conditioner.
Synonyms include land application, land cultivation, land
irrigation, land spreading, soilfarming, and soil incor-
poration.
"Navigable Waters" means "waters of the United States,
including the territorial seas". This term includes, but is
not limited to:
(i) All waters which are presently used, or
were used in the past, or may be susceptible
-------
to use in interstate or foreign commerce,
including all waters which are subject to
the ebb and flow of the tide, intermittent
streams, and adjacent wetlands. "Wetlands1*
means those areas that are inundated or
saturated by surface or groundwater at a
frequency and duration sufficient to
support, and that under normal circumstances
do support, a prevalence of vegetation
typically adapted for life in saturated
soil conditions. Wetlands generally include
swamps, marshes, bogs, and similar areas
such as sloughs, prairie potholes, wet
meadows,, prairie river overflows, mudflats,
and natural ponds.
(ii) Tributaries of navigable waters of the
United States, including adjacent wetlands-
(iii) Interstate waters, including wetlands; and
(iv) All other waters of the United States, such
as intrastate lakes, rivers, streams,
mudflats, sandflats, and wetlands, the use
degradation or destruction of which would
affect or could affect interstate commerce
including, but not limited to:
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(a) Intrastate lakes, rivers, streams,
and wetlands which are or could be
used by interstate travelers for
recreational or other purposes; and
(b) Intrastate lakes, rivers, streams
and wetlands from which fish or
shellfish are or could be taken and
sold in interstate commerce; and
(c) Intrastate lakes, rivers, streams, and
wetlands which are used or could be
used for industrial purposes by
industries in interstate commerce.
(v) All impoundments of waters of the United States
otherwise defined as navigable waters under
this paragraph.
"Owner/Operator" means the person who owns the land on which
a facility is located and/or the person who is responsible
for the overall operation of the facility.
"Publicly Owned Treatment Works" or "POTW" means a treatment
works as defined in Section 212 of the Clean Water Act
(CWA), which is owned by a State or muncipality (as defined
by Section 502(4) of the CWA). This definition includes any
sewers that convey wastewater to such a treatment works, but
-------
does not include pipes, sewers or other conveyances not
connected to a facility providing treatment. This term also
means the municipality as defined in Section 502(4) of the
CWA, which has jurisdiction over the indirect discharges to,
and the discharges from, such a treatment works.
"Reactive Hazardous Waste" means hazardous waste defined by
Section 250.13(c)(l) of Subpart A.
"Run-off" means that portion of precipitation that drains
over land as surface flow.
"Soil Conditioner" means any substance added to the soil for
the purpose of improving the soil's physical properties by
increasing water content, increasing water retention, en-
hancing aggregation, increasing soil aeration, improving
permeability, increasing infiltration, or reducing surface
crusting.
"Treated Area of a Landfarm" means that portion of a
landfarm that has had hazardous waste applied to it, to
include the zone of incorporation.
"True Vapor Pressure" means the pressure exerted when a
solid and/or liquid is in equilibrium with its own vapor.
-------
The vapor pressure is a function of the substance and of the
temperature.
"Zone of Incorporation" means the depth to which the soil on
a landfarm is plowed or tilled to receive waste.
-------
II. Rationale for Regulation
Landfarming is an environmentally acceptable method
for treating and disposing of certain types of hazardous
waste, provided certain operating and design parameters
are adhered to. In the absence of regulatory control,
landfarming has the potential to adversely impact all
environmental media. Unlike landfills, there are usually
no liner or leachate collection systems associated with a
landfarm. Maintaining environmental integrity depends
entirely on the biological, chemical, and physical attenua-
tion properties of the soil and the management techniques
used to optimize those properties. Unfortunately, such
management techniques are not employed at some existing
operations. Site visits to two landfarms (1,2) bore
witness to the fact that some systems are severly abused
as a result of waste over/application, and operation during
periods of extended rainfall.
A successful landfarm is a delicate system with
biological and chemical cycles in dynamic equilibrium with
the soil-waste medium. Such a system requires perpetual
monitoring and maintenance if environmental integrity is to
be maintained.
In terms of a threat to public health and the environment
5^/rJ^i '
there is a dearth of documented damage cases involving
10
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hazardous waste landfarms, even though the potential for
contamination exists. This could be a result of current
landfarm monitoring practices which may be absent, in-
adequate, or inappropriate. State landfarm regulations
frequently stress groundwater monitoring and rarely
require soil monitoring. Groundwater contamination may
take years to manifest itself, thus, even if a site is
currently leaching contaminants, it could take years to
detect the problem.
The absence of air emission monitoring at hazardous
waste landfarms may be another reason for the dearth of
damage cases. According to a recent study (3), there is
no specific mention of protection of air resources in any
State regulation. The study concludes that there is a
strong need for national regulations which recognize the
potential for air pollution from landfarming. A major
objective of the landfarming regulations is, therefore,
to close the gap existing in the State's current regula-
tory approach for controlling air emissions from hazardous
waste landfarms.
Finally, compared to other methods of disposal, such
as landfilling or incineration, lan'dfarming represents
only a small percentage, hence the potential for damage
-------
may be correspondingly small. If this assumption is true,
then as the quantity of waste destined for disposal at
landfarms increases, which it is expected to do, so too will
the potential for human health and environmental impacts.
The following is a discussion of the actual and
potential avenues of contamination and damage incidents
associated with hazardous waste landfarms.
Surface Water Contamination
Surface water situated near a landfarm site is subject:
to pollution from contaminated run-off resulting from erosion
of the soil-waste medium of the treated areas. Because the
process of landfarming concentrates wastes in the soil
surface, run-off water may be contaminated to the extent
that it will impact certain trophic levels in the aquatic
ecosystem (4).
One of the few incidents reported in the literature (5)
involved the removal of contaminated soil from a landfarm a
a result of a rainstorm occcurring soon after an oily sludae
was applied. Erosion of the soil-waste medium by run-off
carried contaminants to a lake (on-site), resulting in a
fish kill.
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Air Emissions
A recent EPA study (3) that evaluated emission control
criteria for hazardous waste management facilities describes
one air-related damage incident resulting from landfarming
of oil refinery waste. In this case, neighbors complained
of odors and there were some reports of damage to paint on
nearby houses.
Although there are few documented cases of air
pollution from landfarming, the potential for release of
significant quantities of pollutants to the atmosphere
exist. The disposal of oily type wastes provides an
excellent example of air pollution potential. Gases and
odors generated increase initially during spreading opera-
tions and subside as microbial decomposition occurs.
However, in the weathering (spreading) method of disposing
of leaded-gasoline storage tank wastes, the vapors can be
inhaled or absorbed through the skin. At the levels of
organically bound lead (20 to 200 ppm) encountered in the
storage tank sludge, potential lead-in-air hazard could
occur during the weathering process (6).
Since many of the oily wastes have a high water
content, they are commonly applied to the land by spraying.
This would allow for aerosol formation and release of waste
13
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constituents. In addition, air pollution can occur through
direct volatilization of constituents contained in the waste
after it has been spread on the land. Again, because of the
high water content of many oily type wastes, initial dis-
posal often involves allowing the water to evaporate from
the waste prior to mixing with the soil. During this
period of time, all constituents of equal or higher vola-
tility than water will be released to the atmosphere and
other waste constituents will also evolve due to co-solvent
processes (3).
A third mechanism for air pollution is by entrainment
of particulates through wind erosion. This latter mechanism
becomes increasingly important throughout the life of an
active landfarming site. Since most oily wastes contain
trace elements, these tend to accumulate in the soil with
each additional application of waste material. The initial
particles released to the atmosphere through wind erosion
for a new site will contain low concentrations of trace
elements; however, several years after a site has been in
operation the concentration of trace elements in soil
particles will be much higher fe).
In addition to the potential for creating ambient
air concentrations of pollutants, in the vicinity of
-------
landfarming areas, which are potentially hazardous to health/
there is a real potential for a significant contribution to
the reduction of ambient air quality through photochemical
reactions of constituents evolving from the waste disposal
site. This may be of particular concern in areas where
ambient concentrations of photochemical oxidants are already
high, such as in parts of California (3).
Groundwater Contamination
$
The landfarming of nonhazardous waste has reulted in
contamination of groundwater by nitrates and phosphates
which were present in the waste or added as fertilizer (7).
Hazardous waste landfarms are subject to the same conse-
quences, though EPA is not aware of any documented ground-
water contamination incidents resulting from the practice.
This lack of documentation should not, however, be inter-
preted to mean that hazardous waste landfarms pose no
threat to the groundwater. The potential for contamination
is, in fact, greater for hazardous than nonhazardous waste-
water and sludge, because the waste is in a liquid/semi-
liquid form and the contaminants are present at greater
concentration (4).
The paucity of data available on landfarm-related
groundwater damage cases may be a result of inappropriate
15
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monitoring methods and the time required for problems to
manifest themselves (as discussed previously).
In light of the potential pollution problems,
landfarming can cause (and the expected increase in
utilization of this disposal method), regulation of this
practice is deemed warranted by the Agency. A landfarm,
as mentioned previously, is a very delicate disposal
system requiring perpetual monitoring and maintenance.
Without proper regulatory control, landfa£\rjs can become
"open dumps," which threaten surrounding environmental
media and have little potential for reclamation, save
excavation of the contaminated soil-waste medium.
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III. Existing Federal or State Regulations/Guidelines
Initial development of the Section 250.45-5, Landfarming
regulations, involved an analysis of existing Federal and
State regulations and guidelines. No Federal standards for
landfarming existed except for draft guidelines to control
the landspreading of sewage sludge to land used for the
production of food-chain crops (43 FR 4942 Section 257.3-5).
These guidelines are primarily concerned with plant up-take
of cadmium and were considered inadequate to control indus-
trial hazardous waste.
The existence of State regulations or guidelines was
determined by contacting State agencies responsible for
regulating solid waste disposal. A survey of 32 States
was conducted by a contractor (4) performing a state-of-
the-art study on the landfarming of industrial and munici-
pal wastes. This study was published in August 1978 and a
summary of the contractor's survey is in Appendix I.
The survey revealed that only four States had guidelines
and that Texas (Texas Department of Water Resources) and
Oklahoma (Oklahoma State Department of Health) were the
only two States that utilized comprehensive guidelines to
evaluate landfarming disposal permits. Minnesota
17
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(Minnesota Pollution Control Agency) developed hazardous
waste landfarming guidelines Xut never gave them the
force of law because the prevailing political climate
did not favor it (8).
Maine and South Carolina have guidelines that pertain
to land cultivation of cellulosic waste materials from the
paper and allied products industry. Land cultivation of
other types of waste is evaluated on a case-by-case basis.
Although 28 of the States surveyed did not have specific
land cultivation regulations or guidelines, indications are
that several States plan to develop regulations in the
future. Mississippi is currently in the process of devel-
oping specific regulations for land cultivation of different
types of wastes, such as agricultural and food processing
wastes, and oily materials. Kentucky, in contrast, has no
plans to write regulations and feels that specific regula-
tions are inappropriate for a variety of reasons. In
particular, the belief was expressed that it is important to
have flexibility to match wastes to appropriate disposal
sites, especially in a State with such widely varying
terrain and soil conditions.
Even though specific regulations may not currently
affect land cultivation in most States, State policies may
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have an impact on the type of wastes that can be land-
farmed. In New York and Vermont, State policy is to dis-
courage and minimize land cultivation of wastes other than
those from agriculture or food processing.
The 28 States not having regulations or guidelines
evaluate landfarming on a case-by-case basis. Evaluation
procedures vary from State to State, but normally include
consideration of the following factors: site topography,
depth to groundwater and adjacent water courses, soil type,
site operating proceju(djres and deactivation plans, and
monitoring requirements. In general, a case-by-case review
can be anticipated to yield requirements that are site and
specific. Ideally, this is the most effective method of
regulation in terms of protecting the environment. The
economics and manpower requirements, however, are excessive,
making this approach inpractical on the Federal level.
Additionally, if States are to assume primacy,
specific Federal regulations will provide EPA with an
objective means of evaluating the equivalency of State
programs.
Developing standards of this nature is feasible as is
evidenced by the accomplishments of the Texas Department of
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Water Resources {TDWR). The TDWR has specific land culti -
vation guidelines that are generally applicable to all types
of industrial wastewaters/sludges. The guidelines address.
a number of factors that must be evaluated when considering
a site for landfarming, including: soils/ topography,
climate, surrounding land use/ and groundwater conditions.
Similarly/ waste composition and cation exchange capacity
of the soils at the disposal site are factors that must
be addressed in detail to facilitate determining the
appropriate waste application rate.
Oklahoma's guidelines are similar to those of Texas,
both of which are summarized in Appendix II. In Oklahoma
land cultivation guidelines are aimed at oily waste. The
suitability of other types of industrial wastewaters/
sludges for disposal by landfarming is determined on a case-
by-case basis. Oklahoma has specifically excluded water
soluble inorganic waste, judging that such waste is not
suitable for land cultivation. A list of wastes deemed to
be amenable to landfarming is also given. The list includes
API separator sludge, oil storage tank bottoms, biological
waste treatment sludge, process filter clays, petroleum coke
waste, process catalyst, water treatment sludge, and process
water treatment sludge.
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The guidelines from both of these States were used
in the development of Section 250.45-5, landfarm regulations,
Modifications, if any, were made to make State guidelines
more suitable for application on a national scale. Other
sources of input to the regulations were the guidelines
developed by the Minnesota Pollution Control Agency.
Meetings and conversations with industry, academia, the
Food and Drug Administration, the U. S. Department of
Agriculture, and consultants to industry provided valuable
information and lended much technical support to the
regulations.
The derivation of each regulation, and its associated
rationale, are addressed in Section V.
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IV. Analysis of Landfarming Regulatory Strategies
There are essentially two regulatory strategies
currently used to control the treatment, storage, and
disposal of hazardous waste. The strategies can be divided
into three approaches, as follows:
I. No standards; regulate on a case-by-case basis.
II. Process and performance standards. Process
standards include material restrictions, and
operating and design standards. Performance
standards specify a desired result without
specifying the method to achieve it.
III. Process and performance standards with a
provision for varying from the prescribed
standards.
The application of these three approaches is discussed.
in terms of their suitability as a Federal regulatory
framework to control the landfarming of hazardous waste,
The advantages and disadvantages of each approach are
discussed as are the rationale for choosing or not choosing
a particular approach.
Approach I
Evaluation of landfarming practices on a case-by-case
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basis (Approach Ij is the ideal regulatory approach in
terms of insuring that the permit is tailored to the site
and takes into account site and waste specific parameters.
This approach advantageously requires that the permitting
official carefully scrutinize and assess each permit
application, on its own merits, in an effort to determine
the appropriate permit requirements.
The major drawback of Approach I is the excessive
economic, manpower, and time requirements needed for
implementation. Another problem is that if EPA does not
promulgate specific standards, there will be no means by
which to assess or compare the equivalency of State
hazardous waste programs to the Federal program. It may
be difficult for a State to even develop a comparable
hazardous waste program without Federal standards to use
as guidance.
A recent survey (4) of the landfarming regulatory
practices of 32 States revealed that 28 use Approach I,
two use a variation of Approach I, and two discourage
the practice. Evaluation procedures vary from State to
State, but normally include consideration of one or
more of the following factors: site topography, depth
to groundwater and adjacent surface water courses, soil
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type, site operating procedures and closure plans, and
monitoring requirements.
Guidelines for controlling the land spreading of
nonhazardous waste are used by some States as guidance to
aid in evaluating permit applications for the landfarming
of hazardous waste. Nonhazardous land spreading guide-
lines are often grossly inappropriate and inadequate for
this purpose.
Only two States, Oklahoma and Texas, use guidelines
developed specifically for controlling the landfarming of
hazardous waste. The guidelines specify minimum require-
ments, of either a process or performance type, and are
incorporated into the permit. These guidelines, although
lacking the force of law, are included in all permits,
except when certain site or waste-specific parameters
dictate that a modification to the guideline(s) be made.
Depending on the parameter in question, the guideline^) may
be made more stringent, less stringent, or deleted, if
made less stringent or deleted, the owner or operator of
the facility may be required to demonstrate that the
objective of the original guideline^ will still be achieved,
Professional judgement must frequently be exercised
when modifying a guideline. This requires a considerable
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amount of expertise on the part of the permitting official,
Finding and hiring individuals of the appropriate caliber
may be a major limiting factor (of this approach) at both
Federal and State levels.
The apparent popularity of Approach I with the States
surveyed does not necessarily mean it was selected because
it was the best approach. It is possible that selection
of Approach I may have been based on it being the only
available choice, rather than the best choice. State
regulatory agencies frequently issue permits on a case-by-
case basis, especially for practices that are uncommon
(relative to the State agency's experience). The reason
Oklahoma and Texas were the only two States that chose to
develop specific landfarming guidelines, rather than rely
on the "no guidelines, case-by-case basis" approach, lends
credence to this assumption. Discussions with representa-
tives of the Oklahoma State Department of Health (11) and
the Texas Department of Water Resources (12) revealed
that there is a prevalence of landfarming as a waste dis-
posal method in both States because of the significant
number of petroleum refineries and petrochemical plants
that utilize the practice. Landfarming in these two
States, unlike the majority of the States surveyed, is
a common waste disposal practice. There was a need for
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a uniform method of evaluating permit applications, which
both States responded to in the form of specific guidelines
Approach I, in spite of its apparent popularity, was
not selected by EPA as a framework for regulating land-
farming. Excessive resource requirements and the lack of
a means for assessing and comparing State programs to the
Federal program make this approach impractical on a
national scale.
Approach II
Approach II involves the use of specific process and
performance standards applicable to all landfarms. These
standards specify the minimum requirements a facility
owner/operator must meet in order to obtain a permit.
Process standards include material restrictions, and
location, design and operating requirements. Standards
of this type essentially tell a facility owner/operator:
(1) what materials (hazardous waste ) are or are not
acceptable for certain treatment, storage, and disposal
practices, and (2) where to locate and how to design and
operate a facility. Process standards find favor with
facility owners/operators that are seeking regulatory
guidance on material restrictions and site location,
design and operation.
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Performance standards specify a desired result without
specifying how to achieve it. Standards of this type are
favored by facility owners/operators that have the necess-
ary treatment, storage, and disposal expertise and want only
to know what end result is desired by the regulatory agency.
As a result of its "cookbook" nature, Approach II would
be easier to implement on a national scale and would utilize
less resources than Approach I. This approach also provides
a basis for assessing the equivalency of State programs.
A major disadvantage of Approach II is its inflexibility.
Even when an alternative method can be demonstrated to meet
or exceed the objective of a set standard, there are no pro-
visions for deviating from that standard. Because of this
inflexibility, Approach II discourages the development of
new and innovative technologies by industry.
None of the States surveyed used this approach to
regulate the landfarming of hazardous waste. Its unpopu-
larity is thought to result primarily from its inflexibility
and, to a lesser extent, from the decision of some States
not to develop specific regulations for a practice that is
still being proven. The inflexibility associated with
Approach II arises from the fact that standards developed
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for such an approach are usually derived from existing
guidelines, which, as the name implies, were meant to
guide, not lead the way step-by-step. This type of
standards development is not an uncommon practice,
especially when the guideline has been tried and tested,
and has found wide application and acceptance. Even with
these attributes, it is sometimes unsafe to transform a
guideline into a rigid standard. The solution to this
problem is to incorporate flexibility into an otherwise
rigid standard; expecially a standard that might not be
suitable for all existing or future technologies. Because
Approach II as presented has no provision for flexibility,
it was rejected for use as a regulatory framework. in lieu
a hybrid approach, Approach III, was developed, and selected
for use as a regulatory framework.
Approach III
In developing Approach III, emphasis was placed on
maximizing the beneficial attributes of Approaches I and
II, and minimizing their inherent disadvantages.
The Section 250.45-5 landfarming regulations were
derived primarily from the guidelines of the Texas
Department of Water Resources and the Oklahoma State
38"
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Department of Health, and to a lesser extent from other
sources discussed in Section II of this document. In an
effort to eliminate the inherent inflexibility associated
with developing standards from guidelines, many of the
standards, where appropriate, are accompanied by notes.
The notes, which are performance oriented, provide for
deviation from the standard provided the owner or opera-
tor can demonstrate to the EPA Regional Administrator,
prior to receiving a permit, that the proposed alternative
method(s) meets the objective(s) of the standard. The
Regional Administrator, therefore, has the discretion to
permit the use of alternate, but equivalent or better,
technologies on a case-by-case basis. This approach affords
maximum flexibility, where possible, by'allowing industry to
either follow the standard or demonstrate the efficacy of
an equivalent method.
Not all of the standards are accompanied by notes,
hence some lack flexibility. Several of the process
standards do not have notes because the Agency made a
decision, based on the best data available, that it was
not possible to deviate from the standard and still meet
the objective (of the standard). The landfarming perfor-
mance standards are not accompanied by notes for two
reasons: (1) they specify a desired result, e.g., pre-
venting the zone of incorporation from becoming anaerobic,
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which is essential to operating a successful landfarm
and, therefore/ cannot be deviated from, and (2) the
performance standards are not restrictive in the sense
that the method to achieve the desired result is not
specified, thus, a note is not needed to provide for
deviation from a particular method . The latter reason
is important in that it differentiates a performance
standard from a process standard, and it justifies why
performance standards are not restrictive (or inflexible)
even in the absence of a note.
Implementation of Approach III, on a national scale
will impact upon economic and manpower resources to a
much lesser extent than Approach I. This is because
Approach III is "cookbook" in nature and, when deviation
from a standard is proposed, the burden of proof is upon
the facility owner or operator. This attribute will keep
judgmental decisions to a minimum, thereby lessening the
need for a workforce of the caliber required in Approach I
Approach III was selected for use as a framework to
regulate the landfarming of hazardous waste because it:
(1) lends flexibility in the form of notes to what would
otherwise be rigid* standards, (2) provides a means by
which permit applications can be more easily evaluated
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and (3) provides an objective basis for comparing the
Federal program to State programs.
31
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V. Identification of Chosen Regulatory Option and
Associated Rationale
(a) Hazardous Waste not amenable to landfarming
The following hazardous waste shall not be
landfarmed:
(1) Ignitable waste, as defined in Section 250.13 (a)
of Subpart A;
(2) Reactive waste, as defined in Section 250.13(c)
of Subpart A;
(3) Volatile waste;
(4) Waste which is incompatible when mixed (see
Appendix I).
Note: A landfarm facility may be used to treat or
dispose of ignitable, reactive, volatile, or in-
compatible waste provided that the owner/operator
can demonstrate to the Regional Administrator, at
the time a permit is issued pursuant to Subpart E,
33.
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that such treatment or disposal will not:
(1) contribute any airborne contaminant to the
atmosphere such that concentrations above the source
have the potential: (i) to exceed permissible ex-
posure levels for that airborne contaminant promulgated
in 29 CFR 1910.1000 (see Appendix III) pursuant to
the Occupational Safety and Health Act of 1970, or
(ii) to contribute two or more listed airborne con-
taminants in a manner which causes the sum of the
following expression to exceed unity:
E * c. + C 4- ... .c
m 1 2 n
L L L
12 n
Where:
E is the equivalent exposure of a mixture of airborne
contaminants, C is the concentration of a particular
contaminant, L is the exposure limit for that contaminant
(29 CFR 1910.1000, Table Z-l, Z-2, Z-3), and (2) affect
the attenuation capacity of a landfarm, through heat
generation, fires, or explosive reactions.
The objective of this regulation is to reduce the
potential for air emissions resulting from the landfarming
33
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of ignitable, reactive, volatile, or incompatible waste.
Discouraging the landfarming of waste within these four
categories reduces the potential occurrence of accidental
fires, explosions, reactions, and related adverse effects;
all of which can lead to hazardous air emissions.
Cognizant of the possibility that certain waste types
within the four categories could be landfarmed in an en-
vironmentally acceptable manner, deviation from this
standard is permitted provided certain requirements
(specified in the note) are adhered to. A detailed dis-
cussion of the options considered by the Agency for
controlling air emissions from hazardous waste facilities
and the rationale supporting the approach taken are pre-
sented in the background document on Air Human Health and
Environmental Standard, Section 250.42-3.
The rationale presented in this document are
specifically concerned with whether or not landfarming
is a viable disposal method for a waste that falls into
one or more of the four categories.
Ignitable Waste
The landfarming of waste with a flash point of less
than 60°C (140°F), i.e., waste characterized as
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ignitable in 250.13(a)(l) and listed in 250.14(a) of
Subpart A, is considered an unsafe practice due to the
potential for fires, explosions, air emissions, and
related adverse effects.
A recent study (4) has shown that during landfarming
operations, fires and explosions can occur. Even after
soil incorporation, some of the waste materials that are
partially exposed can cause fire hazards resulting from
spontaneous combustion of flammable materials.
Potential waste ignition sources exist both during
and after landfarming disposal operations. Actual examples
of potential ignition sources, cited below, provide
rationale for prohibiting the landfarming of ignitable
wastes.
Potential Ignition Sources
1) Heat energy from dark objects absorbing sunlight.
Temperatures can approach 49°C (120°F) in parts
of the United States.
2)* Heat energy generated during waste biodegradation
(in landfills). Temperatures can reach 60°C (140°F).
Y face. •
35
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3)* Heat energy generated during composting of wastes.
Temperatures can reach 70°C (158°F).
4) Electrical energy generated from ignition sources.
Reactive Waste
Reactive waste , characterized in 250.13(a)(3) and
listed in 250.14(a) of Subpart A, i$ not amenable to
landfarming because of the actual and potential problems
associated with its disposal. Examples of the types of
waste affected by this regulation are those that are:
1) Normally unstable and readily undergo violent
chemical change;
2) Capable of detonation or explosive detonation
by a strong initiating source, including waste
which reacts explosively with water;
*It is acknowledged that soil/waste temperatures during
normal landfarming operations are not expected to approach
those encountered in (2) and (3) , however, over-applicatio
of waste, and subsequent soil/waste anaerobiosis can creat
similar conditions.
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3) Readily capable of detonation or of explosive
decomposition or reaction at normal temperatures
and pressures;
4) Forbidden explosives (49 CFR 173.51), Class A
explosives (49 CFR 173.53), or Class B explosives
(49 CFR 173.58), which include pyrophoric sub-
stances, explosives, autopolymerizable material
and oxidizing agents.
An example of problems associated with the landfarming
of reactive wastes, specifically waste explosives, is pro-
vided from the results of field studies conducted by the
military (9). Efforts at landfarming by the Army Materiel
Development and Readiness Command, at Natick, Massachusetts,
and at Edgewood Arsenal, have produced less than satisfactory
results. Whereas some celluosic materials appeared to bio-
degrade/ others tended to biotransform to a recalcitrant
residue. The military has expressed obvious concerns about
the control of leachate from a farmed area. Additional
research by the military suggests that the best results,
for the complete destruction of waste explosives via
"soft" or non-energy intensive disposal methods, appear to
be derived from composting. Indeed, the destruction mechanism
in composting may be thermal rather than biological.
37
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The conclusion reached as a result of the studies by
the military is that, aside from safety problems, existing
methods for the landfarming of waste explosives are environ-
mentally inadequate. Generally, according to the military,
"the most environmentally sound method of disposal, con-
trolled incineration, is potentially the most dangerous
from a personnel safety viewpoint."
One EPA study (13) assessing alternatives for
hazardous waste management in the explosive industry
recommended against land disposal of waste explosives
because of obvious safety considerations. Alternative
disposal methods such as: 1) wet grinding, wet oxidation
sewage treatment, 2) wet grinding, reduction, filtration/
evaporation, calcination, and 3) incineration are proposed
in lieu of landfarming.
The need for further research in this area is essential
and requisite if reactive wastes are to be considered
acceptable for disposal via landfarming.
Volatile Waste
Volatile waste is defined as waste with a vapor
pressure exceeding 78mm Hg at 25°C. The rationale for
selecting this vapor pressure are presented in the
3?
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background document on Air Human Health and Environmental
Standard, Section 250.42-3.
The landfarming of volatile waste is considered to
•Vo r£\e>se c,\M\\^i>i-V o^<-->VM«i Jr ^\\wV
be an unsafe practice because it has the potentially to the
atmosphere (3). The hazards associated with the release
of air contaminants from a landfarm, presented in Section
II of this document, support the need for this regulation
and the Agency' s view that volatilization of hazardous
waste should not be considered an acceptable avenue of
disposal at hazardous waste landfarms.
Incompatible Waste
Rationale for prohibiting the landfarming of
incompatible waste are derived from a draft report by the
California Department of Health (CDOH) (14). The report
cites the fact that there is an exceedingly high risk of
contact of potentially incompatible substances at hazard-
ous waste disposal facilities as a result of a lack of
accurate information and indiscriminate handling of wastes.
Such contact can result in chemical reactions^and in
reaction consequences)which are often more reactive that the
reactants themselves/ e.g., intense heat generation, pressure
generation, fire, explosion, violent reaction, formation of
31
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latent reactive substances, dispersal of toxic substances,
formation of toxic fumes, gases, and other toxic chemicals,
volatilization of flammable or toxic chemicals and solubili-
zation of toxic substances. These consequences can lead to
secondary consequences such as injury, intoxication, or
death of workers, members of the public, domestic animals
and wildlife. Many of these incidents are documented in
Appendix I of the CDOH report. The severity of these
adverse consequences and the swiftness with which they
can occur'emphasize the necessity for adequate precaution-
ary measures regarding management of potentially incompatible
hazardous waste . These measures must be designed to prevent
contact of incompatible substances in all aspects of handling,
storage, and disposal. It is only through such measures that
future damage incidents can be prevented.
(b) General Requirements
(1) A landfarm shall be located, designed,
constructed, and ojegrated to prevent direct
contact between the treated area and
navigable water.
Hazardous waste deposited in a landfarm should not be
allowed to interact with navigable water because it increases
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the liklihood that wastes will escape to the environment (4).
Additionally, the processes of attenuation, upon which the
environmental integrity of a landfarm depends, cannot function
properly under saturated conditions.
A portion of the State of New Jersey's hydrologic
criteria for site location includes a recommendation to
prohibit the establishment of facilities in places where
disposal would bring waste in contact with surface water
(navigable water). This precedent establishes the fact
that a requirement to prevent direct contact is recog-
nized as good practice.
The potential consequences of not having this
regulation are listed below and serve as support rationale.
(A) Direct contact would hasten the movement of
hazardous wastes to navigable water. Inter-
action of the soil/waste mixture and navigable
water has the potential to carry dissolved and
undissolved hazardous constituents away from
the site.
(B) Direct contact will preclude the existence of
an unsaturated zone. This will destroy the
integrity and purpose of a landfarm by inter-
fering with attenuation, both in the zone of
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incorporation and in the underlying soil profile
(which serves as a buffer zone). Additionally,
the time to detect and rectify a problem before
environmental damage can occur is reduced if not
eliminated.
(2) A landfarm shall be located, designed,
constructed, and operated to minimize erosion,
landslides, and slumping in the treated area.
Erosion, landslides, and slumping are three geophysical
forces that can potentially disrupt the environmental
integrity of a landfarm. The main objective of the above
regulation is to ensure that such disruption does not occur
Being cognizant of the fact that few existing or
potential landfarm sites will be free of such forces, the
regulation was written to allow flexibility, i.e.,
engineering against such geophysical forces is acceptable
for both existing and potential sites, it is germane to
point out that locating a landfarm in an area known to be
subject to extensive erosion, landslides, or slumping, will
require that site improvements be made and/or special
operational techniques be employed.
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The potential consequences of not locating or designing
against erosion, landslides, and slumping are listed below:
A) Erosion
Because the zone of incorporation of a
landfarm occupies the uppermost soil layer, it
is constantly exposed to the erosive forces of
wind and water. Wind erosion can effect removal
of soil-waste particles from the landfarm site
and create air pollution problems as well as
contamination of surrounding land and water.
The erosive forces of water are capable of
physically deteriorating the zone of incorpora-
tion. Water erosion can effect removal of the
soil/waste medium via suspension or solution.
The ultimate result is polluted run-off which,
if not collected, can contaminate adjacent land
and water.
B) Landslides
Landslides, along with floods and erosion,
are common phenomena due to weather, the nature
of soils, and gravity. Landslides can effect
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physical changes in a site, thereby directly
affecting the rate at which contaminants reach
the environment. All environmental media could
be adversely affected in the event a landslide
disrupted the treated area of a landfarm.
Areas subject to or having had landslides
are undesirable locations for siting a landfarm
because the loose, unconsolidated rock material
that characterizes such an area would be struc-
turally unsound. Additionally, the soils present
would not be suitable for a landfarming operation,
C) Slumping
The slumping or subsidence of land beneath
a landfarm can:
i) Bring the zone of incorporation and ground-
water into closer proximity, if not direct
contact;
ii) Create depressions in the surface of the
landfarm in which ponding of waste and/or
water can occur.
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The consequences of decreasing the space
between the zone of incorporation and groundwater
are included in the discussion on paragraph (b)(3)
The ponding of waste and/or water in the
treated area can create a hydraulic head which
facilitates the movement of contaminants to the
subsurface and possibly to groundwater. Addition-
ally, if the water or waste stands for extended
periods of time, anaerobic conditions may arise.
The adverse effects of anaerobiosis are presented
in the discussion on paragraph (d) (1).
(3) A landfarm shall be located, designed,
constructed and operated so that the treated area
is at least 1.5 meters (5 feet) above the his-
torical high water table.
Note: The treated area may be located less than 1.5
meters (5 feet) above the historical high water
table if the owner/operator can demonstrate to
the Regional Administrator, at the time a permit
is issued pursuant to Subpart E, that no direct
contact will occur between the treated area and
the water table.
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The objective of this regulation is to ensure that
sufficient distance exists between the treated area and the
historical high water table. Rationale in support of this
regulation are similar to rationale (A) and (B) of paragraph
(b) (1). Additionally, groundwater monitoring at hazardous
waste landfarms will not be required, therefore, it is
imperative that the treated area and the water table be
separated to allow for soil monitoring. The entire concept
of landfarming as a disposal method is based on the premise
that waste will be attenuated by the soil. This process
cannot operate properly in the absence of an unsaturated
soil zone. Requiring separation of the soil/waste medium
and the water table is necessary if a zone of natural
attenuation is to be relied upon. Additionally, the
separation is needed to provide a zone to compensate for
fluctuations in the height of the water table during its
yearly hydrological cycle.
According to one study (15), chemical contamination of
groundwater as a result of landfarming can, to a great
extent, be controlled by proper siting of the facility.
The study suggests that a reasonable distance to groundwater
be one of the location criteria.
A distance of 1.5m to the historical high water table
is considered reasonable and is used by several States for
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landfill siting requirements. The rationale supporting the
use of 1.5m and the term historical high groundwater table
are presented in the Landfill Background Document (para-
graph a, 2) .
Based on groundwater^ cases alone, the 1.5m distance
requirement for landfills is easily supported. Application
of this number to landfarms cannot be justified on the
basis of groundwater damage cases, since none to date have
been documented. However, landfarms, unlike landfills, do
not rely on a natural or artificual liner for waste reten-
tion, and in any land application practice, there is always
a risk of contaminating subsurface waters (16) . This is
especially true at sites with poor management practices (15)
Based on the fact that groundwater monitoring and
liners are not required at landfarms and being cognizant
of the inherent risk of groundwater pollution at such
sites, the 1.5m distance is justifiable.
Recognizing the fact that some sites may be engineered
such that depth to the water table can be less than 1.5m,
e.g., use of an impermeable liner, a note providing for
variance accompanies this paragraph.
H-T
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(4) The treated area of a landfarm shall be
at least 150 meters (500 feet) from any functioning
public or private water supply or livestock water
supply.
Note: The treated area of a landfarm may be less than
150 meters (500 feet) from any functioning public
or private water supply or livestock water supply,
provided the facility owner/operator can demonstrate
to the Regional Administrator, at the time a permit
is issued pursuant to Subpart E, that:
(i) No direct contact will occur between
between the treated area of the landfarm and
any functioning public or private water
supply or livestock water supply;
(ii) No migration of hazardous constituents
from the soil in the treated area of the land-
farm to any public or private water supply or
livestock will occur; and
(iii) A soil monitoring system as specified
in Section 250.45-5(e) has been installed
and is being adequately maintained.
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The objective of this regulation is to provide a
buffer zone between the waste disposal site and nearby
water supplies. A distance of 150m is relied upon in terms
of providing a margin of safety and is not expected to serve
as the main barrier for preventing pollution of a water
supply well. Rationale for this regulation are derived, in
part, from existing State landfill regulations. The case
for applying landfill regulations to landfarms is presented
in the discussion in paragraph (b)(3) of this document.
A review of several States' regulations reveals a
dichotomy in the approach used to develop buffer zone
regulations. Most States prefer regulating on a site-
specific basis, the premise being that the distance needed
between a land disposal site and water supply well is
dependent upon site specific variables, such as soil
permeability, groundwater flow and direction, groundwater
quality and use, etc.
At least two States, Texas (State Department of
Health Resources) and Wisconsin (Department of Natural
Resources), prefer to specify a distance, 500 feet (150m)
and 1250 feet (375m) respectively. The States' rationale
behind specifying a number is that it provides a tangible
point of reference and simplifies enforcement. Being
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cognizant that a specified distance may not be applicable
in some situations, both States maintain a flexible attitude
and allow for concessions to be made. Wisconsin requires
special construction techniques be used for constructing
wells within 1250 feet (375m) of a landfill. Texas allows
wells within 500 feet (150m) of a disposal site if certain
site parameters can provide the equivalent of 500 feet
(150m) of protection.
The regulatory approach taken by EPA, like that of
Texas and Wisconsin, incorporates the advantages of having
a tangible reference point with the versatility of allowing
for concessions to be made under special circumstances
(via the note).
Although the conservative value of 150m was chosen, when
it is used in conjunction with other requirements in Section
250.45-5(b), it provides adequate time for detecting and
responding to a problem when one is detected.
(4) A landfarm shall be located on an area that
has fine grained soils (i.e., more than half the
soil particles are less than 73 microns in size
which are of one of the following types, as
defined by the Unified Soil Classification
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system (ASTM Standard D 2487-69 (: OH - organic
clays of medium to high plasticity? CH - inor-
organic clays of medium to high plasticity;
CH - inorganic clays of high plasticity, fat
clays; MH - inorganic silts, micaceous or
diatomaceous fine sandy or silty soils, elastic
silts; CL - inorganic clays of low to medium
plasticity, gravelly clays, sandy clays, silty
clays, lean clays; OL - organic silts and
organic silt-clays of low plasticity.
Note: A landfarm may be located on an area with soil
types other than those specified above provided
the owner/operator can demonstrate to the
Regional Administrator, at the time a permit is
issued pursuant to Subpart E, that the alternative
soil types will prevent hazardous constituents
from verticlly migrating a distance that exceeds
three times the depth of the zone of incorpora-
tion or 30 centimeters (12 inches), whichever
is greater.
The objective of requiring landfarms to be located
in areas with the soil types specified above is to provide
for maximum attenuation (retention) of hazardous waste
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constituents. The soils specified were selected for their
physical and chemical properties, which directly effect the
capacity of the soil to attenuate wastes. Essentially, the
soil types selected are:
o fine-grained - more than half of the soil particles
are less than 73 mic^rons in diameter;
o silts, clays, or silt-clays with organic or
inorganic components.
Fine-grained soils (silts, clays, and colloids) are
characterized by an extremely large specific surface, i.e.
area per unit weight. Clays, especially swelling clays,
like montmorX'illonite and vermiculite, have both internal
as well as external surfaces. Their specific surface can
reach 800 square meters per gram (17). The larger the
specific surface, the greater is the available area for
attenuation reactions, therefore, finer soil materials
have greater attenuating characteristics than coarser
materials (18, 19). Consequently, the finer the soil
mixture, the less is the migration of waste constituents.
Specific surface is an extremely important waste-attenuation
parameter, however, it is highly variable as a result of
differences in soil texture, types of clay minerals, and
organic matter. Optimizing this parameter, via
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specifying desirable physical and chemical soil properties,
is necessary if landfarming is to be an efficient and
environmentally acceptable method of waste disposal.
Similar soil types, to those discussed, are recommended
by the Oklahoma State Department of Health and Texas
Department of Water Resources in their landfarming guide-
lines. Both of these States have had extensive experience
with landfarming because of the significant number of
petroleum refineries and petrochemical plants (in both
States) that utilize the practice. The soil types
recommended are based on experience and serve as precedent
for this paragraph.
(b) Site Preparation
(1) Surface slopes of a landfarm shall be
less than 5 percent, to minimize erosion in
the treated area by waste or surface run-off,
but greater than zero percent to prevent the
waste or water from ponding or standing for
periods that will cause the treated area to
become anaerobic.
Note: Surface slopes of the landfarm may be greater
than 5 percent provided the owner/operator can
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demonstrate to the Regional Administrator, at
the time a permit is issued pursuant to Subpart E,
that such slopes will not result in erosion caused
by waste or surface run-off in the treated area.
The objective of this regulation is to prevent erosion
and ponding of water and waste in the treated area.
The consequences of erosion have been discussed
previously in the rationale for paragraph (b)(2). According
to one landfarming study (4), prospective sites should be
on relatively level ground with an average grade of 0 to 5
percent. Grades greater than 5 percent will significantly
increase run-off and water velocities with a subsequent
increase in erosion (4).
The opposite end of the spectrum is the ponding of
water and waste as a result of insufficient slope. Accord-
ing to the Oklahoma State Department of Health Guidelines
on landfarming/ a perfectly flat or 0 percent slope will
cause water and waste to accumulate or pond in the treated
area. Anaerobic conditions will subsequently arise with
resultant odor production. Additionally, ponding can
create a hydraulic head, or driving force, which will
push waste constituents to the subsurface and possibly to
groundwater. Further consequences of anaerobiosis in the
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treated area are addressed in the discussion, on paragraph
(d)(1). A grade greater than 0 percent, preferably around
1 percent, should be sufficient, in most cases, to prevent
ponding and to ensure a noneroding surface (4).
Additional precedent for requiring a slope of 0 to 5
percent are the guidelines for land cultivation developed by
the Oklahoma State Department of Health, the Minnesota Pollu-
tion Control Agency, and the Texas Department of Water
Resources (formerly Texas Water Quality Board). All three
States recommend slopes of 0 to 5 percent. The American
Petroleum Institute has recommended the same slope for
the landfarming of oily wastes.
Cognizant of the fact that a landfarm may have a
slope that exceeds 5 percent, yet be engineered to prevent
erosion in the treated area, a variance is provided.
Slopes are permitted to be greater than 5 percent provided
no erosion in the treated area will occur. An actual
example of how this can be achieved is the overland flow
method. Landfarms of this type rely on a heavy vegatative
ground cover to prevent erosion in the treated area.
(2) Caves, wells (other than active monitoring
wells) and other direct connections to the
ss
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subsurface environment within the treated area
of a landfarm, or within 30 meters (100 feet)
thereof/ shall be sealed.
The objective of this regulation is to prevent the
direct entry of wastes to the subsurface environment.
Direct access to the subsurface environment facilitates
pollution, especially groundwater pollution. The fate of
waste that accidentally enters the subsurface environment,
in a more or less direct manner, i.e., without undergoing
attenuation, is difficult to predict and control. Remedial
measures are usually ineffective and are extremely costly.
The reason for applying this requirement to the area
that extends 30m (100 feet) beyond the border of the treated
area is to provide an additional margin of safety. This
30m buffer zone will be expecially important during periods
of severe storms, when the potential for contaminated surface
water to eUcapt the site increases. The buffer zone will
also be important in the event of an accidental spill outside
the confines of the treated area.
(3) Soil pH in the zone of incorporation shall
be equal to or greater than 6.5.
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Note: Soil pH in the zone of incorporation may be
less than 6.5 provided the owner/operator can
demonstrate to the Regional Administrator, at
the time a permit is issued pursuant to Subpart
c
E, that hazardous Constituents, especially
heavy metals, will not migrate vertically a
distance that exceeds three times the depth
of the zone of incorporation or 30 centimeters
(12 inches), whichever is greater.
The objective of requiring the pH in the zone of
incorporation to be 6.5 or above is to maximize the biological
and chemical attenuation properties of the soil. Controlling
soil pH can enhance bacterial growth, hence waste biodegra-
dation. Stewart and Webber (20) found that the optimum pH
for bacterial growth is near 7. More importantly, maintain-
ing a pH of 6.5 or above immobilizes, with few exceptions,
heavy metal cations in the soil. Current research concerning
the pH effect on heavy metal fixation and mobility arises
from the concern over the uptake of such metals by food-
chain crops grown on sludge amended soils. There have been
many studies showing that liming to raise pH decreases the
solubility of many heavy metals and their availability to
plants. As a result of these studies and current acceptable
practices, EPA has published proposed criteria (43 FR 4942)
S7
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specifying a minimum pH of 6.5 for agricultural lands
amended with heavy metal-bearing sewage sludge.
Immobilization of heavy metals via pH control is the
crux of landf arming hazardous wastes. What has been learned
about pH in agriculture is directly applicable to hazardous
waste management practices. In the mining industry, pH
control is a well established practice for treatment of
trace metal-bearing waste waters (19) .
Much of the waste landf armed today contains heavy
metals with concentrations in the thousands of parts per
range. Heavy metals are not biodegradable and,
therefore, accumulate in the soil. Their availability for
leaching is what makes them potentially hazardous. As long
as the metals remain immobilized in the soil, they will
pose no threat to groundwater or surface water. With most
agricultural soil4, the pH can be maintained at or above a
level of 6.5 through the application of lime.
Utilizing a minimum pH of 6.5 or 7.0 is a recommended,
practice at many operating landf arms, especially those
disposing of oil refinery waste (4) . Both the Oklahoma
State Department of Health and the Texas Department of
Water Resources recommend a pH of 6.5 or greater in their
landf arming guidelines for hazardous waste.
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Although most heavy metals become less soluble in
neutral to alkaline soils, there are some notable exceptions.
Studies have shown that the degree of attenuation for anionic
species, such as boron, selenium, hexavalent chromium, molyb-
denum, and some valency states of arsenic, decreases under
neutral to alkaline soil conditions. Migration of these
-F
anions to groundwater is a potential problem iai waste con-
taining these species is applied to soil with a pH of 6.5
or greater.
Banning the landfarming of waste containing mobile
anionic species was considered. Unfortunately, a ban would
categorically prevent the landfarming of waste with even a
trace amount of mobile anionic species. This is not prac-
tical because certain concentrations of such metals could,
in all probability, be landfarmed safely. The fact that
selenuim, chromium, and molybdenum are essential trace
elements further complicates the issue. In lieu of a ban,
extensive soil monitoring is required in the regulations.
The intent of soil monitoring is to detect problems such
as migration before groundwater contamination can occur.
The note that accompanies this regulation provides for
the situation in which the owner/operator can demonstrate
to the Regional Administrator that employing a pH of less
than 6.5 will prevent the waste from migrating. The note
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allows for design flexibility and encourages the development
of new landfarming technologies.
An alternative landfarm design might involve the use
of a low permeability, e.g., 10-7 cm/sec or less, natural
or artificial liner to prevent migration of mobile waste
constituents. Another design might utilize soil with a
pH (less than 6.5) that is the optimum for immobilization
of the waste being applied. This would be a waste-specific
landfarm and would necessarily be limited to accepting a
particular type of waste.
(b) Waste Application and Incorporation
(1) Waste application and incorporation practices
shall prevent the zone of incorporation from
becoming anaerobic.
The objective of this regulation is to prevent the
zone of incorporation from becoming anaerobic once waste
has been applied. The assimilatory capacity of the soil
system for a wide variety of chemical and biological trans-
formations is dependent upon the presence of an aerobic
zone at the soil surface.
6C
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Conditions favoring the growth of most higher plants
generally favor the chemical and biological reactions that
enhance waste degradation in the soil. Management of a
landfarm can, therefore, be patterned after a successful
crop production enterprise, which is in fact the case at
a number of landfarms. Farm equipment is routinely used
to plow, disc, or otherwise till the treated area. This
practice serves to bring the waste into intimate contact
with the soil and, most importantly, aerates the soil.
Mixing and aeration, expecially the latter, facilitate
and enhance biological and chemical attenuation of the
waste.
Aerobic decomposition of organic waste is one of the
main factors that differentiate a landfarm from a landfill.
Soil conditions at a landfill are predominantly anaerobic
and are responsible for many of the problems associated
with landfills, such as gas and odor generation and, to
a certain extent, leachate migration and leachate quality.
Soil conditions at a landfarm are (or should be)
predominantly aerobic, and the environmental integrity of
the operation depends upon that fact, as the following
discussion on the consequences of anaerobic systems
demonstrates:
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Consequences of anaerobic systems are (19):
(1) Gas production
The potential for human health and environmental
damage is significantly increased due to gas
production resulting form anaerobiosis of organic
compounds.
Normally gas production and associated odors
are minimal at a landfarm if the waste is incor-
porated into the soil and undergoes aerobic decom-
position (4). Under anaerobic conditions, however
degradation of organic products can produce carbon
dioxide, methane, and hydrogen sulfide in signifi-
cant quantities. Lesser quantities of alcohols
ammonia, organic amines, mercaptans, and organic
acids can also be produced (21). Evolution of
volatile compounds containing mercury or arsenic
is also possible under anaerobic conditions.
The carbon dioxide that is produced under
anaerobic conditions can unite with water to form
carbonic acid. Carbonic acid production reduce
pH and can effect accelereted migration of certa'
trace contaminants.
a
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(2) Reducing conditions (redox effect)
Reducing (anoxic) conditions favor accelerated
migration of heavy metals as compared with oxida-
tive (oxic) conditions. Trace contaminants such
as arsenic, beryllium, chromium, copper, iron,
nickel, selenium, vanadium, and zinc are much more
mobile under anaerobic than aerobic soil conditions,
all other factors the same.
(3) Organic Acid Production (pH effect)
Organic acids will be produced when organic
materials decompose in a limited oxygen environ-
ment. Organic acids are weak acids which can,
via lowering pH, enhance the mobility of most
trace contaminants through the soil. Organic
acids, produced under anaerobic conditions,
form chelates with many heavy and trace metals.
These metals are then protected (from immobili-
zation reactions) and are available for accelera-
ted movement through soils.
(4) Retardation of Biodegradation
Anaerobic degradation of organic matter
proceeds more slowly than |n&aerobic degradation.
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In addition, anaerobic degradation often stops
at some intermediate stage of oxidation leaving
an accumulation of organic intermediates (which
may be more toxic than the original compound)
in the soil.
In summary, anaerobic decomposition can evolve a
variety of gases (and associated odors) and can accelerate
the movement of trace and heavy metals through the soil.
Cognizant of these effects, preventing anaerobic conditions
must be given major consideration when siting, designing,
constructing, and operating a landfarm. For this reason,
a major emphasis on preventing anaerobic conditions is
reflected in the regulations. Three other paragraphs,
(b)(1)(2)(3), (c)(1), and (d)(2), are indirectly related
to preventing or minimizing the frequency and duration of
anaerobic conditions. All three regulations concern pre-
venting saturation of the zone of incorporation, which is
the most common cause of anaerobiosis at a landfarm.
This paragraph specifies an end result, i.e., prevent
anaerobic conditions, rather than a specific practice to
Achieve the desired end result. A specific operating re-
quirement, such as frequency of tilling or waste applica-
tion rate, was considered but, because landfarming methods
are site specific (as a result of the variables associated
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with site location, waste type, waste quantity, etc.)/
this was considered impractical.
(2) Waste shall not be applied to the soil
when it is saturated with water.
Note: Waste may be applied to the soil when it is
saturated with water provided the facility
owner/operator can demonstrate to the Regional
Administrator, at the time a permit is issued
pursuant to Subpart E, that the soil-waste mixture
will remain aerobic and that hazardous constituents,
especially heavy metals, will not migrate vertically
a distance that exceeds three times the depth of
the zone of incorporation or 30 centimeters (12
inches), whichever is greater.
The objective of this regulation is to prevent the
application of waste to soil that is saturated with water.
The source of the water can be from precipitation or other
exogenous sources/ or from the waste itself. The main
reason for this requirement is that saturated soil favors
accelerated migration of waste constituents via dissolution
or physical removal, or as a result of anaerobic conditions (19)
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Dissolution of waste constituents will be a severe
problem if the waste contains significant amounts of water
soluble substances such as the anions of carbonic, sulfuric,
hydrochloric, and guitric acids, and certain pesticides such
as carbaryl (19). Migration of undissolved constituents is
not anticipated to be a major problem on fine textured
soils with small pore spaces, yruch as the soil types cited
in paragraph (b)(5).
Migration of waste constituents as a result of anaerobic
conditions is, and will be, a major problem at hazardous
waste landfarms. The presence and availability of oxygen
in saturated soil is low compared to unsaturated soil and,
as a result, saturated soil is highly susceptible to becoming
anaerobic. This situation is further aggravated when the
BOD and/or COD of a waste exerts its effect on the soil
system. The major consequences of anaerobic conditions,
previously discussed in paragraph (d)(1), are enhancement
of factors that favo^ waste migration and maladorous emissions,
Site visits to landfarms in Texas and California (1, 2)
revealed that saturated soil conditions created odor and
waste application problems. There was no attempt made, at
V£rV\u\
either site, to determine if^waste migration was occurring.
Attempts at manipulating saturated soil, or even wet
soil, usually aggravate problems because plowing with heavy
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machinery obliterates soil pore spaced. Loss of soil pore
Dore e^aie.j,
space* enhances anaerobic conditions because ^ey are the
channels through which oxygen diffuses into the soil. The
California Regional Water Quality Control Board (San
Francisco Bay Region) feels that landfarming on saturated
soils is not good operating practice. The Board stipu-
lates/ as a permit requirement, that the landfarming of
waste alum sludge from a water treatment plant not be
applied during rainy weather or when soils are saturated (4)
Because the Agency recognizes that some landfarming
operations may dispose of waste safely, even when the soil
is saturated with water, the note that accompanies this
regulation provides for operational flexibility. For
example, some waste will contain an amount of water that
will saturate the soil for a short period of time, i.e.,
a period not long enough for anaerobic conditions to
manifest themselves. Under such conditions, if the owner/
operator can demonstrate that aerobic conditions will pre-
vail during the period the soil is saturated and that their
is no migration of hazardous constituents, a permit will
be issued.
(3) Waste shall not be applied to the soil when
the soil temperature is less than or equal to 0°C.
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The objective of this regulation is to prevent the
accumulation of hazardous waste in the treated area of a
landfarm as a result of decreased microbio.1 activity,
hence waste biodegradation, during periods of freezing
temperatures.
The metabolism of an organism is very closely tied
to temperature. Within the narrow range of temperatures
to which the active organism is tolerant, the metabolic
rate increases with increasing temperature and decreases
with decreasing temperature in a very regular fashion.
o>
This well known biological phenomenon has^significant
effect on the rate of waste biodegradation by soil bacteria.
Essentially the rate of waste biodegradation is dependent
upon the metabolic rate of the bacteria which is dependent
on temperature. According to Harris (22) , microbial activity
slows during the cool seasons and ceases when the soils are
frozen. Empirically, application of waste to soil during
low or freezing temperatures has yielded undesirable results
Francke and Clark (23) reported that low temperatures and
above average precipitation has an adverse effect on micro-
fial activity at an experimental waste oil/machine coolant
landfarm site in Tennessee. Decreased microbial activity
as a result of low temperatures, were also reported for an
oil refinery landfarm in Texas (24).
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Besides decreased microbial activity, frozen soils are
difficult fo\t) manipulate and, as a result, bringing the waste
into intimate contact with the soil cannot be effectively
accomplished. This results in less of an exposure of waste
surface area to biological and chemical attenuation mechanisms.
Lewis (24) reported that at an oil refinery landfarm in Texas,
operation is discontinued during the winter months because
the soil is either frozen or too wet.
Physical characteristics of the waste, such as viscosity,
may change significantly with temperature. Kincannon (25)
o
found that at low temperatures (approximately 4.5C), congealing
and solidification of oily waste sludges was a severe problem.
He found that mixing of the viscous oily matter into the soil
was not successful until ambient temperatures approached 27 c*
Highly contaminated run-off is another potential problem.
As a result of poor mixing and negligible degradation at low
temperatures, waste applied during the winter can effect con-
tamination of run-off during the spring thaw. In addition,
the accumulated waste can overload the soil and destroy the
bacterial population. The consequences are the same as a
waste spill or an over application of waste. Natural recovery
of the soil system is slow and remedial measures are required.
Because of the severity of the consequences associated
with applying waste to the soil during freezing temperatures,
£9
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no deviation from this regulation is permitted.
(4) The pH of the soil-waste mixture in the
zone of incorporation shall be equal to or
greater than 6.5 and maintained until the
time of facility closure.
Note: The pH of the soil-waste mixture in the zone of
incorporation may be less than 6.5 provided the
owner/operator can demonstrate to the Regional
Administrator, at the time a permit is issued
pursuant to Subpart E, that hazardous constituents
especially heavy metals, will not vertically migrate
a distance that exceeds three times the depth of the
zone of incorporation or 30 centimeters (12 inches) ,
whichever is greater.
The rationale for this regulation and the accompanying
note are presented in the discussion on paragraph (c) (3)
The two regulations differ in that this paragraph requires
the pH of the soil-waste mixture to be above 6.5 and maintained
until closure. Paragraph (c)(3) requires that the soil of
the zone of incorporation have a pH of 6.5 or greater prior
to waste application. The objective is to ensure that pn
is controlled both prior to and after waste application.
7C
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Maintenance of a pH of 6.5 until closure is necessary
/)
because the pH - dependent attenuation mechanisms are all
reversible. If the soil pH of a site containing heavy
metals is allowed to decrease, previously immobilized metals
might begin to migrate. Monitoring and maintenance of pH
is necessary because it will gradually decrease over time,
either as a result of decomposition by-products or, in
3
certain part^ of the country, acid precipitation (26). In
the latter case, laboratory and field studies have shown that
acid precipitation can increase the leaching of certion ions
from the soil and decrease soil respir^ation.
(5) Supplemental nitrogen and phosphorous added
to the soil of the treated area^for the purpose
of increasing the rate of waste biodegradation,
shall not exceed the rates of application
recommended for agricultural purposes by the
United States Department of Agriculture or
Agricultural Extension Service.
The objective of this regulation is to allow the
addition of fertilizers to landfarms for the purpose of
enhancing waste biodegradation at rates that will not
adversely impact the soil microbes or create groundwater
or surface water pollution problems.
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The benefit of supplemental nutrients in enhancing
waste decomposition is well known. Increased rates of
waste biodegradation in soils as a result of fertilizer
addition have been demonstrated both in laboratory and
field experiments. Kincannon (25) reported that supple-
mental nutrients can increase decomposition by 80 to 100
percent. Highly carbonaceous waste, particularly oily
waste, benefit from the addition of nitrogen. Without
additional nitrogen, a carbonaceous waste added to the
soil creates a carbon-nitrogen imbalance, i.e., a high
carbon to nitrogen or C:N ratio. The C:N ratio is perhaps
the most important determinant of decomposition rate (20) .
A large C:N ratio may result in excess nitrate. According
to Stewart and Webber (20), a C:N ratio of from 15 to 1 to
30ytoA is desirable as a general guideline.
The positive attributes of fertilizers are quickly
negated when the fertilizer is applied in quantities that
exceed the demands of the system. Excess nitrates in the
soil can, and do, contribute to contamination of groundwater
as a result of their mobility through the soil (4). Over-
application of phosphorous is also a problem. It has been
reported that accumulation of phosphorous in surface soil
can occur if supply exceeds bacterial or plan demands (20)
The excess phosphorous is then available for removal via
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erosion by surface run-off. Percolation of phosphorous
to groundwater is also possible under reducing conditions.
In addition to posing surface water and groundwater
pollution problems, excess nutrients can adversely impact,
instead of enhance, waste degradation by soil bacteria.
Both nitrogen and phosphorous can contribute to excessive
total soluble salts which may cause unfavorable osmotic
conditions for bacterial growth, and excess nitrogen
fertilizer elements can hinder (poison), instead of enhance,
bacterial action (25).
Determining the appropriate amount of supplemental
nutrients to add to a soil disposal system is difficult
because of site and waste specific parameters, and the
dearth of information on the subject. Both of these
factors make specifying fertilizer application rates based
on bacterial needs infeasible at this time. Instead, the
selection of fertilizer quantities is based upon agricultural-
oriented experience. This is a common practice at many land-
farms and has been endorsed as an appropriate environmental
and regulatory mechanism (27, 28).
(e) Soil Monitoring
(1) Background soil conditions shall be
determined by taking one soil core per acre in
7 ?
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the area to be treated. The depth of the soil
core shall be three times the depth -of the zone
of incorporation or 30 centimeters (12 inches) ,
whichever is greater. The bottom one-third of
the soil core shall be quantitatively analyzed
for those constituents known or expected to be
in the waste which make it hazardous. At new
facilities, soil cores shall be taken and analyzed
prior to beginning operation. At existing facili-
ties, background soil cores shall be taken and
analyzed within six months after the effective
date of these regulations.
(2) Soil conditions in the treated area of a
landfarm shall be determined by taking one soil
core per acre, semi-annually. The depth of the
soil core shall be three times the depth of the
zone of incorporation or 30 centimeters (12
inches), whichever is greater. The bottom one-
third of the soil core shall be quantitatively
analyzed for those constituents in the waste
which make it hazardous.
Note: Soil monitoring may be conducted by taking less
than one soil core per acre and/or by monitoring
less frequently than semi-annually, provided the
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owner/operator can demonstrate to the Regional
Administrator, at the time a permit is issued
pursuant to Subpart E, that hazardous consti-
tuents, especially heavy metals, will be
detected before vertically migrating a distance
that exceeds three times the depth of the zone
of incorporation or 30 centimeters (12 inches),
whichever is greater.
(3) If soil monitoring shows that the concentra-
tion of a hazardous constituent in the bottom one-
third of the soil core has significantly exceeded
the background levels established in accordance
with paragraph (e)(1), the owner/operator shall:
(i) Notify the Regional Administrator within
seven days;
(ii) Determine, by soil monitoring, the areal
^a-
extent of vertical contminant migration in
the soil; and
^'
(ii) Discontinue all landfarming in the
contaminated area, as determined in (ii), until
corrective measures can be taken.
7S
-------
Due to the interrelationship of the three soil
monitoring requirements, complete comprehension is best
achieved by initially discussing them as a whole and then
delving into the purpose and rationale for each regulation.
The overall objective of soil monitoring is to identify
physical and chemical changes in the soil conditions of a
£>S
-------
in precipitated form in the zone of soil incorporation,
are retained in soil particles in the semi-saturated fringe,
or are dissolved in groundwater within the zone of satura-
tion. Chemical analyses of soil core samples are usually
faster, easier, and more economical than analyses of ground-
water samples collected from observation wells (4).
By determining the distribution of a chemical constituent
or contaminant in the soil (concentration vs. soil depth),
it is possible to discover whether the pollutant is retained
in the surface soil or is moving slowly to lower soil
depths (30). This information can be used as an early
warning of pending groundwater contamination, and as a
result^makes groundwater monitoring unnecessary at landfarms.
Additionally, EPA is not aware of any documented cases of
groundwater. pollution as a result of hazardous waste land-
farming practices.
A discussion of the rationale/purpose for each paragraph
in soil monitoring is presented. The requirements for the
number of soil cores per acre, the frequency of sampling,
and the analyses of the core samples are, for the most part,
identical in paragraphs (e)(1) and (2), therefore, these
requirements are discussed together, following the general
rationale for paragraphs (e) (1) and (2) .
77
-------
Paragraph (e) (1)
The purpose for establishing background conditions
is to provide a point of reference or measure to which
another point or measure, obtained during site opera-
tion, can be compared (4). Based on this comparison,
it will be possible to quantitatively determine whether
or not a landfarm is accomplishing its intended function
in an environmentally acceptable manner.
Paragraph (e)(2)
The rationale for monitoring the soil of the
treated area of a landfarm are covered in the opening
discussion on the overall objective of soil monitoring
at landfarms.
Soil Core Sampling Requirements
A) One soil core per acre
Requiring one soil core per acre was arrived
at as a result of discussions within EPA .(31, 32)
and members of academia with expertise in the
4
area of landfarming (33, 3^). The number is
-------
based on the procedures used for sampling the
soil conditions of agricultural lands. Normally
this involves taking five to seven cores per ten
acres. Because of the role soil monitoring plays
in the landfarming of hazardous waste/ requiring
one core per acre was not considered to be an
excessive requirement. Taking less than one
soil core per acre is permitted provided certain
conditions (specified in the note) can be met.
B) Semi-annual soil monitoring of the treated area
Monitoring the treated area of a landfarm
at a minimum of two times per year is suggested
as being adequate to detect vertical migration of
hazardous waste before groundwater is threatened (4)
The success of soil monitoring to detect problems
is contingent upon adherence by the the facility
owner/operator to the other landfarming regulations.
When landfarmed properly, waste contaminants in the
treated area rarely move beyond the zone of incor-
3
poration (4, 18, 25, 35, ?6). The Agency acknow-
ledges that some sites may not require semi-annual
monitoring because of a certain site parameter or
operating practice. This is provided for by the
-------
note which requires the owner/operator to
demonstrate that waste migration will be detected
prior to exceeding three times the depth of the
zone of incorporation.
C) Core sample depth of three times the zone of
incorporation or 30 centimeters (12 inches) ,
whichever is greater.
In lieu of requiring a fixed core sample
depth for all sites, one was selected that is
dependent on the depth to which the waste is
incorporated into the soil. This means if the
waste is to be plowed or tilled into the soil
to a depth of six inches, the depth of a core
sample would be 18 inches. In situations where
the waste is not incorporated into the soil or
is incorporated to a depth of less than four
inches, the depth of a core sample will be a
minimum of 12 inches. In this manner, vari-
ability in incorporation methods between sites
is taken into account. Additionally, there is
a direct relationship between the depth to
which a waste is found in the soil profile and
the depth to which it is incorporated into the
soil (4, 18, 25, 35, 26).
fc
-------
This requirement was developed within EPA
and has met with accept^pi^ by State regulatory
agencies, industry, and academia.
D) Quantitatively analyze the bottom one-third of
the core sample for those constituents known or
expected to be in the waste which make it hazard-
ous .
The core sample is composed of three sections,
each of which represents a distinct zone. The
upper section (top one-third of core) represents
the zone of incorporation. This is the. zone or
layer into which the waste is incorporated or
mixed. Data from the literature show that a/
properly managed landfarms, no migration of
waste contaminants occurs beyond the zone of
C
incorporation (4, 18, 25, 35, 36).
The middle section (middle one-third of core)
is the buffer zone. Even though data indicate that
the extent of migration of waste contaminants is
limited to the zone of incorporation, a buffer
zone is provided to allow for the effects of within
site variability, e.g., the depth of the zone of
incorporation may vary from six to eight inches.
-------
The lower section (bottom one-third of core)
represents the indicator zone. The presence or
absence of waste contaminants in this zone indi-
cates whether or not a landfarm is functioning
properly. Contamination of this zone, in view
of data from the literature, is considered
M
unacceptablejand appropriate remedial measures
must be taken. It is for this reason that only
the bottom one-third of the soil core need be
analyzed.
Although no precedent for the EPA soil
monitoring approach could be found in State
regulations or guidelines, a similar approach
was arrived at independently by an EPA contractor
that recently performed a state-of-the-art study
on landfarming practices (4) . The contractor,
in the "operational recommendations" section,
stated that "a landfarm site must be properly
monitored to ensure that waste constituents
are retained in the layer of incorporation.
This can be accomplished by collecting soil
samples at three depths (0 to 30, 30 to 60,
and 60 to 90 cm) prior to site activation and
f-f
-------
at 3-to 6-mo intervals thereafter. Soil samples
collected should be analyzed for those constituents
present in the waste which may result in water
it
pollution problems. The only major difference
between this and the EPA approach is the con-
tractors ' recommendation of a fixed core sample
depth which, as mentioned previously, is con-
sidered inappropriate due to variations in
incorporation methods. On the whole, the
contractor's approach lends complete support to
the EPA approach.
Paragraph (e)(3)(i, ii, iii)
This paragraph prescribes the plan of action that
must be taken when contamination is detected in the
bottom one-third of the soil core. Part (i) of this
paragraph requires that the EPA Regional Administrator
c/
be notified. The purpose #z>X this is to apprise EPA of
the problem and receive technical assistance on remedial
measures. Parts (ii) and (iii) of this paragraph re-
quire determining the areal extent of contamination
and the cessation of waste application in that area.
The latter requirement is necessary because application
to the contaminated area will only aggravate the problem
-------
and lessen the chances of reversing the damage to
the soil system. Notably this approach allows site
operation to continue, except in the contaminated
area, thus preventing a backlog of wastes.
(f) Growth of Food-Chain Crops
Food-chain crops shall not be grown on the
treated area of a landfarm.
Growth of food-chain crops upon hazardous waste
landfarms is prohibited. The purpose of this prohibi-
tion is to protect against human consumption of toxic
materials that may adhere to or be taken up by such
crops. It is recognized, however,that there may be
certain hazardous waste that could be safely applied
to land on which food-chain crops are grown if certain
management practices are employed. For example, for
waste similar to sewage sludge from publicly owned
treatment works, it may be possible to develop manage-
ment controls similar to those that EPA is currently
developing for such sludges under Section 4004 of this
Act and Section 405 of the Clean Water Act (e.g., con-
trol of application rates, soil/waste pH, etc.). How-
ever, EPA has considerable data on the effect that
-------
POTW sewage sludge has on food-chain crops. This
data made it possible to develop rules for land-
farming management controls in lieu of a rule
prohibiting the growth of food-chain crops. In
contrast, there is a dearth of information on the
effects that other types of sludges have on food-
chain crops.
Given the potential for high levels of 'toxic
constituents in the hazardous waste that could be
landfarmed under these regulations, and the lack
of information on crop uptake of contaminants from
these wastes, a general prohibition on the growing
of food crops is deemed warranted,
(g) Closure
(1) A landfarm shall be designed and operated
so that, by the time of closure, the soil of
the treated area(s):
(i) is returned to its pre-existing
condition, as established in paragraph (e)
(1) if the facility began operation after
promulgation of this requirement (i.e., a
new facility).
-------
(ii) is returned to equivalent pre-existing
condition, as determined by soil analysis of
similar local soils that have not had hazard-
ous waste applied to them, if the facility
began operation prior to the promulgation of
this requirement (i.e., an existing facility).
Soil analysis of similar local soils shall
not be required at existing facilities if
background soil data are available and those
data establish background conditions for the
treated area(s).
(2) Soil of the treated area(s) of a new or existing
facility that does not comply with paragraph (g)
(1)(i) or (ii), respectively, shall be analyzed
to determine if it meets the characteristics of
a hazardous waste as defined in Subpart A. in
the event the soil is determined to be a hazard-
, //• .*/)&// M n/novatf C't/y sr)c.sicjJLff as CL S)c.
ous waste^in accordance with all applicable
requirements of this Part.
Note: The soil at a landfarm, if determined to be a
hazardous waste, need not be removed provided
the owner/operator can demonstrate to the
Regional Administrator that, because of its
f(
-------
special design and/or because of its location,
the landfarm provides long term integrity and
environmental protection equivalent to a land-
fill as specified in Section 250.45-2. In the
event of such a showing, the owner/operator shall
comply with the applicable closure and post-closure
provisions of Sections 250.43-7 and 250.45-2
(c and d).
The major objective of closure, paragraphs (g) (1) and
(2) , is to prevent the conversion of huge tracts of productive
land to land with limited potential for future use. Meeting
this objective requires that the soil of the treated area(s)
/.<2-
of a landfarm be returned to its previously existing, £.#./
prior to waste application, condition. New facilities will
utilize the soil monitoring background data developed prior
to beginning operation. Existing facilities must use the
background soil conditions of similar local soils as the
basis for comparison unless site data exist that estab-
lishes background conditions for the soil of the treated
area(s) prior to any waste application. The soil in a
landfarm is a filter medium which, when subject to appli-
cation of waste containing non-degradable contaminants,
eventually becomes loaded with such contaminants, espe-
cially heavy metals. Left unattended, the contaminants of M-JL
-------
soil-filter medium will eventually be carried away by
surface run-off, or will migrate to groundwater due to
natural changes in physical and chemical soil parameters.
Therefore/ the contaminated soil-filter medium, if deter-
mined to be a hazardous waste under Subpart A, must either
be decontaminated or disposed of as a hazardous waste.
The Texas Department of Water Resources (TDWR) incor-
porates a similar approach into some of the permits issued
for landfarms. In one case, TDWR requires that final clo-
sure shall consist of the removal of all soil to a depth
of 12 inches in any area of the disposal site where the
soil presents a potential hazard to surface water. This
is determined by comparing the results of leaching tests
performed on soil from the disposal area and soil from an
area that has not had waste applied. A significant in-
crease, over background, of waste materials or degradation
products requires removal of the soil.
The note accompanying this paragraph provides for
&
exemption from the soil removal requirement in the situation
where a landfarm, because of its special design and/or
because of its location, provides long term integrity and
environmental protection equivalent to a landfill, as
specified in Section 250.45-2. Examples of existing
-------
landfarms that might be in this category are the landfarms
in California that are required to dispose of Group I
wastes (hazardous materials) in Class I disposal sites.
Essentially, these landfarms are on landfills and therefore
could, if California's Class I disposal sites meet the
landfill requirements in Section 250.45-2, be closed in
accordance with those requirements instead of paragraphs
(g) (1) and (2) .
-------
REFERENCES
1. Lytle, Paul E. Site visit: Gulf Coast Waste
Disposal Authority, Houston, Texas; trip report.
U.S. EPA, Office of Solid Waste, Washington, D. C.
January 1, 1978. 8 p.
2. Lennon, James V. Site visit: IT Corporation,
Martinez, California; trip report. U. S. EPA,
Office of Solid Waste, Washington, D. C.
October 24, 1978. Slide presentation.
3. TRW. Evaluation of Emission Control Criteria for
Hazardous Waste Management Facilities. Contract
No. 68-01-4645, U. S. Environmental Protection
Agency, April 1978.
4. SCS Engineers, Land Cultivation of Industrial Wastes
and Municipal Solid Wastes: State-of-the-Art Study
Volume I. Contract No. 68-03-2435, U. S. Environ-
mental Protection Agency, August 1978.
5. U. S. Environmental Protection Agency. Report to
Congress: Waste Oil Study. April 1974.
6. Hatayama, H. K., and D. Jenkins. An Evaluation of the
Weathering Method of Disposal of Leaded Gasoline
Storage Tank Wastes: A Summary. in: Proceedings
of the National Conference about Hazardous Waste
Management; San Francisco, February 1-4, 1977;
In press.
7. Adriano, D. C., et al. Effect of Long Term Land
Disposal by Spray Irrigation of Food Processing
Wastes on Some Chemical Properties of the Soil
and Subsurface Water. J. Environ. Qual., 4:242-^&£
1975. ;
8. Personal communication. Jim Kinsey, Minnesota
Pollution Control Agency, to L. A. Weiner, Office
Of Solid Waste. December 14, 1978.
9. Personal Communication. George Marienthal, Department
of Defense, Washington, D. C., to L. A. Weiner,
Office of Solid Waste. October 19, 1977.
-------
10.
11. Personal communication. Don Hensch, Oklahoma State
Department of Health, to L. A. Weiner, Office of
Solid Waste. December 19, 1978.
12. Personal communication. Steve Jones, Texas Department
of Water Resources, to L. A. Weiner, Office of Solid
Waste. December 19, 1978.
13. Processes Research, Inc. Alternatives for Hazardous
Waste Management in the Organic Chemical, Pesticides
and Explosives Industry. Contract No. 68-01-4127,
U. S. Environmental Protection Agency, 1977.
14. California Department of Health. Recommended General
Options for the Management of Incompatible Hazardous
Waste Treatment, Storage and Disposal Facilities.
Research Grant No. R-804692010, U. S. Environmental
Protection Agency, May 1977.
15. U. S. Environmental Protection Agency. Draft Environ-
mental Impact Statement: Criteria for Classification
of Solid Waste Disposal Facilities. Office of Solid
Waste. April 1978.
16. Phung, H. T., D. E. Ross, and R. E. Landreth. Land
Cultivation of Industrial Wastewaters and Sludges.
Proc. National Conference on Treatment and Disposal
of Industrial Wastewaters and Residues. 1977 (in
press)
17. Mortland, M. M., and W. D. Kemper, Specific Surface/
In Methods of Soil Analysis, Part 1, Physical and
Mineralogical Properties/ Including Statistics of
Measurement and Sampling. C. A. Black, ed. American
Society of Agronomy, Inc. 1965. p. 532-544.
18. Page, A. L. Fate and Effects of Trace Elements in
Sewage Sludge When Applied to Agricultural Lands.
A Literature Review Study. EPA-670/2-74-005,
U. S. Environmental Protection Agency. January 1974.
19. Fuller, W. H. Movement of Selected Metals, Asbestos,
and Cyanide in Soil: Applications to Waste Disposal.
EPA-600/2-77-020, U. S. Environmental Protection
Agency, April 1977.
-------
20. Stewart, B. A., and L. R. Webber. Consideration of
Soils for Accepting Wastes. In: Land Application
of Waste Materials. Soil Conservation Society of
America, Akeny, Iowa, 1976. pp. 8-21.
21. Mosier, A. R., el al. Odors and Emissions from Organic
Wastes and Waste Waters. American Society of Agronomy,
Madison, Wisconsin, 1977. pp. 531-571.
22. Harris, J. 0. Petroleum Wastes in the Soil. In:
Land Application of Waste Materials, Soil Conserva-
tion Society of America, Akeny, Iowa. 1976. pp 249-
253.
23. Francke, H. W. , and F. E. Clark. Disposal of Oil Wastes
by Microbial Assimilation. Contract No. W-7405-eng-26
U. S. Atomic Energy Commission. May 16, 1974. '
24. Lewis, R. S. Sludge Farming of Refinery Wastes as
Practiced at Exxon's Bayway Refinery and Chemical
Plant. Presented at the National Conference on.
Disposal of Residues on Land, St. Louis, Missouri
September 13-15, 1976. '
25. Kincannon, C. B. Oily Waste Disposal by Soil Cultiva-
tion Process. EPA -R2-72-100, U. S. Environmental
Protection Agency, December 1972.
26. Likens, G. E. Acid Precipitation. Chemical and
Engineering News. November 22, 1976. pp 29-44.
27. Personal communication. Kirk Brown, Texas A&M University
to L. A. Weiner, Office of Solid Waste. January 27 1978.
28. Personal communication. Keith Young, U. S. Department
of Agriculture (SCS) to L. A. Weiner, Office of Solid
Waste. October 17, 1978.
29. Lund, L. J., A. L. Page, and C. 0. Nelton. Movement of
Heavy Metals Below Sewage Disposal Ponds. J EmH
Qual., 5:330-334, 1976. viron.
30. Baker, D. E., and L. Chesnin. Chemical Monitoring of
Soils for Environmental Quality and Animal and Human
Health. Adv. Agron. 27:305-374, 1975.
31. Personal communication. Emer^y Lazar, Office of Solid
Waste to L. A. Weiner, Office of Solid Waste.
October 3, 1978.
-------
32. Personal communication. Bruce Weddle, Office of Solid
Waste, to L. A. Weiner, Office of Solid Waste.
October 3, 1978.
33. Personal communication. Kirk Brown, Texas A&M University,
to L. A. Weiner, Office of Solid Waste. January 27, 1978.
34. Personal communication. Michael Overcash, North Carolina
State University to L. A. Weiner, Office of Solid Waste.
February 7, 1978.
35. Huddleston, R. L. Treatment of Oily Wastes by Land
Farming. Presented at the RSMA Meeting "Disposal of
Industrial and Oily Sludges by Land Cultivation,"
Houston, Texas, January 18-19, 1978.
36. Raymond, R. L., J. 0. Hudson, and V. W. Jamison.
Assimilation of Oil by Soil Bacteria. In: Pro-
ceedings of the 40th Midyear API Meeting. 1975.
-------
VII. Appendices
APPENDIX I
Summary of State Regulations Affecting Land Cultivation (1)
-------
APPENDIX I
SUMMARY OF STATE REGULATIONS AFFECTING LANDFARMING
State
Cali fornla
Connecticut
Delaware
Florida
Pertinent Regulations
There are no specific guidelines or regula-
tions for land cultivation
Spray Irrigation guidelines serve as one
reference point In evaluating land cultivation
applIcatlons
The state "Water Reclamation Law" dictates
the groundwater quality must be maintained at
sites utilizing land disposal of wastewater
Waste for land'cultlvatlon must be biodegra-
dable
Group 1 wastes (hazardous materials) must be
disposed of In Class I disposal sites
There are no specific guidelines or regulations
for land cultivation
Permits are required for all land disposal
operations
There'are no specific regulations or guide-
lines for land cultivation
A permit Is required for disposal of waste by
land cultivation, just as for any other
disposal methods
Review of land cultivation permit applications
concentrates on waste characteristics and site
characteristics such as soil types and depth
to groundwater
There are no specific guidelines or regulations
for land cultivation
Spray Irrigation guidelines are used to some
extent as a reference point for nutrient and
hydraulic loading considerations related to
land cultivation disposal sites
(continued)
-------
APPENDIX I (continued)
State
Pertinent Regulations
Florida (Continued)
Georgia
I daho
Illinois
Indiana
Substantially different climatic conditions
in different parts ot" the state make flexible
guidelines attractive
There are no specific guidelines or regula-
tions for land cultivation
Permits are not required for land disposal of
wastewater 1f there Is no surface discharge.
The state reviews plans and specifications to
establish the environmental adequacy of all
waste disposal methods
Regulations governing spray irrigation faci-
lities prevents the use of spraying without
a cover crop
There are no specific regulations or guide-
lines for land cultivation
Specific spray irrigation regulations requiring
that no groundwater mound results and that no
salt intrusion be observed on neighboring
property is also applied to land cul tivation of
wastewaters
There are no specific guidelines or regula-
tions for land cultivation
Permits are required
There are no specific guidelines or regula-
tions for land cultivation
Land cultivation has recently received increased
emphasis due to groundwater pollution problems
which showed up at several sites during «
the summer of 1976. These sites had operated
unsuccessfully the previous years.
(continued)
-------
APPENDIX I (continued)
State
Kansas
Pertinent Regulations
There are no specific guidelines or regulations
for land cultivation
Spray irrigation regulations are used for
reference in evaluating land cultivation of
wastewaters
Kentucky
Mai ne
Maryland
Specific land cultivation guidelines are not
desired since flexibility in matching wastes
and disposal sites is desired. Flexibility is
particularly important due to the widely
varying terrain experienced with the state
Discharge permits are not required for waste-
water land cultivation systems with zero
surface discharge, but construction permits
are required. Provisions also exist for
periodic inspection to ensure proper opera-
tion and zero discharge conditions
There are no specific regulations or guide-
lines for land cultivation
Guidelines are currently being prepared for
disposal of paper mill sludge by land culti-
vation
Guidelines have been written for disposal of
municipal sewage sludge by land cultivation
There are no specific guidelines or regula-
tions with the exception of certain bacterio-
logical standards which have been set for stme
food processing wastes \
Specific spray Irrigation regulations and
sludge disposal guidelines aid in the evalua-
tion of land cultivation sites
(continued)
-------
APPENDIX I
(continued)
State
Pertinent Regulations
Massachusetts
filch igan
Minnesota
Mississippi
There are no specific guidelines or regula-
tions for land cultivation
Certified sanitary landfill facilities must
be used for disposal of hazardous waste
Land cultivation requires state approval
There arc no specific guidelines or regula-
tions but there are specific procedures re-
quired for site investigation prior to grant-
ing a permit for land cultivation; moni-
toring wells are required
Groundwater standards are in the process of
being drafted which will be utilized in
evaluating future land cultivation sites.
All disposal sites will be required to ensure
that the neighboring groundwater meets the
state standards (which basically will be
drinking water standards)
There are no specific regulations or guidelines
for land cultivation
Land cultivation is uncommon except for
food processing wastes
A permit Is required from the state for the
operation of land cultivation sites; the
state must approve each type of woste being
disposed at the site
Existing regulations are vague, but there are
plans to write specific guidelines for
various categories of waste such as oily
Waste, agricultural waste, etc.
(continued)
-------
APPENDIX I (continued)
State
Pertinent Regulations
New Hampshire
New York
North Carolina
Mo specific guidelines or regulations currently
exist, but permission to operate a land
cultivation facility is required
Permission is granted based on a view of waste
composition and site soil types, topography
and operating procedures. Permission is
granted on a temporary basis contingent on
successful test plot results. If test plot
application results are successful, a more
permanent permission permit would be issued
There are no specific guidelines or standards
of review for land cultivation disposal
The state policy is to discourage land appli-
cation of to.xic waste
Guidelines for spray irrigation are used as
an aid in reviewing land cultivation disposal
application
No specific guidelines have been written for
land cultivation, but specific evaluation
procedures are utilized to evaluate applica-
tions
Applications for use of land cultivation dis-
posal requires that a soil scientist and an
report on the site to
design features and
agronomist review and
determine appropriate
operating procedures
It was Indicated that specific regulations
are not desired, since flexibility needs to
be maintained. In this way, a site appropriate
for a specific type of waste can be identi-
fied and utlized
(continued)
-------
APPENDIX I (continued)
State
Pertinent Regulations
Ohio
Oklahoma
Oregon
Pennsylvanla
• There are no specific guidelines or regulations
for land cultivation
t Land application has received little emphasis
to date since it is used only sparingly
• Land cultivation disposal sites are regulated
under the "Controlled Industrial Waste Disposal
Act, 630S Supp. 1976." This establishes
minimum site standards and other factors such
as waste storage capacity. Case-by-case
analysis is still required to evaluate land
cultivation disposal applications
• Specific regulatory guidelines were promul-
gated in response to the large quantities of
oily waste requiring disposal (see Table 12)
• There are no specific guidelines or regula-
tions for land cultivation
• Specific guidelines for municipal wastewater
treatment, sludge disposal, and/or spray
irrigation are used as a reference point in
evaluating land cultivation applications
• There are no specific guidelines or regula-
tions for land cultivation
• Spray irrigation guidelines are used as a
reference for evaluating land cultivation of
wastewater
I The general policy 1s to prohibit land culti-
vation of toxic waste which is not biodegrada-
ble
(continued)
-------
APPENDIX I
(continued)
State
Rhode Island
South Carolina
Tennessee
Texas
Pertinent Regulations
No specific guidelines or regulations for
land cultivation
Off-site disposal of waste requires a permit
Written permission Is required If solid
wastes are disposed 1n any way other than
landfllling
Specific guidelines apply to spray irrigation
disposal facilities
Specific regulations are written for land
farming of cellulosic wastes. Permits are
requi red
Minimum site criteria have been written for
hazardous waste disposal
Groundwater monitoring of land cultivation
sites is normally required
There are no specific regulations or guide-
lines for land cultivation
All types of disposal facilities are required
to submit plans for approval. Each site must
then obtain an operating registration from
the state. Registration is not granted to a
site unless the operation is determined to be
satis factory.
Hazardous waste management legislation Is in
preparation which may have some impact on the
types of waste which may be land cultivated
As a general rule, the state does not approve
disposal of toxic waste by land cultivation^
One of the few states which has specific
guidelines for evaluation of land cultivation
disposal applications. However, these guide-
lines are fairly general
(continued)
-------
APPENDIX I
(continued)
State
Pertinent Regulations
Texas (Continued)
Vermont
Virginia
No permit Is required for on-site disposal of
waste. However, it is required that such
waste disposal be recorded In the property
records
The principal focus of the guidelines is to
prevent the buildup of toxic materials in the
soil. A safety margin Is provided between
the maximum allowable toxic constituent
concentrations and the level at which these
constituents may become detrimental to soil
productivity (see Table 12).
i There are no guidelines or regulations per-
taining to land cultivation and there are
no specific prohibitions against the use of
this disposal method for industrial waste
It is state policy to discourage land culti-
vation as a disposal method for industrial
waste other than food processing waste.
Approximately 60 percent of Vermont residents
rely on groundwater for their drinking water
supply, and therefore, are very sensitive to
groundwater pollution potentials arising from
land disposal practices
» There are no specific guidelines or regulations
for land cultivation
> Site plans are reviewed to insure that surface
and groundwater standards will not be exceeded
l There is a general reluctance to utilize land
cultivation for disposal of toxic or hazardous
waste
(continued)
-------
APPENDIX I
(continued)
State
Pertinent Regulations
Washington
llest Virginia
Wisconsin
There are no specific guidelines or regula-
tions for land cultivation
State control is exercised principally through
NPDE5 regulatory system, even for sludges
.Guidelines have been written for spray irriga-
tion facilities, a relevant feature being
that there is a five year limit on spray
Irrigation at any one site
There are no specific regulations or guidelines
for land cultivation
Land cultivation is seldom used and has
received little attention
Land spreading of toxic waste is discouraged,
although specific regulations have not been
written
A possible exception to this general policy
would be dilute solution of toxic waste which
are biodegradable
A specific permit program exists governing
spray irrigation. Information gained from
this program can be utilized to help ensure
proper design and operation of land cultivation
Sites
-------
APPENDIX II
Summary of Texas and Oklahoma
Land Cultivation Guidelines
-------
APPENDIX II SUMMARY OF TEXAS AND OKLAHOMA LAND CULTIVATION GUIDELINES
Guideline (Sumnary Statement)
Item
Texas
Oklahoma
• Soils
s
0 Topography
t Climate
• Surrounding Land Use
t Groundwater Conditions
• Waste Restrictions
• Application Rates
• Should be deep, prefer high
clay and organic content
and have large surface area
(best soils are classed as
CL, OL, Ml, CH and at under
the Unified Soil Classifica-
tion System)
• Prefer surface slopes less
than 5 percent, greater
than 0 percent
• High net evaporation, median
mean temperature, moderate
24-hr, 25-yr frequency maxi-
mum rainfall
t Sparsely populated, or provide
buffer and locate downwind
from nearby residences
• Avoid shallow potable ground-
water. If not possible, pro-
vide vegetative cover, avoid
high application rates, moni-
tor groundwater quality
t Not addressed
• Minimum waste composition
analysis: Cl, 1*04, Total N,
Zn, Cg, HI, As, Ba, Hn, Cr,
Cd. B, Pb, Hg, Se, Na, Mg, Ca
t Should be deep, have large total
surface area and have high clay and
organic content (best soils are
classed as CL, OL. Ml, Cll and Oil under
the Unified Soil Classification
System)
• Slope should be less than 5 percent,
greater than 0 percent
t High net evaporation, median mean
temperature, moderate 24-hr, 50-yr
frequency maximum rainfall
• Sparsely populated, or provide
buffer and locate downwind from
nearby residences
• Avoid shallow potable groundwater.
If not possible, provide vegetative
cover, avoid hltih application rates,
rigidly monitor groundwater quality
• Hater soluble inorganic industrial
wastes should not be land cultivated
• Minimum waste composition analysis:
Zn, Cu, HI, As, Ba, Hn, Cr, Cd, B,
Pb, llg, Se, Ha, Hg, Ca, Cl, PV>4,
Total N
(continued)
-------
APPENDIX II (continued)
Guideline (Summary Statement)
Item
Texas
Oklahoma
• Application Rates
t Determine soil cation exchange •
capacity (CEC)
Total metals application over
site life should be less
than 50 percent of GEC of top 1
ft of site's soil
If crop grown and harvested at
site, total metal application
in 30-yr period should be less
than 5 percent of CEC
Total N applied in waste, less
than 125 Ib /ac/yr
Annual free water applied in
the waste should be less than
annual evaporation rate
Not addressed
t Not addressed
Determine soil CEC if any of the
elements In waste composition analysis
above are present
• Not addressed
• Not addressed
Total N applied in waste, no more
than 125 Ib /ac/yr, or the maximum
amount utilized or assimilated by
vegetative cover
Total free water applied should be no
more than the net evaporation for
time period between applications
Oily waste application rate must be
such that soil-waste mixture contains
no more than 10 percent oil by weight
Recommended application rate for oily
wastes at established (over 6 mo old)
sites:
- 35 bbl o1l/ac/mo - without fertilizer
- 60 bbl oll/ac/mo - with fertilizer
(continued)
-------
APPENDIX II (continued)
Guideline (Sunirary Statement)
Item
• Operational
Restrictions
• Nixing Frequency
I Mixing Depth
Texas
Oklahoma
t All runoff must be contained
(use dikes or lined control
collection basin) unless
discharge permit Is obtained.
Collection basin should con-
tain 25-yr. 24-hr maximum
rainfall
• Soil pH must be maintained at
above 6.5 while the site Is
active
• Mix waste Into soil as soon
as possible
• Vegetation for human or animal
consumption must be analyzed
for metals contained 1n the
waste before feeding
• Not addressed
• Not addressed
All runoff must be contained unless
discharge permit 1s obtained (use
dikes or lined central collection
basin). Collection basin must contain
all site runoff from a 50-yr, 24-hr
maximum rainfall.
• Soil p!l must be maintained at above
6.5 while site 1s active
• Mix waste into soil as soon as possi-
ble
• Vegetation for human or animal con-
sumption must be analyzed for metals
and any elements in the waste which
are known to be concentrated by the
plant species before use or sale
• Dependent on rainfall. Recommended prac-
tice Is to mix twice monthly for first 2
months, then once every other month
t Sludge should be mixed Into soil to
a depth of 6 to 12 1n
-------
BQ-30
RESOURCE CONSERVATION AND RECOVERY ACT
Subtitle C - Hazardous Waste Management
Section 304 - Standards Applicable to Owners and Operators
of Hazardous Waste Treatment, Storage, and
Disposal Facilities.
DRAFT
BACKGROUND DOCUMENT
Section 250.45-6 Chemical, Physical, and
Biological Treatment Facilities
December 15, 1978
U.S. Environmental Protection Agency
Office of Solid Waste
-------
This document provides background information and support
for regulations which are designed to protect the air, surface
water, and groundwater from potentially harmful discharges
and emissions from hazardous waste treatment, storage, and
disposal facilities pursuant to Section 3004 of the Resource
Conservation and Recovery Act of 1976. It is being made
available as a draft for comment. As new information is
obtained, changes may be made in the regulations, as well
as in the background material.
This document was first drafted many months ago and
has been revised to reflect information received and Agency
decisions made since then. EPA made changes in the proposed
Section 3004 regulations shortly before their publication
in the Federal Register. We have tried to ensure that all
of those decisions are reflected in this document. if
there are any inconsistencies between the proposal (the
preamble and the regulation) and this background document
however, the proposal is controlling.
Comments in writing may be made to:
Timothy Fields, Jr.
U.S. Environmental Protection Agency
Office of Solid Waste
Hazardous Waste Management Division (WH-565)
401 M Street, S.W.
Washington, D.C. 20460
-------
Legislative Authority
Subtitle C of the Solid Waste Disposal Act, as amended by the
Resource Conservation and Recovery Act of 1976 (Pub. L. 94-580, hereinafter
called the Act), creates a legislative framework to control hazardous waste.
Congress has found that such waste presents "special dangers to health
and requires a greater degree of regulation than does nonhazardous solid
waste" (Sec. 1002(b)(5)). Because of the seriousness of this waste
problem, Congress intended that the States develop programs to control
it. In the event that States do not choose to operate this program,
the U.S. Environmental Protection Agency (EPA) is mandated to do so.
Subtitle C creates a management control system which for those
wastes defined as hazardous requires "cradle-to-grave" cognizance,
including appropriate monitoring, recordkeeping and reporting throughout
the system. Section 3001 requires EPA to define criteria and methods for
identifying and listing hazardous wastes. Those wastes which are
identified or listed as hazardous by these means are then included in
the management control system constructed under Section 3002-3005 and
3010. Those that are excluded will be subject to the requirements for
nonhazardous solid waste being carried out by States under Subtitle D
under which open dumping is prohibited and environmentally acceptable
practices are required.
Rationale
The legislative purpose of Subtitle C of the Act was to provide EPA with
the mechanism to not only identify wastes which are hazardous, but to
-------
recommend methods of treatment, storage, and disposal which will render
such waste nonhazardous.
The Act clarifies this goal under Section 3004 (3)(4) which
states that the facility is to be designed, located, and constructed to
treat, store, and dispose of hazardous waste in accordance with operating
methods, techniques, and practices as may be satisfactory to the
Administrator of EPA.2 Congressional history further emphasizes that,
most important of all, Section 3004 will require the disposition of
hazardous waste in facilities specifically designed for their disposal,
and incorporating safeguards necessary to protect human health and the
environment.3 The Agency (EPA) has documented in its damage files
many incidents resulting in human health and environmental damage
which could have been prevented if the waste would have been properly
treated prior to disposal.^
This document specifically addresses chemical, physical and biological
treatment of hazardous waste. The Agency considers treatment a preferred
means of waste management over disposal techniques such as landfill ing,
because treatment can detoxify, decrease volume, and in some cases
recover raw materials. This in turn reduces the total amount and the
quantity of toxic waste entering (ess preferred methods, such as disposal
thus diminishing the potential for human health and environmental
damage.
Treatment techniques vary widely, and thus it is very difficult to
write specific standards which apply to all possible chemical, physical and
biological treatment systems. In addition, wastes are generally treated
-------
by a combination of chemical, physical, and biological systems which
not only change for different types of waste, but also varies within a
particular industry for identical wastes. Thus, each waste process
combination tends to be.unique. For these reasons, the Agency wants to
encourage a certain degree of flexibility in the matching of treatment
processes with waste types.
Since treatment processes are tailored to fit the individual
requirements of the facility and the hazardous waste being handled,
measures used for reducing emissions or discharges cannot easily be
generalized. The Agency's approach is to present general, flexible
regulations which will be applicable to all process/waste combinations.
General, flexible regulations will also encourage innovation and indirectly
will encourage treatment in preference to disposal, since the flexible
nature of the regulations will probably make them easier to comply with.
The Agency will depend on a case-by-case evaluation of the individual
suitability of each process and process/waste combination by the permitting
official to provide control. Specific conditions will be added to the
*
permit to implement the findings of his evaluation. He will be assisted
in making his evaluation by a manual which will contain detailed technical
information on each process and process/waste combination. Data on test
results both successes and failures, will be included. This will be up-
dated periodicly as the permitting and monitoring processes yield additional
information.
-------
The rationale for most of the regulations are self explanatory.
c
The regulations which provide basi$ control are those requiring a
trial or test prior to permitting and the requirement for an automatic
cut-off. The trial will constitute a test of the environmental suitability
of the waste/process combination. The test protocol will ensure a
thorough evaluation and conditions will be placed on the permit to
implement findings of the test. The automatic feed cut-off will be
tfied to sensors for critual process parameters (pressure, temperature
etc.). Therefore, if there is an upset in the normal process, the waste
feed will be stopped automatically, eliminating the possibility of emissions
or other environmental problems.
Another unreported protective provision requires the removal of
hazardous residuals upon closure. This provision ensures that hazardous
waste will not remain in the area so as to provide a continuing fiyrmii.
Should a facility owner/operator desire to leave hazardous residuals
on-site after closure, it will be necessary to obtain a disposal permit
and comply with the regulations therefor*.
Presented in Appendix I are a series of brief summaries on applications
operations, and design of methods for chemical, physical, and biological
treatment.
-------
REFERENCES
1U.S. Congress, House, Report of the Committee on Interstate and Foreign
Commerce, H. Doc. 94th Congress, 2nd Sess., 1491, pp. 6,7.
Resource Conservation and Recovery Act, U.S. Code, Vol. 42, Sec. 3004 (1976).
3ll.S. Congress, House, Report of the Committee on Interstate and Foreign
Commerce. H. Doc. 94th Cong. 2nd, Sess., 1491, pp. 28, 57.
4U.S. Environmental Protection Agency, "Damage Cases," (EPA Docket, 1978).
-------
APPENDIX I
METHODS OF CHEMICAL, PHYSICAL, AND
BIOLOGICAL TREATMENT
-------
Carbon Absorption
.action
1
Carbon absorption is a surface phenomenon . It is normally considered
2,3,4.5,6
plicable where: (1) an impurity is in very dilute concentration; (2) an
ipurity is sufficiently valuable to warrant recovery; (3) the waste is partially or
tally non-combustible and the waste is toxic to biological growth, such as leachates
to landfills; (5) the waste is predominantly inorganic or non-biodegradable, and;
the waste is seasonal or periodic.
Carbon in one of the most versatile and economically attractive solid absorbents.
ber commercially important solid absorbents are acid-treated clays, bentonite,
7
unina, bauxite, and fuller's earth .
Carbon absorption can be used as a tertiary treatment stage for removing
t«.«;tory organics following other modes of treatment. When impurity concentration
8
low some waste streams may be treated more economically at their source .
rbon absorption, combined with other physical-chemical processes, has been shown
be a technically feasible alternative to conventional secondary wastewater treatment;
9,10,11
i several pilot and full scale physical-chemical plants have been designed
-------
Theoretical Considerations
The absorption process is a chemical and physical bonding of an absorbate
molecule to an absorbent surface. Strong bonding between an absorbate and an
absorbent resulting in an irreversible union is referred to as chemical absorption.
Weak bonding, typically characterized by Van der Waals1 forces, resulting in a -union
which is generally reversible is noted as physical absorption. It is physical absorp-
tion which is most frequently used for the removal of impurities irom waste streams.
Feundlich and Langmuir developed the equations most often used to describe
absorption equilibrium. The quantity of absorbate that can be tied up by an absorbent
is a function of temperature and absorbate concentration. Normally, isothermal
conditions are obtained and the amount of impurity absorbed is determined as a function
of concentration.
12,13
The Feundlich isotherm equation for a single absorbate is:
1/q
X = p (C)
M
where X = Amount of absorbate removed per unit weight of absorbent.
M
C = Equilibrium concentration of absorbate in solution following absorption
p, q - Empirical constants
-------
14
The Langmuir isotherm equation for a single absorbate is:
M 1 +jC
where X = Amount of absorbate removed per unit weight of
M absorbent.
C = Equilibrium concentration of absorbate in solution
following absorption.
i, j = Empirical constants.
This equation assumes that there are a fixed number of available sites, each
B» equivalent energy on the absorbent surface and absorption is reversible. When
irate of absorption of molecules onto the surface of the absorbent is equal to the
* of desorption of molecules from the surface, equilibrium is reached. The rate
is the difference between the amount absorbed at the influent concentra-
land the maximum concentration that the absorbent can remove at that influent
15
icentration. At equilibrium this difference is zero .
There are three steps involved in the absorption of constituents from solution
porous absorbents: (1) transport of the absorbate through a surface film to the
erior of the absorbent; (2) diffusion of the absorbate within the pores of the absorbent;
absorption and bonding of the solutions on the interior surface of the absorbent.
ps i and 2, film and pore diffusion are generally considered rate limiting since
16,17,18
Of non-porous absorbents is rapid
-------
Several factors which affect absorption are surface area of the absorbent,
19.20
physical and chemical characteristics of the absorbate, pH and temperature
The extent of absorption is proportional to the total surface area that is
available for absorption; therefore, as the solid absorbent becomes more finely
21.22
divided and more porous, greater absorption characteristics normally are reflected
Physical and chemical features displayed by the absorbate generally dictate
23,24
its absorption tendencies. Absorption: (1) increases with decreasing solubility
of the absorbate in the carrier stream; (2) increases as molecular size of the absorbate
decreases; (3) decreases with increasing ionization of the absorbate, and (4) increases
with a polar absorbate in a non-polar carrier stream in contact with a polar absorbent
and decreases when the carrier stream becomes polar and the absorbent non-polar.
Absorption of an absorbate is affected by the pH of the carrier stream, generally^
absorption increases for organic absorbates with decreasing pH, This may result
from neutralization of negative charges at the surface of the absorbent as the hydrogen
ion concentration is increased. This, in effect, reduces hindrance to diffusion and
increases the availability of the absorbents active surface. Furthermore, the degree
25, 2f
of ionization is governed by pH affecting the absorption of acidic and basic absorbates
Temperature variations in wastewater streams only have a similar affect on
absorption. Absorption reactions are generally exothermic and, therefore, absorption
27
mcreases with decreasing temperatures .
-------
Process Applicability, Description and Design Considerations
Carbon absorption has been cited for use in removing color, organics,
inorganics, taste, and odor ?§, 2^ 36, 31. it has been used to treat
wastes from food processing, textile, chemical, and pharmaceutical
concerns, battery manufacturs (mercury), and Federal Services (Agent
Orange contaminated with TCDD (2, 3, 7, 8 - tetrachlorodiben 80-p-
dioxin and TNT from munitions waste water).3^
Mercaptan and inorganic sulfur bearing compound*responsible for
taste and odor in wastewater have been successfully removed by carbon
absorption 33, 34.
Guisti^et al, have reported a considerable amount of data on the
absorption of organics using activated carbon. Organic compounds
containing less than four carbons were shown amenable to carbon absorptions
as follows: undissociated organic acids, aldehydes, esters^ ketones,
-------
inlet and outlet distributor system and an upper and lower support for
the bed of absorption media. The media may be supported on a mechanical
grid or on inert catalyst support-balls.
If the bed is deep, intermediate supports may be necessary. Screens
may be used instead of support-balls to retain the absorbent from above.
Normally, U.S. standard 20 mesh screen size is recommended for particles
ranging from 1/16 to 1/8 inch in diameter38. The absorbers can be designed
for pressure or gravity flow to achieve the desired contact time between
wastewater and carbon. Flow rates are generally less than 10 gpm/ft.2
of carbon bed. Industrial wastewater generally has contact times 1n
excess of 60 minutes versus domestic wastewater which is about half
that. The media bed is usually greater than 10 feet in depth39.
To ensure uniform distribution throughout the bed, with a minimum amount
of flow channeling, simple plenunisshould be provided, at the inlet and
outlet. This can be achieved with coarse support-balls or free volume4*).
Tanks are generally constructed of stainless steel or steel coated
with rubber or epoxy to prevent corrosion. Other systems may employ
wooden tanks or cement basins, where gravity feed is used^l.
-------
OTNOTES
'; N. Cheremisinoff, ed., "Carbon Absorption of Air and Water
Pollutants, " Pollution Engineering, July, 1976, p. 24.
IBID., p. 27,
John R. Stukenberg, "Physical-Chemical Wastewater Treatment Using a
Coagulation-Absorption Process, " Journal Water Pollution Control
Federation 47 (February, 1975): 338.
I Ho, W. C. Boyle, and R. K. Ham, "Chemical Treatment of Leachateas
from Sanitary Landfills, " Journal Water Pollution Control Federation
46 (July, 1974): 1776.
Chanel Ishifari and John T. Cookson, Jr., "Absorption of Sulfur-Containing
Taste and Odor Compounds," Journal Water Pollution Control Federation
45 (March, 1973): 515.
l"'.T. Cookson, Jr., "Design of Activated Carbon Absorption Beds, " Journal
Water Pollution Control Federation 42 (December, 1970): 2124.
Cheremisinoff, pp. 24-25.
Q. M. Giusti, R. A. Conway, and C. T. Lawson, "Activated Carbon Absorption
of Petro-Chemicals, " Journal Water Pollution Control Federation 46
(May, 1974): 947
glD.. p. 847.
Peter F. Atkins, et al. , "Ammonia Removal by Physical-Chemical Treatment, "
Journal Water Pollution Control Federation 45 (November, 1973): 2372.
torn B. Henshaw, "Absorption/ Filtration Plant Cuts Phenols from Effluent. "
Chemical Engineering, May, 1971, p. 47.
If naif & Eddy, Inc. , Wastewater Engineering Collection, Treatment, Disposal
(New York: McGraw-Hill Book Company, 1972), p. 347.
-------
FOOTNOTES - Page 2 (Carbon Absorption)
13
Giusti, p. 952.
14
Jain S. Jain and Vernon L. Snoeyink, "Absorption from Bisolute Systems
on Activated Carbon, " Journal Water Polution Control Federation 45
(December, 1973): 2463.
15
Metcalf & Eddy, Inc., p. 247.
16
IBID., p. 349.
17
James S. Mattson and Frank W. Kennedy, "Evaluation Criteria for Granular
Activated Carbons, " Journal Water Pollution Control Federation 43
(November, 1971): 2213.
18
Cookson, p. 2128.
19
Walter J. Weber, Jr., "Physicochemical Processes for Water Quality Control"
(New York: John Wiley & Sons. Inc., 1972), p. 229-236.
20
Cheremisinoff, pp. 24-26.
21
Weber, p. 229.
22
Cheremisinoff, pp. 24-25.
3
Matthew M. Zuckerman and Alan H. Molof, "High Quality Reuse Water by
Chemical-Physical Wastewater Treatment," Journal Water Pollution
Control Federation 42 (March. 1970): 446.
Weber, pp. 230-231.
25
Stukenberg, p. 339.
26
Weber, p. 234.
27
IBID., p. 236.
-------
FOOTNOTES Page 3 (Carbon Absorption)
28
T. J. Tofflemire, L. J. Hetling, and W. W. Shuster, "Activated Carbon
Absorption and Polishing of Strong Wastewater, "Journal Water Pollution
Control Federation 45 (October, 1973):2177.
29
R.F. Deyine, S. D. Gleditsch, and C. A. Kieda, "Characterization of
Industrial Wastewater for Carbon Absorption Treatment, "Pollution
Engineering, August, 1976, p. 30.
30
Cheremisinoff, p. 25»
31
U.S. Environmental Protection Agency, Office of Solid Waste, Draft
Report on Methods of Cord Practice Carbon Adsorption, Arthur D. Little,
Inc., (1977) pg. 2,
32
Ibid, pp. 2, 3, 9.
33
Yasud Uend, "Catalytic Removal of Sodium Sulfide from Aqueous Solution,"
Journal Water Pollution Control Federation 46 (December, 1974):2779.
34
Chanel Ishifari and John T. Cookson, Jr., "Absorption of Sulfur-Containing
Taste and Odor Compounds, "Journal Water Pollution Control Federation
45 (March, 1973):518.
35
Fiusti, p. 93.
36
K. Daniel Linstedt, Carl P. Houck, and Joan T. O'Connor, "Trace Element
Removal in Advanced Wastewater Treatment Processes, "Journal Water
Pollution Control Federation 43 (July, 1971):1511.
37
Cheremisinoff, p. 31.
38
George M. Lukchis, "Part II - Equipment Design, "Chemical Engineering,
July, 1973, p. 86.
-------
39
Cheremisinoff, p. 31.
40
Lukchis, p. 86.
41
U.S. Environmental Protection Agency, Office of Solid Waste, Draft
Report on Methods of Good Practice Carbon Absorption. Arthur D. Little,
Inc., (1977), pg. 10.
42
IBID.. P. 85.
43
Cheremisinoff, p. 3K
/r.
-------
Membrane Processes
production
Membrane processes are seeing more and more application iri industrial waste
ream treatment. Features which make membrane processes appealing for indus-
1.2
iial use include : (1) separation of dissolved materials from one another or
ton the waste stream without a phase change, (2) a physical barrier in the form
a membrane between the product and the waste stream without a phase change,
I less energy consumption than either vaporization or crystalization, and (4) only
lall temperature changes in product and waste stream.
Membrane processes are typified by a fluid containing two or more components
f-ttact with one side of a semi-permeable boundary and the other side is in contact
th a fluid that receives the component that transverses the boundary. The boundary
membrane is a mass of polymer chains containing interstitial spaces through which
3
ilecules or ionic species can pass . The membrane phase is usually heterogeneous
nature. Physically it is a dry solid* a solvent-swollen gel or liquid that is immo-
4
ized • The degree of cross-linkage determines the extent of inhibition that takes
ice with respect to certain species transferred through the membrane. The driving
fee may be an electrical potential as in electro-dialysis or a hydrostatic pressure
5
in reverse osmosis .
-------
REVERSE OSMOSIS
Theoretical Considerations
Reverse osmosis is one of several membrane processes which is becoming
more popular as a method for treating and/or recovering various species found pre-
sent in industrial waste streams,
This is accomplished when two solutions of different solvent activity are sep-
arated by a semi-permeable boundary or membrane. Fluid transport through the
membrane occurs in the direction of lower chemical potential until a thermodynamic
6
equilibrium across the membrane is reached . The pressure head across the
boundary is the osmotic pressure. Osmosis or osmotic pressure is a function of
both temperature and pressure and results from the unequal bombardment of a semi-
permeable boundary by solvent molecule. This unequal bombardment is due to the
presence of solute molecules on one side of the membrane* Thus, the differences
7
in solvent pressure increases with increasing amount of solute , By applying an
.external pressure to overcome the osmotic pressure* the chemical potential levels
are reversed and the flow through the membrane is in the opposite direction to the
8,9
lower chemical potential . The efficiency of the membrane to transport solvent
is a measure of production or flux. Flux is the amount of solvent recovered per unit
10
time per unit area of membrane . Mechanisms where selected species move across
11,12
a membrane include : (1) molecular sieving, where there is a difference in
solvent and solute molecule size and flow is restricted to certain species based on
-------
i size of the membrane; (2) diffusion, where the flow of solvent is dependent
ressure gradient across the membrane and the flow of solute is determined
oncentration gradient across the menbrane, and/or (3) dissolution of solute,
ydrogen bonding between the solute and the membrane increases the amount
e available for diffusion. Thus, alcohols, amines, amides, and carboxylic
hich are capable of donating and accepting protons permeate membranes better
13
esters, aldehydes, ketones and sulfones which can only accept protons .
tace a concentration gradient is established and the flow of solvent proceeds,
'eased concentration of solute at the membrane surface can cause several detri-
effects such as: (1) decreased reverse osmosis solvent-flow driving force
mal pressure due to increased local osmotic pressure; (2) increased solute
ration in the product due to concentration polarization; (3) decreased membrane
i
to increased concentration of various waste constituents at the membrane
s; and (4) precipitation of soluable salts and particulate matter on the membrane
due to the effects of concentration polarization. Concentration polarization
atio of solute concentrated at the membrane surface to the solute concentration
ifluent waste stream. The concentration potential is proportional to the re-
of product. High product recovery can be maintained at low concentration
ition by recycling the effluent waste stream and/or by increasing turbulence
14
e membranes
olute rejection is the ratio of the concentration differences of that specie
the membrane to the bulk concentration of that specie present in the influent
15
team. Normally, solute rejection conforms to the following rules :
-------
(1) rejection increases as ion valence increases; (2) rejection is greater for dis-
sociated species than for partially dissociated species; {3) salts are more strongly
rejected than their acid or base form; (4) high molecular weight, water soluble
organics are strongly rejected, and; (5) undissociated low molecular weight organic
acids are slightly rejected whereas their salts are strongly rejected.
Process Applicability, Description and Design Considerations
Reverse osmosis has been used: (1) to treat dilute pulping waste ;
17,18
(2) to treat or recover soluble organic chemicals ; (3) to remove phosphorous
19,20 21,22
and nitrogen containing compounds ; (4) to desalt brackish water ;
23
(5) to recover metals from plating and metal finishing wastes ; (6) to treat textile
24 25
and petro-chemical waste ; (7) to remove pesticides ; and (8) to remove precipitant
26
ducing chemcials
There are basically four types of reverse osmosis premeators: (1) plant
27,28.29
; id frame; (2) tubular; (3) spiral wound; and (4) hollow fine fiber . The most
widely used membranes for reverse osmosis applications are cellulose acetate and
polyamide. The polyamide membrane has an advantage in that it is more chemically
and physically stable than the cellulose acetate membranes. However, cellulose
acetate membranes have a higher water permeability rate and lower compaction
30
characteristics which in the past have made it the membrane of choice . The
31,32,33
active surface of the membrane has a thickness of 3 to 2500 angstrom
pH range for the cellulose acetate membrane, to prevent membrane hydrolysis, is
34,35
3 to 3 . The polyamide membrane can be operated at a somewhat higher pH
36
of 5 to 11 .
-------
Temperature, pressure, and concentration (within limits) determine the rate
termeability or flux through a membrane. Operating temperature and pressure
o 37,38,39,40
s normally 0 to 32 C and 50 to 1500 PSE, respectively „ From 15
o
30 C, water flux increases about 3.5% per degree increase. Similarly, as
sssure increases, the separation of solute increases. However, if both temperature
pressure are not controlled within the limits of operation for a particular mem-
o
Joe, filter deterioration is accelerated. At temperatures above 30 C most
snbranes become unstable showing poor selectivity and loss of strength, while
tessive pressure can cause membrane compaction affecting membrane efficiency
43
ilife .
The flow rates through reverse osmosis units are on the order of 2. 5 to
COOO gallons per day. Flux through these units range from 7 to 12 gallons /day/
44,45,46
tore feet of membrane for cellulose acetate and polyamide membranes
namic membranes formed from zirconium oxide, fulvic acid, and polyacrylic acid
47, 48
re fluxes on the order of 100 to 200 gallons /day/ square feet of membrane
In order to promote membrane life and prevent flux decline, due to impaction
m fouling, waste streams can be pretreated prior to reverse osmosis. Generally,
^treatment schemes involve: (1) suspended solids and precipitating compounds
Wval; (2) temperature and pH control; and (3) disinfection to prevent the growth
'organisms on reverse osmosis equipment. In those cases where the concentration of
'Uoidal matter and precipitate is not excessive, flux decline can be prevented by
49
'riodic membrane cleaning and/ or backwashing without extensive pretreatment .
-------
ELECTRQDYIALYSIS
Theoretical Considerations
Electro dialysis is a process whereby ionic components in solution are separated
through semi-permeable, ion selective membranes employing an electrical potential
50,51
gradient as the driving force
When chemical compounds are dissolved in solution, positively charged cations
and negatively charged anions form. In the presence of an electric field, cations
migrate towards the negatively charged cathode while anions migrate in the opposite
direction, toward the positively charged anode. By alternating cation-exchange mem-
branes (only permeable to cations) and anion-exchange membranes (only permeable
to anions) across the electric field it is possible to concentrate ions between a pair
52
of membranes leaving the solution ion-free between the adjacent pair .
The amount of current carried by an ion in solution is generally proportional
to its size. Small cations such as hydrogen, proceed through the solution at a higher
velocity and, therefore, carry a greater current than would larger cations or anions
such as potassium or chlorine. The transference number is that fraction of the
53
current carried by an ionic species
The flow of solution through the unit creates a velocity gradient between the
membranes and becomes static at the boundary layer of each membrane. Ion move-
ment through the solution near or at the boundary layer is only by electrical transfer
and diffusion. However, near or at the center, ions are transferred electrically
J)4:
by diffusion and by physical mixing .
The selectivity of the membrane affects the transference number of the ion.
+
' -ons X and Y each have a transference number of 0.50 in solution, because the
-------
on-exchange membrane is only selective for X , the transference number is
+
C"y 1.0 for X and 0.0 for Y . Similarly, the transference number of Y
+
i respect to the anion-exchange membrance is 1.0 and 0.0 for X . Since Y
'carries 50% of the current in solution (transference number being 0, 50 in
tion) but 100% of the current when passing through the anion-exchange membrane
Deference number being 1.0 in the anion-exchange membrane) and if one faraday
electricity passes through the membrane and solution, then 0.5 gram equivalents
? would be transferred to or away from the membrane surface and 1.0 gram
*<*
ivalents would be transferred through the anion-exchange membrane. This results
„ •
i depletion of Y on one side of the anion-exchange membrane and a concentration
f on the other. This is the desired effect with respect to electrodialysis process.
'ever, if the current density (amps/square feet) is increased to the point where
''*Completely depleted on one side of the membrane and totally concentrated on
other* concentration polarization results. At this point, hydroxide ions form from
ionization of water and pass through the anion-exchange membrane. This in turn
eases the pH of the solution in the Y concentration zone and can lead to the
:ipitation of calcium carbonate or magnesium hydroxide on the surface of the
abrane. In addition, dimensional changes in the anion-exchange membrane can
IT from the passage of hydroxide ion through the membrane. Also, the increasingly
'water at the surface of the membrane increases the resistance of the membrane
55
, increasing the energy requirements for the process . Concentration polari-
ai can be limited by controlling the rate of current density to concentration in
lilute stream and by achieving smaller boundary layer thickness through hydro-
56
channel design .
-------
Process Applicability, Description and Design Considerations
57,58,59
Electrodialysis systems have been employed : (1) for desalina-
tion of brackish water and whey; (2) to treat and/or recover constituents from
metal plating and finishing wastes; (3) to recover heavy metals such as chrome,
lead, mercury, copper, and silver; (4) to treat battery manufacturing waste;
(5) to treat wood pulp wash water; (6) to treat glass etching solutions; (7) to deni-
trify agriculture run-off; (8) for demineralization; and (9) to recover organic chemicals.
The ion-exchange membrane used in electrodialysis must have good perm-
selectivity for ions of opposite charge, a low water transport number, be a reasonably,
60
good electrical conductor and be physiochemically stable . Commercial membranes
have the appearance of a sheet of plastic and generally consist of cross-linked
polystrene. The attached groups on the polymer are what gives the membrane its
selective characteristics. A ploymer with sulfonate groups (-SO H) attached would
3 +
be a cation membrane, ionizing to form a mobile counter-ion of hydrogen (H ) and
a fixed negative charge (-SO ). The polymers of an anion membrane may have a
3 +
quarternary ammonia group (-NR OH ) attached to it. Upon ionization it would
3
produce a mobile counter-ion hydroxyl group (OH _ and a stationary positive charge
+ 61,62
(-NR )
3
A stack of these membranes terminated at each end with an electrode and plate
comprises an electrodialysis system. The membranes and electrodes are compressed
between the end plates and resembles a plate-and-frame filter- press. One section
of the system consists of a cation and anion membrane in that order. The compart-
ment between the membranes is the desalting zone while the compartment adjacent
to the cation and anion membrane on the cathode and anode side respectively are con-
-------
ration zones. The unit or cell pair is about 0. 1 inch thick and consists of a cation
63
, a desalting zone, an anion membrane and a concentration zone
Flow through the unit is critical in controlling polarization. This can be ac-
plished by using small channel spacings to contain and direct the flow, high
64
illation velocities, and turbulence promoters .
Spacer design determines flow patterns through the unit, the tortuous path
ioys a coiled spacer arrangement which provides a longer resistence time for
solution. High linear velocity and presssure drop are necessary to reduce con-
65
•ation polarization in this type of unit . The flow velocity for the tortuous
66
system ranges from 0.33 to 1.6 feet/ second . Sheet flow spacer design con-
of an open frame with a plastic sheet separating the membranes. The plastic
: serves to promote turbulence in the unit. Flow velocity for the sheet flow
67
•n ranges from 0. 17 to 0.33 feet/ second .
2
Commercial stack size for electrodialysis systems range from 0.25 feet /
2 2
»r with 4.95 feet of membrane /stack to 21.52 feet /spacer with over 25,000
of membrane/ stack. At 20-50% salt removal, large stacks have a capacity
68
0 OOO gallons /day . The total capacity of installed electrodialysis facilities
6 69
istimated to be greater than 20 x 10 gallons /day .
Operation of electrodialysis systems are generally conducted as: (1) continuous
urith stacks arranged in parallel or series; (2) batch with recirculation; and
ed and bleed continuous flow where influent concentration is adjusted with
70, 71
ict
Ancillary equipment should be lined or coated with plastic to avoid stray
72
rical currents and the introduction of metal ions into the system .
-------
To prevent process plugging and membrane fouling, influent to the electro-
dialysis system should be pretreated to check suspended matter and the possibility
of salt precipitation. For those waste streams which are low in these substances,
pretreatment can be minimized by periodic cleaning and/or backwashing of the
73
unit
-------
TNOTES
rt E. Lacey, "Membrane Separation Processes, " Chemical Engineering,
September, 1972, p. 56.
•E. Cruver and I. Nusbaum, "Application of Reverse Osmosis to Wastewater
Treatment, " Journal Water Pollution Control Federation 46 (February,
1974): 301
, p. 56.
Uter J. Weber, Jr. , Physicochemical Processes for Water Quality Control
(New York: John Wiley & Sons, Inc. , 1972), p. 307.
*ey, p. 56.
S. LJ»a and H. Kirk Johnston, "Reverse Osmosis as an Advanced Treatment
Process, " Journal Water Pollution Control Federation 48 (July, 1976):
1804-1805. ~~ "
*er, p. 311.
gar C. Kaup, "Design Factors in Reverse Osmosis, " Chemical Engineering
April. 1973, pp. 47-48
pp. 1804-1805.
, P- 50*
p. 1805.
, P- 314-
A. Duvel, Jr. , and Theodore Helfgott, "Removal of Wastewater Organics
Reverse Osmosis, " Journal Water Pollution Control Federation 47
(January, 1975): 61.
-------
14
Weber, pp. 322-323.
15
Weber, p. 320.
16
Averill J. Wiley, et al., "Concentration of Dilute Pulping Wastes by Reverse
Osmosis and Ultra Filtration, " Journal Water Pollution Control Federation
42 (August, 1970): R282.
17
"Reverse Osmosis Module Operates Below 450 PSE," Chemical Engineering,
April, 1971, p. 74.
18
M. F. Hamoda, K. T. Brodersen, and S. Sourirajan, "Organics Removal by
Low Pressure Reverse Osmosis, " Journal Water Pollution Control Federation
45 (October, 1973): 2152. "
19
Lim, pp. 1809-1813.
20
Nicholas P. Chopey, ed., "Reverse Osmosis: Hollow Fibers Get Tryouts, "
Chemical Engineering, February, 1971, p. 30.
21
"Du Pont Wins Coveted Award, " Chemical Engineering, October, 1971, p. 34.
22
J. Charles Jennett and Calvin c. Patterson, "Treatability of Reverse Osmosis
Raffinates by Activated Sludge, " Journal Water Pollution Control Federation
43 (March, 1971): 381. ™ '
23
Lional B. Luttinger and Gabriel Hoche, "Reverse Osmosis Treatment with Pre-
dictable Water Quality," Environmental Science and Technology 8
(July, 1974): 617.
24
IBID., p. 617.
25
Edward S. K. Chian, Willis N. Bruce, and Herbert H. P. Fang, "Removal of
Pesticides by Reverse Osmosis, " Environmental Science and Technology
9 (January, 1975): 5458.
30.
-------
lim, P. 1814.
ftttinger, p. 614.
•acey, p. 68.
raver, p. 302.
febcr, p. 317.
Ucey, p» 58.
CTE Ups Capabilities of Reverse-Osmosis Elements, " Chemical Engineering,
June, 1976, p. 83.
, PP» 53-54.
, p. 319.
•uttinger, p. 614.
lim, p. 1805.
CTE tips Capabilities of Reverse-Osmosis Elements, " Chemical Engineering,
June, 1976, p. 83.
*cey
. 68.
4m, p. 1805.
Ver, P. 314.
JX
-------
42
Chian, p. 58.
43
Kaup, p. 49.
44
Cruver, p. 303.
45
Weber, p. 322.
46
Chian, pp. 53-54.
47
Kaup. p. 49.
48
Weber, p. 322.
49
IBID., p. 328.
50
I
Metcalf & Eddy, Inc., Wastewater Engineering Collection, Treatment, Disposal
(New York: McGraw Hill Book Company, 1972), p. 659.
51
Frank H. Seels, "industrial Water Pretreatment, " Chemical Engineering,
February, 1973, p. 32.
52
Frank B. Leitz, "Electrodialysis for Industrial Water Cleanup, " Environmental
Science & Technological 10 (February, 1976): 136.
53
Lacey, p. 62.
54
IBID., p. 62.
55
IBID., p. 63.
56
Weber, p. 342.
32-.
-------
;tzf pp. 138-139,
few Electro-Chemical Approach to Recovering Copper from Ore or Scrap
Metal," Chemical Engineering, May, 1974, p. 51.
*r, PP- 351-352.
D,, p. 341.
0., p. 340.
itz. p. 136.
D.. p. 136.
4er, p- 342.
er, P- 349»
itz. p. 136.
&., P- 136.
J,. P- 136-
« 137-138.
, P- 349-
pp. 136-137.
D., P- 13fi-
, PP- 349-350.
-------
Filtration
Introduction
Filtration units for the removal of impurities present in industrial effluents
can be utilized: (1) in combination with oxidation-reduction precipitation; (2) in com-
bination with flocculation-sedimentation; (3) as a pretreatment for more sensitive
physicochemical processes; or (4) as an individual unit operation.
Types of units include deep granular filters (single medium, dual media,
and multimedia) and precoat filters (diatomaceous earth and perlite). Granular
filter media usually consists of sand, crushed anthracite coal, diatomaceous earth,
perlite or combinations thereof. In the past diatomaceous earth and perlite filters
1
have found a variety of applications in treating industrial waters .
Theoretical Considerations
The process variables and mechanisms involved in particulate matter removal
2
by a filtration unit exhibit complex relationships. Process variables include :
(1) filter media grain size, shape, and density; (2) filter media porosity; (3) media
headless characteristics; (4) filter bed depth; (5) filtration rate; (6) allowable head-
loss; (7) influent characteristics; (8) filter bed charge; and (9) fluid characteristics.
Process variables 1, 2, 3, 4, 5, and 9 are used as design criteria for determining
the clear water headless through the medium. Process variables 7, 8, and 9 are
necessary in understanding the biological and chemical properties of the waste
stream to be filtered. Influent characteristics such as: (1) suspended solids con-
centration; (2) floe or particle size and distribution; (3) floe strength; (4) floe or
particle charge; and (5) the charge associated with the filter media will affect the
length of the filter run, chemical dosage (when applicable) and/or the filter
-------
4,5 6,7,8
ency • Removal mechanism for filtration processes are : (1) strain-
jchanical and/or chance contract); (2) sedimentation; (3) inertial impaction;
terception; (5) chemical absorption (bonding and/or chemical interaction);
lysical absorption (electrostatic forces, electrokinetic forces and/or van der
3 forces); (7) adhesion and adhesion forces; (8) coagulation-flocculation; and
ological growth. Removal mechanisms 1 through 5 are physical or mechanical
•
are, while 5 through 9 are related to the chemical and surface characteristics
i suspended matter and the filter bed. Physical mechanisms are related to
13 physical parameters of the filter medium, such as grain size, porosity,
spth. Particle charge, chemical compositions, and chemical additions are
sary factors to describe mechanisms involving chemical and surface character-
9.10
•
*f
/Precoat filters remove solids by mechanical straining whereby a cake of solids
on the influent side of the filter media. Depending on particle size removal
ids in deep granular filters may be by mechanical straining (large particles)
lombination of transport and attachment mechanisms (small particles). The
x>rt mechanisms brings the particle from the bulk solution to the surface of
edia. l>y gravitational settling, diffusions, interception, and/or hydrodynamics.
is affected by such physical characteristics as filter media, filtration rate,
;emperature, and the density and size of suspended particles. Attachment
may involve electrostatic interaction, chemical bridging or specific
* These are affected by the chemical characteristics of the influent and
media. These mechanisms for removal in deep granular filters may take
gixnultaneously but as the filter run progresses, the dominance of both the
-------
transport and attachment mechanisms may change. This changing of removal mech-
11,12
anisms can affect effluent quality and the headloss characteristics of the filter
Hydraulic flow through a porous filter medium generally follows Darcy's
Law for laminar flow in a clean filter bed. As the void spaces available for flow
becomes clogged due to the accumulation of particulate matter on the filter surface.
the flow velocity through the voids increases. If the filtration rate is to be constant,
an increase in energy to overcome frictional losses within the filter is necessary.
This is considered a headloss or a decrease in the total energy of the water across
the filter bed. At the point when the headloss affects effluent quality, system eco-
nomics, and/or desired flow rate, the filter unit must be removed from the system
13
and the media cleaned or replaced .
Jf.
-------
cess Applicability, Description and Design Considerations
^ filtration systems are generally used in conjunction with other unit operations
i
processes for the removal of suspended solids, flocculated organics, and inorganic
ipitates. Specific systems have been cited for removal of iron oxide, scale,
and grease from steel mill rolling process wastewater and trace inorganic
14,15,16
allies
The critical segment of a filtration unit is the medium. The medium should
17
! such physical and chemical characteristics as to allow it to : (1) hold a large
itity of filtered matter; (2) provide good effluent clarity; and (3) be readily
Qed by back-washing.
Common sand specifications for deep granular filters are a depth of 24 to 30
es with an effective grain size of 0.45 to 0.55 mm and a uniformity coefficient
Beater than 1.65. Normally, an anthracite -sand filter will include 12 to 24
3
es of anthracite and 6 to 16 inches of sand. A typical dual media filter, designed
low about 6 inches of intermixing during backwashing, would employ 12 inches
Lter sand (effective size 0.5 to 0.55 mm, uniformity coefficient less than 1.65)
12 inches of crushed anthracite coal (effective size 0.9 to 1.0 mm, uniformity
18,19
less than 1.8) .A multimedium filter would generally use 3 inches
trnet (effective size 0.2 to 0.6 mm, uniformity coefficient less than 1.0), 12
SB of sand (effective size 0,4 to 0.8 mm, uniformity coefficient 1.2 to 1.6),
15 inches of anthracite (effective size 1.0 to 2.0 mm, uniformity coefficient
20
to 1m 8) • Typical flow rate for both dual and multimedium filters is 6 gpm/
21,22,23
ft. of filter bed and ranges from 2 to 12 gpm/sq. ft. of filter bed
T u***ts can eitner employ pressure or gravitational flow.
-------
Filter operation cycle averages one day, but can vary from approximately
0. 5 to 2.0 days, at which time the filter unit is taken out of service and back-
24,25
washed . High velocity backwash normally results in a 15 to 30% expansion
26
of the media at a flow rate of 15 to 19 gpm/sq. ft. of filter bed . In cases where
additional bed agitation is necessary to free filter medium of particulate matter,
high velocity water jets have been shown successful. The jets should be 2 to 3 inches
above the level of expansion with a flow located 2 to 7 gpm/sq. ft. of filter bed at
27
45 to 75 psig. The distribution system may either be fixed pipe or rotating arm .
The underdrain system supports the filter medium, distributes the backwash
•water, and prevents loss of filter media. A layer of graded gravel over the under-
drainage system is necessary to prevent loss of filter medium where influent orifices
29
axe larger than grain size . Design parameters for manifold and lateral systems
30
to accommodate wash rates of 4 to 22 gpm/sq. ft. of filter bed are : (1) diameter
of perforation 1/4 to 1/2 inch; (2) spacing of perforations 3 to 12 inches; (3) spacing
of laterals 3 to 12 inches; (4) ration of cross-sectional area of manifold to the sum
of the cross-sectional area of the laterals served 1.75 to 2.0; (5) ratio of sum of
the area of the orifices to the total filter area 0.0015 to 0.005; and (6) ratio of lateral
length to its diameter less than 60.
The wash water gutter should be designed to carry the maximum wash rate with;
31
2 to 3 inches of free fall into the channel at the upper end .
Precoat filtration utilizes a thin layer (1/16 to 1/8 inch) of diatomaceous earth
32
or perlite which is wasted at the end of each filter cycle .
The tank or precoat unit is either pressure or vacuum driven. The unit consists
of a septa which supports the filter medium and directs filter effluent to a collection
33
manifold . Septum arrangement is basically of two designs: (1) vertical leaf filters ff
-------
h have a number of flat septa closely spaced on a filtrate collection header; and
34,35
slindrical septum filters where the septa are arranged horizontally . About
; as
to 0, 2 pounds of diatomite or perlite makes up the filter bed . Filter cycles
rery short due to the hydraulic compression of solids on the precoat. Longer
r runs can be promoted by adding filter aid or body feed during the filtration
>d. The mixing of solids and filter aid results in a more porous filter cake
37
bus a longer filter cycle . The desired length of a filter cycle is 24 hours
38
at continous attendance would be unnecessary for manual operations . Pressure
's also have a longer filter cycle over vacuum units due to higher available pres— —
(headless through a vacuum, filter typically being 20 feet as opposed to 100 feet
39 2
ressure units) . The filtration rate is generally from 0.5 to 2. 5 fpm/sq. ft."
ter bed with an optimum body feed of 25 to 200 mg/liter. This, however, may
feet by higher power costs when comparing vacuum pressure precoat filters.
-------
FOOTNOTES
1
Walter J. Weber, Jr., Physicochemical Processes for Water Quality Control
(New York: John Wiley and Sons. Inc.. 1972) p. 139.
2
George Tchobanoglous. "Filtration Techniques in Tertiary Treatment, w Jour*"*!
Water Pollution Control Federation 42 (April. 1970): 605. ~
3
Metcalf & Eddy, Inc., Wastewater Engineering Collection, Treatment, Disposal
(New York: McGraw Hill Book Company, 1972) p. 644.
4
Tchobanoglous, p. 605.
5
Metcalf & Eddy, Inc., p. 644.
644.
lous, p. 605.
aomas A. Jordan, Mriganka M. Ghosh, and Russel H. Boyd, Jr., "Fhysico-
Chemical Aspects of Deep-Bed Filtration, " Journal Water Pollution Control,
Federation 46 (December, 1974): 2745.
9
0
Metcalf & Eddy, Inc., p. 645.
Tchobanoglous, p. 605.
1
Weber, p. 141.
2
Jordan, p. 2745.
3
Weber, p. 142.
Bengt Bengtsson, Anders Halldin, and Lars Hallen, "Wastewater Treatment at
Swedish Steel Mills, " Journal Water Pollution Control Federation 47 (April
1975): 773.
-------
C. R. Symons, "Treatment of Cold-Mill Wastewater by Ultra-High-Rate
filtration, " Journal Water Pollution Control Federation 43 (November,
>1971): 2280.
Toshiro Maruyama, Sidney A. Hannah, and Jesse M. Cohen, "Metal Removal
by Physical and Chemical Treatment Processes, " Journal Water Pollution
Control Federation 47 (May, 1975): 963.
Weber, p. 168.
IBID., p. 169.
Tcnobanoglous, pp. 611-617.
IBID. . p. 614.
Metcalf & Eddy, Inc., p. 646
Maruyama. p. 865.
Symons, p. 2280.
Bengtsson, p. 776.
Symons, p. 2284.
Weber, p. 171.
gro., p. 174.
Symons, p. 2283.
Weber, p. 175.
-------
30
IBID., p. 178.
31
IBID., p. 179.
32
Weber, p. 183.
33
IBID., p. 183.
34
IBID., p. 186.
35
Symons, p. 2285.
36
IBID., p. 2285.
37
Weber, p. 183.
38
IBID., p. 189.
39
IBID., pp. 183, 190.
40
Weber, p. 190.
41
Symons, p. 2285.
-------
Coagulation, Flocculating, and Precipitation
Introduction^
The removal of many impurities from industrial waste streams can be ac-
complished by coagulation and flocculation, or precipitation. 'Many
impurities which are physically too small or chemically stable in the
carrier stream will not gravitationally settle. Unit operations such as
coagulation, flocculation and precipitation have been successfully employed
to aid in the separation of impurities from their liquid vehicle. The
application of natural or synthetic agents with or without pH adjustments
can be used to promote settling. The aggregation of impurities into
settleable colloids involves two distinct steps: (1) the transport of
particles to effect interparticle contact; and (2) particle dfstabilization
to permit attachment when contact occurs. Coagulation is the affect of
both transport and destabilization while flocculation applies to only
transport.2
Theoretical Considerations
Coagulation is concerned with the aggregation of unstable colloids. Unstable
or irreversible colloids owe their apparent state to charge and solvation
3,4
effects. The charge associated with most colloidals in waste streams
is negative. The magnitude of which is frequently affected by pH and
ionic content of the carrier stream. Since the primary charge on the
particles is counter balanced by the carrier stream, an electric double
layer exists at every interface between a particle and the carrier liquid.
This results in an ionic concentration gradient with an increase in the
concentration of carrier stream ions at the surface of the particle,
decreasing with increasing distance from the surface. Thermal agitation
causes these carrier ions to diffuse so that the two competing processes
(diffusion vs. electrostatic attraction) can spread the charge in the
carrier liquid over a diffuse layer establishing the ionic concentration
-------
5
gradient as described .
Chemical coagulants can bring about destabilization of colloids by four dif-
6
ferent mechanisms : (1) diffuse layer compression; (2) absorption to produce
charge neutralization; (3) enmeshment in a precipitate; and (4) absorption to allow
interparticle bridging.
Ions of different charge (counter-ions) to the primary charge of the colloid
are attracted while those of similar charge are repelled. Destabilization of a colloid
'is brought about by charge neutralization at the surface of the colloid by increasing
the concentration of counter-ions in the waste stream. The coagulant effectiveness
7,8
of these ions tends to increase with increasing charge
Colloid-carrier liquid interaction can affect the ability of a coagulant to neu-
tralize colloidal charge and thus bring about destabilization. Therefore, carrier
liquid molecules which are firmly bound to the colloidal particle must be removed if
9
a direct coagulant-colloid bond is to form . This is accomplished by adding coagulants
which have a greater affinity for the colloid than does the carrier liquid and in suffi-
cient quantities to promote neutralization.
Rapid precipitation of metal hydroxides (AL(OH) , Fe(OH) , Mg(OH) or
3 32
metal carbonates (CaCO ) can enmesh colloidal particles in their precipitates as
3
they are formed. Coagulants such as metal oxide or hydroxide (CaO or Ca(OH) )
2
and metal salts (AL (SO ) , FeCl ) if used in sufficient concentration can produce
2433
this effect. The greater the amount of colloidal particles in the carrier liquid, the
'
-------
economical treatment even though the impurities in the waste stream are
also negatively charged. This is accomplished by functional groups on
the polymer whsich are absorbed onto the surface of the particle forming
a polymer-particle complex. Interaction between polymer-particle complexes
results in bridging and thus destabilization ''» ^.
Interparticle contact can occur by several mechanisms: (1) contact
by thermal motion or peri kinetic flocculation, often termed Brownian
motion or Brownian diffusion; (2) contact resulting from bulk fluid
motion or orthokinetic flocculation, as in stirring; and (3) contacts
resulting from rapidly settling particles overtaking and colliding with
more slowly settling particles '•*.
ol
Precipitation is the formation of an insjfuble product from formation
ionic species whose concentration is such that their solubility product is
exceeded. A metal salt (MA) in a very dilute solution can be assumed to
be completely ionized. The solubility(s) of MA can then be expressed as
S - [M+] - [A-]
and the solubility product (Ks) is:
Ks - $2 = [M+] [A-]
<*/
The fin* concentration of the cation [M+] in solution is dependent
c
on the concentration of the union [A-] in solution. Temperature, ioni£
strength, and the presence of other dissolved species can alter the
solubility equilibrium. 15
Since the hydroxide or oxide salt of a metal is generally insoluble,
precipitation is accomplished and.dependent on proper pH control.
-------
Process Applicability, Description and Design Considerations
Coagulation and flocculation or precipitation have been shown applicable
for (1) the removal of suspended solids; ' (2) treatment of leachate
18
from landfills and wastes containing toxic substances; (3) dye color
19
removal from textile wastewater; (4) removal of organic content and
, •- 20 ,,.> •, 21,22,23,24
color from spent vegetable tanning solution; (5) metals removal;
(6) phosphorus removal; ' ' and (!}•• treatment of paint industrial
28
wastewater.
Coagulation in a flowing, dispersed system is more enhanced than by Brownian
motion alone. Although turbulent flow increases the rate of coagulation
for micron size particles, it also breaks up larger size particles
29
(approximately 100 mm) and impedes sedimentation. Coagulating dispersed
particles in a flocculator has another disadvantage in that the flow field
is not homogenous. A possible alternative to this is for coagulation to
occur in a turbulent pipe transporting in the dispersion directly to the
30
sedimentation tank.
Sedimentation units are generally rectangular or circular in shape with
31
horizontal or incline flow. Circular tanks have diameters from 40 feet
32,33,34
to 100 feet, with depths of 7 to 12 feet. Rectangular units have
a maximum length and width of 300 feet and 80 feet respectively.
Length to width ratios of 3:1 and 5:1 are common with a width to depth
35,36
ratio of 2:5. Loading rates have been cited from 200-900 gpd/sq. ft.
with rates exceeding 600 gpd/sq. ft for flow rates greater than 1.0 mgd.
-------
Detention times for sedimentation tanks normally ranges from 0.25 to
4.0 hours, with little increase in the degree of sedimentation occuring
after 2 hours. 41,42,43.44,45,46,47,48
The detention time for flash or rapid mixers with turbine or flash
mixing is in the order of 2 to 5 minutes with times as low as 10 seconds
being cited. 49'50
Inorganic coagulant dosage has been shown to be 145 to 175 mg/1. While
organic flocculant dosage is generally less than inorganic (20 to 60 mg/1)
the chemical cost is higher. 1>52>53 In large plants, lime can be reused
by recalcination of spent lime sludge driving the cost of this inorganic
54
coagulant even lower.
Floes with good settling properties have been produced in 10 to 30
55,56
minutes. In all cases, chemical reagent dosage for coagulation,flocculat ion,
t»nd rretl*P(iltaCi'Dm should be determined by jar testing and whenever possible
by pilotnp'laHt studies.
Chemical precipitation is based upon the addition of a chemical reagent
to precipitate the desired or chemically plausible amount of hazardous
comp°nent- Solubility product knowledge is sufficient for design of
simple waste streams. However, as the waste stream becomes more complex
several factors must be considered:
(1) Simultaneous precipitation of several compounds, and
co-precipitation;
(2) Complexation by ammonia, cyanide, polyphosphates,
tartrate, oxalate, and other materials; and
(3) Metals which exhibit amphoterism, e.g., aluminum
-------
and chromium which have minimum solubility at a definite
pH.
Precipitation does not require complex system design or control for most
applications. The operating mode is either batch or continous depending
on the type and size of the waste stream to be treated. Wast^ streams
requiring long reaction times or processes producing small.or intermittent
flows are appropriate for batch operations, whereas, large streams with
uninterrupted flow may require continous systems.
Equipment types generally include:
(1) Influent Equilization- Holding tanks or basins
with agitators are used in continous feed processes
to create a more uniform constant stream to the reactor;
(2) Reagent Storage - The physical and chemical properties
of the reagent dictates the type of storage facility
u
to be used. Caustic solutions, for example, may be
stored in open or closed tanks while quicklime is kept in
waterproof silos, hoppers, or bags. Feed rate and
delivery schedules form the bases for determining
storage capacity;
(3) Feed and Delivery- Liquids and slurries or reagents
or waste streams are delivered to the reaction vessel
by pumps while solid reagents require conveyors and
dispensers, and ancillary equipment such as lime shakers;
and
-------
(4) Agitation and Reaction- The reaction vessel or
tank design generally follows the same criteria as
discussed earlier. Tanks used for precipitation with
subsequent flocculation and sedimentation may have a conical
/ e
base use as a svttler. Tanks may be round, square, or
/
rectangular and may be built above or below ground. Agitation
is mild, so that particle agglomeration is not inhibited,
utilizing propeller or turbine type impellers.
Construction materials vary with types of chemical reagents and waste
stream characteristics. In addition, the expected service life, operating
temperature, physical strength, flow rate, and mechanical abrasion must
be considered when selecting such materials.
4 /
At ambient temperatures examples of recommended materials for Banding
59
different acids and alkalies are:
(1) Concentrated sulfuric acid (75%-95%) can be handled
with lead while more dilute solutions ( 10%) may require only
rubberj
(2) Hydrochloric acid at all concentrations-rubber and
sodium hydroxide concentrated - rubber or stainless steel;
4
(3) Dilute sodium hydroxide can be accomfhdate^ with carbon
steel or cast iron; and
(4) Calcium hydroxide can be handled with stainless steel,
rubber, or carbon steel.
-------
Walter J. Weber, Jr., Physicochemical Processes for Water Quality Control
(New York: John Wiley § Sons, Inc., 1972) p.62 .
2
Weber, p. 63.
IBID., p. 64 .
Metcalf § Eddy, Inc., Wastewater Engineering Collection, Treatment, Disposal
(New York: McGraw Hill Book Company, 1972), p. 336.
5
Weber, p. 65.
6
IBID., p. 68.
?IBID., p. 68.
8Metcalf § Eddy, Inc., p. 337.
9Weber, p. 72.
10
IBID., P. 72.
11
IBID., p. 73.
12Metcalf § Eddy, Inc., p. 338.
13
Weber, p. 92.
14
U.S. Environmental Protection Agency, Office of Solid Waste, Draft
Report on Methods of Good Practice in Precipitation
Arthur D. Little, Inc., (1977), p. 2.
15IBID., p. 2.
16J.B. White and M.R. Allos, "Experiments on Wastewater Sedimentation,"
Journal Water Pollution Ctiaatrol Federation 48 (July, 1976): 1841.
-------
R. Stukenberg, "Biological-Chemical Wastewater Treatment,"
Journal Water Pollution Control Federation 43 (September, 1971): 1792.
18 John R. Stukenberg, "Physical -Chemical Wastewater Treatment Using
a Coagulation-Absorption Process, "Journal Water Pollution Control
Federation 47 (February, 1975): 338.
Jack S. Kace and Henry B. Linford, "Reduced Cost Flocculation of a
Textile Dyeing Wastewater, "Journal Water Pollution Control Federation
47 (July, 1975): 1971.
H.D. Tomlinson, et al., "Removal of Color from Vegetable Tanning Solution,"
Journal Water Pollution Control Federation 47 (March, 1975): 1975.
21
Toshiro Maruyama, Sidney A. Hannah, and Jesse M. Cohen, "Metal
Removal by Physical and Chemical Treatment Processes," Journal Water
Pollution Control Federation 47 (May, 1975): 962.
2^K. Daniel Lindstedt, Carl P. Houck and John T. O'Connor, "Trace
Element Removal in Advanced Wastewater Treatment Processes," Journal
Water Pollution Control Federation 43 (July, 1971): 1511.
23
B. Gorans son and P-0 Mobert, "Metal-Finishing Wastewater Treatment in
Sweden," Journal Water Pollution Control Federation 47 (April, 1975): 764-765.
^ U.S. Environmental Protection Agency, Office of Solid Waste, Draft
Report on Methods of Good Practice in Precipitation, Arthur D. Little, Inc.,
(1977), p. 3.
.. , p. 3.
26
John F. Ferguson, David Jenkins, and John Eastman, "Calcium Phosphate
-------
Precipitation at Slightly Alkaline pH Value," 'Journal Water Pollution
Control Federation 45 (April, 1973): 629.
27
Sotirios C. Grigoropoulds, Richard C. Vedder, and D. Wayne Max, "Fate of
Aluminum-Precipitated Phosphorous in Activated Sludge and an Aerobic
Digestion," Journal Water Pollution Control Federation 43 (December, 1971):
2380.
28
Chin-Pao Huang and Mehdi G. Hadirian, "Physical-Chemical Treatment of
Paint Industry Wastewater," Journal Water Pollution Control Federation
47 (October, 1974): 2340.
29
Michael A. Delichatsios and Ronald F. Probstein, "Scaling Laws for
Coagulation and Sedimentation," Journal Water Pollution Control Federation
47 (May, 1975): 941.
30
IBID., p. 945.
31
K.M. Yao, "Theoretical Study of High Rate Sedimentation," Journal Water
Pollution Control Federation)! 42 (February, 1970): 220.
32
Weber, p. 128.
33Metcalf § Eddy, Inc. p. 448.
34
White, p. 1752.
35Yao, p. 226.
36Weber, p. 128.
37
Metcalf § Eddy, Inc., p. 448.
?8Weber, p. 128.
-------
39
Maruyama, p. 965.
40Goransson, p. 766.
41Yao, p. 218.
42 John R. Stukenberg, "Biological-Chemical Wastewater Treatment," Journal
Water Pollution Control Federation 45 (September, 1971): 1794.
Maruyama, p. 964.
44Tomlinson, p. 572.
45Weber, p. 128.
46Metcalf § Eddy, Inc., p. 447.
4'Goransson, p. 776.
48White, p. 1745, 1950.
49Metcalf 5 Eddy, Inc., p. 278.
50-romlinson, P« 5^2-
51Kace, p. 1973.
CO
Tomlinson, p. 572.
R. Stukenberg, "Physical-Chemical Wastewater Treatment Using
a Coagulation-Absorption Process,!' Journal Water Pollution Control
Federation 45 (September, 1971): 1792.
55Metcalf 5 Eddy, Inc., p. 278.
56Tomlinson, p. 572.
-------
U.S. Environmental Protection Agency, Office of Solid Waste, Draft Report
on Methods of Good Practice in Precipitation, Arthur D. Little, Inc.,
(1977), p. 4.
IBID., p. 7.
59IBID., p. 9.
6°IBID., p. 9.
61IBID., p. 14.
62
IBID., p. 14.
63IBID. p. 15.
-------
Ion Exchange
liuction
Tne swapping of one ion for another or ion exchange has been used for the
of hazardous impurities and the recovery of valuable constituents found
1.2
4$nt in industrial waste streams .
and selection of resins allow the ion exhcnage system to be
3
absorpton applications . The process is stable, predictable and operates
4,5,6
Ja high degree of efficiency in most cases . Resins are normally regenera-
\ site using basic, acidic and salt solutions and/ or regenerable nonaqueous sol-
J
• . Ion exchange is economically competitive with other treatment processes
8
of capital investment, operation and maintenance . This fact, plus the
*t advantages mentioned above makes ion exchange a unit operation worth Donald-
's when treating an industrial waste.
Ion exchange processes, however, are not without drawbacks. Normally, the
% stream must be pretreated to ensure that the influent to the ion exchange vessel
9
%e of suspended solids to prevent particulate fouling of the resin bed . Other
associated with the system are resin losses and mechanical failures that
10
'lit in operational shutdown
-------
Theoretical Considerations
Ion exchange is a process whereby ions of similar charge in a solution are
exchanged for ions held by electrostatic forces to charged functional groups on the
11
surface of a solid immersed in that solution
The nature of the functional groups determines the exchange capacity, exchange
12,13
equilibrium, and the selectivity of the ion exchange resin . Functional acid
groups such as sulfuric (R-SO H), phenolic (R-OH), carboxylic (R-COOH). and
3
phosphonic (R-PO H ) are cation exchangers or those resins capable of exchanging
3 2
cations. Functional groups for anion exchange resins are primary amine (3-NH ),
2
secondary amine (R-R'NH), tertiary amine (R-R1 N) and the quaterary ammonium
+ _ 2
group (R-R1 N OH). Both cases, the R represents the resin and the R1 an organic
3 14.15
dical such as the methyl group .
The charge carried by the functional group is balanced by a counter charge
ssessed by the resin maintaining electroneutriality. The driving force is due to
16.17
concentrational differences between the ions in solution and the ions in the resin
The exchangeable ions of an acidic cation resin may be either hydrogen or some mono-
valent cation such as sodium, whereas the exchangeable ion for a basic anion resin
may be the hydroxide ion or some other monovalent anion. The exchange between
the ions in solutions and the ions in the resin will continue until equilibrium is attained.
Thus, there are two characteristics typified by an ion-exchange reaction: (1) the reaction
always involves an equivalent transfer of ions; and (2) every exchanger will be selective
18
for one ion over another
The rate at which ions are exchanged between the solution and the resin is con-
trolled by one of two diffusional transport processes: (1) film diffusion or the diffusioa
-------
|as across a hypothetical film of solution surrounding each particle of exchange
}, and (2) pore diffusion or the diffusion of ions through the interstitial pores
" 19
e resin particle itself .
The selectivity of a resin for the exchange of ions is dependent upon ionic
ge and ionic size, the former being the more significant. Thus, for typical
is and cations found in wastewater, the following order of selectivity would be
20
fctively :
3- 2-
PO ;> so > ci
4 4
4+ 3+ 2+ +
Th ? Nd > Ca ^ Na
Normally, ions of higher ionic charge are preferentially exchanged for thos of
21
Some exceptions are as follows :
2- - 2-
SO ^ I /> NO > CrO ^ Br
4 34
ions are of equal charge, the ion with the smallest radius in solution
more tightly by a resin. Thus, for the alkali metals and the alkaline arth
22
the order of selectivity is respectively :
Ce /> Rd > K • Na ^> Li
and
2+ 2+ 2+ 2+ 2+
Ba /" Sr ^> Ca /? Mg Be
-------
23
Similarly, for monovalent anions the order of selectivity is :
CNS / CIO ~"7>I /> NO
4 3
HSO /> NO ">• Cl ^> HCO
42 3
CH COO > OH > F
3 '
Factors which affect the rate of exchange and/or the selectivity of the resin
are mixing, flow rate, resin particle size, solution concentration, and resin cross
linkage. The rate of exchange increases as the flow rate and/or the mixing increases
and the resin particle size decreases. The rate of exchange and the selectivity of
the resin and the rate of exchange are inversely proportional to the cross linkage
24,25
of the resin .
It is the selectivity and rate characterists of ion exchange resins which can
often be exploited to handle specific hazardous waste streams with a high degree
of efficiency.
Progress Applicability, Description and Design Consideration
Ion exchange processes have been employed in the past to treat waste streams
for the removal and recovery of: (1) heavy metals such as mercury, chrome, alumi-
26,27,28
num., gold, silver, platinum, manganese, palladium, zinc, and nickel ; (2) color
and minerals ' ; (3) soluable organic compounds 31,32 . (4) nitrogen and phospho-
38
33,34,35,36,37^ ^ radioactive isotopes.
-------
The treatment of industrial wastes can be somewhat complicated by the pre-
sence of materials or conditions which may clog, attack or foul resins.
Suspended solids and other matter can clog a resin bed, inhibiting flow and
39
reducing the efficiency of ionic transfer. Strong oxidizing agents such
as nitric acid can attack resin crosslinks having a detrimental effect on
40
performance. The pH of the waste stream has been shown to have a
considerable affect on the exhange characteristics on various resins. The
41 42 43
optimum range being 4 to 8. ' ' Generally, resins are stable at
o 44 45
temperatures to 100 C or higher. '
For ease of regeneration and maintenance, ion exhange systems should be
built in duplicate. This allows one unit to be taken off line while one
unit remains active. Exchangers are usually constructed as vertical cylinders
with top to bottom flow. Exchangers usually range in depth from 2 to 6
46,47,48
feet. Depending on the resin, 50 to 100% of the packed bed height
49 50 51
is allowed for expansion. ' ' All tanks and internal parts which come
into contact with the strong acid or alkali regenerant should be
lined or coated with resistant materials, such as phenolic or vinyl chloride
polymer. The plastic coatings are generally about 0.01 inches in thickness
while hard rubber liners are about 0.2 inches in thickness. ' The flew
rate through the exhanger is normally 5 to 10 ft/sec. ' ' ' Head
•
loss through a pressurized exchanger is approximately 1 to 2 feet with a
pressure loss of a few pounds per square inch. 58»59
Conductivity or pH is frequently used to monitor the performance of
low exchange systems. While the waste stream is being treated monitoring
should be directed at those species of interest. If a number of different
species are being removed simultaneously, monitoring should be conducted on
'*J ir
-------
those species which are known to be the least strongly bound to the
resin.
This can be accomplished by using electrochemical monitors, such as
ion selective electrodes or by simple color tests available in kit-forms.
During the regeneration phase of ion exchange, conductivity or pH
may be more than adequate. 2
-------
)TNOTES
r -a R. Fair, Burton B. Crocker and Arnold R. Null, "Trace Quantity Engineering. "
itJiical Engineering, August, 1972, p. 61.
rin R. Higgins, "ion Exchange: Its Present and Future Use, " Environmental
ience and Technology 7 (December, 1973): 1110.
R. Kim, Virnon L. Snoeyink, and F. Michael Saunders, "Absorption of
"ganic Compounds by Synthetic Resins, " Journal Water Pollution Control Federa
48 (January, 1976): 120.
hn H. Koon and Warren J. Kaufman, "Ammonia Removal from Municipal Waste
ters by Ion Exchange, " Journal Water Pollution Control Federation 47 (March,
?5): 448.
ibert Kunin and Donald F. Downing, "Ion-Exchange System Boasts More Pulling
, " Chemical Engineering, June, 1971, p. 67.
F. Dean, Frank L. Bosqui, and Kenneth H. Landquette, "Removing Heavy
from wastewater, " Environmental Science and Technology 6 (June, 1972): 521.
&, p. 120.
eldon Evans, "Nitrate Removal by Ion Exchange, " Journal Water Pollution Control
jderation 45 (April, 1973): 632.
chael Semmens and John Gregory, "Selectivity of Strongly Basic Anion Exchange
sins for Organic Anions, " Environmental Science and Technology 8 (September,
74): 834.
H. Seels, "Industrial Water Pretreatment, " Chemical Engineering, February,
fa. p. 31.
flter J. Weber, Jr., Physic ochemcal Processes for Water Quality Control
W York: John Wiley & Sons, Inc., 1972), p. 261.
-------
12
Semmens, p. 837.
13
Weber, p. 262.
14
Kim, p. 121.
15
Weber, pp. 262-263.
16
Semmens, p. 837.
17
Wever, p. 263.
18
IBID.. p. 271.
19
IBID., p. 218.
20
Weber, p. 74.
21
IBID., p. 275.
22
IBID., p. 275.
23
Wever, p. 276.
24
IBID., p. 279.
25
Semmens, p. 837.
26
"Winning Heavy Metals from Waste Streams, " Chemical Engineering. April.
1971. pp. 62-63.
-------
2?
Toshiro Maruyama, Sidney A. Hannah and Jesse M. Cohen, "Metal Removal
by Physical and Chemical Treatment Processes, "Journal Water Pollution Control
Federation 47 (May, 1975): 768-770.
28
U.S. Environmental Protection Agency, Office of Solid Waste, Draft Report
on Ion Exchange, Some Current Practices in Waste Treatment, Arthur Q. Little,
Inc., (1977) pg.l.
29
R.L. Sanks, "The Recycling of Kraft Beach Wastes, "Journal Water Pollution
Control Federation47 (July, 1975): 1927.
"Cleanup System Makes Pure Processing-Water, "Chemical Engineering, February,
1973, p.66.
31Kim, pp. 122-131.
32
Semmens, p. 834.
33Koon, p. 449.
34Kunin, p. 69.
Evans, p. 633.
"Ion Exchange Process Made Continuous, "Chemical 5 Engineering News,
August, 1976, p.23.
37
Dean, p. 521.
•ZQ
J Higgins, p. 1113.
•59
Seels, p. 31.
-------
40
U.S. Environmental Protection Agency, Office of Solid Waste, Draft
Report on Ion Exchange, Some Current Practices in Waste Treatment
Arthur D. Little, Inc., (1977) pg. 4~
41
Kin, p. 125
42
"Winning Heavy Metals from Waste Streams, "Chemical Engineering, April
1971, p. 62.
43
Koon, p. 455
44
Weber, p. 280
45
Sanks, p. 1925
46
Koon, p. 451
47
Weber, p. 297
48
Sanks, p. 1925
49
Koon, p. 451
50
Sanks, p. 1925
51
Weber, p. 297
52
IBID., p. 297
53
U.S. Environmental Protection Agency, Office of Solid Waste, Draft
Report on Ion Exchange, Some Current Practices in WASTE Treatment
Arthur D. Little., Inc., (1977) pg. 6~
54
IBID., p. 2
55
IBID., p. 297
-------
56
Sanks, p. 1927
57
Koon, p. 461
58
Weber, p. 281-297
59
Koon, p. 461
60 ,..
U.S. Environmental Protection Agencym Office of Solid Waste, Draft
Report on Ion Exchange, Some Current Practices in Waste Treatment
' Arthur D. Little, Inc., (1977) p. 4.
61
IBID, p. 9
62
IBID., p. 9
-------
Oxidation-Reduction
Introduction
Redox or oxidation-reduction reactions are characterized by a
loss of electrons (oxidation) or a gain of electrons (reduction).
Organic oxidation-reduction reactions include not only complete
electron transfer but the transfer of any hydrogen species other
than the proton or any oxygen species other than an oxide or the
hydroxide ion'.
a*
The purpose of suchAredox reaction is to convert potentially
hazardous chemical substances to less harmful or more desirable
species. The most effective oxidants with respect to cost, handling,
process compatability, and treatment efficiency are ozone, permanganate,
2
chlorine and chlorine dioxide .
Theoretical Considerations
Those substances which function as an electron acceptor are
considered oxidizing agents while a reducing agent is any material
which serves as an electron donor. Thus, depending on the oxidation
state of the agent and the reaction conditions, a given element can
assume either role.
Reactant concentration, temperature, system composition, and
impurities play a primary part in reaction kinetics. However, due to
the atypical characteristics of most industrial waste streams, kinetic
relations should be determined experimentally.
-------
The use of catalysts such as silica, clays, metal ions, and
activated carbon may be beneficial in promoting reaction pathways of
lower activated energy thus accelerating reaction rates^..
One of the most influential parameters in redox reactions is the
pH. The rate of oxidation may be affected by pH as a result of one
or more of the following effects: (1) changes in the free energy of
the overall reactions; (2) variations in the reactivity of constituents;
and/or (3) special hydroxide ion or hydronium ion catalysis.
General trends of organic compounds with respect to oxidative
reactivity is as follows^: (1) high reactivity-phenols, aldehydes,
aromatic amines, thioalcohols, thioethers; (2) medium reactivity-
alcohols, alkyl-substituted aromatics, nitro-substituted aromatics,
unsaturated alkyl groups, carbohydrates, aliphatic ketones, acids,
esters, and amines; and (3) low reactivity-halogenated hydrocarbons,
saturated aliphatic compounds, benzene.
Process Applicability, Description and Design Considerations
Redox reactions have been used for the: (1) oxidation of cinnabar
(HgS) in acid minewaters^; (2) reduction of mercury and lead compounds ;
(3) treatment of textile wastes ; (4) oxidation of phenols and reduction
of chemical oxygen demand**^; (5) treatment of metal finishing
wastes * '; (6) treatment of wastewater with oxy-aromatic and
heterocyclic aromatic compounds'^; oxidation of weak black liquor
from pulp mills^, and (7) radioactive contaminants'^.
-------
Ozone is an effective treatment for industrial wastes due to its powerful
oxidizing potential and lack of adverse side reactions. Present dis-
advantages relate mainly to the cost and efficiency of ozone generating
equipment making it only economical on a large scale, and/or closed
systems. This can be exemplified by comparing the theoretical production
of 1058g of ozone produced per kilowatt hour (kW-hr) of electrical energy
with that of most industrial generators of only 150g/kW-hr16. The most
efficient application of ozone is in a closed system where the ozone
has immediate contact with the waste stream. Several mechanisms are
employed to promote maximum contact of ozone and waste stream.
The Otto partial-injector system utilizes a head drop across the
face of the injector to mix the ozone with the solution as it passes
through the injector at about 14 ft. of head. The ozonated solution
moves to an upflow reactor where oxidation takes place prior to discharge^?.
A rapidly rotating propeller is used to draw ozone through its
porous base while mixing it with the waste solution. The Kerag system
employs this action at the bottom of the reaction column where oxidation
18
takes place .
A third method uses an ozone-solution misdirection in conjunction
with a porous diffuser at the bottom of the contact chamber to mix
and promote oxidation^.
Permanganate treatment of industrial wastes has the added advantage
over ozone of being easier to feed and monitor. The disadvantage is in
separating the insoluable hydrous manganese dioxide. Potassium permanganate
-------
is physically a dark purple solid and chemically very reactive. It
has been used for the destruction of organic residuals, such as,
aldenudes, mercaptans, phenols, and unsaturated acids.^0 Permanganate
dosages range from 0.5-2.0 ppm (as KMnO) depending on the waste stream
being treated and the operating conditions. This can be controlled
somewhat by adjusting the pH (decreasing dosage with increasing pH)
or by the addition of a suitable catalyst. In systems which employ
activated carbon as a treatment step, oxidation should take place prior
to absorption due to reduction of the permanganate by the carbortZl.
Hydrogen peroxide is another highly reactive oxidizing agent used
to remove chlorine (following chlorination treatment) and iron. In
processes where post treatment of the wastewater involves distillation
or crystallization all unspent peroxide must be removed because these
00
techniques tend to concentrate the unused reagent.
Chlorine has been used in alkaline solutions for the oxidation of
cyanide. The use of chlorine or chlorine dioxide for treatment of waste
streams high in organic content should be joined with carbon absorption
to prevent chloronated hydrocarbons from entering the environment. The
toxic and highly unstable nature of chlorine and chlorine dioxide makes
handling the storage somewhat precarious when in the gas form. However,
both are stable once in solution. Generally, the oxidative potential of
chlorine is still widely used due to its cost effectiveness, availability,
oxidizing power, and adaptabilityi23
Base metals (i.e., iron, aluminium, and zinc), sulfur dioxide and
sulfite, and ferrous sulfate are reducing agents which have found some
applicability in hazardous waste treatment. Reducing agents however,
-------
may introduce new ions into the process stream which can result in
further treatment requirements.^
Of those agents only sulfur dioxide a gaseous, high toxic irritatent
requires special care in handling.25
Construction materials must be chosen for each design process to
life.
protect personnel and to ensure equipment frra-.
Construction materials for dry chlorine are steel, stainless steel,
cast iron, wroughtiron, copper alloys, nichel alloys, and lead. Wet
chlorine, however, can only be handled at low pressure in chemical
stoneware, glass, or porcelain by high silica iron, monel metal and
Hostalloy.27
Steel and other common structural metals can be used under dry
conditions for storing sulfur dioxide. In the presence of moisture lead,
type 316 stainless steel, and plastics (i.e., ABS, PVC polyester, and
on
epoxy glass) are recommended. °
Storage of oxidation and reduction agents should be in cool, well
ventilated areas. Vent location is dependent on the agent since some
gas agents are heaver than air. Agents which are highly reactive when
contacted by various organics, moisture or other agents should be
segregated and stored in fireproof areas.
Many oxidation and reduction reactions are sensative to pH. Monitoring
and control of the system is therefore achieved by pH control and by use
of oxidation/reduction electrodes. Temperature control is also important
and may require heat exchange equipment or additional detention time to
reduce heat from oxidation reactions which are generally exothermic.29
70
-------
FOOTNOTES
1
Walter J. Weber, Jr., Physicochemical Processes for Water Quality
Control (New York: John Wiley & Sons, Inc., 1972), p. 363.
2
IBID., p. 365.
3
IBID., p. 375.
4
Weber, p. 378.
5
John E. Burkstaller, Perry L. McCarty, and George A. Parks, "Oxidation
of Cinnabar by Fe (III) in Acid Mine Waters, "Environmental Science
& Technology (July. 1975):678.
6
U. S. Environmental Protection Agency, Office of SOI id Waste, Draft
Report on Oxidation - Reduction>Arthur D. Little, Inc.m (1977) pp. 31, 32.
7
Alfred B. Scaramelli and Francis A. DiGiano, "Wastewater Treatment
Physical and Chemical Methods, "Journal Water Pollution Control Federation
47 (June, 1975):1255.
8
Joseph P. Gould and Walter J. Weber, Jr., "Oxidation of Phenols by Ozone,"
Journal Water Pollution Control Federation 48 (January, 1976):60.
9
U. S. Environmental Protection Agency, Office of Solid Waste, Draft
Report on Oxidation - Reduction, Arthur D. Little, Inc., (1977) pp 27.
10
IBID, pg. 28.
11
B. Goransson and P. 0. Moberg, "Metal-Finishing Waste Treatment in
Sweden," Journal Water Pollution Control Federation 47 (April, 1975):765.
12
Weber, p. 381.
7t
-------
13
Dennis C. Macau!ey, "Chemicals and Allied Products, "Journal Water
Pollution Control Federation 45 (June, 1973):1220.
14
"Tonnage Oxygen is Used to Oxidize Weak Black Liquor at a Pulp Mill,"
Chemical Engineering, May, 1971, p. 76.
15
Weber, p. 387.
16
Weber, p. 348.
17
IBID., p. 384.
18
IBID., p. 384.
19
Weber, p. 385.
20
U.S. Environmental Protection Agency, Office of Solid Waste, Draft Report
on Oxidation Reduction,.Arthur D. Little, Inc., (1977) pp. 5, H. *
21
IBID., p. 394.
22
U.S. Environmental Protection Agency, Office of Solid Waste, Draft Report
on Oxidation Reduction, Arthur D. Little, Inc., 0977) pp. 5, \s.
23
Weber, p. 395.
24
U.S. Environmental Protection Agency, Office of SOI id Waste, Draft
on Oxidation Reduction, Arthur D. Little, Inc., (1977) pp. 17"!
25
IBID., p. 6.
26
IBID., p. 8.
-------
27
IBID., p. 8.
28
IBID., p. 3.
-------
Activated Sludge
Introduction
The activated sludge process utilizes a flocculated suspension to
accumulate and store a bio-mass. The microbial population may be
specifically adapted or acclimated to handle certain toxic organic
and inorganic wastes; however, shock loading or high accumulation
through absorption or bio-concentration of these substances may result
1,2
in process failure
3
The use of air or pure oxygen in an activated sludge process is :
(1) to supply the metabolic oxygen requirement of the heterotrophic treat'
ment organisms, and (2) to produce mixing within the reaction vessel.
Thus the transfer of gases through the various phases within a reactor
is critical to the removal of colloidal and dissolved substances for which
4
biological processes are designed .
7V-
-------
Theoretical Considerations
The mass transfer scheme of a gas being dissolved in a liquid occurs in
5
four steps : (1) the movement of gas through the vapor phase to the gas-liquid
interface; (2) the passage of the gas through the gas film of the gas-liquid interface;
(3) then the passage through the liquid film of the gas-liquid interface; and (4) the
dispersion of the gas throughout the bulk of the solution. In quiescentor stagnant
conditions the rate limiting step is considered the diffusion of the gas through the
bulk of the solution. If the solution is sufficiently agitated by mechanical or forced
air mixers, the rate limiting step comes the rate of transfer through the gas-liquid
6
interface .
Since the constituents which make up air are non-reactive in water, with the
Inception of carbon dioxide, their respective solubilities are directly proportional
to their partial pressure. As the concentration of impurities, the concentration of
substances which react with the gas. and the temperature of the liquid increase the
solubility of the gas in the liquid decreases. Thus the solubility of oxygen in waste-
7
water is generally less than 95% of that in pure water .
Once the oxygen is in solution it can be absorbed by the biosphere and utilized
in the detoxification and degradation of the matter present in the waste stream.
75"
-------
3cess Applicability, Description and Design Considerations
Activated sludge systems have been cited for: (1) the removal of heavy metals
8,9,10 11.12
•m waste streams ; (2) detoxification of bleached kraft mill effluents ;
13
the treatment of feedlot runoff ; (4) the treatment of complex plastics manufacturii^
14 15
stes ; and (5) the treatment of industrial wastewaters in general .
The three basic systems for aeration and gas transfer are compressed gas,
16,17
pirators, and mechanical agitators .
Compressed air systems are of two types, diffused air or dispersed-air systems.
a diffused air system, the air is normally filtered, to prevent fouling, then passed
•ough porous plates or tubes, porous membranes or wound fibers or metallic fila-
18
>nts . For a diffused air system, the reactor depth and width is usually restricted
15 and 30 feet respectively. An air feed rate of 3 cfm per lineal foot of reactor
*
20 to 30 scfm/1000 cu. ft. of tank volume is necessary to provide a transverse
19,20
locity of 1.5 fps in order to accomplish vertical transverse roll . To prevent
tivated sludge floes from settling, a velocity of 0.5 fps across the reactor bottom
21
necessary .
Oxygen-transfer efficiencies of 12% or more have been shown for compressed-
r systems, corresponding to a transfer rate of approximately 1.8 lb/(hp)(hr) under
andard rating conditions. More frequent rates occuring in wastewater are 0.5 -
8 lb/(hp)
-------
Air aspirator systems are either mechanical or hydraulic in nature. Mechanical
Ors are hollow-blade impellers or vortex generating devices which move with
6nt force to discharge atmospheric air into the solution. A transfer rate of
.5 Ib. oxygen/(hp)(hr) are common for mechanical aspirators. Hydraulic
Orators utilize a venturi tube or similar device to create a low-pressure condition
ae waste being pumped through it. This in turn draws atmospheric air into the
in. For atmospheric air systems, oxygen transfer rates can be as low as 1 Ib.
5 per horsepower hour. However, hydraulic aspirators operating with compressed
23
ihave rates as high as 6 Ib. oxygen/(Hp)(hr) .
24
Mechanical aerator systems include surface aerators and aerator pumps .
1? aerators are either the horizontal axis brush type or the vertical axis turbine
power requirements for mechanical aerators is 0.50 to 1.0 hp/1000 cu.
25
Reactor volume . The transfer rate of brush aerator is about 3.5 - 5.0 Ib.
li/(hp)(nr). Aeration pumps are normally turbines associated with a draft tube.
*ste is pumped over a weir or through a set of vanes by the turbine which is
4 near the surface of the solution. Turbine type aerators have a transfer rate
26,27
-7.5 lb/(hp)(hr)
Typical aeration tank dimensions for activated sludge reactor channels range
28,29
0 to 17 feet in depth, 15 to 33 feet in width, and 30 to 100 feet in length
liquor volatile suspended solids maintained in the reactor ranges from 500 to
30,31,32,33
mg/1
The sludge age or mean cell residence time for activated sludge units can be
34,35,35,37
tan 0.25 days or greater than 34.0 days
77
-------
Activated sludge reactors have displayed detention times ranging from 0.5 to
38,39,40,41
hours
i
Since industrial wastes are generally atypical with chemical oxygen demands
some cases exceeding ten times that of domestic wastewater, pilot plant studies
>uld be conducted in order to determine loading criteria, reactor type, sludge
>duction, oxygen requirements and effluent characteristics.
-------
SOTES
-i
U.J' J. Mulligan and Robert D. Fox, "Treatment of Industrial Wastewaters, "
deal Engineering, October, 1976, p. 51.
id D. Neufeld, "Heavy Metals -Induced DefLocculation of Activated Sludge, "
al Water Pollution Control Federation 48 (August, 1976): 1945, 1947.
ir J. Weber, Jr. , Physiochemical Processes for Water Quality J^ontrol,
York: John Wiley & sons, Inc., 1972), p. 50.
talf & Eddy, Inc. , Wastewater Engineering Collection Treatment Disposal
^York: McGraw Hill Book Company, 1972), p. 644.
8 E. Albertson and David D. Gregorio, "Biologically Medicated Inconsistencies
(ration Equipment Performance, " Journal Water Pollution Control Federation
(ay, 1975): 976.
lP. 505.
„ p. 509.
I A. Cheng, James W. Patterson and Roger A. Minerar, "Heavy Metals Uptake
ctivated Sludge, " Journal Water Pollution Control Federation 47 (February,
): 365.
is K. Wood and George Tehobanolous, "Trace Elements in Biological Waste
, " Journal Water Pollution Control Federation 47 (July, 1975): 1937.
Jd D. Neufeld and Edward R. Hermann, "Heavy Metal Removal by Reclimated Acti-
1 Sludge, " Journal Water Pollution Control Federation 47 (February, 1975): 325.
, Mueller and C. C. Walden, "Detoxification of Bleached Kraft Mill Effluents, "
Hal Water Pollution Control Federation 48 (March, 1976): 504-506.
7*.
-------
Ralph R. Peterson, "Design Criteria for High-Purity Oxygen Treatment of Kraft Mill
Effluent. " Journal Water Pollution Control Federation 47 (September, 1975): 2317.
Terence J. McGhee, David S. Backer, and Michael V. O'Neal, "Biological Treatment
D£ Feedlot Runoff, " Journal Water Pollution Control Federation 48 (January, 1976): 156
Hugh J. Campbell, Jr., and Robert F. Rocheleau, "Waste Treatment at a Complex
Plastics Manufacturing Plant, " Journal Water Pollution Control Federation 46
[February, 1976): 257. ~~ '
Mulligna, p. 50.
Weber, p. 517.
Albertson, p. 976.
IVIetcalf & Eddy, Inc., p. 506.
[BID., p. 519.
Weber, p. 518.
[BID., p. 518.
IBID., p. 518.
Weber, p. 519.
Albertson, p. 976.
i
Metcalf & Eddy, Inc., p. 519.
Weber, p. 520.
-------
calf & Eddy, Inc., p. 519.
)., p. 520.
erson, p. 2324.
).. p. 2324.
py D. Benefield and Clifford W. Randall, "Design Procedure for a Contact
ilization Activated Sludge Process, " Journal Water Pollution Control Federa-
48 (January, 1976): 150.
Her, p. 503.
:alf & Eddy, Inc., p. 498.
jifld, p. 150.
)hee, p. 159.
ipbell. p. 264.
calf & Eddy, Inc., p. 498.
srson, p. 2324.
5hee, P- 159.
ipbell, P. 263.
calf & Eddy, Inc., p. 498.
-------
BD-31
Resource Conservation and Recovery Act
Subtitle C - Hazardous Waste Mangement
Section 3004 - Standards Applicable to Owners
and Operators of Hazardous Waste
Treatment, Storage, and Disposal
Facilities.
DRAFT
BACKGROUND DOCUMENT
Section 250.46 Standards for Special Wastes
a. Cement Kiln Dust Waste
b. Utility Waste
c. Phosphate Rock Mining,
Beneficiation, and Processing
Was te
r
d. Uranium Mining Waste
e. Other Mining Waste
f. Gas and Oil Drilling Muds
and Oil Production Brines
U.S. Environmental Protection Agency
Office of Solid Waste
December 15, 1978
-------
This document provides background information and
support for regulations which are designed to protect the
air, surface water, and groundwater from potentially
harmful discharges and emissions from hazardous waste
treatment, storage, and disposal facilities pursuant to
Section 3004 of the Resource Conservation and Recovery
Act of 1976. It is being issued as a draft to support
the proposed regulations. As new information is obtained,
changes may be made in the regulations, as well as in
this background material.
This document was drafted to reflect information
received and Agency decisions. EPA made changes in the
proposed Section 3004 regulations shortly before their
publication in the Federal Register. We have tried to
ensure that all of those decisions are reflected in this
document. If there are any inconsistencies between the
proposal (the preamble and the regulation) and this
background document, however, the proposal is controlling.
Comments in writing may be made to:
Timothy Fields, Jr.
U.S. Environmental Protection Agency
Office of Solid Waste
Hazardous Waste Management Division (WW-565)
401 M Street, S.W.
-------
Table of Contents
1. RCRA Mandate and Authority
2. Rationale for 250.46 Special Waste Standards
3. Rationale for Designating Wastes as Special
4. Identification of Regulatory Options
5. Analysis of Regulatory Options and Identifica-
tion of Chosen Regulatory option
6. Rationale for the Application of Specific Subpart
D Regulations to Special Waste
7. Rationale for the Application of Additional Subpart
D Regulations to Some Special Waste
8. Wastes Which Were Considered, but Were Not Selected,
for Designation as Special Wastes
9. EPA Studies on the Establishment of Substantive
Reguirements for the Designated Special Wastes
-------
1. RCRA Mandate and Authority
The Congress of the United States, via Section
3004 of Subtitle C of the Resource Conservation and
Recovery Act (RCRA) of 1976 (Pub. L. 94-580), mandates
that the Administrator of the U.S. Environmnental
Protection Agency promulgate regulations establishing
performance standards applicable to owners and operators
of hazardous waste treatment, storage and disposal
facilities as may be necessary to protect human health
and the environment. These standards are to include,
but need not be limited to, requirements respecting:
(1) operating methods, techniques, and practices; (2)
location, design, and construction; and (3) contingency
plans for effective action to minimize unanticipated
damage that might occur at these facilities.
All provisions of this Act (including Section
3004) must be integrated with the Clean Air Act (42
U.S.C. 1857 and following), the Federal Water Pollution
Control Act (33 U.S.C. 1151 and following), the Federal
Insecticide, Fungicide, and Rodenticide Act (7 U.S.C.
135 and following), the Safe Drinking Water Act (42
U.S.C. 300f and following), the Marine Protection
Research, and Sanctuaries Act (33 U.S.C. 1401 and
following) and such other Acts of Congress as grant
authority to the EPA Administrator. A stated purpose
of the above requirement was to avoid duplication to
the maximum extent possible. Such integration, however,
is to be effected only in a manner consistent with the
goals and policies expressed in RCRA and the above-
listed Acts. >
-------
This document provides the background for regulations
to be promulgated under this framework of authority.
Rationale is provided for the special wastes concept and
for the specific regulations for facilities that treat,
store, and disposel of individual special wastes.
2. Rationale for Section 250.46 Special Waste Standards
Upon enactment of RCRA, the primary focus of the
regulatory- effort was toward control of the toxic and
otherwise hazardous residues from production and subsequent
air and water pollution control processes associated with
the manufacturing industries. However, in the course of
preparing the Subtitle C regulations, it became clear
that additional wastes would enter the control universe
by virtue of their characteristics when compared to the
characteristics of hazardous wastes developed under
Subpart A. For some of these wastes, the Agency has very
little information with respect to composition and
characteristics, the degree of hazard posed by the wastes,
the effectiveness of current or potential waste management
technologies, and the technical and economic practicability
of imposing the Subpart D standards on facilities managing
these wastes. The limited information that the Agency
does have, however, indicates that these wastes occur in
very large volumes, that they generally do not move far
from the point of generation, that the hazard levels
appear to be low and that they are not generally amenable
to the control techniques developed in Subpart D.
-------
3. Rationale for Designating Wastes as Special
In the foregoing Section, the rationale for a "special
waste category was presented. In this section, the
i
rationale for designating specific wastes as special" is
discussed. The Agency chose to designate wastes as
"special" based on the following criteria:
1. Lack of information on waste characteristics
0-f
2. Lack of information on the degreeienviron-
mental hazard posed by disposal
3. Lack of information on waste disposal practices
and alternatives
4. Very large volumes and/or large numbers of
facilities
5. Limited movement of wastes from point of
generation
6. Few, if any, documented damage cases
7. Apparent technological difficulty in applying
current Subpart D regulations to the waste
8. Potential high economic impact if current
Subpart D regulations are imposed
By and large, criteria (1), (2), and (3) are the
driving force in the decision - making process, although
the other conditions are met to some degree in each case.
-------
4 . Identification of^ Regulatory Options
Options available to the Agency for dealing with
these wastes when they are hazardous include:
1. Apply all Subpart D regulations to special waste
facilities in the same manner as other facilities.
2. Apply only procedural regulations such as manifest
and reporting requirements monitoring regulations,
access control requirements, and in a few cases, some
tailored control regulations designed to minimize
specific hazards.
3. Exempt special waste facilities from Subpart D
regulation until more information can be gathered.
5. Analysis of Regulatory Options and Identification of
Chosen Regulatory Option
Option 1 has the advantage that all hazardous wastes
are subject to the regulation; thus removing the need for
EPA to defend why certain wastes are singled out for
special treatment when inadequate management of them
might pose a hazard to human health and the environment.
On the other hand, due to a lack of information, the
Agency is unable to adequately assess the hazards posed,
or the technological or economic practicability of imposing
the Subpart D regulations By implementing Option 1 now,
the Agency could be imposing substantial economic burden
on the economy for little or no net environmental benefit.
Thus, option 1 was rejected.
-------
Option 3 eliminates the potentially high economic
impact and allows time to investigate the hazards posed
and to tailor any necessary regulations. It does not,
however, provide a mechanism to gather information on
movement, volumes, potential damages, and so on. Further,
there are no regulations at all to provide basic protection,
such as access control.
Thus, Option 2 was chosen by the Agency. The limited
regulations were chosen for inclusion based on the following
criteria:
1. Provides protection from known or strongly
suspected hazards
2. Limits direct access to the wastes
3. Causes data to be gathered and reported on
volumes, characteristics, movement, and extent of
environmental hazard posed by current management
practices, i.e., monitoring data
4. Does not impose costly technical and financial
requirements until further information on their
necessity and practicality can be gathered.
These limited regulations will be implemented by
rule, i.e. .eligible facilities complying with the regulations
will be considered as having a permit under Subpart E
(permit regulations). Additionally, eligible facilities
must comply with the notification requirements of Section
3010 and Subpart G.
-------
Only facilities or processes within facilities which
handle the "special" waste only, are eligible for this
status. For example, land disposal operations which mix
"special wastes" with other hazardous wastes, will not be
eligible.
6. Rationale for the Application of Specific Subpart D
Regulations to Special Waste
This section will discuss which of the Subpart D
regulations are incumbent on special waste facilities, to
what extent, and why. The other regulations were not
included because they were not thought to be necessary to
carry out the limited control program previouwly discussed
It is not practical to discuss each of the Subpart D
regulations here, so only those chosen are included.
Most of the regulations are similar for each of the
"special" wastes. There are, however, some requirements
which are applicable only to one waste. These are pointed
out in the next section.
-------
General Facility Standards. Special wastes are generally
exempt from the general facility standards (250.43),
except those dealing with waste characterization samples.
The other general facility standards concern treatment,
storage, and disposal, which impose high impacts and
which are not necessary for data gathering purpose or to
control access. However, the waste sampling requirements
are necessary because waste characterization information
is essential to devising substantive standards.
General Site Selection (apply to new sources only)
The general site selection standards provide basic
prohibitions on siting of facilities in areas where the
facility could readily harm the environment or the environment
could readily harm the facility. Thus, they constitute a
very basic level of protection and the Agency believes
they should be observed in locating new facilities.
These standards will not be imposed on existing facilities
for the present due to the impracticability of relocating
existing wastes.
Security. Fences, signs and controlled access are the
requirements for security. Such standards provide a
basic protection by limiting unauthorized and unknowing
access to the wastes. Economic impacts of instituting
these controls are not prohibitive even for the large
volume wastes.
-------
Manifest System, Recordkeeping, and Reporting. The
purpose of the manifest system is to safeguard the transporta-
tion of wastes from one location to another, usually from
the jurisdiction of one company to another. Most special
wastes are disposed on site, due to the volumes involved.
In cases where there is insufficient land on site, or the
site is located in a wetland or a floodplain, the waste
is transported nearby to a facility owned by the generator
or by a contractor acting as an agent of the generator.
The waste is transported either by pipeline or by truck
to a site which is usually less than ten miles away.
However, where the waste is treated or disposed off site,
the manifest system is a toll which provides basic assurance
II
-------
that the waste leaves the generator and arrives at the
disposal site. The cost is minimal, thus, manifests will
be required for hazardous special wastes shipped off
site.
The recordkeeping requirements include keeping track
of the waste, its location, analyses of the waste, monitoring
data, visual inspections, closure requirements, and
operating information. As discussed elsewhere, special
wastes are to be exempt from contingency plan and training
requirements and, therefore, the recordkeeping requirements
related to these activities are not necessary. The other
records are necessary for reporting purposes.
The reporting requirements include potentially damaging
incidents, problems with monitoring systems, monitoring
data, and notice of closure. Also included is an annual
report covering volumes, sources and types of waste
received, and methods of disposal and treatment. While
there are unlikely to be any potentially damaging incidents
in special waste facilities, the occurrence of any such
incidents would be cause for concern and should be reported.
Because special wastes which are classified as hazardous
are likely to fail the toxicity standard, it is important
that monitoring data be provided and that problems with
the monitoring system be corrected. Also, if the waste
is classified as hazardous, care will need to be taken
regarding closure of the facility.
-------
Information of this type is essential if the Agency
is to prepare substantive regulations to cover these
wastes. Thus, all of the reporting requirements will be
mandatory for special wastes.
VjLsual Inspections. The visual inspection Section requires
daily inspection and recording of the physical condition
of the facility. Visual inspections are a low cost way
of providing general oversight of operations for any kind
of facility and are often incorporated as a good operating
practice. They can also be used to provide an early
warning of possible public health and environmental
problems. The Agency believes all facilities should
carry our such inspections.
Closure and Post Closure. The Agency has little information
on useful closure procedures for "special" waste facilities
and thus has decided to defer the technical standards for
implementing closure. To gather information on possible
environmental problems, however, the Agency will require
special waste facilities to comply with the post closure
monitoring requirements.
13
-------
Groundwater and Leachate Monitoring. As previously discussed,
gathering of information for future development of re-
gulations is a primary function of the limited special
waste regulations. Information on groundwater pollution is
absolutely essential to that task and thus the groundwater
monitoring regulations mus be observed by special waste
facilities. Most special waste facilities on the other
hand have not been designed to permit leachate monitoring
and thus these requirements have been deferred.
Groundwater monitoring data is required to be taken no
more frequently than quarterly, depending on the size of
the site, so the retention of four data sets per year does
not appear overly burden some and yet is expected to
provide necessary data for regulation preparation.
However, in the case of gas and oil drilling muds and
oil production brines, EPA does not feel that the imposition
of groundwater monitoring requirements would be appropriate.
7. Rational for the Application of Additional Subpart D
Regulations to Some Special Waste
In addition to the above standards and associated
rationales, which apply to all special wastes, there are
other standards which are being applied to phosphate
mining, beneficiation, and processing waste; and uranium
mining waste. These additional requirements and associated
rationales are presented below.
-------
(1) Location of waste deposits shall be recorded on
reference maps which shall be maintained through
the operating and post-closure periods.
Rationale
EPA requires that the disposal locations of hazardous
waste be known through this recordkeeping requirement
to assist in the evaluation of and response to any
environment or health-threatening situations which
might arise subsequent to disposal.
In the special case of wastes involving very high
annual volumes handled and having relatively uniform
chemical composition, such as overburden, phosphatic
clays (slimes), waste rock, tailings and gypsum, the
Agency believes that such waste locations after disposal
can best be identified in relation to operation and
reclamation plans and maps established as a matter of
normal mining and processing activities at the site.
Retention of such records beyond the period of
active operations is needed, in addition, to allow the
permitting officials to judge the adequacy of closure
plans as regards land use.
(2) Land reclaimed by filling with these special
wastes shall be used for residential development
only where provisions have been made to prevent
alpha radiation exposure from Radon 222
-------
inhalation from exceeding background levels by
0.03 Working Level Units and gamma radiation from
exceeding background levels by 5 micro-Roentgens/hour.
The possible need for special constriction methods for
structures on such reclaimed land shall be identified
to any future land owner(s) by recording a stipulation in
the deed of the reclaimed land.
Rationale
Mining and other activities which displace or disturb
naturally occuring deposits of Radium 226 may present
increased potential hazard to health due to a resulting
increased concentration of Radium 226 or removal of
shielding overburden.
Unnecessary distribution of Radium 226 in the
form of products, by-products and wastes containing
Radium may also occur. Known areas of concern
include the use of mineral area, mined areas, and waste disposal
piles for residential development or for other uses
where prolonged human exposure might result in a
statistical increase in the risk of cancer.
While not all areas of concern may be addressed
directly by these regulations, some avoidance of
undesirable adverse effects from the disturbances
to radium bearing formations is possible though a
performance standard incorporating the level of
protection needed.
-------
For existing structures on phosphate related mineral
lands in Florida, the EPA's Office of Radiation Programs
has drafted guidelines, which, although subject to change
upon final adoption, provide the conceptual background
for minimizing human exposure to artificially increased
radiation from the radioactive decomposition of Radon gas
associated with the natural occurrence of Radium 226.
The Agency has therefore incorporated the level of
protection at 0.03 Working Level Units above background.
The level of 0.03 is, however, at the threshold of
statistically significant incresed health effects and may
be too high for this purpose. Comments received indicate
that a level of 0.02 Working Level Units including back-
ground may more protective of human health. Additional
comments on this subject are requested.
Research studies sponsored by EPA's Office of
Radiation Programs indicate that special construction
methods for buildings will lead to decreased trapping of
Radon, and are to be recommended for residential develop-
ment on mineral-related land in Florida. It seems
reasonable, in the presence of uncertainties in the
predictive relationship of radium 226 levels in soil
tf
-------
to the exposure of humans to Radon in buildings, not
yet constructed on reclaimed land, to alert future land
owners of the possible risk by identifying the need for
special construction methods in some instances by a
stipulation to the deed of the reclaimed land .
Where no measurement of Radon levels inside structures
is possible, a more useful measure of potential exposure
may be through a direct measurement of Radium levels in
the soil in terms of picocuries per gram.
However, under Subpart D, performance standards
for the management of these special wastes as are
determined hazardous under Subpart A shall be established.
Ongoing studies within EPA have not yet addressed
management of the special wastes in sufficient detail.
These proposed regulations make use as a measure
of human exposure the level of gamma radiation at 5
micro-Roentgens/hour above background. Support for
such a choice is based upon the figure of 6 R/hr. for
gamma exposure to be normal background for unmineralized
regions within Central Florida (as determined by EPA).
To allow for radiation level raiation in different
mining areas, a level of one-fourth the hourly extrapolation
(from the safe level of 170 millirems/yr.) above background
was chosen.
-------
(3) Building products manufactured from hazardous
special waste shall not be used if the products cause
alpha radiation exposure from Radon 222 inhalation to
exceed background levels by 0.03 Working Level Units,
or gamma radiation to exceed background levels by 5
micro-Roentgens per hour. Purchasers of waste and of
products manufactured from waste shall be advised of
this requirement by the seller.
Rationale
The use of building products manufactured from
radium containing waste, such as phosphate slag, may
contribute to an entirely unnecessary health risk.
Performance levels chosen are based upon general
health risk estimates, as described above for residential
development, but may need specific evaluation based
upon the proposed use.
The requirement placed by the Agency upon the
seller is a reasonable one in view of past incidents
involving the use of radioactive tailings as fill.
(4) Analysis required under Section 250.43-8(c) (5)
shall also include determination of Radium concentra-
tion .in picocuries/gram.
Rationale
Analysis for radium concentration of the waste in
-------
pico cur ies /gram should be related to the radium level
in picocuries per liter of any groundwater or leachatc
sample analyzed since the radium is a major constitutent
of the waste.
(5) In the case of phosphate rock mining, benef iciation ,
and processing waste, analysis required under Section
i
250.43-8(c) (6) shall also include the following:
(i) Radium, picocuries /gram
(ii) Phosphate, mg/liter
(iii) Fluoride, mg/liter
mlfi
Selection of the parameters Radium, Phosphate and
Fluoride in the comprehensive analysis of any groundwater
or leachate sample was based upon the fact that these
are expected major contaminants and should be related
back to the waste's chemical composition. These parameters
are also specified as being of concern in monitoring
under the NPDES permit program. Methods of analysis
for these parameters are available.
(6) In the case of uranium mining waste, analysis
required under Section 250 . 43-8 ( c) (6) shall also include
the following:
(i) Radium, picocuries /gram
(ii) Thorium, picocuries/ gram
(iii) Processing reagents, mg/gr.
(iv) Molybdenum, mg/gr.
-------
Rationale
Choice of these parameters for analysis under
the groundwater and leachate comprehensive analysis
is based upon the fact that they are likely to be
major characteristic pollutant parameters in the waste.
Thorium and nolybdenum are often associated with uranium
deposits and should be determined in the background
determination both because they themselves are toxic
ions and because they may be increased in concentration
by mining activities.
Environmental concerns for processing reagents
present in leachate above the 5 ppm level support
the inclusion of processing reagents specific to the
site in the analysis. The presence of such reagents
in samples may allow a cleaner separation of natural
background from man-caused contamination.
(7) In the case of uranium mining waste, as part of
closure of disposal facilities, the site shall be
reclaimed so as to support plant life indigenous to
the surrounding area and shall be revegetated with
such plant life.
NOTE: Other plant life may be substituted if
the substitute species provide an equivalent
degree of stability to the soil.
'21
-------
Rationale
To parallel the closure requirements imposed on
landfills under Section 250.43-7, a cover requirement
is established for the larger areas disturbed during
waste disposal operations in mining. It is expected
that this requirement shall present little or no
additional burden in view of existing State and local
laws for reclamation of mining sites.
The note also highlights EPA recognition of local
variations, while stressing the special need for site
stability due to the possibility of flood or injury
from collapse or movement of waste disposal piles.
8. Wastes Which Were Considered, But Were Not Selected
for Designation as Special Wastes
Dredge Spoils^
Certain dredge spoils may be hazardous if the source
is a water body near a heavy concentration of industry.
Also, in future, dredging may be undertaken simply
to remove a pollutant rather than for navigational purposes
For example, dredging of the James river to remove
Kepone and of the Hudson River to remove PCB*s have
been proposed. The Agency has concluded, however, that
the volumes of dredge spoil likely to be hazardous
from navigational dredging is small and that dredging
for pollution control purposes will produce sludges
which must be controlled to prevent secondary pollution.
ML
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Therefore, dredge spoils have not been granted "special"
status.
Sewage Sludge
Sewage sludge has also been considered as a "special"
waste when hazardous. It occurs in fairly large quantities,
is generally of a relative low hazard level when hazardous
at all, and it would create an economic burden if
Subpart D controls were imposed. On the other hand,
the Agency knows quite a lot about the characteristics
of and hazards posed by sewage sludge. Thus, the
Agency has detemined that substantive regulations can
be written now to control sewage sludge disposal.
However, since the normal sludge source, publicly owned
treatment works (POTW's), is already heavily regulated
under the Clean Water Act (CWA), the Agency has decided
to regulate sludge disposal under the same Act (Section
405 CWA). By design, regulations prepared under Section
405 will provide an equivalent degree of control for
hazardous sewage sludges as would be afforded by the
Subpart D regulations.
9. EPA Studies on the Establishment of Substantive
Requirements for the Designated Special Wastes
The agency is commencing studies of the designated
special wastes with the goalof proposing substantive
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requirements, where warranted, in the future. This
work will be done partially by EPA and partially by
contact. The following information will be gathered:
0 waste characteristics and degree of hazard
0 quantities generated and transportation patterns
0 methods of treatment and disposal used and
environmental acceptability
0 alternative methods of treatment and disposal
and environmental acceptability
0 cost of alternative methods
0 possible alternative regulatory approaches
0 economic and environmental impact analyses
of the regulatory alternatives
The limited requirements imposed by the current
regulations will assist in the gathering to information
as will the publication of an Advance Notice of Proposed
Rulemaking (ANPR), which will solicit data and comment.
It is possible that not all of the above study phases
will be necessary, since we may find some wastes to be
non-hazardous.
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BD-32
DRAFT
BACKGROUND DOCUMENT
RESOURCE CONSERVATION AND RECOVERY ACT
SUBTITLE C - HAZARDOUS WASTE MANAGEMENT
REGULATORY ANALYSIS
DECEMBER 15, 1978
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLID WASTE
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This document provides background information and
support for regulations which, have been drafted pursuant to
Subtitle C of the Resource Conservation and Recovery Act of
1976. It is being made available as a draft to support the
proposed regulations. As new information is obtained,
changes may be made in the background information and used
as support for the regulations when promulgated.
This document was first drafted many months ago and has
been revised to reflect information received and Agency
decisions made since then. EPA made some changes in the
proposed regulations shortly before their publication in the
Federal Register. We have tried to ensure that all of those
decisions are reflected in this document.
Comments in writing may be made to:
Michael J. Shannon
Hazardous Waste Management Division (WH-565)
Office of Solid Waste
U.S. Environmental Protection Agency
Washington, D.C. 20460
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Re gulato ry An aly s i s
1. Statement of the Problem
EPA has compiled over 400 case studies of the harmful
consequences of inadequate hazardous waste management.
These cases include incidences of surface and groundwater
contamination, direct contact poisoning, various forms of
air pollution and damage from fires and explosions. Nationwide,
half of all drinking water is supplied from groundwater
sources and in some areas contamination of groundwater
resources currently poses a threat to public health. EPA
studies of a number of generating industries in 1975 showed
a total of 90% of the potentially hazardous wastes generated
by those industries to be managed by practices which were
not adequate for protection of human health and the environment.
Subtitle C of the Solid Waste Act as amended by the
Resource Conservation and Recovery Act of 1976 (RCRA),
creates a regulatory framework to control.hazardous wastes.
The proposed rules are part of a series of seven required to
implement the hazardous waste management program.
This Subtitle is designed to regulate hazardous waste
management using a pathways approach. This approach regulates
the path and destination of any waste found to be hazardous
without particular attention to the source. This approach
is basically different from that used to regulate air and
water pollution where sources are more easily identified and
where specific standards can be written and adjusted to each
industry.
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Subtitle C requires that standards be established for
generators, transporters and facilities which treat, store or
dispose of hazardous wastes. The link that will make these
separate standards a system of hazardous waste control is the
manifest system that is required. The manifest system will
make possible tracking of individual waste loads from the
generator to the ultimate destination of the hazardous waste.
It is EPA's responsibility under this Subtitle to develop
through these standards and the manifest system an overall,
national system of hazardous waste control. This system is
intended by Congress to be implemented through the States where
possible. For this purpose, EPA must develop guidelines
for judging the equivalency of State programs to Federally
written standards and for allocating grant funds to eligible
State programs. Implementation of the hazardous waste program
through the States can increase the effectiveness of limited
Federal resources and thereby better protect public health
and the environment.
Any regulatory program as large and new as the hazardous
waste program.can be expected to require many adjustments on
the part of the regulated community. In particular, the
requirement that generators of hazardous waste must manage
their wastes in an environmentally, sound manner will create
large new demand for adequate hazardous waste management
capacity. EPA must take into account the need for more
hazardous waste management capacity as it develops this regulatory
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program because public health and the environment will not
be well protected if one of the real results of the program
is to shut down most of the facilities currently available.
However, the interim status period is reviewed as a buffer
for capacity creation in the program start-up period.
In summary, the purpose of the regulations under Subtitle
C has been to develop an overall, national hazardous waste
control program to protect public health and the environment.
This program is to be implemented through the States where
possible and has to be responsive to the indirect, interactive
effects of regulation on an interrelated network of generators,
transporters and hazardous waste facilities.
2. Description and Selection of Alternatives
General
The Subtitle C regulations are intended to present a
comprehensive hazardous waste control program and as such
there are some issues relating to all sections of the Subtitle
and some alternatives possible for the program as a whole.
There are other issues and alternatives which are relevant
to individual sections of the program such as to generator
or facility standards only. As far as possible, alternatives
will be described under the section in which they are most
relevant. However, two broad issues relevant.to the entire
program will be described in this section. Theyiare: (1)
provision of general standards vs, standards that are specific
to an industry; and (2) phasing of the Subtitle C program.
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To date, environmental regulation has generally been
written on an industry-specific basis. RCRA requires that
standards be written for generators, transporters, treaters,
storers and disposers of hazardous waste, with no specific
direction provided that would vary those standards by type
of generator. The development of industry-specific standards
was nevertheless considered in the design of the Subtitle C
program.
In the course of this consideration, it wa,s determined
that most wastes classified as hazardous would entail similar
management. This would be true not only for the financial
and administrative requirements of the program, but also
with respect to performance, design and operating standards
for treatment, storage and disposal facilities. However, it
was also determined that some wastes could be handled with
differing facility design and operating standards or differing
administrative requirements, and still
meet environmental and public health standards.
Further, there were some wastes for which insufficient data
were available to determine appropriate management techniques.
The proposed rules thus allow for the following: (1) general
standards applicable to all wastes for transportation, treatment,
storage and disposal; (2) specific provisions in the treatment,
storage and disposal regulations for different or less stringent
design and operating standards to be used by permit writers
in the preparation of permits for specific waste types and
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facilities as long as the overall health and environmental
standards are met; (3) deferral of applicability of the
•treatment, storage and disposal standards for selected waste
categories until information is gathered and assessed to
determine how they can best be handled (i.e., raining waste,
utility waste/ dredge spoils, oil drilling brines and muds,
gypsum piles, cement kiln dusts and uranium mill tailings);
and (4) specific provisions for generators of small quantities
of hazardous waste, most retailers and farmers.
Although there is no explicit authority in the Act for
phasing of the regulations, phasing was considered as a
possible alternative during development of the program. One
method of phasing would be to use a classification of degree
of hazard to regulate the most hazardous wastes first and to
gradually include less hazardous wastes* However, it was
determined that degree of hazard is a function of the state
of the waste in its management cycle as well as of the
intrinsic properties of the waste, and that it is mismanagement
of the waste which presents the greater problem. Priority
action on permit applications could more accurately reflect
the phasing that would be desirable rather than a classification
of waste type regardless of disposal method.
Phasing could also be done by industry grouping or SIC
code grouping, or by including the largest generators first
and gradually including the smallest using successively
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smaller wastestream size definitions of a generator. However,
any possible phasing of regulatory authority would have
precluded control over large quantities of hazardous waste
for significant periods of time. Further, no phasing of
regulatory authority was permitted by the Act.
Hazardous Waste Definition
Section 3001 provides a means for determining whether a
waste is hazardous for the purposes of the Act, and, therefore,
whether it must be managed according to the other Subtitle C
regulations. Section 3001 (b) provides two mechanisms for
determining whether a waste is hazardous: a set of characteristics
of wastes and a list of particular hazardous wastes.
Specific criteria were used both for selecting particular
characteristics and for listing particular wastes. Three
criteria were then used for refining this candidate set of
characteristics: that the characteristic could provide a
general description of the property or attribute rather than
appearing merely as a list of sources; that the likelihood
of a hazard developing if the waste were mismanaged is
sufficiently great; and that a reliable identification or
test method for the presence of the characteristic is available.
Use of this last criterion has lead EPA to describe each
'characteristic by specific testing protocols, including
interpretation instructions. Where this was not possible,
(e.g., reactivity) the characteristic is set out as a description
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readily recognizable by persons working in the field (e.g.,
"readily capable of detonation at normal temperatures and
pressures") together with a test protocol available in cases
of uncertainty.
Under these criteria, several groups of characteristics
were developed. These groups are:
a. Ignitability, Corrosivity, Reactivity
b. Limited Toxicity (EP* with 10X SDWA Primary
Drinking Water Standards)
c. Radioactivity and infectiousness
d. EP* with standards for organics
e. Genetic, aquatic, and phytotoxic bioassays
For each of the groups of characteristics above, a
number of alternatives were-considered. EPA could have:
adopted the group of characteristics as a means of identifying
hazardous waste; used the group of characteristics in developing
lists of hazardous wastes; or deferred adoption of the
characteristic pending further study. Adopting a group of
characteristics as a means of identifying wastes causes
generators of waste with such characteristics to be responsible
for making the determination of hazard. Many generators
would find it prudent to test to determine the exact character
of his waste unless he accepted its hazardousness and complied
accordingly. For this reason it is important to consider
the burden such testing could place on generators.
*The Extraction Procedure (EP) is a laboratory
procedure developed by EPA to estimate the potential mobility
of a waste in an uncontrolled landfill or open dump environment.
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Making a group of characteristics part of EPA's listing
effort would remove much of the testing burden from generators.
Not all of the testing burden would be shifted off Lo the
generators on to EPA however. A procedure would be necessary
for showing that a particular waste was not hazardous,
despite being listed by EPA. This procedure would be available
to generators seeking to avoid coverage by the regulations
and would require some testing.
A decision to study a group of characteristics further
would result in more information becoming available to EPA
on which to decide the efficacy of testing methods and of
hazard levels. Based on information received, EPA could
either include the group of characteristics as a means of
identifying hazardous wastes or work to improve the efficacy
of the testing methods.
Only the first two groups of characteristics Ci-e.. i
ignitable, corrosive, reactive and limited toxicity) have
been chosen as waste identification characteristics. These
characteristics are relatively simple, the tests are well
developed and recognized by the scientific community, inexpensive
to test, and they cover a large proportion of the total
amount of hazardous waste EPA believes should be controlled.
Generators will not be required to know the characteristics
of wastes outside the characteristics in these two groups
for purposes of determining if the wastes are hazardous.
However, it was also decided that hazardous wastes could be
It)
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listed due to characteristics in any of the groups including
the characteristics of infectiousness and radioactivity.
Retaining the power to list wastes deemed hazardous in the
Administrator's judgement, regardless of which characteristics
they might have, was necessary to maintain control over
those wastes which, through experience, were known to be
hazardous but for which no efficacious testing procedure
could be devised.
The last two groups of characteristics (i.e., EP with
standards for organics and genetic, aquatic and phytotoxic
bioassays) have been included in an ANPRM. to obtain more
information to improve EPA's understanding of the efficacy
of testing for these characteristics. At the present time,
EPA does not believe these areas of testing to be sufficiently
developed to permit large-scale, reliable testing of wastes.
Generators
Section 3002 of RCRA requires EPA to set standards for
generators of hazardous waste. Four major issues were
considered in deciding what constitutes a generator under
this section. The first is what lower limit on the amount
of hazardous waste produced should be included in the definition
of a generator. The second and third concern whether to
include retail establishments and farmers as generators and
what type of special provision might be necessary if they
are included. Last, the frequency and type of reporting
requirements to place on generators were also considered.
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There are several reasons for setting a lower limit on
the definition of a generator. While there is some evidence
of damage due to small quantities of hazardous waste, most
damage cases studied by EPA involved large quantities.
Further, there is substantial evidence that co-disposal of
small quantities of hazardous waste with municipal solid
waste is in most respects as environmentally acceptable as
disposal of such quantities at a hazardous waste facility.
Exclusion from the regulations of very small hazardous v/aste
producers would eliminate the paperwork burdens of manifests/
reporting and recordkeeping on hundreds of thousands of
insignificant producers. An exclusion would also free
limited EPA and State resources to deal more effectively
with larger generators which EPA studies have shown to
produce a preponderant majority of the total amount of
hazardous waste generated.
In considering excluding small generators from S3002
requirements, it was found that low quantity generators were
affected most greatly (administrative cost per unit) by the
section. The determination was made to establish an exclusion
to reduce this burden. The cutoff for the exclusion presented
the problem of balancing environmental benefit and economic
cost. Several cutoff levels were considered: 27 Ibs., 100
kgs., 250 kgs.,, and 1000 kgs. For 100 kgs., between 50 and
60 percent of the manufacturing generators (SIC 20-39) would
be excluded where 99.5% of the waste would still be covered.
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For 1000 kgs., the exclusion rate would be increased to 85%,
and the waste covered would be reduced to between 92% and
93%. In light of these figures, a cutoff lower than 100
Kgs. appears unnecessary because environmental protection
seems adequate where only one-half of one percent of the
waste is out of the system.
Perhaps a more important factor for determining where
to set the cutoff level is the co-disposal issue. EPA has
determined that the ratio of non-hazardous waste to hazardous
waste in a sanitary landfill (Subtitle D of RCRA) carries
significant impact at 1:1 to 3:1. If one assumes that all
excluded generators produce the maximum (100 kg./month), the
ratio of that waste when disposed in a sanitary landfill
would have a ratio of 25:1 or 30:1. If the cutoff is 1000
kg./month, the ratio will be 3:1 or 4:1. The latter approaches
the dangerous level defined by the Agency. One final determinan
is the number of damage incidents of the excluded hazardous
waste at non-hazardous waste facilities. It has been found
that 5% of damage cases involved waste amounts under 100
kg*, but 25% involved 1000 kg. or less. As a result of the
data for these three criteria, the Agency has chosen the 100
kg. per month figure as the cutoff. Both the benefit to the
generators and the remaining environmental protection was
deemed adequate at that level.
Likewise, four alternatives for retail establishments
were considered: (1) no special provisions; (2} no reporting
requirements for retail generators and special notification
13
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arrangements for gas stations; (3) exemption of generators
having contracts with voluntarily licensed haulers; and (4)
defer coverage under Subtitle C and study. Due to the very
high numbers of retail establishments and the small quantities
of hazardous waste produced by these establishments, EPA
decided not to require reporting by retail generators except
for waste oil generation (including gas stations) over which
special controls are necessary to mitigate the burden
this entails, special arrangements will be possible to allow
gas stations and other waste oil generators to notify EPA or
an authorized State of their, generator status through a
major oil company or State independent retailers association.
This will allow large numbers of almost identical generators
to notify at less cost than would be possible if they notified
individually. It was further decided that any waste oil generator
having a contract that would transfer responsibility to a
voluntarily licensed hauler or facility owner/operator would
not be a generator pursuant to Section 3002. This transfer
of liability will not reduce the effectiveness of the generator
standards because the necessary control will still exist. A
decision to transfer such responsibility significantly
reduces the administrative cost to a very small producer of
hazardous wastes.
With respect to including farmers as generators, the
three alternatives considered were: (.11 no special provisions;
(2) exclude farmers who have arrangements with their pesticide
suppliers which, are acceptable to EPA; and (3) exclude farmers
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due to control under FIFRA. EPA decided waste pesticides
and waste pesticide containers were the only significant
hazardous waste produced by farmers and those would be
better controlled under FIFRA than RCRA. .Farmers will not
be generators pursuant to Section 3002 of RCRA.
Section 3002(6) of the Act requires reports to EPA Cor
an authorized State) at such times as the Administrator
deems necessary. Three major alternatives were considered
for reporting. A quarterly summary of all wastes generated
was considered for each generator. Instead of quarterly
summaries a single annual summary was also considered along
with the additional requirement that manifests sent by but
not returned to a generator would be reported. The third
alternative requires the same annual summary; however,
manifest exceptions need only be reported quarterly.
EPA believes the annual summary with the quarterly
manifest exception reporting requirement provides adequate
information. More frequent reporting would be more costly
without providing sufficient additional information to
justify the cost. The generator reporting standard chosen
therefore requires all generators to provide annual summaries
of hazardous wastes handled and quarterly reports of unreturned
manifests.
Transporters
Section 3Q03 of the RCRA requires that EPA establish a
system which controls the transportation of hazardous waste.
Five of the following six major issues were resolved, and
the regulations were proposed on April 28, 1978. The primary
IS
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issue centered on the proper relationship between the EPA
requirements and the Department of Transportation's authority.
Other considerations included provisions for the complexity
of the manifest requirement, additional safety provisions, a
permit program for haulers, minimum insurance coverage for
spills, and reporting requirements in the event of a spill.
Major alternatives to each of these issues are discussed below.
It was determined that the role of DOT in the regulation
structure should be as great as possible. Transporters perceive
DOT as the regulatory authority, and their resources and
expertise in this area surpass EPA's. Therefore, independent
EPA regulations would not be a wise action. An
alternative would be to allow DOT regulations to remain unaltered.
Their program for the transportation of "hazardous material"
would cover the bulk of "hazardous waste" as defined in
Section 3001. This alternative is acceptable; yet, EPA could
also adopt DOT regulations, providing enforcement powers for
both agencies and extending the coverage of the regulations to
intrastate commerce. Another alternative would be to influence
DOT to make their regulations compatible with RCRA before EPA
adoption. In those instances where the agency finds DOT
authority lacking, EPA could write supplemental regulations.
Writing supplemental regulations would add flexibility, and
adoption of the DOT regulations would allow transportation
experts to handle the problems directly and would reduce
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confusion by being more efficient. In light of these considerations,
the Agency began by attempting to pursuade DOT to alter
their regulations and after all possible agreeable changes
were developed, EPA adopted them. EPA has only written
supplementary regulations in those instances where there is
no authority under DOT regulations.
With respect to manifest requirements, the Agency is
establishing a manifest requirement for transporters under
the "cradle-to-grave" system. The two options would be to
require a specific manifest which must accompany the waste
at all times or to allow flexibility where it can be shown
that a DOT shipping paper carries data equivalent to a
manifest. A rigid system would provide for close control
and the ability for tight enforcement. A flexible approach
would reduce the burden on the transporters (e.g., in a
railroad where a computer system has been established) but
would provide the same basic data. The Agency has chosen to
allow for an alternative delivery document where no manifest
is with the vehicle and equivalent information is carried.
The system will provide a similar degree of control and
information.
EPA was faced with an opportunity to provide for safety
provisions greater than those already adopted. If these
provisions were considered important, this could be accomplished
by referencing the DOT motor carrier safety regulations or
developing similar EPA regulations. It was determined that
n
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EPA does not have adequate capability to implement or enforce
the regulations, so no action was taken. Likewise, the
Agency weighed the establishment of a permit program for
haulers of hazardous waste. After the ICC ruled that wastes
are probably not within their authority, EPA determined that
no action would be taken on this issue.
An additional area of coverage would be the requirement
that transporters have adequate insurance in the event of a
spill. Such a regulation could be unnecessary because
coverage presently exists. However, the Agency determined
that due to information limitations, the issue merits
further consideration. The Agency chose to study the issue;
a report has been contracted and is due in December. If it
is determined that spill insurance should be an Agency
consideration, we will write regulations which should reduce
the burden on the municipalities who often bear the burden
of spill cleanup.
Lastly, EPA considered the issue of spill reporting
regulations. Taking no action would result in less regulation.
Making the transporter responsible for spill reporting would
provide for greater environmental protection and would
expand EPA's information base. Such regulations were written
because they were deemed a reasonable approach to the issue.
Facilities and Permits
Section 3005 of RCRA requires the establishment of a
permit program for hazardous waste facilities. Section 3004
requires standards on which the permits will be based. As
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will be discussed below, Section 3005 and the State delegation
program under Section 3006 are being integrated with proposals
for the NPDES and UIC program under Parts 122, 123, 124 and
128 of the Code of Federal Regulations. Therefore, the bulk
of this discussion will focus on alternatives considered
under Section 3004. Several major issues arise under the
sections of RCRA dealing with facilities standards and
permitting. Among these are the question of what type of
standards to write for facilities, several questions concerning
which facilities are subject to the standards, and the
question of a priority system and coordination for permitting
activities. Financial requirements will be discussed separately
in the next part of this analysis.
EPA considered these different ways to write standards
for facilities. The first way would set ambient standards
for air quality, water quality and for other relevant factors.
These standards would be set at levels known to be safe. It
is not always possible to know why a standard of this type
has been exceeded, that is, the source_of the pollutant is
difficult to determine, and consequently this type of standard
is difficult to enforce. Also, it is difficult to set safe
levels for the thousands of substances that might be found
in hazardous waste.
The second type of standard would prescribe limits on
hazardous waste management activities. This type of standard
can be enforced but would tend to hold technology stagnant
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along the prescribed limits. The third type of standard
would directly regulate pollutant releases from a given
source. Although new technology can be encouraged, such a
standard is generally limited because a hazardous waste
disposal site often discharges from several points and so
would be impossible to regulate as a, single, given source.
EPA has decided to combine the strengths of each of
those types of standards by using a mixed structure for the
facility standards. The approach selected defines human
health and environmental standards which will be the final
determinant of a particular facility's acceptability. In
addition to these human health and environmental standards
will be design and operating standards which provide measurable
criteria. If a facility is found to violate the human
health and envrionmental standards despite compliance with
the operating standards, a reasonable schedule will be
designed to bring the facility into compliance with both
standards. The operating standards will be used as the
primary enforcement tool. The health and environmental
standards will be used as an operating mechanism only when
deemed necessary by the enforcing authority.
The question of how to regulate inactive hazardous
waste management sites has been pivotal in the development
of the program. In general, EPA regulations will require
far more care at hazardous waste management facilities than
has been common in the past. To apply the same standards to
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inactive sites that will be applied to new and existing
sites would force large numbers of old or abandoned sites
into non-compliance. In addition to the technical and economic
problems encountered in any attempt to enforce new standards
on inactive sites, the legal question of expost facto lawmaking
is raised. Instead of either strictly applying the RCRA
regulations to inactive facilities or completely exempting
such facilities from coverage EPA has decided to use the
imminent hazard powers of Section 7003 to act in instances
were some threat to public health or the environment is
presented.
To integrate the Subtitle c facility standards a,nd
permitting activities with BAT Toxics/Pretreatment Standards
and NPDES permits several alternatives were considered.
Five categories of potential permittees were identified:
Off-site hazardous waste management facilities, facilities
subject to upcoming BAT Toxics/Pretreatment standards but
currently without NPDES permits, facilities with NPDES
permits and subject to upcoming BAT Toxics/Petreatment
standards, facilities not subject to BAT Toxics/Pretreatment
standards but currently possessing NPDES permits, and other
facilities.
For those categories subject to NPDES permit revision,
renewal or new permit issuance it would be possible to
conduct Subtitle C permit granting activities according to
NPDES schedules. These categories could also be made subject
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to Subtitle C recordkeeping, reporting, monitoring and
manifest requirements upon promulgation of these general
requirements and granted permits gradually according to
NPDES schedules.
Due to limited resources for permitting of hazardous
waste management facilities and the procedural constraints
on permit granting, a priority system for permitting was
necessary. Granting Subtitle C permits according to NPDES
schedules and priorities where possible could eliminate
duplicate contacts with permitting authorities. Facilities
seeking permits could present the necessary materials for
both hazardous waste and NPDES permits at the same time
although the permits could remain separate.
EPA decided the priorities for hazardous waste facilities
permitting will be in the same order as the categories
listed above. Off-site hazardous waste management facilities
will be the highest priority because it is expected that
large numbers of generators will choose off-site management
due to economies of scale rather than operate their own
permitted facilities. EPA also believes this approach is
necesssary to avoid delays in the creation of new off-site
hazardous waste management capacity which will be essential
to protect human health and the environment. The second
priority will be those facilities seeking NPDES permits for
the first time under the BAT Toxics/Pretreatment standards.
These facilities will soon be required to have similar EPA
2.1.
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permits and it would be wasteful to both the permitting
authorities and the permit seekers to prepare twice for
permits at a single facility. The third priority will be
those facilities with NPDES permits and soon subject to the
BAT Toxics/Pretreatment standards. These will be handled on
a basis similar to the second priority group but somewhat
later as their permits are revised through NPDES. The
fourth priority group will be those facilities with NPDES
permits but not subject to the unpcoming BAT Toxics/Pretreatment
standards and they will be reviewed for Subtitle C permits
as their NPDES permits are renewed. The fifth priority
group will be all other facilities, those on-site but without
any current or prospective requirement for an NPDES permit.
During interim status (before a permit is issued but
following the notification required by Section 3010 and
application for a permit), it was determined that an abbreviated
set of design and operating standards would apply.
Financial requirements under the Act are required by
Section 3004(6) of the Act. This Section calls for requirements
respecting ownership/ continuity of operation and financial
responsibility for hazardous waste management facilities as
may be necessary or desirable. Four areas for financial
requirements were identified: assuring funds for site
closure, funds for post-closure site monitoring and maintenance,
site life liability, and post-closure liability and remedial
action. Requirements for post-closure monitoring and maintenance,
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and post-closure liability and remedial action, pertain only
to disposal facilities because no hazardous wastes will
remain at treatment or storage facilities after proper
closure. The major choices facing EPA for each of these
areas were whether to set requirements leading to private
arrangements; to seek additional legislative authority to
establish a government administered fund; or to defer and
conduct further studies before rulemaking.
Precedents are numerous for requiring a facility to set
aside sufficient funds to assure proper closure. Both
nuclear power plants and strip-mining operations are required
to set aside sufficient funds before operation to assure
site restoration. EPA decided a requirement to set aside
before operation the full amount necessary to close a site
was not burdensome, would in most cases guarantee adequate
closure and could be done through the private arrangement of
a trust fund.
Assuring funds for post-closure site monitoring and
maintenance would require a far greater commitment of resources
than assuring funds for closure. Monitoring and maintenance
at disposal facilities must be conducted for twenty years
post-closure in accordance with technical facility requirements
under Section 3004. Monitoring and routine maintenance are
predictable expenses and can be estimated even for a period
twenty years. A fund sufficient to pay for twenty years of
post-closure monitoring and maintenance would be on the
Z4-
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order of a few hundred thousand dollars depending on the
facility size. EPA has decided that creation of such a fund
for each disposal facility, with payments made into it
throughout the operating life of the facility, is necessary
to assure that the activities of monitoring and maintenance
will be carried out after closure. Expenditures for these
essential activities can be planned and will have to be paid
regardless of any requirement to establish a fund to pay
them. The requirement will only assure that the funds are
available before operations cease. This requirement also
can be fulfilled through the private arrangement of a trust
fund.
To assure adequate financial responsibility for liability
during site operation, EPA examined the several forms such
financial responsibility might take. EPA decided to accept
any evidence of financial responsibility (e.g., insurance,
mutual assessment organization or self-insurance with limits)
at the level set by EPA for all facilities. EPA is working
to assure availability of some form of financial responsibility
to all firms with environmentally acceptable facilities.
Financial responsibility for post-closure liability and
remedial action post-closure is more difficult to assure
than similar responsibility during site operation. Creation
of a fund sufficient to pay insurance premiums for any
significant period after closure of a disposal facility
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would result in a fund many times larger than that required
for post-closure monitoring and maintenance. Such insurance
premiums could be very difficult to predict and there is
strong evidence the required insurance would not be availalbe.
In light of such obstacles, EPA decided to reserve authority
to require post-closure financial responsibility for liability
and remedial action and for this one area of financial
requirements is investigating the possibility of a government
administered fund.
Noti fication
Section 3010 requires all generators, transporters, and
facility operators to notify the Administrator of their
hazardous waste management activities. The Agency was faced
with the option of whether or not to publish regulations
under this section. It was decided to publish regulations
in order to disseminate information to a wider group of
interested persons, to clarify specific requirements, and to
standardize data formats. These regulations have been
proposed in the Federal Register. Two issues arise out of
this decision to write regulations: the degree of flexibility
in notification reporting procedures and the level of confidential!
maintained by the Agency.
A stringent approach to the filing question would
require each place of operation to file a comprehensive,
mandatory notification form which must be submitted to a
central agency. Although such a system would provide a high
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degree of control, the Agency has adopted several provisions
for flexibility. Under the present policy/ each generator
need not file an application as long as a central firm
identifies each place of operation. Instead of a mandatory
form, minimum guidelines for filing will be offered with an
optional standard form available. Furthermore, no testing
is required to prove whether or not a waste is hazardous.
In addition, each applicant is allowed an additional ninety
days for the identification of toxic waste because of the
potential burden of the test (EP). The Agency believes
that these procedures will provide an adequate amount of
coverage at a reasonable level of cost. The option of
allowing the states to be notified in lieu of the Agency has
been rejected because of the questions surrounding the
legality of Limited Interim Authorization for states to
conduct notification activities before the effective date of
authorization under Section 3006(c).
Provisions for confidentiality would protect trade
secrets but would make it more difficult for th.e public to
obtain a clear identification of hazard levels. In order to
balance those concerns, EPA has established a confidentiality
procedure which puts the burden on the notifier to demonstrate
the need for confidentiality if the public request access to
data.
2-1
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3. Economic Consequences
General
The economic impacts of Subtitle C regulations were
analyzed for three major sets of alternatives consolidated
from the choices considered under Sections 3001, 3002, and
3004 of RCRA. Each alternative thus represents a "menu" of
provisions in a number of different regulations. Table 1
summarizes the variable parameters of each of the three
options that have been analyzed.
The analysis of these alternatives have been necessarily
qualitatively in many cases. For example, costs of compliance
have been quantified for those industry segments EPA believes
will be most affected by the regulations, but the effects of
these costs on prices, output, employment and plant closures
have been determined judgmentally. Increased generator
demand for hazardous waste management capacity was examined
quantitatively where possible for its effects on the overall
network of facilities supplying this capacity, and some
judgmental conclusions were reached regarding desirable
capacity levels.
The three options evaluated are described in the following
sections.
In effect, each major option is a, trade-off of varying
degrees of public health and environmental protection on the
one hand, and scope of program coverage and subsequent cost
on the other. Option C was considered far less protective
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Table 1
Hazardous Waste Regulatory Alternatives
3001 H.W. Identification
HTw. Characteristics
Option A
Ignitable
Corrosive
Reactive
Radioactive
Toxic
-»90
56,100,000
<100 kg/mo.
520,000
102,000
212,000
Yes
Qtrly.
3 yrs.
Yes
10,000
No. H.W. Listed ( .
Amt. H.W. Controlled (MT) * '
3002 H.W. Generators
Size Exemption
No. o_f Generators
Pesticide Users
Retailers
Transport .Manifest
Reporting Frequency
Records Retention
3003 H.W. Transporters
Emerg. Spill Reports
No. of Transporters
j004 Facility Standards
"Special Wastes Controlled
Dist. to Water Wells
LF Soil Permeability (cm/sec)
LF Volatiles Banned
Groundwater Mon/Reporting
Financial Requirements
Site Life Liability
Post-Closure Monitoring
Post-Closure Liability
No. of Disposers
Economic Impact
Annual Cost CO $1786H
No. of Product Lines 69
% Product. Valued 2% 24
0.5-2% 26
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of public health and the environment than was deemed desirable
while Option A was considered too costly and uncertain in
scope. To reduce overall uncertainty and cost and yet still
be protective of public health and the environment, Option B
is the option reflected in the proposed rules.
Option A
Option A is the most comprehensive set of provisions in
terms of public health and environmental protection. It
corresponds to the status of the regulations ca. spring
1978. In Option A, the greatest quantity of potentially
hazardous waste is controlled, with the definition keyed to
testing against all the characteristics considered, including
toxicity and radioactivity. The number of generators is
significantly larger than in Option B, and quarterly reporting
is required. Additionally, post-closure monitoring is
required for 40 years under Option A. Post-closure liability
insurance is also required.
The major categories of requirements and their corresponding
expected incremental costs arid cost ranges are, in millions
of dollars:
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Activity Annual Cost Low High
Technical Requirements $264 149 597
Financial Requirements 1060 511 1576
Recordkeeping/Reporting 41 39 77
Monitoring/Testing 261 170 516
Administration 97 96 187
Training 32 22 55
Contingency Planning 31 18 50
1,786 1005 3058
The costs presented above are only for the seventeen major
industry groupings studied by EPA as significant generators of
hazardous waste. These industry groupings are: textile mill
products, inorganic chemicals, organic chemicals (partial coverage),
pesticides, explosives, petroleum refining, rubber, leather
tanning and finishing, metals smelting and refining, electro-
plating and metal finishing (partial coverage), special machinery
manufacturing, electronics components, and batteries.
These seventeen industry groupings were divided into 69
industry segments of which 24 were projected to experience high
economic impact (compliance costs higher than 2% of annual sales).
Of these, ten industry segments were identified as likely to
experience some plant closures and job losses. They are:
Electroplating
Wool Fabric Dyeing and Finishing
Knit Fabric Dyeing and Finishing
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Mercury Cell Chlorine
Chlorobenzene
Leather Finishers
Mercury Smelting and Refining
Secondary Copper Smelting
Secondary Lead Smelting
Secondary Aluminum Smelting
The incremental economic impact of hazardous waste management
regulations on transporters in any option is expected to be
relatively insignificant due to current DOT regulations.
Option B
Option B is the result of a detailed program review and
options analyze which were conducted in the early summer of
1978. The degree of uncertainty in program scope and cost
is reduced from Option A by limiting use of hazardous waste
characteristics, and increased use of specific listings of
hazardous waste in the definition process. Actual program
scope and cost are reduced by exempting certain classes of
hazardous waste generators, limiting the reporting require-
ments, eliminating certain financial responsibility provisions,
and by reducing the requirements on certain high volume wastes
pending further analysis and evaluations.
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The major categories of requirements and corresponding
incremental costs and cost ranges under Option B for the 17
major industry groupings studies are (in millions of dollars):
Activity Annual Cost Low High
Technical Requirements $258 145 581
Financial Requirements 121 92 153
Recordkeeping/Reporting 14 13 26
Monitoring/Testing 104 68 206
Administration 70 69 135
Training 32 22 55
Contingency Planning 31 18 50
630 427 1206
The changes in reporting requirements lower expected annual
reporting costs from $41 million to $14 million. Changes in the
financial requirements lower the expected annual costs of those
requirements from $1060 million to $121 million. Together those
two changes result in expected cost reductions of $966 million.
Despite significant differences in costs between Option A
and B, it is expected that not much difference in impacts will be
experienced by the most impacted industry segments. Under Option
B eight industry segments (Option A segments excluding chloroben-
zene and knit fabric dyeing and finishing) can be considered
likely to experience some plant closures and job losses. However,
total costs are significantly reduced, as is the degree of
uncertainty on the regulated community.
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Option C
Option C is the least protective of public health and
the environment and the least costly of the options analyzed.
It aims to further reduce requirements on small hazardous
waste generators by raising the size of the exemption to
1000 kg. per month. In this option, storage up to 1 year does
not need a permit. In addition, there is no toxicity charac-
teristic in this option; site life liability insurance is
decreased from $5 million to $2 million; and post-closure
monitoring is required for only 10 years.
Activity Annual Cost Low High
Technical Requirements $249 139 562
Financial Requirements 65 56 76
Recordkeeping/Reporting 8 7 13
Monitoring/Testing 75 49 149
Administration 53 52 102
Training 26 18 45
Contingency Planning 24 15 40
$501 $336 $987
Other Studies and Results
EPA has studies in progress on several other industry
groupings in addition to the above mentioned seventeen. These
industry groupings include: electric services, service stations,
pulp and paper mills, soil preparations and crop services, certain
segments of the chemicals industry, metals and minerals except
petroleum and industry supplies. Each of these industry groupings
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has special circumstances which may require special considera-
tion once EPA completes its technical and economic studies.
As a result of work done in impacts of the regulations on
hazardous waste management capacity certain conclusions are
possible. An economic incentive will exist for a major shift
from on-site hazardous waste management to off-site hazardous
waste management due to economics of scale in larger facilities.
If sufficient capacity can be created off-site, incremental
compliance costs can be reduced. Without sufficient new off-
site capacity a serious shortfall of acceptable hazardous waste
management capacity is likely to occur in the short run. The
possibility of such a shortfall with its probable adverse environ-
mental consequences, has influenced EPA decisions regarding the
pace of implementation, and has resulted in a system of implemen-
tation priorities as described earlier. Additionally, the interim
status period can be viewed as a safety value for capacity
creation in the program start-up period.
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