Site Operations Plan Syosset Landfill, Prepared by Geraghty & Miller, Inc

Geraghty & Miller, Inc.

r SITE OPERATIONS PLAN SYOSSET LANDFILL

August 1986 H

Geraghty & Miller, Inc. Ground-Water Consultants 125 East Bethpage Road Plainview, New York 11803 (516) 249-7600

OPC114 Geraghty & Miller, Inc.

CONTENTS

Page

1. INTRODUCTION ...... 1 1.1 Purpose ...... 1 1.2 Format ...... 1 1.3 Project Team ...... 2

2. SAMPLING PLAN 2.1 Data Verification, Data Base Establishment and Aerial Photograph Study ...... 3 2.2 On-Site Ground-Water Study ...... 4 2.2.1 Drilling ...... 5 2.2.2 Soil Sampling for Laboratory Analysis ..... 6 2.2.3 Well Installation ...... 6 2.2.4 Well Development ...... 7 2.2.5 Geophysical Logging ...... 8 2.2.6 Water Quality Monitoring ... 8

2.3 Landfill Dimension Study ...... 11

2.3.1 Installation of Borings .... 12 2.3.2 Collection of Soil/Waste Samples ...... 14 2.3.3 Well Installation ...... 16 2.3.4 Well Development ...... 17 2.3.5 Water Quality Monitoring .... 17

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Page 2.4 Off-Site Ground-Water Study ...... 18

2.4.1 Work Plan ...... 18 2.4.2 Operations Plan ...... 19 2.4.3 Integration of the Data collected during the Off-Site & On-Site Ground-water . Investigations ...... 19 ' 2.5 Subsurface Gas Study ...... 20

I'I ' 2.5.1 Construction of Gas Monitoring Wells ...... 20 ^ 2.5.2 On-Site Study ...... 21 fn 2.5.3 Off-Site Study ...... 24 0 3. QUALITY ASSURANCE/QUALITY CONTROL PLAN ... 24 4. HEALTH & SAFETY PLAN ...... 35 P 4.1 Introduction ...... 35 I 4.2 Management ...... 36 4.3 Hazard Evaluation ...... 36 ,1 4.4 Air Monitoring ...... 39 rT 4.5 Personal Protective Equipment .... 41 4.6 Facilities ...... 42 4.7 Decontamination ...... 43 4.8 Training ...... 44 4.9 Health Monitoring ...... 45 4.10 Emergency Procedures ...... 47

5. FEASIBILITY STUDY ...... 48

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Page 6. DELIVERABLES AND SCHEDULE ...... 50

6.1 Deliverables ...... 50 6.2 Schedules ...... 52

REFERENCES ...... 54

TABLES

3.1 Inventory of Safety Equipment to be Kept On Site

FIGURES

1.1 Syosset Landfill - RI/FS Team 2.1 Site Location Map 2.2 Proposed Monitoring Well Locations 2.3 Construction Details of the Monitoring Wells 2.4 Proposed Landfill Boring Locations 2.5 Construction of Wells Placed in Landfill Borings 2.6 Typical Gas Monitoring Well 2.7 Proposed Gas Monitoring Well Locations 2.8 Gas Monitoring Well Sampling Apparatus 3.1 Data Review and Management Process 4.1 Schematic of Decontamination Facility 6.1 Syosset Landfill Remedial Investigation Schedule C.I Typical Completion for Wells Equipped with Submersible Pumps C.2 Sample/Discharge Fitting and Flow-through Cell oaou? Geraghty & Miller, Inc.

APPENDICES

A. Example Data Tables B. Protocol for Screening Soil Samples for vocs C. Protocol for Sampling Ground Water by Sub- mersible Pump D. Protocol for Sampling Ground Water with a Bailer E. Analytical Parameters F. Protocol for Soil Sampling G. Laboratory Quality Assurance/Quality Control Procedures H. Geraghty & Miller, Inc. Forms I. Composition of Bentonite J. Toxicological/Hazard Data

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1. INTRODUCTION

1.1 Purpose

The Site Operations Plan (SOP) for the Syosset Landfill has been developed to provide a detailed description of the scope-of-work, on-site investigation methodologies, quality assurance/quality control and the health and safety require- rn ments which were referenced in the Work Plan for On-Site Re- } 1 medial Investigation/Feasibility Study at the Syosset Land- j fill, Syosset, New York, June 1986. The SOP has been pre- U pared in accordance with the agreements stated in the Admin- |r, istrative Consent Order (ACO) between the Town of Oyster Bay r- and the United States Environmental Protection Agency **• (USEPA) signed in July 1986; the formation of the SOP ad- f| heres to the requirements of a Remedial Investiga- tion/Feasibility Study (RI/FS) as outlined in the Guidance T f|i Documents for Remedial Investigation and Feasibility Studies P dated June 1985. The completion of the tasks and deliver- * ables presented in the SOP will insure consistency with the | National Contingency Plan (NCP) for CERCLA-funded investigations.

1.2 Format

The format of the SOP is divided into the following « sections: Section l is the Introduction; Section 2 de-

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scribes the Sampling Plan. The Sampling Plan contains the tasks for the On-Site Remedial Investigation. They are Data Verification, Data Base Establishment, and the Aerial Photo- graph Study; the On-Site Ground Water Investigation; the Landfill Dimension Study; the Off-Site Ground Water Investi- gation, and the Subsurface Gas Study. Section 3 contains the Quality Assurance/Quality Control Plan, and Section 4 describes the Health and Safety Plan. The alternatives which may be considered during the feasibility study are described in Section 5 and the Deliverables and SOP Schedule are presented in Section 6. All tables, figures and appendices which supplement Sections 1 through 6 are presented in the Tables, Figures and Appendices sections of the SOP.

1.3 Project Team

The project team (Syosset Landfill - RI/FS Team) which will conduct the SOP is given on Figure 1.1 which also indicates responsibilities and chain of command. Geraghty & Miller, Inc. will be responsible for performing the site investigative work. Geraghty & Miller, Inc. is under sub- contract to the firm Lockwood, Kessler and Bartlett (LKB), who will function as project managers and provide oversight and engineering expertise throughout the RI/FS.

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2. SAMPLING PLAN

2.1 Data Verification, Data Base Establishment and Aerial Photo Study

Geraghty & Miller, Inc. will attempt to contact each firm or agency who has conducted studies and/or collected j data on the Syosset Landfill to determine what data/sample collection protocols were employed. The following designa- I tions will be assigned to each result:

i U = collection protocol unknown !.i: N = collection protocol not satisfactory |.ri *S = collection protocol satisfactory

Mr The assignment of a designation will be based on f!f whether the protocol is consistent with guidance given in USEPA manuals on ground-water investigation and sampling |j (see References). The designation will be clearly noted on ,T each data sheet, or the report cover.

P Water-level and water-quality data from these previous studies will be entered into a computerized data management system. This system will reproduce the data in tabular form; examples of the tables are given in Appendix A. Data, generated during the RI/FS, will also be entered into this system. Geraghty & Miller, Inc. • _4_

A division of LKB conducts aerial photograph surveys of Long Island. LKB will provide aerial photographs of the Syosset Landfill taken during the years when landfilling operations were underway. The photographs will be studied with the intention of pinpointing the likely areas and depths in the landfill in which industrial wastes may have been placed. The determination of potential "hotspots11 at the Syosset Landfill will be used to guide the selection of sample depths in the Landfill Dimension Study. A site location map of the Syosset Landfill is provided in Figure 2.1.

2.2 On-Site Ground-Water Study

The initial ground-water investigation at the site (ERM, 1983) identified leachate impacts to the ground water under the site. The proposed study has been designed to determine the extent of these impacts on-site, to determine the potential for off-site migration and to develop a plan for delineating off-site, ground-water contamination. The investigation will rely on accurate water-table and vertical piezometric head measurements to determine flow directions. A more detailed and comprehensive geologic and geochemical data base than currently available will be developed so that factors controlling contaminant migration and attenuation in the aquifer can be understood. Geraghty & Miller, Inc. _

2.2.1 Drilling

In order to establish ground-water conditions in the water-table zone around the site, two new shallow wells will be installed at the locations shown on Figure 2.2. These wells will be drilled to depths similar to the existing mon- p itoring wells (approximately 140 feet). The wells will be I installed in an 8-inch diameter borehole drilled by the mud- 1 rotary method using a bentonite and water mixture as the circulation fluid. Bentonite is a mixture of 90% sodium- ti montmorillonite clay and 10% polymers. The composition of n the bentonite, which will be used during drilling, is given in Appendix I. f: Drilling Method J , •• Mud rotary drilling method uses a rotating drilling bit which removes cuttings by continuous circulation of a f| drilling fluid as the bit penetrates the formation. The drilling fluid is pumped through the drill bit and flows up- | ward in the annular space between the borehole wall and , drill pipe carrying the formation cuttings in suspension to land surface. The drilling fluid forms a thin layer of mud on the wall of the hole whi h reduces seepage loss of drilling fluid to the formation and supports the walls in order to prevent caving of the borehole during drilling.

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Formation Sampling

A 2-inch diameter split-spoon sampler, 2-feet in length, will be used to collect core samples from the borings at 5-foot intervals and at changes in the lithology. i Samples will be described, with special attention given to r identifying fill materials encountered while drilling. Four deeper wells will be drilled using the same method {, described above. Each of these wells will be approximately I" 200 feet in depth; proposed locations are shown on Figure *J 2.2. ur 2.2.2 Soil Sampling for Laboratory Analysis

D All split-spoon samples will be screened for volatile ji organic compounds (VOCs) using the protocol described in Ap- pendix B. In addition, soil samples will be collected at li 30-foot intervals, stored in VOA bottles and sent to the r laboratory for analysis of VOCs using EPA Method 601/602. At this time, it is anticipated that 15 samples will be submitted for analysis.

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2.2.3 Well Installation

All wells will be constructed of threaded flush joint, 4-inch I.D. PVC casing and screen. Screen will be 10 feet in length with a slot size of 0.020 inches. No solvents or glues shall be used to join casings or screens.

Gravel pack will be poured down the borehole to fill the annulus around the screen. The gravel pack will consist of No. 1 J. Korie Co. sand or equivalent. A weighted steel tape will periodically be placed down the annulus to ensure that the gravel pack comes above the screen. Bentonite slurry will then be pumped to fill the remaining borehole annulus. The slurry will act as Seal and prevent contaminants from migrating vertically in the borehole. The top of the well will be fitted with a vandal-resist ant locking steel cover, cemented in place to a depth of at least two feet below grade. Figure 2.3 shows the construction detail for the monitoring wells. Well SY-2 has been found to be damaged and will be replaced with a monitoring well of similar depth, constructed in the manner previously described.

2.2.4 Well Development

After the wells are installed, a submersible pump and/or surge block will be used to develop the wells. The

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purpose of development is to remove the finer grained materials from the gravel pack and wall of the borehole. Development will also remove fine sand, silt and clay from the natural formation that immediately surrounds the gravel pack and well screen so that the well will yield water relatively free of silt and sand.

2.2.5 Geophysical Logging

When the shallow and deep boring are drilled to the proposed depths, each borehole will be geophysically logged by gamma and electric methods. The electric log records the apparent resistivities of the subsurface formations and the spontaneous potentials generated in the borehole. This log is useful in differentiating between saturated clay formations (which exhibit relatively low resistivities) and saturated sand formation (which exhibit relatively high resistivities) . The gamma log measures the radiation of gamma rays from certain radioactive elements that occur naturally in subsurface clay formations. Low intensity gamma-ray activity indicates a sand layer.

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2.2.6 Water Quality Monitoring

Water-Level Measurements

Water-level measurements will be taken from the new and previously installed on-site wells on a monthly basis (see I schedule), during the Remedial Investigation. P Monitoring Frequency

l.i Two rounds of water-quality samples will be taken from 1 the new and previously installed on-site wells after all the : 1 ' wells are installed; the rounds will be approximately one f month apart.

11 Sampling Equipment and Protocol II 11 The wells which will be installed as part of this pro- [ gram will be equipped with dedicated electric submersible pumps (Grundfos, all stainless steel pump, with PVC riser [ pipe). Samples will be taken from these wells according to the protocol described in Appendix C. Samples from the existing (EPM) wells will be taken by the bailer method, given t \ in App.ndix D.

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Analytical Parameters

The first round of samples taken from the on-site wells will be analyzed for the list of selected USEPA Priority Pollutants (note: both filtered and unfiltered samples will be taken for aetals analysis) and additional parameters given in Appendix E. The organic analyses for this first round will be done by gas chromatograph/mass spectrometer (GC/MS) methods, (the only exception is the PCB analysis, which will be done by the GC method (EPA 608) which allows a lower detection limit). Thereafter, GC methods will be employed for most organic analyses. The compounds included in the Acid and Base/Neutral Extractables and PCBs generally exhibit very little, if any, mobility in the ground-water environment. Their inclusion in the list of analytical parameters was done in the broad interest of a complete investigation, and not in the expectation that these are likely ground water contaminants. Therefore, any or all of these three classes of compounds will be deleted from the analytical list if the following criteria are met:

1) Analytical results for samples taken during the Landfill Dimension Study show the actual waste to contain trace or non-detectable concentrations of these compounds.

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2) None of these compounds is detected in ground-water samples taken during the first two rounds of sampling.

Field and Trip Sample Blanks j During each round of ground-water sampling, blank and replicate samples will be submitted along with the actual I samples. One replicate sample to be analyzed for the entire :' list of parameters will be taken during each sampling round. The replicate sample will be labeled with a dummy number so Ji that it is not known to the laboratory as a replicate (a blind replicate) . One field blank for VOCs will be taken I- each day of sampling; the field blank will be opened at the H| site and brought into contact with a cleaned bailer, and then resealed. One trip blank for VOCs will accompany each I day's samples. Trip blanks and field blanks will be identified to the laboratory so that notification of possible con- i. tamination may be done before all samples are analyzed.

2.3 Landfill Dimension Study

The previous Landfill Dimension Study (Bowne, 1983) reported the depth of the landfill to range from 36 to 91 feet; the landfill is apparently deeper in the southeast

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section. The previous study also indicated "... that the wastes in the landfill are already highly decomposed", based on the results of water samples from their borings.

The RI/FS landfill dimension study has been designed to:

1) provide further definition of the depth of the landfill, and

|j 2) provide a chemical characterization of the wastes in I-T the landfill. I >

I Data for determining the dimensions of the landfill and characterization of wastes will be collected by installing Fl.!i borings directly through the landfill, and by analyzing wa- i! ter quality samples collected from monitoring wells installed within two of the four landfill borings. I r 2.3.1 Installation of Borings Four borings will be drilled through the fill at the locations shown on Figure 2.4, utilizing the wash-boring method. If this proves unfeasible an alternative cased-boring technique, i.e power auger, will be utilized; both techniques are described herein.

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Wash Boring Method

The wash boring method penetrates the subsurface by driving casing with a drop weight while maintaining a constant head of water in the casing. Potable water will be I obtained from TOB-DPW. The purpose of adding water during i drilling is to prevent the ignition of methane or other po- i! tentially explosive subsurface gas mixtures by restricting the movement of such gases through the drill column, and by 1 saturating the formation and preventing sparking in the i i event that the drilling tools strike metal in the subsurface ( ; fill. The casing is to be driven in five-foot intervals i followed by the circulation of potable water to remove accu- mulated material (cuttings) from inside the casing. The ma- !n terial is washed to the surface and is bled through a "T" at the top of the pipe where it flows into a tank for settling and recirculation. After the cuttings have been removed, ! - soil/waste samples will be collected using a 2-inch diameter, 2-foot long, split-spoon sampler. i Power Auger Method

In the power auger metiiod, the borehole is drilled using a hollow-stem auger while maintaining a constant head of water in the hollow-stem auger. After the hole has been ad-

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vanced five feet, a soil/waste sample will be collected using a split-spoon sampler. The soil/waste sample is collected through the hollow-stem. Each boring will penetrate the total depth of the landfill and will be terminated ten feet below the water table. :

_ 2.3.2 Collection of Soil/Waste Samples

II Soil/Waste Sampling

|. Split-spoon samples will be collected at five-foot in- .,, tervals during drilling using; a standard 2-inch (O.D.) '-1 split-barrel sampler. Samples will be collected by the pro- J" tocol given in Appendix F, paying special attention to the details listed below: If 1) Prior to sampling, the borehole must be washed clean I' of cuttings.

I: 2) During sampling, a constant head of water will 1 be maintained in the; casing/hollow-stem auger. The water used, and the purpose for this step are described in Section 2.3.1 (Wash Boring Method).

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Saatple Description

A geologic description of each sample will be entered in the log by the on-site hydrogeologist. The samples will then be sealed in an air-tight glass container and properly labeled. Selected samples of the formation taken from below the fill will be subjected to grain size analysis (sieve * analysis) to estimate permeability values. I" Soil Quality Analysis ii I, All split-spoon samples will be screened for volatile '' organic compounds (VOCs)'according to the protocol in Ap- |* pendix B. Additionally, three samples of the landfill subsurface material from each boring will be selected for labo- | ratory analysis in accordance with the following priorities:

'•-'' 1. First priority - Soil samples, which have an obvious I chemical odor, or are discolored. « .

| 2. Second priority - Depths identified by the aerial photo survey as likely locations of industrial waste.

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appropriate section) and appended protocols. These measures include decontamination procedures and the use of replicate and blank samples. In order to eliminate transcription errors and promote uniform reporting of field data, G&M has developed a series of site investigation reporting forms. These forms replace the usual bound notebook. Data and information are collected directly on these forms and are submitted weekly to the project manager. Copies of the various forms are given in Appendix H.

G&M sets very stringent standards for its personnel. Before attaining a field supervisory capacity, field personnel must meet the following criteria:

1. Acceptable college education. A high percentage of the firm1s field staff possess advanced degrees or post-bachelor's degree education.

2. Train for an extended period of time in the field with direct supervision by senior staff. Typically, each professional re- ceives extensive, hands-on training in areas of ground-water hydraulics, quality, instru-

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3. Third priority - An evenly spaced top-middle-bottom set of depths will be selected for each boring. The depths will be determined by estimating the thickness of the fill based on the borings in the 1983 Sidney B. Bowne report. * i The samples will be analyzed for the selected list of USEPA Priority Pollutants given in Appendix E (organic analyses by T GC/MS, except PCBs as explained previously). The portion of the sample used for metals analysis will be extracted by the iii EP procedure. • c Borehole Abandonment C After sampling is complete, two of the landfill borings I: will be sealed (grouted) to total depth. The borings will IT be grouted using tremie methods with a bentonite and water mixture, the composition of which is given in Appendix I. I Soil cover and landfill profiles will be restored. ir . 2.3.3 Well Installation

As shown in Figure 2.4, two of the borings will be completed as monitoring wells. The wells will be constructed of flush joint, 2-inch I.D. PVC casing with a 10-foot screen of appropriate slot size (no glues will be used). The

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screen will be installed so that the upper two or three feet are above the water table. The annulus around the screen will be gravel packed to at least two feet above the screen with J. Morie Co. No. 1 sand, or equivalent, and the remaining borehole -annulus will be sealed using tremie methods with a bentonite and water mixture. The top of each well will be fitted with a vandal-resistant, locking, steel cover, cemented in place to a depth of at least two feet below grade. The well construction is depicted on Figure 2.5.

2.3.4 Well Development

After the monitoring wells have been installed, the wells will be developed using a bailer. The development processes will be used to attempt the removal of fine grained materials in the vicinity of the well screen. The wells will be developed by bailing several times the amount of water in the casing, until relatively clear water is obtained. The bailer used will be decontaminated and bailer cord discarded between wells as described in Appendix D

2.3.5 Water Quality Monitoring

Water-quality samples will be taken from the two wells installed as part of the Landfill Dimension Study. The water-quality samples will be collected on the same schedule

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and for the same parameters as the wells installed in the On-Site Ground-Water Study. The wells will be sampled by the bailer method, which is given in Appendix D.

2.4 Off-Site Ground-Water Study

I An off-site ground-water investigation will be under- j taken if the results of the on-site investigation indicate I the likelihood of an off-site leachate plume.

!:, To date, there has been no investigation of off-site n ground-water contamination from the Syosset Landfill, although Well N-4133 was closed in 1973 due to aesthetic prob- I lems possibly related to landfill leachate (EKM, 1983). While the closing of Well N-4133 is regarded to be the re- I! suit of off-site leachate migration, the existence of a i plume is not confirmed and pumpage of Well N-4133 may have been the most significant factor affecting contamination. Upon completion of the on-site ground-water study, the ex- I i tent of on-site contamination and the local hydrogeology 1 will be defined. This will be related to regional hydrogeology and the geologic conditions which control leachate migration and/or attenuation.

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2.4.1 Work Plan

If an off-site ground-water investigation is deemed necessary, a detailed work plan will be prepared and submitted to USEPA and NYSDEC for review and approval. Ground- water flow directions (horizontal and vertical), water-qual- . ity data, local geology and geochemistry will form the basis * for selecting new, off-site, monitoring well sites, existing F! wells for sampling and for generally determining the area(s) of off-site investigation. The work plan would be submitted f |; for USEPA approval prior to the Final RI Report (see sched- c r 2.4.2 Operations Plan

[M Upon notification of approval of the Off-Site Work Plan ... by the USEPA, an Operations Plan (OP) will be developed k based upon the work plan for the Off-Site Investigation. fT' The OP will provide the detailed scope-of-work, investigation methodologies, the QA/QC requirements and a Health and [ Safety Plan required to adequately complete the program. » The OP will be prepared in accordance with the most recent USEPA guidance document which has been published at the time of USEPA approval.

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2.4.3 Integration of the Data Collected During the On- Site and Off-Site Ground-Water Investigations

Wells installed as part of an off-site investigation will be sampled twice (one month apart), along with the on- t site wells. Water-level measurements will also be collected I in the off-site and on-site wells. !

I 2.5 Subsurface Gas Study r L This study has been designed to determine the nature IT and extent of subsurface landfill gases on-site. The results of this study will be used to design the venting , *- „ F system for capping and closure of the site.

1: This study will employ a network of shallow gas moni- r! toring wells. The gas monitoring wells will be sampled and li analyzed for gaseous hydrocarbon content. Sampling shallow [ soil gases followed by analysis for hydrocarbons is a technique which has been used for several decades in geochemical 1 prospecting for petroleum. Application of this technique to landfill investigations and monitoring of subsurface contamination has been discussed by USEPA (1983), USEPA (1985), Lappala and Thompson (1983), and Lobasso and Barber (1983). Previous studies at the site and Geraghty & Miller, Inc. experience indicate that the highest concentrations of gases

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are usually found during periods of low barometric pressure. Therefore, sampling periods will be performed (to the extent possible) during periods of low or falling barometric pressure .

2.5.1 Construction of Gas Monitoring Wells

The gas monitoring wells will be constructed of hand- slotted 1-inch I.D. PVC casing, installed in 2-inch boreholes drilled with a hand-operated bucket auger. The borehole will be backfilled with sand to within one foot of land surface, and then sealed with a bentonite slurry. The gas monitoring wells will be installed at depths of 4-5 feet below land surface. This depth will place the lower portion in the refuse (Bowne, 1983 reported 6 inches to 4 feet of clean fill over the refuse). The construction details of a typical gas monitoring well is shown on Figure 2.6. The top of the well will be capped and fitted with short lengths of polyethylene and silicone tubing to allow attachment of sampling and gas monitoring equipment.

2.5.2 Gas Sampling

A total of 19 gas monitoring wells will be installed at the locations shown of Figure 2.7. Once installed, these wells will be regularly monitored (at periods of low baro-

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metric pressure, if possible), using a Century Systems Model 118 Organic Vapor Analyzer (OVA). A description of the OVA and its application to contamination investigations has been discussed by USEPA (1983), USEPA (1985), Barber and Braids (1982), and Lobasso and Barber (1983). Measurement will be taken with the standard OVA probe and with an activated . charcoal filter probe (which adsorbs essentially all other 1 organic vapors and gases except methane); the OVA probe will p be inserted directly into the silicone tubing, which pro- i. vides an air-tight fit. Readings will be recorded as [j "Total" and "Methane," as parts per million in air by volume j.j (ppmv). The OVA will be calibrated to methane according to ^ the manufacturer's instructions prior to each round of sam- P pling.

[j Lobasso and Barber (1983), have indicted that the high- ., est readings occur after five minutes of pumping. The OVA j: " will be used to pump (about 2L/min) selected wells and measure hydrocarbons for one hour each. Concentration vs. time Ii • ' . r profiles will then be constructed. If the concentration of gas exceeds the range of the OVA (1,000 ppmv), a peristaltic pump and MSA Explosimeter will be used. This information will be used to determine the period of pumping necessary to reach the highest concentration of gases.

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After optimum times are established and two full rounds of OVA measurements are completed (at least one week apart), samples for laboratory analysis will be collected from the 10 gas monitoring wells which have the highest readings of non-methane compounds (i.e., "Total" concentration minus ,- "Methane" concentration). These samples will be analyzed { for Volatile Organic Compounds (VOCs) listed in Appendix E. I1 The typical protocol for this type of sampling would 11 employ a charcoal tube and desportion with carbon disulfide fr (NIOSH Method). In conversations with our laboratory, we 'li have found that this method is not entirely suitable for the t." purposes of this investigation because of the following factors : fi .,, 1. Vinyl chloride breakthrough Li f'' 2. High detection limits, depending on concentrations

I 3. Not applicable to all VOCs listed * Consequently, we propose to use an innovative technique, which will overcome these problems. The techniq-e is based on using a laboratory trap instead of the charcoal « tube for sample collection; this is the standard trap used

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in the Purge and Trap technique (Tekmar, Supelco, or equivalent) . After sampling, the trap is then simply connected to the gas chromatograph and thermally desorbed. The setup of this sampling apparatus is shown on Figure 2.8. Weekly OVA readings will be taken from these wells.

Each well will be tested to determine if gases are venting tinder pressure. This will be done by attaching a one liter air sampling bag to the well and recording the time it takes to fill. Bags will be left on for a maximum of one hour.

2.5.3 Off-Site Study

In the event that significant concentrations of gases are found at the (boundaries of the landfill, the investigation will be extended off-site. Significant concentrations are defined as follows:

1. Potentially explosive amounts of methane (25% of the Lower Explosive Limit or greater}.

2. Exceeding occupational exposure limits published by OSHA or ACGIH.

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The investigation will be extended until the extent of migration of subsurface gases is defined; this investigation will be conducted concurrently with the off-site ground-water investigation. The previously described monitoring and construction techniques will be used in the off-site study.

3. QUALITY ASSURANCE/QUALITY CONTROL PLAN

This Quality Assurance/Quality control (QA/QC) Plan is presented according to the recommended USEPA format (USEPA, 1983).

• 1. Project Name: Syosset Landfill, On-Site Remedial Investigation

2. Project Requested By: Town of Oyster Bay

3. Date of Request: December 1985

4. Date of Project Initiation: July 1986

5. Project Manager: John Lekstutis

6. Project Quality Assurance Manager: Andrew J. Barber

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7. Project Description:

A. Objective and Scope Statement

The Remedial Investigation (RI) at the Syosset ». Landfill has been undertaken to fill data gaps i in hydrogeology, water quality, and potential r subsurface gas migration. B. Data Usage t r Data collected during this project will be used to determine: 1) the extent of on-site P environmental impacts; 2) the need for off-site investigation. The completed RI will supply [i! data for the Feasibility Study (FS) for rp remediation of the site. In

[ C. Monitoring Network Design and Rationale

I The location and depth of the proposed ground- water monitoring wells were selected based on existing hydrogeologic data from the site, in order to complement the. existing database. The location of the landfill borings were likewise selected to complement previous borings through

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the fill, to complement existing data on the thickness of the fill. The gas monitoring wells were located on a regularly spaced grid pattern, to develop data on subsurface gas over i the entire site area. ; t I O. Monitoring Parameters and their Frequency of • Collection F Sample types, analytical parameters and Uf • collection frequency have been previously p specified in Appendix E and in the identified I II sections: p 2.2.2 - Soil Sampling for Laboratory Analysis 2.2.6 - Water Quality Monitoring (On-Site |f Monitoring Wells) _, 2.3.2 - Collection of Soil/Waste Samples 'l: 2.3.5 - Water Quality Monitoring (Landfill [" Boring Wells) 2.5.2 - On-Site Study (Gas Monitoring Wells) [ , E. Parameter Table

Analytical paramc ters have been previously specified in Appendix E and in the identified sections:

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2.2.2 - Soil Sampling for Laboratory Analysis 2.2.6 - Water Quality Monitoring (On-Site Moni- toring Wells) 2.3.2 - Collection of Soil/Waste Samples 2.3.5 - Water Quality Monitoring (Landfill Boring Wells) 2.5.2 -on-Site (Gas Monitoring Wells)

8. Project Fiscal Information: Not Applicable

9. Schedule of Tasks and Projects:

A detailed schedule of activities and deliverables is given in Section 6 of this SOP.

10. Project Organization and Responsibility:

The project team has been previously specified in Section 1.3 of this SOP, indicating general responsibilities. The data review and management process is shown schematically on Figure 3.1. Specific responsibilities will be as follows:

Sampling Operations - Geraghty & Miller, Inc. Field Scientist Sampling QC - Andrew J. Barber

000147 * j Geraghty & Miller, Inc.

Laboratory Analysis - Thomas Powell (EcoTest) Laboratory QC - Thomas Treutlein (EcoTest) Data Processing Activities - Karen Barbaro Data Processing QC - Geraghty & Miller, Inc. Scientist Data Quality Review - Andrew J. Barber Performance Auditing - Thomas Treutlein/Andrew J. Barber I Systems Auditing - Thomas Treutlein/Andrew J. Barber If Overall QA -Andrew J. Barber Remedial investigation Leader - Christopher G. I Creed

11. Data Quality Requirements and Assessments QA/QC Statements: li flj EcoTest Laboratories of North Babylon will supply analytical services for samples taken during the in [[. investigation at the Syosset Landfill, with the

|rr exception of GC/MS analysis. GC/MS work will be k . done by York Laboratories. QA/QC statements from I these laboratories are given in Appendix G. The analytical methods to be employed are given in I Appendix E.

Specific measures for assuring that the samples are representative and that the integrity has been maintained are described in the SOP (in the

OCC148 Geraghty & Miller, Inc; i appropriate section) and appended protocols. ? These measures include decontamination procedures and the use of replicate and blank samples. In order to eliminate transcription errors and promote uniform reporting of field data/ G&M has i developed a series of site investigation reporting • forms. These forms replace the usual bound notebook. Data and information are collected directly on these forms and are submitted weekly r » to the project manager. Copies of the various L forms are given in Appendix H.

II G&M sets very stringent standards for its p personnel. Before attaining a field supervisory capacity, field personnel must meet the following lii criteria:

Pa 1. Acceptable college education. A high percent - | age of the firm's field staff possess advanced degrees or post-bachelor's degree education.

2. Train for an extended period of time in the field with direct supervision by se- • nior staff. Typically, each professional re- ceives extensive, hands-on training in areas of ground-water hydraulics, quality, instru-

000149 Geraghty & Miller, Inc. -31-

mentation, contractor supervision, and record keeping.

3. Demonstrate the ability to carry out all aspects of field investigations independently. :

* 4. Demonstrate good communicative skills includ- r ing written report preparation. In addition to the analytical methods and L protocols for the collection of samples and data, r> there is a thorough review and management process for data. This process is shown schematically in F Figure 3.1. The two sources of data are the laboratory and the field. There is interaction I,, between the lab and field personnel in the form of r> sample collection delivery and chain of custody. ' Data generated by either of these sources is I reviewed prior to submission to the Project Manager or Project Geochemist. After submittal, 1 the data are reviewed a second time. At any one « of these review points, data may be questioned or rejected. Some reasons for questioning data are given below:

000150 Geraghty & Miller, Inc. -32-

Inconsistent with data previously collected at the site

- Inconsistent with studies done at similar sites

t - Inconsistent with previous studies on local or I regional hydrogeologic conditions

IF - Inconsistent with reported site usage

Some examples of reasons for rejecting data are -, given below: I*. p - Physical impossibilities, e.g. - a water table elevation in a monitoring well exceeding the 1 1 elevation of the top or below the bottom of the

,r well.

'! - Chemical impossibilities, e.g. - the concentra- ILi tion of an individual cation exceeding total | dissolved solids concentration. w - Strong likelihood of sample contamination, evidenced by trip and field blanks.

- Poor correlation between replicate samples.

000151 Geraghty & Miller, Inc.

The review process insures that the data is examined by both the generators (field and lab) and also by objective technical management personnel. In the event that data is rejected, an j attempt will be made to salvage the old data (e.g. - refer to raw lab data} or generate new data (e.g. - another round of samples), if possible. f Any gaps or replacements in the data will be clearly noted on all appropriate tables. II .. Once data is accepted, it will either be entered '- into the project file directly or into the Ger- r aghty & Miller, Inc. computerized Data Management System. Typically, numeric data such as water [[ levels and water-quality data Will go into the .- computer system. Data are entered and printed out *• in tabular form (see Appendix A for an example of I printout tables). Data which are more in the form of text, e.g. - drilling logs, are put directly [ into the project file as hard copies.

12. Sampling Procedures:

Sampling procedures have been previously specified in the identified sections:

00015? Geragbty & Miller, Inc.

2.2.2 - Soil Sampling for Laboratory Analysis 2.2.6 - Water Quality Monitoring (On-Site Monitor- ing Wells) 2.3.2 - Collection of Soil/Waste Samples 2.3.5 - Water Quality Monitoring (Landfill Boring I Wells) 2.5.2 - On-Site Study (Gas Monitoring Wells) ri, 13. Sample Custody Procedures: ;£ ?' r Sample custody procedures are described in the sampling procedures. An example chain-of-custody I form is given in Appendix H.

1P: 14. Calibration Procedures and Preventative Main- r tenance:

I Specific procedures for calibration of field equipment are given in the sampling procedures. i Laboratory procedures for calibration and * maintenance are listed in the QA/QC statements given in Appendix G and the specific analytical method.

000153 Geraghty & Miller, J.nc. -35-

15. Documentation, Data Reduction, and Reporting:

Procedures for documentation, reduction, and reporting of data are given in Part 11 of this QA/QC plan.

16. Data Validation:

Procedures for validation of data are given in Part 11 of this QA/QC plan.

17. Performance and systems Audits:

Procedures for auditing performance and systems operations are given in Part 11 of this QA/QC Plan.

18. Corrective Action:

Procedures for corrective action are given in Fart 11 of this QA/QC Plan.

19. Reports:

Specific procedures regarding the issuing of reports are given in Section 6 of this SOP.

000154 Geraghty & Miller, Inc.

4. HEALTH AND SAFETY PLAN

4.1 Introduction

t This Health and Safety Plan (HASP) has been developed . to protect the health of personnel during the course of the * remedial investigation at the Syosset Landfill. This HASP F' was prepared based on principles of industrial hygiene and Geraghty & Killer, Inc. experience, using current Federal |[i regulations and published guidelines, texts and references. r c•^ 4.2 Management All site operations will be under the direction of the |[| project geologist. This individual is empowered to make the .,, routine decisions on working conditions and safety equipment ^ selection. At the beginning of the day, site personnel will T be briefed on the expected activities for that day by the site manager; this will include a discussion of specific I hazards. The project geologist reports directly to the Safety Manager on safety issues. The Safety Manager is responsible for the preparation and implementation of the HASP and is the only one wh. may make changes in the HASP. Dis- putes over safety issues will be resolved by the Safety Man- ager .

000155 Geraghty & Miller, Inc.

4.3 Hazard Evaluation

The investigation of ground-water conditions around any landfill (accepting hazardous or non-hazardous waste) has certain potential hazards:

- Presence of explosive levels of gases (particularly I" methane) in and around the landfill

I, - Presence of noxious odors from putrified waste

- Presence of toxic gases, e.g. - hydrogen sulfide, r generated by decomposition of wastes.

H! The drilling operations will use either circulated wa- • ! ter or mud as a drilling fluid, thus the possibility for r explosion during drilling is very remote. The Syosset Landfill reportedly received sludges con- I taining heavy metals. Previous investigations at the site I * have determined the presence of Volatile Organic Compounds (VOCs), heavy metals (arsenic, cadmium, chromium and lead) and elevated levels of leachate indicators (e.g. - iron, ammonia, chloride, etc.) in ground-water samples. Individual VOCs were detected at 21 ug/L or less, and the total VOC

000156 Geraghty & Miller, Inc ""* .3 o ~

concentration for a single well did not exceed 100 ug/L. Thus, it is unlikely that VOCs volatilizing from cuttings or contaminated ground water pumped from wells during drilling development or sampling operations will pose an inhalation hazard. Contact with contaminated cuttings or water (and subsequent ingestion of contaminants) is a possible hazard.

Although no data are available to indicate the presence of vinyl chloride (VC), it merits particular attention in this hazard evaluation because:

1) The reported disposal of VC and PVC wastes at this site (ERM, 1983).

2) VC has been found in the air at other sanitary landfills (Malcolm Pirnie, 1983).

3) The recommended occupational exposure limits for VC in air are very low: 0.5 ppm (OSHA, 19B3) and 5 ppm (ACGIH, 1984).

4) VC has poor warning properties, i.e. - most people would not recognize the odor of VC at a concentration of less than 1% (100,000 ppm) in air (Verschueren, 1983).

000157 Geraghty & Miller, Inc.

The method of VC disposal was not stated, and it is un- clear how this was done; VC is a gas at standard temperature * and pressure. It is unlikely that pressurized cylinders were put into the landfill because: 1) VC is a raw material and would necessarily be conserved, and 2) such cylinders are valuable, typically requiring payment of demurrage to m. the supplier. It is possible that traces of VC could be present in some of the PVC wastes reportedly put into the |i landfill, but this would not likely account for appreciable amounts of VC. Any VC which might emanate from a boring |, would be quickly diluted in the atmosphere. Thus, hazardous I concentrations are not anticipated, but the possibility is *~ not being ruled out. 0 Thus, this HASP must address the following hazards: 1 .,, - Explosive levels of gases in boreholes *a - Noxious odors P - Toxic gases, especially vinyl chloride - Contact with waste or contaminated soil or water. I I Toxicological and hazard data for vinyl chloride, hydrogen sulfide, nickel, lead, arsenic, cadmium and chromium are given in Appendix J. These data will be explained and made available to site personnel at the training session.

000158 Geraghty & Miller, Inc. -40-

4.4 Air Monitoring

Subsurface gas samples will be taken as part of the Sampling Plan; these samples will be taken at points likely to have the highest concentrations of landfill gases. The results of these samples will be used to guide further air . monitoring to select respiratory protection (if necessary).

P Air monitoring with direct reading instruments will be conducted during drilling operations. The air around the lii borehole will be surveyed, as will the atmosphere at shoul- trj der height (breathing zone) around the rig. This survey *** will take place at break points in the operation, e.g. - I start-up, adding rods, etc.

['] The main survey instrument employed will be an HNU Model PI-101 Photoionizer equipped with a 10.2 eV lamp or a Ir! LI Photovac TIP (10.6 eV lamp). These instruments employ a " Photoionization Detector, which is particularly sensitive to {w halogenated organic compounds like vinyl chloride. Neither ] of these instruments detects methane (as does the Foxboro , Organic Vapor Analyzer), so that trace amounts of a compound like vinyl chloride will not be "masked" if relatively high concentrations of methane are encountered. The survey instrument will be calibrated according to the manufacturer's instructions. In the event that a reading of 5 ppm or

000159 Geraghty & Miller, Inc.

greater is recorded around the borehole, a detector tube measurement will also be taken to determine the presence of vinyl chloride.

In order to monitor for potentially explosive levels of methane, an MSA Explosimeter will be kept on site. Although the drilling methods essentially preclude the possibility of explosion, the meter may be used for investigatory purposes as needed. Hydrogen sulfide will be monitored with an Enmet CGS-10 Tritector; the instrument will sound an alarm if 10 ppm of hydrogen sulfide (the AC6IH Time Weighted Average) is detected.

4.5 Personal Protective Equipment

Based on the hazard evaluation, there is no apparent respiratory hazard, thus the use of respiratory protective equipment is not anticipated. Further data on airborne contaminants will be collected in the Air/Gas Study and by on- site monitoring with direct-reading instruments and detector tube; if these data indicate the necessity for respiratory protective equipment, it will be provided. Respirators equipped with organic vapor cartridges will be kept on site. If vinyl chloride or hydrogen sulfide are determined by air monitoring to be a respiratory hazard, full face canister masks and/or engineered ventilation will be employed. All

000160 Geraghty & Miller, Inc. * *"*

respirators will be NIOSH and MSHA (Mine Safety and Health Administration) approved. The types and quantities of respirators are given in Table 3.1.

The standard work uniform for personnel involved in j_ drilling operations will be:

' - Hard Hat F - Safety Glasses - Tyvek Coveralls I;. - Gloves - Latex, Nitrile, PVC or PVA - depending on r job I II - Boots - Rubber, mid-calf.

If conditions become particularly sloppy or dusty due to weather, more stringent protection will be employed, in- I-T eluding, but not limited to: Li - Inner Gloves - Taping boots and gloves to coveralls to eliminate possible leakage at the wrist and ankle - Polyethylene-coated coveralls or raingear - Face Shields - Hoods .

000161 Geraghty & Miller, Inc. -43-

4.6 Facilities

A project trailer will- be kept on site during the drilling program. This trailer is equipped with propane heat, first aid kit, and a fire extinguisher. The trailer will serve as a sign-in point for visitors? the supply of safety equipment will be stored in the trailer.

The Town of oyster Bay Department of Public Works facility lies within the bounds of this site. Available from the facility are telephone for emergency use, potable water and lavatories.

' 4.7 Decontamination

k The working area (drilling site) will be divided into _ three zones: restricted zone (exclusion zone), decontamina- * tion zone (contaminant reduction zone), and a clean zone (support zone). This process is shown schematically on Fig- ure 4.1. The restricted zone is a limited access area, f which will be established at each drilling location. The restricted zone will cover an approximate 50- foot radius around the drilling location. Only authorized personnel, who have satisfied the training and health monitoring requirements of this HASP, will be allowed in the restricted zone. Personnel will exit the restricted zone by passing Geraghty & Miller, Inc. -44-

through the decontamination zone. Equipment and clothing will be removed starting with boots, then gloves, coveralls, hard hat and glasses. Respirators, if used, will be sani- tized daily and stored in plastic bags. Equipment which is to be re-used, such as boots, will be rinsed off and stored in plastic bags. Disposable equipment will be placed in bags or drums; based on the hazard evaluation, it is not anticipated that clothing and equipment will have levels of contamination which might preclude disposal as normal trash. Personnel will wash face and hands before leaving the decontamination area. The clean zone will serve as a meeting and storage area.

4.8 Training

Geraghty & Miller, Inc. employees are required to attend a 3-hour course given in-house on safety at chemical plants and waste sites. Additionally, selected employees attend 5-day type courses (EPA, National Water Well Associa- tion, and others). Before being allowed to work unsuper- vised at any site, new employees work several days with an experienced employee.

Prior to initiating site work, all site personnel (Geraghty & Miller, Inc. and subcontractors) will be re-

000163 Geraghty & Miller, Inc. .

quired to attend a training session given by the Safety Man- ager. This session will include the following topics: - Site history - Specific hazards (including toxicological data) - Hazard recognition - Standard operating procedures - Decontamination (personnel and equipment) - Emergency procedures - Respirator fit and use.

4.9 Health Monitoring

Geraghty & Miller, Inc. has established a Health Moni- toring Program with occupational health specialists at Long Island Jewish Hospital in New Kyde Park, New York. All site personnel (Geraghty & Miller, Inc. and subcontractor) who will perform daily site activities will have had an examination within 12 months preceding the start of on-site work, and will receive exit physicals within one month of completion of the on-site program.

The standard examination consists of the following:

- Personal, family and environmental history - Hands-on physical examination - Snellen's eye examination

000164 Geraghty & Miller, Inc. —46"

- Pap smear (females over age 21) - Hemoccult testing (over age 40) - Laboratory testing:

A. Complete Blood Count:

1. Red blood count 2. White blood count 3. Differential screening 4. Hemoglobin 5. Hematocrit

B. Urinalysis:

1. Sugar 2. Albumin 3. Specific gravity 4. Microscopic

C. Laboratory Chemistries:

1. A/6 Ratio 2. Albumin 3. Alkaline, Phosphatase 4. Bilirubin, Total 5. Calcium

000165 Geraghty & Miller, Inc. -47-

6. Chloride 7. Cholesterol 8. Creatinine 9. GGT 10. Globulins 11. Glucose . 12. Iron * 1 13. Lactic Dehydrogenase (LDH) t 14. Phosphorus I i 15. Potassium [• . 16. Protein, Total ., 17. SCOT ^ 18. SGPT I * 19. Sodium 2 0. Triglycerides fl 21. Urea Nitrogen (BUN) 22. Uric Acid Li I' D. Special Testing

| 1. PCBs in serum * 4.10 Emergency Procedures

In the event of an accident, an ambulance or the fire * department can be summoned using the telephone located

000166 Geraghty & Miller, Inc.

: within TOB-DPW. The nearest hospital is Syosset Community , Hospital, located at 221 Jericho Turnpike, Syosset, New York 4 (telephone number (516) 496-6400) . The nearest fire department is Station No. 3, located on South Oyster Bay and Park- field Avenue, Syosset, New York (telephone (516) 921-6220) .

i 5. FEASIBILITY STUDY

H Although it is not possible to select the remedial re- ii I sponse(s) for the Syosset Landfill at this time, the SOP r! {[t provides the general guidelines and potential sections which p will aid in the selection of the appropriate remedial alter- I i ^ natives. The feasibility study will be conducted concur- O rently with the remedial investigation and will follow the n format given in the USEPA Guidance Document (June 1985) : - Development of a range of alternatives li P - Technical and economic evaluation of alternatives

| " - Identification of the best alternative, or combi- • nation of alternatives.

At this time, it is anticipated t'.at the range of remedial alternatives (in addition to capping) to be considered during a remedial feasibility study of the Syosset Landfill

000167 Geraghty & Miller, Inc. -49-

will include source control, subsurface gas control and water-supply protection. Under each control category, a number of remedial actions are evaluated. Categories and potential actions are outlined as follows:

Potential Actions 1. Source Control Total Waste Removal Partial "Waste Removal ("Hot Spots") Capping with runoff control

2. Subsurface Gas Control Venting of methane and other landfill gases including treatment, if required

3. Ground-Water Control Low permeability bar- e riers (slurry walls, etc.) Hydraulic barriers B (pumping wells) Combinations of the above i; 4. Water Supply Protection - Long-term, ground-water monitoring - Water supply monitoring - Water supply replace- ment (relocation of affected wells) - Water supply treatment to potable quality

000169 Geraghty & Miller, Inc.

Remedial actions which may be implemented are methane control and capping of the landfill as provided under RCRA and NYSDEC Part 360 regulations for Solid Waste Management Facilities. These are established techniques for closure of a variety of waste management units and the Town of Oyster Bay has indicated a desire to expedite the capping of this site in anticipation of the proposed Landia Station.

6. DELIVERABLES AND SCHEDULE I

I 6.1 Deliverables

Il-' Throughout the performance of the RI/FS tasks, data f will be regularly provided to representatives of USEPA and NYSDEC as it becomes available. Four official documents are H planned for the tasks described in this work plan: I 1 1. Off-site Investigation Work Plan - In the event [7 that off-site work is necessary, a detailed work plan will be submitted for approval. This work I plan will be issued in advance of the Interim . • Remedial Investigation Report. A meeting with USEPA and NYSDEC will be held before preparation of the work plan so that their comments can be incorporated and the approval process accelerated.

000169 Geraghty & Miller, Inc.

2. Interim Remedial Investigation Report - This report will be prepared after the completion of the on- site tasks. It will be an interpretative report based on the data collected during the on-site tasks 'and will address the data gaps identified in Section 1.6 of this work plan. In addition, the results of the on-site investigation will be analyzed to determine if there is a possibility of risk to the public health and the environment due to activity at the Syosset Landfill. The Interim R.I. Report will be submitted to the EPA and the ij NYSDEC for review and comment within the dictates of the overall program schedule.

3. Final Remedial Investigation Report - In the event f! that 'it is clear that off-site work is not ri necessary, the Interim Report will be designated as I i ' the Final Report. In the event that off -site work ! is necessary, this report will be an interpretive report summarizing the entire investigation and i will include the data collected during the off-site » investigation. The Final R.I. Report will be submitted to the EPA and NYSDEC for comment.

OPC17U , Geraghty & Miller, Inc. -52-

4. Feasibility Study Work Plan- This work plan will be prepared in coordination with the remedial investigation tasks. The work plan will be submitted fifteen days after the issuance of the Final Report on the RI. The work plan will be submitted after meeting with the USEPA and NYSDEC I to allow for incorporation of their recommendations . I! In addition, as required by the AGO, monthly progress li reports will be submitted to the USEPA.

J i: 6.2 Schedule The schedule for tasks described in this SOP is given [1 on Figure 6.1. The starting date for the schedule is the r] date of official approval of the SOP by USEPA. The time al- 1 lowances shown are reasonable estimates based on Geraghty & Miller, Inc. experience, with minor additional allowances for frequent problems such as inclement weather, mechanical [ failure, etc. In the event of a major problem such as a * strike, alterations to the schedule may be necessary. The schedule does not provide for EPA review and approval of various t«sks during the course of the program. The time necessary for EPA review and approval will be added to the program schedule.

000171 Geraghty & Miller, Inc. -53-

A close working relationship between the technical representatives of the Town and the USEPA is anticipated. Such a relationship 1) allows for timely resolution of problems, 2) assures that all parties are kept up to date and 3) expe- dites the approval process for deliverables.

Respectfully submitted, GERAGHTY & MILLER, INC.

Andrew J. barber Senior Scientist/Health and Safety Manager/ Project Geochemist L Christopher G. Creed Senior Scientist/Project Manager/ Fl Project Hydrogeo]

Michael J. McEactlern Associate/Project Officer August 4, 1986 AJB/CGC/MJM:vk

000172 Geraghty & Miller, Inc.

REFERENCES

American Colloid Company. 1986. Personal Communication. American Conference of Governmental Industrial Hygienists, Inc. (ACGIH). 1984. TLVs - Threshold Limit Values for Chemical Substances and Physical Agents in the Work Envi- ronment and Biological Exposure Induces with Intended Changes for 1984-1985. ACGIH, Cincinnati, Ohio. Barber, A.J. and O.C. Braids. 1982. Application of a Portable Organic Vapor Analyzer in Ground-Water Contami- nation Investigations. "Proceedings of the Second Natural Symposium on Aquifer Restoration and Ground-Wa- ter Monitoring". National Water Well Association, Wor- thington, Ohio. Brobst, R.B. and P.M. Buszka. 1986. "The Effect of Three Drilling Fluids on Ground Water Sample Chemistry," Ground Water Monitoring Review, Volume 6, No. 1, pp. 62-70, Na- ti tional Water Well Association, Worthington, Ohio. Bowne, Sidney B. and Son. 1983. Capping and Closure of the Svosset Landfill, prepared for the Town of Oyster Bay. Chemical Information System (CIS) Data Bases, Chemical In- L formation System, Inc. Baltimore. Environmental Monitoring Systems Laboratory. 1983. Charac- terization of Hazardous Wastes Sites - A Methods Manual. Volume II. Available Sampling Methods. USEPA, reproduced by the U.S. Department of Commerce National Technical In- formation Service (NTIS), Springfield, Virginia. ERM-Northeast. 1983. Investigation of Landfill Impact on Groundwater Quality. Syosset and New Hyde Park Landfills, prepared for the Nassau County Department of Health. Franson, Mary Ann H. et al. eds. 1981. Standard Methods for the Examination of Water and Wastewater (15th Edition). APHA; AWWA-WPCF, Washington, D.C. Isbister, John. 1966. Geology and Hydrology of Northeastern Nassau County. Loner Island. New York. U.S. Geological Survey Water-supply Paper 1825, Washington, D.C. Kimmel, G.E., and O.C. Braids. 1980. "Leachate Plumes in Groundwater from Babylon and Islip Landfills, Long Island, New York." Geological Survey Professional Paper 1085, Washington, D.C.

000173 Geraghty & Miller, Inc.

Lappala, E.G. and G.M.Thompson. 1983. Detection of Ground Water Contamination by Shallow Soil Gas Sampling, "Proceedings of Characterization and Monitoring of the Va- dose (Unsaturated) Zone." National Water Well Associa- tion , Worthington, Ohio. Lobasso, T. and A.J. Barber. 1983. A Monitoring and Removal Plan for Leaked Propane in the Vadose Zone, "Proceedings of Characterization and Monitoring of the Vadose (Unsaturated Zone,". National Water Well Associa- tion, Worthington, Ohio. Malcolm Pirnie, Inc. 1982. Special Study Renort: Landfill Gas Monitoring Study, prepared for Syosset Central School District. Malcolm Pirnie, Inc. 1983. Special Study Report; Landfill Gas Migration Study - Updating Supplement, prepared for Syosset Central School District. Nassau County Department of Health. 1983. Laboratory Chemi- cal Analyses. 1975-1983. Nassau County Planning "Department. 1984. Draft Environmental Impact Statement for the Proposed Construction of a 1500- Car Commuter Parking Facility at Landia (Syosset). National Institute for Occupation Safety and Health (NIOSH), Occupational Safety & Health Administration (OSHA). 1978. NIOSH/OSHA Pocket Guide to Chemical Hazards. DHEW (NIOSH) B Publication 78-210, Cincinnati, Ohio. NIOSH, OSHA. 1981. Occupational Health Guidelines for Chem- ical Hazards. DHHS (NIOSH) Publication 81-123, Cincin- nati , Ohio. NISOH. 1983. Registry of Toxic Effects of Chemical Sub- i: stances 1981-1982 Edition (3 Volumes). DHHS (NIOSH) Pub- lication No. 83-107, Cincinnati, Ohio. NWWA. 1980. Manual of Recommended Safe Operating Procedures and Guidelines for Water Well Contractors and Pump In- stallers. NWWA, Worthington, Ohio. OSHA. 1983. General Industry; OSHA Safety and Health Stan- dards (29CFR 1910). U.S. Department of Labor, Washington, D.C. PettiJohn, R.A. 1977. "Nature and Extent of Groundwater Quality Changes Resulting from Solid Waste Dis- posal, Marion County, Indiana". Water Resources Investi- gations 77-40, U.S. Geological Survey, Washington, D.C.

000174 Geraghty & Miller, Inc.

Table 3.1 Inventory of Safety Equipment to be Kept on Site

Minimum Quantity on Hand Item

10 Tyvek Coveralls, assorted sizes 5 Polyethylene-Coated Tyvek Coveralls, assorted sizes 1 dozen Nitrile Gloves 5 sets Raingear 1 box (100) Latex Surgical Gloves 10 Tyvek Hoods 2 MSA Full Face Ultra Twin Air-Purifying Respirator 4 MSA Half Face Comfo II Air-Purifying Respirator 2 boxes (10 ea.) Organic Vapor Cartridges 10 pair Safety Glasses 6 Hard Hats 1 First Aid Kit 1 Fire Extinguisher, ABC Type 4 Splashshields (Hard Hat Compatible) 1 Enmet (CGS-10 Tritector) \ 1 MSA Explosimeter 1 Century Systems OVA 1 HNU Photoionizer or Photovac TIP 1 10 gallon eye wash station Plastic Sheeting and Plastic Bags

Duct Tape 000175 SYOSSET LANDFILL - RI/FS TEAM £& MILLER, INC. uround-Haier Conlulianu TOWN OF OYSTER BAY I DPW USEPA CD NYSDEC O PROJECT MANAGER Q J. LEKSTUTIS (LKB)

GAM PROJECT OFFICER HEALTH A SAFETY OFFICER M. MCEACHERN A. BARBER (GAM)

-L REMEDIAL INVESTIGATION LEADER FEASIBILITY STUDY LEADER C. CREED GEOHYDHOLOGI8T PAUL LAPPANO ENV. ENGINEER (GAM) (LKB)

D. ST. GERM AIM GEOLOGIST ROSE PELINO CIVIL ENGINEER (GAM) (LKB)

A. BARBER GEOCHEMIST RAY WEGENER CHEMICAL ENGINEER (GAM) (LKB)

DAVID SCHANTZ FIELD TECHS JEFF OVERTON ENV. SCIENTIST RICHARD SWEDORG (LKB)

JIM PLUNK ETT AERIAL PHOTO C. CREED GEOHYDROLOGIST (LKB) INTERPRETER (GAM)

LABORATORY DRILLER

TO BE BID FIGURE 1.1 / . QAS MONITORING WELL

SYOSSET LANDFILL SITE PLAN

SITE LOCATION MAP

FIGURE 2.1 t Miller. Inc. ! ; />^ ,- ' ; -. .-=.-^--Vx I \/'

SCALE 1*. *00' . • ••, ',' ••o'-"^• V y , / "'N-•—...,. , f .^ /--\/.,....»aJ""'\ .. ' ' \ 1, 0A. n • - - -^ -• / ' J 1 i/; ••": " /" • x^ \ --" r-oX'-;'-.-—SY 2 :l : ' "" '-' - ^ \ ; "'-:" ^nf.3^..\ ->"Aia* - ' '-^^*«5^.-.

veut . GAS MONITORING WELL

MOTE COWT0U* >Wtf«V»l» S LOCKWOOO. r«oM '»" SuMvfv ** SIONUT • went *$O«* It KESSLER a SYOSSET LANDFILL SITE PLAN C014UI'""! I •*«••*«'*• jr BARTLETT. IN StTJSSFT NfWYOtIK 11^9!

WtLL INST«tLEO UNDER THE SUPERVISION OF ERM-NORTHEAST T *ELL FOR WELL SY-2 PROPOSED MONITORING WELL LOCATIONS FOR SHALLOW WELL

FOR WELLS DRILLED TO THE 200 FT DEPTH iOIL*WimlNC DRILLED UNOFR THE SUPERVISION 3f LOCKWOOD KESSLER AND BARTLETT, INC FIGURE 2 Geraghty & Miller, Inc.

•LOCKING STEEL COVER

SPACE ——r I CEMENT •? ' L

4 INCH ID PVC CASING !v ^ j;

;——53 .—— — 6 INCH DIAMETER BOREHOLE ij;

— p———— BENTONIT B E SLURRY

ij; !

• \m ——————— SANS* D PACK ; = : ————— 1100 FT. LENGTH OF SCREEN -L -" ' ' g " '• ' -i L APPROXIMAT** E DEPTH I40FEET

iii g SAND PACK ^•B

_^^».»————— »«l^—— MM———— ™•H«IWB» ,< 10 FT. LENG1 i •Tw ^ APPROXIMATtfrpprwi MATE DEPTH 200 FEET

MtEPAftED FOR LOCK WOOD, KItSLEft AMD BAKTtETT. WC. AND THE TOWN OF OYftTE* »AV

•VOttET LANDFILL •YOitET, MEW VOAK CONSTRUCTION DETAILS OF THE MONITORING WELLS GAS MONITORING WELL HW6

WATER MONITORING WF

SY-6

ANIMAL <3H6U6fe *

= - = S LOCKWOOD. Sm ST"i KESSLER & SYOSSET LANDFILL SITE PLAN m.m.mS BARHETT. INC

tXPLANATION RING WELL INSTALLED UNDER THE SUPERVISION OF ERM-NORTHEAST iORING DRILLED UNDER THE SUPEHV I'ttON Of IOOO KEbStf R AIM) BARTLETT. INC

S£0 SOU BORING LOCATION WHERF MONITORING *l LI PROPOSED LANDFILL BORING LOCATIONS Hi INSIALLEU

>ED SOIL BORING LOCATION FIGURE 2.4 _ 'GERAGHTY V& MILLER, INC. Ground-Water Consultants

LOCKING STEEL COVER

CEMENT CLEAN FILL

2-INCH I.D. PVC CASING

BENTONITE SLURRY

REFUSE >INCH BOREHOLE

FORMATION

GRAVEL PACK : •;v-"' : Water Tftbl* IT? -? • • § v •• •frrr* 10-FOOT LENGTH OF SCREEN

PREPARED FOR LOCKWOOD. KE88LER AND BARTLETT. INC. AND THE TOWN OF OYSTER BAY

•YOSSET LANDFILL SYO88ET. NEW YORK CONSTRUCTION OF WELLS PLACED IN LANDFILL BORINGS

FIGURE 2.5

00018J,30- Y& MILLER. INC. Ground- H 'airr Consultants

POLYETHYLENE/SILICONE TUBING CAP

•1-INCH I.D. PVC CASING r .LAND SURFACE •BENTONITE SLURRY

• 2-INCH-DIAMETER BOREHOLE

4-6'

L •HAND CUT SLOTS PI GRAVEL PACK i;

PREPARED FOR LOCKWOOD. KESSLER AND BARTLETT, INC. AND THE TOWN OF OYSTER BAY

SYO8SET LANDFILL SYOSSET, MEW YORK

TYPICAL GAS MONITORING WELL

FIGURE 2.6 000132- :_ ,*»-"> \

GAS MONITORING WELL UKie

WATER MONITORING

-lNACTlN/6

NOTE CONTOUR INTERVALS FROM i<»7T SURVEY BV = = - = S LOCKWOOD. SIDNEY a BOWNC ft SON KESSLER & I AKinCTII I CITE Dl AM CO »H o o o

SY(

EXPLANATION A MONITORING WELL INSTALLED UNDER THE SUPERVISION OF ERM-NORTHEAST r\ SOIL BORING DRILLED UNDER THE SUPERVISION OF LOCKWOOD KESSLER w AND BARTLETT, INC

(6) PROPOSED GAS MONITORING WELL LOCATION _ 'GERAGHTY *& MILLER, INC. Ground- Waitr Consultants r TRAP

POLYETHYLENE AND 8ILICONE TUBING

GAS MONITORING WELL

PREPARED FOR LOCK WOOD, KE8SLER AND SARTLETT, INC. AND THE TOWN OF OYSTER BAY

SYO88ET LANDFILL •YO88ET, NEW YORK

GAS MONITORING WELL SAMPLING APPARATUS

FIGURE 2.8 00(5185 ^ITGERAGHTY ?& MILLER. INC. Ground- H'aier Consultants

SAMPLE CONTAINERS (INITIATE CHAIN OF CUSTODY)

SAMPLE COLLECTION

GENERATION OF DATA DATA COLLECTION OR GENERATION ON GAM FORM

CHECK BY PROJECT GEOLOGIST CORRECT PROBLEM

IDENTIFY PROBLEM

SUBMISSION TO WEEKLY \y PROJECT MANAGER JL:: LABORATORY DATA FIELD DATA REVIEW: REVIEW; PROJECT PROJECT MANAGER GEOCHEMIST PROJECT GEOLOGIST

YES YES

ENTRY INTO DATA HARD COPY MANAGEMENT PROJECT FILE SYSTEM

PROOF AND CORRECTION OF TYPOGRAPHICAL _ ERRORS

DATA t RETAIN DATA FORMAT REVIEW BY IN SYSTEM SUBMITTER i .ACCEPTABl "8 PREPARED FOR LOCKWOOD. KESSLER AND BARTLETT. INC AND THE TOWN OF OYSTER BAY LEGEND

8YOSSET LANDFILL ftflfl 1 K ft SYOSSET. NEW YORK U X M° 'GERAGHTY V& MILLER, INC. Ground- M oler Consultants

WORK ZONE

BOOT REMOVAL EYE WASH STATION

BENCH

COVERALL REMOVAL

66-GALLON DRUMS

GLOVE REMOVAL

DROP OFF HARD HAT. GLASSES, OTHER EQUIPMENT 09 Im-

WASH-UP

CLEAN ZONE

TRAILER

PREPARED FOR LOCKWOOD, KE8SLER AND BARTLETT, INC. AND THE TOWN OF OYSTER BAY

• YO8SET LANDFILL BYOSSET. NEW YORK

SCHEMATIC OF DECONTAMINATION FACILITY

FIGURE 4.1 000 f $7 TIME IN WEEKS

8 t 13 17 21 25 *• 33 37 41 48 49 83 87 81 «8 8* 73 77 81

1. DEVELOPMENT Of SITE OPERATIONS PLAN • SAMPLING PLAN • OA/OC PLAN • HEALTH » SAFETY PLAN

1. EVALUATION OF EXISTING DATA-BASE AND AERIAL PHOTOGRAPHS

3. SUBCONTRACTOR PROCUREMENT • MD PREPARATION • RESPONSE. SELECTION

4. PHASE 1 FIELD ACTIVITIES • QftOUNOWATER MONITORING WELL INSTALLATION • LANDFILL SORINQ8 ••i •MHHM • SAMPLING — - - - • WATER LEVEL MEASUREMENTS . » „ ______• OA8 MONITORING WELL INSTALLATION • SAMPLING < • l •

S. EVALUATION OF PHASE 1 DATA

S. PHASE II FIELD ACTIVITIES • DEVELOPMENT OF PHASE II WORK PLAN —— • IMPLEMENTATION OF PHASE II ACTIVITIES

T. DEVELOPMENT OF THE Rl REPORT

•. FEASIBILITY STUDY • DEVELOPMENT OF F8 WORK PLAN _

t. DELIVERASLES LEGEND • PHASE II WORK PLAN , • PHASE 1 Rl REPORT -, CONTINUOUS ACTIVIT- • FINAL Rl REPORT . . PERIODIC ACTIVITY • FS WORK PLAN ' ^•* FIGURE 8.1 SYOSSET LANDFILL o REMEDIAL INVESTIGATION SCHEDULE o o *-><* 00 Or* Geraghty & Miller, Inc.

POWER CABLE WITH MARINE TYPE PLUG EXISTING LOCKING COVER DISCHARGE PIPE ( I- INCH PVC) WITH ACCESS PORT QUICK CONNECT FITTING WITH PLUG rrri

SUPPORT EYE BOLT

STAINLESS STEEL CABLE CLAMP AND BAIL LOOP

4-INCH PVC CAP

STAINLESS STEEL SUPPORT CABLE

4- INCH PVC CASING

6-INCH STEEL CASING

PORT FOR SUPPORT CABLE ( 0.25" DIA )

TOP VIEW OF 4-INCH PVC CAP PORT FOR DISCHARGE LINE I.25"OA )

ACCESS PORT WITH PLUG (I.25"DIA.)

PORT FOR POWER CORD (0.5"DIA.)

Fr*ptr»d fcy OERAOHTY t MIIJLtR, WC. fer UOCKWOOO. KEtSLER AND BARTLETT. INC. TYPICAL COMPLETION AND THE TOWN OF OYSTER §>AY FOR WELLS EQUIPPED WITH

8YOSSET LANDFILL SUBMERSIBLE PUMPS SYOSSET, NEW YORK "BOTftfS SAMPLE / DISCHARGE FITTING

VALVE VALVE

TO FLOW-THROUGH DISCHARGE CELL

'/<" POLYETHYLENE COUPLING TUBING

PVC RISER PIPE

PROTECTIVE CASING

FLOW-THROUGH CELL DISCHARGE

DISCHARGE FROM FITTING ABOVE 000 \ HOLES FOR BUFFERS, ELECTRODES.etc.

Pr«p«r»d by OERAQHTY A MILLER, for SAMPLE / DISCHARGE FITTING LOCKWOOD. KEISLER AND 1ARTLETT, INC. AND THE TOWN OF OYSTER BAY AND FLOW-THROUGH CELL

SYOSSET LANDFILL SYOSSET, NEW YORK FIGURE C.2 000190 Geraghty & Miller, Inc.

APPENDIX A

EXAMPLE DATA TABLES

000191 OJ 03 :QNCENTRATIQNS mg/L (UNLESS OTHERWISE SF-EC1FIED) *••-< CD WELL SAMFLE COLLECT ION ALUMINUM AI1T IMONY CADMIUM COPPER IRON LEAD MANGANESE ^ NUMEiER DATE PROTOCOL as A) a& bb as Cd as. CLI as. Fe as Pb as Mn O

1 6/J9/B5 N <0.05 .O.O05

N - Not satisfactory S - Satisfactory U - Unknown WATER LEVEL DATA FOR OFFSITE MONITORING AND OBSERVATION WELLS. €*•) OCTOBER 5, 1984 03 »H O MEASURING DEPTH o POINT to WATER LEVEL ELEVATION WATER ELEVATION o ( f eet above(feet below (feet above WELL mean measur i ng mean COLLECTION NUMBER sea level) point) sea level) PROTOCOL SS3S — ^— =

Phase 3 ttl 111.43 37.22 74.21 N Phase 3 1(2 118.74 44.12 74.62 U Phase 3 t»3 126.51 49.82 76.69 S Phase 3 *4 ISO. 08 72.01 78.07 N Off site 5A 137.13 64.02 73.11 U Qffsite 5B 138.43 65.36 73.07 S Off site 6A 160.24 9O.23 70.01 N Off site 6B 16O.39 87.42 72.97 U Qffsite 6C 159.99 88.65 71.34 S Offsite 6D 159.23 89.46 69.77 N Off site 6£ 16O.88 87.43 73.45 U Qffsite 6F 158.75 92.34 66.41 S Off site 7A 148.44 78.21 70.23 N Offsite 7B 147.78 95.71 52. O7 U Offsite BA 134.94 88.88 46. 06 S Offsite 8B 134.24 77.77 56.47 N Offsite BC 135.66 99.99 35.67 U Offsite 9A 153.35 98.98 54.37 S Offsite 9B 153.50 87.87 65.63 N Offsite 9C 153.53 76.76 76.77 U Offsite 9D 152.95 67.67 85.28 S Offsite 10A 161.12 68.79 92.33 N Offsite 10B 161.28 79.78 81.50 U Qffsite 10C 160.27 96.96 63.31 S Offsite 1OD 161.17 86.85 74.32 N Offsite 11A 8O. 19 55.55 24.64 U Offsite 11B 79.91 56.29 23.62 S

N - Not satisfactory S - Satisfactory U - Unknown Geraghty & Miller, Inc.

APPENDIX B PROTOCOL FOR SCREENING SOIL SAMPLES FOR VOCs

0 E

000194 Geraghty & Miller, Inc.

APPENDIX B

Protocol for Screening Soil Samples for VOCs

Equipment: TIP, OVA or HNU . Sample jars with lids (approximately 250 ml) * Polyethylene sheeting I' Rubber band

: Procedure: ii 1. Transfer a representative portion of the sample into the sample I j jar and fill it approximately halfway.

I 2. Seal the jar with a piece of the polyethylene sheeting and secure it with a rubber band. f1 n 3. Store the sample for at least one hour in a warm area (25°C minimum). 4. In order to take a measurement, push the intake probe of the in- 1 1 strument through the plastic, taking care not to allow soil or wa- r ter to enter the intake. 5. Record the highest reading, which usually occurs within 5 seconds of puncturing the seal. Record measurement on log. Allow meter to return to zero before next measurement.

000195 ' Geraghty & Miller, Inc.

r APPENDIX C i; PROTOCOL FOR SAMPLING GROUND WATER BY SUBMERSIBLE PUMP c r

000196 Geraghty & Miller, Inc.

APPENDIX C

Protocol for Sampling Ground Water by Submersible Pump

Equipment: Generator Distilled Water Extension Cord Rags Measuring Tape and Chalk (M-Scope) MICROT M Laboratory Cleaner Sample/Discharge Fitting Sample Containers Sample Bottles Plastic Sheeting Filter Funnel Flow-through Cell Prefilters • pH Meter and Buffers 5.0 urn filters Test Tube or Vials 0.45 urn filters Conductivity Meter and Standard Graduated Bucket Gloves (Latex, Nitrile, or equivalent) Vacuum Pump Thermometer Vacuum Flasks Procedure: 1. Wells will be completed as shown in Figure C.1. Unlock the well and measure the depth to water with a chalked tape or M-Scope to the hundredth of a foot. Calculate the amount of water standing in the well.

2. Connect the sample/discht^ge fitting (shown on Figure C.2) to the discharge pipe. Start generator and plug extension cord in; connect extension cord to the pump power cable.

000197 Geraghty & Miller, Inc. C~2

3. Using the valve on the fitting, adjust the pumping rate so that it is not continuously drawing down to the pump intake (consult sam- ling logs from previous sampling rounds for pumping rates for individual wells, if possible). Periodically measure the the flow rate using a graduated bucket. Record pumping rates on sampling log.

4. Pump three times the amount of standing water from the well before I sampling. Put on protective gloves.

1it 5. When the well is nearly ready for sampling, attach the flow- through cell to the discharge, as shown in Figure C.2. Insert r |.i thermometer, conductivity standard, and pH 4 and 7 buffers (con- p tained in test tube or vials) into the flow-through cell and

" allow a few minutes for thermal equilibration. Read and record

Ff temperature; set pH temperature knob to the measured temperature

and calibrate meter with buffers; calibrate conductivity meter. |IJ Insert pH electrode and conductivity cell into the flow-through cell. Record pH and conductivity. Label all sample containers

:l { (project, well,date, etc.) and wrap with tape. fI " 6. Clean funnel and flasks with 2% MICROT M" solution and distilled water. Fill a flask about two-thirds with sample. Filter the sample sequentially through prefilter, 5.0 urn and finally 0.45 urn filters. Transfer sample to pre-acidified container for metals analysis.

000198 C-3 Geraghty & Miller, Inc.

7. Adjust valve so that flow from the sample discharge (polyethylene tubing) is a trickle. Fill VOC vials, making sure there are no trapped air bubbles. 8. Fill remaining containers and place all filled containers in cooler with ice. Note: do not rinse bottles with sample water before filling, as some containers contain preservatives.

9. Complete Water Sampling Log and Chain of Custody form.

10. Lock well and deliver samples to laboratory as soon as possible. Obtain signature from receiver at laboratory on Chain of Custody. n

000199 Geraghty & Miller, Inc.

r APPENDIX D PROTOCOL FOR SAMPLING GROUND WATER WITH A BAILER

L. Fl

000200 Geraghty & Miller, Inc.

APPENDIX D

Protocol for Sampling Ground Water with a Bailer

Equipment: Measuring Tape and Chalk or M-Scope Prefilters Rags Filters (0.45 urn, 5 urn) Distilled Water Filters Funnel (Gelman) Plastic Sheeting Vacuum Flasks (1 liter) Nylon Cord Vacuum Pump (electric or hand operated) Bailer (PVC, Teflon or Stainless Steel) Thermometer I'! MICRO""TM1 Laboratory Cleaner LJ Sample Bottles Buckets, Graduated 1 1 i Gloves (Latex, Nitrile or equivalent)" p, pH Meter and Buffers J » Conductivity Meter and Standard PJ Beakers Brushes f; [[ Procedure: 1. Open the well and clean off any surficial dirt from the protective i: casing.

2. Measure the depth to water in the well to the hundredth of a foot with a chalked tape or M-Scope; sound the depth of the well, if necessary. Compute the amount of water standing in the well.

3. Place plastic sheeting down around the well and secure it at the corners.

000201 Geraghty & Miller, Inc. D_2

4. Disassemble the bailer, if appropriate, and immerse the bailer in a 2% solution of MICROT M , or pour the solution in and over the bailer. Scrub the bailer with a brush to remove surficial contaminants. Rinse the bailer (or parts) with copious amounts of distilled water. Wear clean gloves when handling a clean bailer.

I 5. Reassemble the bailer and place on the plastic sheeting. Attach an appropriate length of nylon cord to the bailer using a secure I; knot.

I j 6. Lower the bailer into the well and into the water column gradual- ., ly, to minimize turbulence. Allow the bailer to sink and become ' * fully submerged. Recover the bailer from the well and empty into c a graduated bucket. 7. Bail three times the amount of standing water from the well, or f! bail well dry and allow to recover. Bailer cord can be held in

I : hand or laid on plastic sheeting while bailing.

M 8. Prepare to take pH, conductance and temperature measurements. Calibrate conductivity meter with standard, and pH meter with 1 pH 4 and 7 buffers; rinse electrode and cell with distilled water.

9. Fill a beaker with sample and immerse thermometer, pH electrode and conductance cell. Swirl pH electrode and record pH. Swirl conductance cell and record conductance. Record temperature.

00.0.202 Geraghty & Miller, Inc. D"3

10. Label all containers (project, well, date, etc.) and wrap with tape.

11. Clean funnel and flasks with 255 MICROT M solution and rinse with distilled water. Fill one of the flasks about two-thirds full. Filter the sample consecutively through a prefilter, 5.0 urn filter and finally through a 0.45 urn filter. Transfer the sample to the pre-acidified container for metals analysis.

12. Fill the 40 ml vials for VOCs, insuring that there are no air bub- " bles. Ii! "- 13. Fill remaining sample containers. Note: Do not rinse containers 1,i with sample, as some containers contain preservatives.

14. Close well.

n11 15. Pack samples on ice in a cooler. Fill out remaining data on Water rj Sampling Log and complete Chain of Custody. Deliver samples to P the lab as soon as possible and obtain receivers signature on { : Chain of Custody form.

I 16. Discard cord, gloves and sheeting. Place bailer in plastic bag until next use.

000203 Geraghty & Miller, Inc.

APPENDIX E

ANALYTICAL PARAMETERS li [I C B

000204 Geraghty & Miller, Inc. APPENDIX E ANALYTICAL PARAMETERS

SELECTED ENVIRONMENTAL PROTECTION AGENCY PRIORITY POLLUTANTS

Base-Neutral Extractable Organics Volatile Organics Metals

Acenaphthene Benzene Antimony Acenaphthylene Bromoform Arsenic Anthracene Carbon tetrachloride Beryllium Benzidine Chlorobenzene Cadmium Benzo(a)anthracene Chlorodibromomethane Chromium Benzo(a)pyrene Chloroethane Copper 3,4-Benzo f1uoranthene 2-Chloroethyl vinyl ether Lead Benzo(ghi)perylene Dichlorobromomethane Mercury Benzo(k)fluoranthene Dichlorodifluoromethane Nickel bis(2-Chloroethoxy) methane 1.1-Dichloroethane Selenium bis(2-Chloroethyl) ether 1.2-Dichloroethane Silver bis(2-Chlorisopropyl) ether 1.1-Dichloroethylene Thallium bis(2-Ethylhexyl) phthalate 1.2-Dichloropropane Zinc 4-Bromophenyl phenyl ether 1.3-Dichloropropylene Butyl benzyl phthalate Ethylbenzene 2-Chloronaphthalene Methyl bromide PCBs 4-Chlorophenyl phenyl ether Methyl chloride Chrysene Methylene chloride PCB.-1242 [ Dibenzo(a,h)anthracene 1,1,2,2-Tetrachloroethane PCB-1254 1.2-Dichlorobenzene Tetrachloroethylene PCB-1221 1.3-Dichlorobenzene Toluene PCB-1232 1.4-Dichlorobenzene 1,2-trans-Dichloroethylene PCB-1248 3,3'-Dichlorobenzidine 1.1.1-Trichloroethane PCB-1260 Diethyl phthalate 1.1.2-Trichloroethane PCB-1016 Dimethyl phthalate Trichloroethylene Di-n-butyl phthalate Trichlorofluoromethane 2,4-dinitrotoluene Vinyl chloride 2,6-dinitrotoluene Di-n-octyl phthalate 1,2-diphenylhydrazine Acid Extractable Organics Fluoranthene Fluorene 2-chlorophenol Hexachlorobenzene 2,4-Dichlorophenol Hexachlorobutadiene 2,4-Dimethylphenol Hexachlorocyclopentadiene 4,6-Dinitro-o-cresol Hexachloroethane 2,4-Dinitrophenol Indeno(1,2,3-c,d)pyrene 2-Nitrophenol Isophorone 4-Nitrophenol Naphthalene p-Chloro-m-cresol Nitrobenzene Pentachlorophenol N-Nitrosodimethylamine Phenol N-Nitrosodi-n-propylamine 2,4,6-Trichlorophenol N-Nitrosodiphenylamine Phenanthrene Pyrene 1,2,4-Trichlorobenzene 000205 Geraghty & Miller, Inc.

Additional Parameters

Total cyanides Total Dissolved Solids Specific Conductance pH Chloride Nitrate Ammonia Hardness Bicarbonate Carbonate Sulfate Sodium Potassium Barium li Iron i; c

000206 Geraghty & Miller, Inc. E-3

Analysis Method Number

Volatile Organics ERA 601 and 602 or ERA 624 Base/Neutral Extractables EPA 625 Acid Extractables EPA 604 or EPA 625 PCBs EPA 608

Metals Antimony EPA 204 Arsenic EPA 206 Beryllium EPA 210 Cadmium EPA 213 Chromium EPA 218 Copper EPA 220 Lead EPA 239 Mercury EPA 245 Nickel EPA 249 Selenium EPA 270 Silver EPA 272 Thallium EPA 279 L Zinc EPA 289 0 Additional Parameters Total Cyanide SM 412D, EPA 335.2 Total Phenols SM 51 OB Total Dissolved Solids SM 209D Specific Conductance SM 205 PH SM 423 Chloride SM 407A Nitrate SM 418F, EPA 353.2 Ammonia SM 417B, EPA 350.2 Hardness SM 314B, EPA 130.2 Bicarbonate SM 403, EPA 310.1 Carbonate SM 403, EPA 310.1 Sulfate SM 426C, EPA 375.4 Sodium SM 303A, EPA 273.1 Potassium SM 303A, EPA 258.1 Iron SM 303B, EPA 236.1 Barium SM 304, EPA 208.2

00020? Geraghty & Miller, Inc.

APPENDIX F

PROTOCOL FOR SOIL SAMPLING

EI r

000208 Geraghty & Miller, Inc.

APPENDIX F

Protocol for Soil Sampling

Equipment: Split Spoon Sampler(s) MICROm T M Laboratory Cleaner Brushes Plastic Buckets _., Distilled Water (several gallons) •• Plastic Sheeting I Table (optional) Surgical Gloves (or equivalent)

Procedure: C 1. Prepare a 2% solution of MICROT M and distilled water in a bucket. fl 2. Disassemble the split spoon sampler and immerse all parts and the I! T | i spatula in the MICROM solution. Scrub with brush to remove any i adhering particles. ' Note: Wear gloves while cleaning equipment and taking samples to avoid sample contamination. Change gloves frequently.

3. Rinse all parts with copious amounts of distilled water. Place clean parts on plastic sheet (using a table makes this operation easier).

4. Reassemble sampler when all parts have been cleaned. Store sampler in a plastic bag if it is not to be used immediately.

000209 Geraghty & Miller, Inc. p_2

5. Transfer the sampler to the driller (or helper); be sure that this person also has clean gloves on.

6. The sample will then be collected by the driller using the standard penetration test.

• 7. Obtain the sampler from the driller and place it on plastic sheeting. r 8. Unscrew the end cap and break the spoon open to expose the sample. i: 9. Using only the spatula, cut off the top 2-3 inches of sample and discard, and transfer an appropriate portion to the sample con- n tainer. Fill the container as completely as possible.

*•* 10. Fill out the sample label (project, location, depth, date, etc.) FFI and cover with transparent tape. Place the container in a cooler with ice.

11. Fill out Sample/Core Log and Chain of Custody Form (copies of i these forms are given in Appendix H). !

I 12. Deliver sample to the lab as soon as possible; obtain signature i on Chain of Custody Form.

00021C Geraghty & Miller, Inc.

APPENDIX G I LABORATORY QUALITY ASSURANCE/QUALITY CONTROL PROCEDURES

L 0 r ii

000211 'CO!£ST LABORATORIES, INC. ENVIRONMENTAL TESTING

377 SHEFFIELD AVE. • N. BABYLON, N.Y. 11703 • (516) 422-5777

Dec. 6, 1985

Geraghty & Miller I North Shore Atrium I 6800 Jericho Tpke. Syosset, NY 11791 r1 ; Attn: Mr. Andrew J. Barber

[j Dear Andy:

1 I J Enclosed please find outline of our standard QA/QC Procedures. We expect to have any GC/MS work done by York laboratories. Their outline of QA/QC procedures is being sent to us. We shall forward it to G you as soon as we receive it. p l.i Very truly yours, EcoTestr Laboratories, Inc.

TBxmas R. TreuuTein Director

H>-3 PREVENTATIVE MAINTENACE Preventative maintence is accomplished through extensive in-house maintenance of instrumentation. All equipment is serviced on a routine basis and by manufacturer's representatives as required. CORRECTIVE ACTION Problems with routine analyses are brought to the attention of the director in charge of a particular operation; the Director reviews the situation and decides on a course of action. Analyses are rerun once the problem has been identified and remedied. It is the responsibility of each technician to bring problems to the attention of the director as soon as a problem has been discovered. INSTRUMENTAL QUALI1Y CONTROL FOR WET CHEMISTRY The Following Checks are Performed and Recorded: Conductivity Meter Bi-annual check of conductivity cell over range of interest with 5 standards. Monthly cell constant determination. pH Meter Daily check with 4.0, 7.0 & 10.0 buffers. Turbidimeter Bi-annual complete calibration. li Daily check with one standard in each range. Manual Spectrophotometer Quarterly calibration for each parameter using at least 5 n standards. Daily high and low standards for each parameter or depending f on parameter, a 5 point curve may be produced. *•" Analytical Balance Annual service by professional. | Monthly check with complete series of class S weights. Ii Daily check with single class S weight. Drying Ovens j• Annual calibration of thermometers against NBS thermometers. i Daily temperature recordings. BOD Incubators Bi-annual calibration. Daily check of temperature.

000213 MONITORING OF PRECISION AND RECOVERY Wet Chemistry- Approximately 1 duplicate natural sample is included with every 15 analyses and the data is presented on an R bar, range control chart. Separate records are kept for potable and wastewater samples. Approximately 1 spike of a natural sample is performed with every 20 analyses and recorded on an X bar control chart. Separate records are kept for potable and wastewater sanples. Five standard calibration curves are generated every three months or more frequently. Standards in high and low concentration ranges are included with each batch of samples. These standards must be II within + 10% of theoretical value or samples are repeated. If repeated analysis still exceeds + 10%, a new calibration curve is generated and samples are reanalyzed. EPA control samples are analyzed for parameters that are available from EPA. One sample is included with each batch of samples run. • [5 Atonic Absorption- Quality assurance for netals analysis by Atomic Absorption 0 consists of twice daily analysis of a known reference sample, duplicate analysis of one tenth of the samples, and recovery analysis of one tenth of the samples. Graphite Furnace AA is n performed by the standard additions method. - Quality assurance data is calculated and tabulated by computer* - The correlation coefficient of the curve (minimum of five 0 standards) is computed and must be greater than 0.97. - The warning limit for analysis for all data is at +1.96 times the standard deviation and the control limit at + 2.58 the standard deviation. - Analyses performed within a run with an out of control r result are -reanalyzed.

000214 Gas Chronatography- Quality assurance for organ!cs analysis by gas chronatography consists of twice daily analysis of a known reference sample, duplicate analysis of one tenth of the samples, and recovery analysis of one tenth of the samples. Quality assurance data is calculated and tabulated by computer. The correlation coefficient of the curve is computed and must be greater than 0.97. The warning limit for analysis for all data is at +1.96 times the standard deviation and the control limit at +2.58 the standard deviation. Analyses performed within a run with an out of control result are reanalyzed.

I! f! 0

000215 • ; r. YORK LABORATORIES DIVISION

, QUALIFICATIONS, EXPERIENCE li

1- c AND n I* STANDARD OPERATING PROCEDURES

P r

000216 5.0 SPECIFIC LABORATORY TECHNIQUES (INSTRUMENTAL)

The need for good instrumental analysis is paramount In a laboratory such as ours. With state-of-the art instrumentation the tendency is to emphatically trust the microprocessor systems for QC purposes. In fact, good QC is required on a more regular basis for instrumentation than with vet chemistry since the thought processes are minimized and are handled by electronic means. Should a malfunction occur, the only monitor is a good QC program.

5.1 Gas Cbromatography/Mass Spectrometry (GC/MS •' [ Most samples analyzed in our laboratory are volatiles by Purge and Trap (EPA 624) methodology and Base/Neutral/ ; Extractables (EPA 625 - capillary column). The GC/MS 1 system for volatiles is a packed column (1% SPlOOO/Carbo- pack C) attached to a glass jet separator interface. Each day (and as corrective action for tuning indicates) the I system is manually tuned. Typically, this involves performing a peak width and mass axis calibration for the tuning compound Perfluorotributyl amine (PFTBA). The pro- C file subsequent to this tune is hard-copied and placed in nthe Instrument Tuning log. Performance is verified by injection of 50 ng of Bromof luorobenzene. The key ion abundance criteria for BFB are listed in the EPA 624 | Method. Should any ion be out of the criteria windows, | i the system is to be retuned. Experience indicates that adjustment of the ion-focus will typically bring BFB into criteria.

r- Once in criteria, reagent water is to be analyzed to [ determine if the system is int«?rf«rt»nee free. Initial calibration (5 point) is preformed and verified each day of analysis (if not verified within ± 25% a new curve is constructed). The samples are analyzed according to EPA Method 624 and EPA contract work by the CLP volatiles protocol.

Analysis for Base/Neutral/Acids is conducted on a capillary column (DH-5,30 meters, 1 u lilm) connected directly to the ion source. Kach day the system is manually tuned by calibrating peak widths and mass axis on PFTBA. The 000217 121 J '•'.''•' tuning performance is checked by injection of 50 ng of Decafluorotriphenyl phosphine (DFTPP) in accordance with EPA protocol. Should any mass be out of the allowed criteria, the system must be retuned before analysis. Experience in our laboratory indicates that the typical problem ions are the relative abundances of Mass 51 and Mass 442. Adjustment of the entrance lens, then performing another peak width and mass axis calibration will most likely bring DFTPP into criteria. j Subsequent analyses are conducted according to EPA 625 or ' for EPA work, according to the contract protocols. ! ' 1 5*2 Gas Chromatography (GC) j In our laboratory, most analyses are performed according I to referenced methods from EPA. The most common method is EPA Method 608 for PCB's and Pesticides. The protocol is j strictly followed. Sample extract injections are performed utilizing auto injectors.

Where referenced protocols for a particular analyte are L not found, the following standard operation procedures are utilized.

Column Selection - a wealth of literature and experience in our laboratory is at your disposal to help you choose the proper column for a GC analysis. The column chosen should be able to separate the compounds of interest efficiently. If no literature is available for your specific problems (this will be rare) keep in mind some rules of thumb:

• What types of compounds you're working with are important - is it a. highly polar material or very non-polar (n-aliphatics); is it reactive or thermally labile?

• The major types of liquid phases for packed column use are classified as very polar, moderately polar, low polarity and non-polar. These types should cor- respond to the polarity of your material. Chromatographic Conditions - as stated earlier, the literature lists various Chromatographic conditions to effect good analysis.

In general, the injection port and detector temperatures should be equal or the detector temperature slightly warm- er. The injection port should never be significantly (10°C) hotter than the detector as condensation on the detector may occur.

One should also keep in mind the compounds to be chromato- i. graphed. Many times injection port temperatures if too hot can decompose or rearrange certain compounds which are thermally labile. Silanization of injector areas is also helpful in eliminating losses of certain ompounds.

Quantitative Analysis - in our laboratory external standard peak height and peak area measurements are used. As long as the standards and samples are run under the exact same Chromatographic conditions this method is accurate, allowing for matrix affects which are examined L through surrogate checks. The following guidelines are used for quantitative C analysis: 1. A blank is run to show that the system is interference free. This blank is run at a high sensitivity.

When temperature programming with high liquid phase loadings (>5%), some column bleed may create baseline drift necessitating lowering the sensitivity to some L love 1.

2. A series of standards is prepared which cover the lower detectable limit you are going to achieve, and two (2) other ranges which are dependent upon where you think your sample will fall, but covering the linear working range.

123

-.OfI 000219 These standards are injected going from the lowest to the highest concentrations.

3. Subsequent to these injections, the calibration factor for each standard is calculated. They must agree within ± 10% or a problem may exists. This problem may be detector linearity, injection technique or thermal decomposition of the material in the injection port, to name a few.

Peak areas are measured using electronic integration.

4. At all times the area of a sample must be bracketed by two standards, one higher and one lower. This will insure the sample analyte is within the linear working range of the particular column/detector system.

The linear working ranges of the GC detectors we have at York are listed as follows:

L Detector Working Range Comment I Flame 0.5 ppm to Depends upon type lonization 10,000 ppm of compound

I! Thermal 0.1% to 100% Independent of Conductivity type

Electron 0.05 ppm to Only for electron I Capture 20 ppm deficient atoms Flame 0.1 ppm to Only for sulfur or Photometric 100 ppm phosphorus compounds

5-3 Atomic Absorption Spectrophotometry (AAS)

Atomic absorption spectroscopy is a very useful instrumental technique for metals analysis. Basically, tht? technique involves absorption of radiation specific to an

124 Geraghty & Miller, Inc.

r APPENDIX H GERAGHTY & MILLER, INC. FORMS li c n

00022: GERAGHTY ',> MILLER. INC. iround- H ater Consultants

DAILY LOG

Well(s). . Project/No.. .Page. .of.

Site Location

Prepared By

Date/Time Description of Activities

-9-00222 _ 'GERAGHTY Y& MILLER, INC Ground-Water Consultants

SAMPLE/CORE LOG Boring/Well. .Project/No. .Page. .of. Site Drilling Drilling Location _ .Started. .Completed.

Total Depth Drilled. .(feet) Type of Sample/ Hote Diameter ___ .(inches) Coring Device _ Length and Diameter of Coring Device __ .Sampling Interval. .feet

Drilling Fluid Used .Drilling Method. Drilling Contractor ___ .Driller. .Helper. Prepared Hammer Hammer n By———————— .Weight_ Prop . inches SampWCoi* Depth . ThM/HydrauBe (fMt Mow land urface) Cora PiMtura or li. ftooovtry Blows per S i: From To (tact) Inch** Sampta/Com DMeription c G 11 fi r , '

• Cr-022! J^GERAGHTY '.'& MILLER, INC. Ground-U'eier Consultants

SAMPLE/CORE LOG (Cont.d)

Prepared By

Svnpta/Cor* Depth Thm/Hydraullc (fMt Mow U~ _.__., Cora PfMauraor rtocovtry Blowsp«r6 FfOfn TO (f*et) Inches teT*>l«/Cor* Dwcription

00025J4 _ 'GERAGHTY ?& MILLER, INC Ground- U'aitr Consultants

WELL CONSTRUCTION LOG

m* T Prftjact Well .,ft LAND SUftFACE Touun/CHy 7 / / / Crvinty State / ParrnfcNn- • , ..,,.,„.„•._„_ / ****• .- . _. inch diameter / / drilled hole Land-Surface Elevation / / and Datum „,„.,,.,, test d surveyed / ^ *s_Welf casing, n / / inch diameter, ,_,„„-.,„_.„.-!, ' ««imaled / Installation Dates(s) // C Backfill Orilling Method «jh Grout drilling Contractor Drilling Fluid

———— ft* •Bentonite O slurry Development Techniques(s) and Date(s) ft. D pellets

1 1 ".*.',*• * Ruid Loss C5uring Drilling _.,., .., „ gallons si? .*•'•'• A 1m* Water Removed During Development „..,.,_„ gallons rw !S :**':\ ^Well Screen. Static Depth to Water .„. „ ., , feet helowM P «•• & •• ___ inch diameter !& , slot Pumping Depth to Water feet below VI P MM i•• KJ ••> Pumping Duration ,.„.„.. hours •• •• •'•'* •• ^C Grave! Pack Yield gpm Date

•V % mm .* ^— O Sand Pack Specific Capacity .,„.„. gpm/ft i•« m ^D Formation !;( m* ':J& Collapse Welt Purpose ^ ••* •:Vl •• 1 M n _ —— tt* • '$?. rif. te i •^^ ., . ** Remarks

iMeasuring Point is Top of \Veil Casing Unless Otherwise fJoted.

• Depth Below Land Surface Prepared by

000225 _ GERAGHTY f& MILLER, INC £•Ground- Waitr Consultants WATER SAMPLING LOG

Project/No. . Page. .of.

Site Location. Coded/ Site/Well No. Replicate No. . Date ____ Time Sampling Time Sampling Weather _ Began ___ Completed __

EVACUATION DATA

Description of Measuring Point (MP)

Height of MP Above/Below Land Surface. MP Elevation.

Total Sounded Depth of Well Below MP . Water-Levet Elevation

Held ____ Depth to Water Below MP. Diameter of Casing _ Gallons Pumped/Bailed Wet ____ Water Column in Well. Prior to Sampling ___

Gallons per Foot. Sampling Pump Intake Setting Gallons in Well. (feet below land surface) ___

Evacuation Method.

L SAMPLING DATA/FIELD PARAMETERS

Color. .Odor. ______Appearance _____ .Temperature. »F/°C

Other (specific ion; OVA; HNU; etc.).

Specific Conductance, umhos/cm_____ PH

Sampling Method and Material.

Container Description

Remarks

* Sampling Personnel •

WELL CASING VOLUMES GAL./FT 1.%" - 0.077 2" m 0.16 3' - 0.37 4- » 0.6S 1-Vi" « 0.10 2-%" - 0.24 3-Vi" - 0.50 6" - 1.46 •

Sampler(s) ______SAMPLE CONTAINER DESCRIPTION

Date SAMPLE IDENTITY Sampled Total Remarks

Total No. of Containers

Relinquished by:. .Organization:. Received by:. .Organization:. Date: _____ . Time: Date: _.__ Time: Relinquished by: Organization:. Received by: _ . Organization: _ o Date: ______Time: ___ __ Date: ____ Time: .__ Relinquished by:. Organization:____..._. Received by: ______.Organization:_ 'Date:_____ Date: __ ._„._. Time: __„

/--*it.t.>>t« oKinr\inn Kill il (Use extra sheets, if necessar-' fcf MILLER, INC Ground-H'aitr Consultants

LOCATION SKETCH

We«(s) _____ Project/No. ______Page ____ of ____

Site Location ______

Observer ______

(Locate all wells, borings, etc. with reference to three permanent reference points; tape all distances; dearly label all wells, roads, and permanent features)

I! n i; r

Oft ft I______I

000228 Geraghty & Miller, Inc.

r APPENDIX I I" COMPOSITION OF BENTONITE

C P

000229 Geraghty & Miller, Inc.

APPENDIX I

Composition of Bentonite Drilling Fluid

Component Approximate Percentage

Montmorillonite (sodium base) 85.00% Quartz 5.00% Feldspars 5.00% Cristobalite 2.00% Illite 2.00% Calcite 0.50% Gypsum 0.50% Polymers* 0.01%

*Polymers (polyacrylate or polyacrylamide) are added to most bentonite mixtures to enhance viscosity and stability. The molecular weight of the polymers employed is greater than 10 AMU.

Sources: American Colloid, 1986; Brobst and Buszka, 1986.

OPE230 Geraghty & Miller, Inc.

APPENDIX 3

*J TOXICOLOGICAL/HAZARD DATA 0 C f!

000231 type 4/msds.onmtads

Conversion to local identifiers resulted in 1 unique occurrences.

Conversion Entry 1; Accession No. 721659B

(CAS) CAS Registry Number: 7440-38-2 •

(FML) Chemical Formula: AS4

(USS) Common Uses: METALLURGY FOR HARDENING COPPER, LEAD ALLOYS.

(MEIEDD 0001) HIGH-PURITY (SEMICONDUCTOR GRADE) IS USED TO MAKE r GALLIUM ARSENIDE FOR DIPOLES AND OTHER ELECTRONIC DEUICES; AS A DOPING AGENT IN GERMANIUM AND SILICON SOLID STATE PRODUCTS.

CSAARS* 0001 ) .

(CON) Containers: BARRELS, DRUMS. SEE ALSO CACODYLIC ACID, ACCESSION

NO. 8300187, FIELD 014. c (BIN) Binary Reactants: BARIUM BROMATE, BARIUM CHLORATE, BARIUM f. CHLORIDE, BARIUM IODATE, BROMATES, BROMINE PENTAFLUORIDE, BROMINE TRIFLUORIDE, BROMOA2IDE, CALCIUM BROMATE, CALCIUM

CHLORATE, CALCIUM IODATE, CESIUM ACETYLENE CARBIDE, CHLORATES,

CHLORINE, CHLORINE MONOXIDE, CHROMIUM TRIOXIDE, FLUORINE,

HYPOCHLOROUS ACID, IODATES, IODINE PENTAFLUORIDE., LITHIUM

MAGNESIUM BROMATE, MAGNESIUM. CHLORATE, MAGNESIUM IODATE,

NITROGEN TRIBROMIDE, NITROGEN TRICHLORIDE, POTASSIUM BROMATE,

POTASSIUM CHLORATE, POTASSIUM IODATE, POTASSIUM NITRATE,

POTASSIUM PERMANGANATE, POTASSIUM PEROXIDE, RUBIDIUM CARBIDE,

RUBIDIUM ACETYLENE CARBIDE, SILVER NITRATE, SODIUM BROMATE,

SODIUM CHLORATE, SODIUM IODATE, SODIUM PEROXIDE, ZINC BROMATE,

ZINC CHLORATE, ZINC ICDATE. (NFICAM 0001) POUDERED ALUMINUM;

BROMINE AZIDE iBROMOAZIDE'); DIRUBIDIUM ACETYLIDE; FLUORIDE5 OF

BROMINE, CHLORINE, AND IODINE; PALLADIUM; ZINC; DICHLORINE 000232 OXIDE (CHLORINE MONOXIDE); NITROSYL FLUORIDE; POTASSIUM DIOXIDE

(SUPEROXIDE). (BRETH* 0001)

(SGM) Synergistic Materials: MAY BE SYNER6ISTIC WITH SELENIUM WHEN

PRESENT IN DRINKING WATER (Rll*** 3001). INSUFFICIENT DATA ARE

AVAILABLE TO PERMIT A FINAL JUDGEMENT REGARDING SYNERGISTIC

TOXIC EFFECTS. HOWEVER, THERE MAY BE SYNERGISTIC TOXIC EFFECTS

FROM EXPOSURE TO AIRBORNE ARSENIC COMPOUNDS AND CIGARETTE

SMOKING OR FROM EXPOSURE TO ARSENIC COMPOUNDS AND SULFUR

DIOXIDE. THE DIFFICULTY IN IDENTIFYING SYNERGISTIC EFFECTS

BETWEEN ARSENIC AND OTHER ENVIRONMENTAL POLLUTANTS IS DUE TO THE

LONG LATENCY PERIOD OF ARSENICAL CANCER, PERHAPS 20 TO 30

YEARS. CDC5S«* 0001 )

(ANT) Antagonistic Materials: SELENIUM IS APPARENTLY ANTAGONISTIC TO

ARSENIC. PHYSIOLOGICAL ANTAGONIST TO THYROID HORMONES

0001).

L (FDD Detection Limit (Field: Techniques ,Ref > ( ppm ) : .03, ARSENIC m STAIN TEST, (BNW10* 0037)

(LDL) Detection Limit (Lab; Techniques ,Ref ) (ppm): .03, ARSENIC STAIN

TEST. (BNW10» 0037). NEW METHODS CAN DISTINGUISH INDIVIDUAL

ARSENIC COMPOUNDS. SCIENTISTS AT THE NATIONAL BUREAU OF

STANDARDS AND THE U.S. DEPARTMENT OF AGRICULTURE DEVELOPED SUCH

A METHOD FOR MONITORING INDUSTRIAL WASTES AND SPOT-CHECKING

DRINKING WATER. ARSENIC SPECIES ARE SEPARATED BY HPLC AND AN

INTERMEDIATE STRENGTH ANION EXCHANGE RESIN COLUMN. ANALYSIS IS

BY ATOMIC ABSORPTION SPECTROPHOTOMETRY. DETECTION LIMIT IS 0.250

PPM. (CENEAR 0009) ROCKWELL INTERNATIONAL DEVELOPED A MORE

SENSITIVE, FASTER METHOD FOR OSHA THAT ALSO DISTINGUISHES AMONG

THE SPECIES. ALTHOUGH DEVELOPED FOR AIR (DETECTION LIMIT FOR

•SRSENATE IS 1.57 .MU.G/CU M AIR;, IT COULD PRESUMABLY BE USED

FOR WATER SAMPLES. AIR FILTERS WITH ADSORBED PARTICULATES ARE 000233* EXTRACTED WITH" A CARBONATE/BORATE BUFFER. THE SOLUTION IS

SEPARATED ON A DIONEX ANION EXCHANGE COLUMN. THE ELUENT IS

MIXED WITH 15% HYDROCHLORIC ACID, THEN SODIUM BOROHYDRIDE, AND

FINALLY ARGON. THE HCL CLEAVES C-AS BONDS. BOROHYDRIDE REDUCES

THE INORGANIC SPECIES TO ARSINE, WHICH IS DECOMPOSED INTO

ELEMENTAL ARSENIC. THE ARSENIC IS MEASURED BY ATOMIC ABSORPTION

SPECTROPHOTOMETRY. THE PEAKS ARE CORRELATED WITH THE PARENT

COMPOUNDS, WHOSE CHROMATOGRAPHIC RETENTION TIMES ARE KNOWN.

(CENEAR 0007). INORGANIC TRIVALENT OR PENTAVALENT ARSENIC,

MONOMETHYLATED AND DIMETHYLATED ARSENIC ACIDS CAN BE DETERMINED

!' IN WATER SAMPLES BY ELECTROTHERMAL ATOMIC ABSORPTION

SPECTROMETRY AFTER APPROPRIATE ACIDIFICATION PROCEDURES 11 ', CONCENTRATED HCL OR A MIXTURE OF HCL, HCL04, AND HBR) AND

[., EXTRACTION BY TOLUENE'IN THE- PRESENCE OR ABSENCE OF KI. A WET

OR DRY ASHING STEP IS NEEDED FOR THE DETERMINATION OF AROMATIC

L DERIVATIVES AND OF ARSENIC THIOL COMPLEXES. (IAEHDW 0002). A

P| RADIOANALYTICAL DETERMINATION OF AS(III) AND AS(V) IN NATURAL

WATERS WAS DESCRIBED BY STARY ET AL. (1980).

( REFERENCES TO SEVERAL ANALYTICAL METHODS FOR INORGANIC OR TOTAL r> ARSENIC IN SPECIFIC BIOLOGICAL AND ENVIRONMENTAL MATRIXES ARE

REVIEWED IN (IMEMDT 0023). METHODS INCLUDE VISIBLE

( • SPECTROPHOTOMETRY, ULTRAVIOLET SPECTROPHOTOMETRY, FLAME ATOMIC i ABSORPTION AND ATOMIC ABSORPTION SPECTROPHOTOMETRY (AAS),

NEUTRON ACTIVATION ANALYSIS, SPARK SOURCE MASS SPECTROMETRY,

INDUCTIVELY COUPLED PLASMA-ATOMIC EMISSION SPECTROMETRY, X-RAY

FLUORESCENCE, DIFFERENTIAL PULSE POLAROGRAPHY, FLUORESCENCE,

AND GAS CHROMATOGRAPHY WITH AAS.

(STD> Standard Codes: ICC - POISON B, POISON LABEL; USCG - POISON B,

POISON LABEL; NFPA - 3,2,-.; NIOSH NO. C60525000. (FLM) Flanmability: MODERATE IN FORM OF DUST WHEN EXPOSED TO HEAT OR 000234 FLAME OR BY CHEMICAL REACTION WITH.POWERFUL OXIDIZING AGENTS.

(TCP) Toxic Combustion Prod.' WHEN HEATED OR ON CONTACT WITH ACID OR

ACID FUMES EMITS HIGHLY TOXIC FUMES.

SURROUNDING FIRE. USE WATER IN FLOODING QUANTITIES AS FOG. USE

FOAM, CARBON DIOXIDE, OR DRY CHEMICAL. CBUXEH* 0031)

(EXP) Explosiveness: SLIGHT - AS DUST. REACTIVE ONLY UNDER EXTREME

CONDITIONS.

| (MLT) Melting Point (C.>: BIS (SUBLIMES WITHOUT MELTING)

(SPG) Specific Gravity: 5.727 (25/4)

Ir. (VPN> Vapor Pressure (mm Hg): Bl

r- (PER) Persistency: WILL PERSIST IN VARIOUS FORMS. MAJOR ATMOSPHERIC

ARSENIC IS PARTICULATE, BUT A GASEOUS ARSENIC SPECIES OCCURS,

II ESPECIALLY WHERE TOTAL ARSENIC CONCENTRATIONS ARE HIGH. THIS MAY li BE GASEOUS AS4.QB AS WELL AS ARSINE AND METHYLARSINES. A MARCH L • 1977 STUDY IN COMMERCE, TEXAS, REPORTED FOUR TO NINE TIMES A£

MUCH INORGANIC AS ORGANIC ARSENIC IN THE AMBIENT AIR. THE

f! RESIDENCE TIME FOR ARSENIC IN THE TROPOSPHERE IS ABOUT NINE

I I DAYS. THE FORM EMITTED FROM COMBUSTION SOURCES AND SMELTERS IS ARSENIC TRIOXIDE, WHICH FORMS AS

• ; IN AQUEOUS MEDIA. ARSENITES IN THE ENVIRONMENT ARE OXIDIZED TO r ARSENATES. IN WATER, SOLUBLE ARSENIC CONCENTRATIONS VARY WITH PH, DISSOLVED OXYGEN, OXIDATION-REDUCTION POTENTIAL, AND

MINERALS PRESENT IN WATER OR SOIL SOLUTION. ARSENATE AND

ARSENITE ARE THE PRIMARY SPECIES IN NATURAL WATERS. UNDER

AEROBIC CONDITIONS, AS(V) IS STABLE IN SPECIES RANGING FROM

H3AS04 TO AS04 SUPER 3-, DEPENDING ON PH. MILD REDUCING

CONDITIONS FAVOR LESS WATER-SOLUBLE AS(III) SPECIES RANGING

FROM H3AS03 TO AS03 SUPER 3-. THE LEAST WATER-SOLUBLE AND HIGHLY VOLATILE AS, ASH3, AND DIMETHYLARSINE ARE FORMED UNDER STRONGLY 000235 REDUCING CONDITIONS. AS(V) FORMS BONDS WITH ORGANIC S, N, AND C;

AS BONDS WITH ORGANIC SH GROUPS BUT NOT AMINO GROUPS. LOW

MOLECULAR WEIGHT ORGANIC COMPLEXES WITH AS(V) PREVENT ADSORPTION

AND COPRECIPITATION OF ARSENATE WITH SESQUIOXIDES, HUMICS, ETC.

(DOSS** 0001) UNDER OXIDIZING CONDITIONS, ARSENIC MIGRATES TO

SOIL B AND C HORIZONS, WHERE IT IS HELD ON IRON AND ALUMINUM

COMPOUNDS. (CA(AS>4)2 FREQUENTLY OCCURS AS AN INSOLUBLE

COMPOUND IN SOIL. USUALLY ARSENITE AND ARSENATE ARE IN

EQUILIBRIUM; BUT UNDER WATERLOGGING (REDUCING CONDITIONS), THE

MORE SOLUBLE AND MOBILE ARSENITE PREDOMINATES. LOW r CONCENTRATIONS OF ARSENIC IN WASTEWATER AND LEACHATES PROBABLY [ WILL NOT PRECIPITATE IN SOILS. (MOVIS* 0001) IN LANDFILL LEACHATE EXPERIMENTS, ARSENIC CH2AS04 SUPER -) WAS CLASSIFIED AS i; SLOWLY MOBILE, BEING LESS MOBILE THAN ZINC AND CADMIUM IN ACID SOILS AND LESS MOBILE THAN CHROMIUM IN NEUTRAL TO ALKALINE c SOILS. (MOVIS* 0001). THIS EXPERIMENTAL RESULT WAS BORNE OUT IN p ABOUT 85 WELLS AND SPRINGS MONITORING INDUSTRIAL WASTE DISPOSAL SITES IN 13 STATES: ARSENIC WAS FOUND IN ONLY FOUR SAMPLES AT

30 TO 5,800 .MU.6/L. (SBMIG* 0001) THE EXTENT OF LOSS OF ARSENIC

APPLIED TO FIELD SOILS BY VOLATILIZATION HAS NOT BEEN

QUANTIFIED. SOIL EROSION CAN BE ANOTHER SIGNIFICANT LOSS OF

ARSENIC, BUT PLANT UPTAKE IS AN INSIGNIFICANT REMOVAL PATHWAY.

(30ULA8 0001) BIOTRANSFORMATION— THE THERMODYNAMICALLY STABLE

ARSENATE PREDOMINATES IN DEEP OCEANS: BUT IN CONTINENTAL SHELF

ENVIRONMENTS, BIOTA MEDIATE REDOX REACTIONS FAVORING REDUCED

SPECIES. UP TO 20X OF THE ARSENIC IN THESE WATERS IS UNSTABLE

ARSENITE AND DIMETHYLARSINE. MARINE ALGAE IN BACTERIA-FREE

CULTURES TAKE UP ARSENATE FROM SEAWATER AND BIOSYNTHESIZE AND

RELEASE ARSENITE AND UP TO 12 SOLUBLE ORGANCARSENIC COMPOUNDS,

INCLUDING METHYLARSONATE AND DIMETHYLARSINATE. ARSENATE MAY BE CONVERTED IN THE ENVIRONMENT VIA ARSENITE, METHANEARSONIC ACID

2>, AND DIMETHYLARSINIC ACID (CACODYLIC ACID) TO

DIMETHYLARSINE <(CH3)2ASH> BY METHANOBACTERIUM UNDER ANAEROBIC

CONDITIONS. ARSINES MAY BE RELEASED TO THE AIR, OXIDIZED BACK

TO PRECURSORS, OR DEMETHYLATED AND RETURNED AS ARSENATE TO THE

SOIL, WHERE BOTH METHYLATION AND DEMETHYLATION CAN OCCUR.

DIMETHYLARSINIC ACID IS A MAJOR, UBIQUITOUS FORM OF

ENVIRONMENTAL ARSENIC: IT IS VERY OXIDATION RESISTANT AND,

[ UNLESS SUBJECT TO BACTERIAL OXIDATION, MAY HAVE A CONSIDERABLE

RESIDENCE TIME IN NATURAL WATERS. SOIL MICROOR6ANISMS CAN

|: DEGRADE MSMA (MONOSODIUM SALT METHANEARSONIC ACID) AND DSMA

I: DISODIUM SALT), WHICH ARE USED TO CONTROL JOHNSON BRASS ON

RIGHTS OF WAY ALONG SECONDARY HIGHWAYS. PURE CULTURES OF THE

{;, ORGANISMS REQUIRE 7 DAYS TO DEGRADE 3 TO 202 OF 14C-LABELLED

C02 AND INORGANIC ARSENATE.

Li. (PFA) Potential for Accumulation: ARSENIC IS CONCENTRATED TO n LIMITED n EXTENT BY AQUATIC LIFE. IT IS A CUMULATIVE POISON IN MAMMALS ALTHOUGH A SMALL PERCENT IS CONSIDERED ESSENTIAL FOR NORMAL r !. LIFE. POSITIVE. CONCENTRATION FACTORS - MARINE AND FRESHWATER l PLANTS, INVERTEBRATES; AND FISH 333 (R170*« 0001). HALF-LIFE IN i TOTAL HUMAN BODY 280 DAYS CR172** 0001). THE PDA TOTAL DIET [" MONITORING PROGRAM SHOWS THAT THE AVERAGE DAILY INTAKE OF

ARSENIC (AS AS203, WHICH IS 76* AS) HAS DECREASED FROM

APPROXIMATELY 130 .MU.S/DAY IN 1968 TO APPROXIMATELY 20

.MU.G/DAY IN 1974. THE FOOD GROUP COMPRISING MEAT, FISH, AND

POULTRY CONTRIBUTED THE MOST ARSENIC. MEAT AND POULTRY CONTAIN

ARSENIC LARGELY DUE TO THE COMMON -USE OF CERTAIN ORGANOARSENICAL

COMPOUNDS SUCH AS ARSANILIC ACID <4-AMINOPHENYLARSONIC ACID, 4-

H2NCSH5ASC(OH>2> TO STIMULATE GROWTH OR TO PREVENT OR TREAT

DISEASES. IN THE SURVEY. THE MEAN ARSENIC CONCENTRATION IN 000237 CHICKEN LIVER AND MUSCLE WAS 0.08 MS/KG (AS AS203) AND IN BEEF,

MILK, AND EGGS, 0.02 TO 0.03 MG/K6. FINFISH CONTAINED THE

HIGHEST LEVELS OF ARSENIC, RANGING FROM NOT DETECTED TO 19.1

MG/KG (ARSENIC AS AS203); THE MEAN OF 1.47 MS/KG UAS UP TO

TWICE AS HIGH AS MEAN CONCENTRATIONS IN SHRIMP, OYSTERS, AND

CLAMS. ALTHOUGH ALL SHELLFISH WERE TAKEN FROM APPROVED

HARVESTING AREAS, CERTAIN INDIVIDUAL MOLLUSK SAMPLES CONTAINED

MORE THAN 10 TIMES THE MEAN ARSENIC CONCENTRATION FOR THE

I SPECIES. IN OTHER FOOD GROUPS, RICE CONTAINED A MEAN ARSENIC

(TRIOXIDE) CONCENTRATION OF 0.1B MG/KG. THE DROP IN THE TOTAL r DAILY DIETARY INTAKE IS PROBABLY DUE TO THE DECLINE IN USE OF ARSENIC-CONTAINING PESTICIDES SINCE THE LATE 1950S. (EVHPnZ t 00:0) !': (EDF) Etiological Potential: APPEARS RELATED TO OCCURRENCE OF BLACKFOOT DISEASE. ARSENIC IS THOUGHT TO BE A FACTOR IN THE G OCCURRENCE OF HAFF'S DISEASE IN HUMAN BEINGS. Carcinogenicity: POTENTIALLY CARCINOGENIC IN yATER. POTENTIAL.

(CUJQPAV 0001) EPIDEMIOLOGICAL STUDIES INDICATE AN APPARENT [] CAUSAL RELATIONSHIP BETWEEN SKIN CANCER AND HEAVY EXPOSURE TO INORGANIC ARSENIC VIA MEDICATION, CONTAMINATED WELL WATER, OR f! OCCUPATIONAL EXPOSURE. SKIN CANCER AS A RESULT OF ARSENICAL

POISONING IS CHARACTERIZED BY MULTIFOCAL LESIONS OVER THE ENTIRE

BODY. AMONG THE SEVERAL TYPES OF SKIN CANCER, EFITHELIOMA

DEVELOPING ON THE KERATOSES SITE IS MOST COMMON. THE CAUSAL

RELATIONSHIP BETWEEN EXPOSURE TO ARSENICAL DUST AND LUNG CANCER

UAS CONFIRMED BY EPIDEMIOLOGICAL OBSERVATIONS IN 1977. PINTO

<1977) SHOWED A HIGHER RISK OF LUNG CANCER AMONG WORKERS

EXPOSED TO ARSENIC TRIOXIDE IN SMELTERS AND INSECTICIDE

FACTORIES. RESPIRATORY CANCER MORTALITY HAS BEEN RELATED TO AN

ARSENIC EXPOSURE INDEX (INTENSITY AND DURATION)' AND TO THE 000238 AVERAGE LEVEL OF ARSENIC IN THE URINE. AT PRESENT THERE IS

INSUFFICIENT KNOWLEDGE OR EVIDENCE ABOUT THE NATURE OF MECHANISM

OF ARSENIC CARCINOGENICITY IN HUMANS TO DETERMINE A THRESHOLD

LEVEL FOR ARSENIC. WICKSTROM (1972) HAS CITED AN INCREASED

RELATIVE FREQUENCY OF DEATHS FROM LUNG CANCER IN POPULATIONS

; EXPOSED TO ARSENIC IN DRINKING WATER IN ARGENTINA. TUMORS IN

OTHER ORGANS HAVE ALSO BEEN REPORTED IN THESE STUDIES IN

POPULATIONS EXPOSED TO INORGANIC ARSENIC AS MEDICATION. AS AN

INSECTICIDE, AS CONTAMINATED WINE, AND IN DRINKING WATER. IARC

(1373), HOWEVER, CONCLUDED THAT THE RELATIONSHIP BETWEEN ARSENIC r EXPOSURE AND A HIGHER RISK OF CANCER IN ORGANS OTHER THAN SKIN I- AND LUNGS HAS NOT BEEN CONFIRMED. IN SPITE OF THE EPIDEMIOL06IC

'. ASSOCIATION BETWEEN EXPOSURE TO ARSENIC AND CANCER OF THE SKIN n E i AND LUNGS IN MAN, RELIABLE AND CONSISTENT ANIMAL MODELS OF ARSENIC CARCINOGENICITY HAVE NOT BEEN ACHIEVED. OSSWALD AND ti SOERTTLER (1971) SUGGESTED LYMPHOMA WAS INDUCED IN MICE THAT

|Ff| ; WERE EXPOSED TO SEVERAL ARSENICAL COMPOUNDS BY SEVERAL ROUTES.

THE MECHANISM?S) OF INORGANIC ARSENIC CARCINOGENICITY IS

|j SPECULATIVE. IT IS GENERALLY ACCEPTED BY MEDICAL AND REGULATORY

.. AUTHORITIES THAT TRIVALENT ARSENIC IS AN OCCUPATIONAL

'• CARCINOGEN. THE DATA REGARDING HAZARDS ARISING FROM EXPOSURE f - TO PENTAVALENT ARSENIC ARE CONTRADICTORY, AND DIFFERENT t BIOCHEMICAL MECHANISMS FOR THE TWO FORMS OF INORGANIC ARSENIC

HAVE BEEN POSTULATED. SINCE THE ACTUAL MECHANISM(S) RESULTING

IN RESPIRATORY CANCER ARE NOT PROVEN, PENTAVALENT ARSENIC IS

TREATED AS A CARCINOGEN UNTIL CONVINCING EVIDENCE IS PRESENTED

TO THE CONTRARY. (FEREAC 0001 0004) (IMEMDT 0003) AND OTHER

REFERENCES CITED IN (DOSS** 0001) IN 1979, THE INTERNATIONAL

ASSOCIATION FOR RESEARCH ON CANCER (IARC) CONCLUDED THAT

INFORMATION ON THE CARCINOGENICITY OF ARSENIC COMPOUNDS IN \ EXPERIMENTAL ANIMALS IS INADEQUATE FOR EVALUATION. THE

INFLUENCE OF CONSTITUENTS OTHER THAN ARSENIC TRIOXIDE OF THE

WORKING ENVIRONMENT CANNOT BE EXCLUDED IN EPIDEMIOLOGICAL

! STUDIES. AN ASSOCIATION BETWEEN EXPOSURE TO ARSENIC COMPOUNDS

AND BLOOD DYSCRASIAS AND LIVER TUMORS HAS BEEN SUGGESTED BY

CASE REPORTS. (IMEMDT 0020) THERE IS SUFFICIENT EVIDENCE THAT

INORGANIC ARSENIC COMPOUNDS ARE SKIN AND LUNG CARCINOGENS IN

HUMANS, DATA THAT SUGGEST AN INCREASED CANCER RISK AT OTHER

| SITES ARE INADEQUATE FOR EVALUATION. (IMEMOT 0023) I. (MUT) Mutagenicity: ARSENATES ARE KNOWN TO INHIBIT PHOSPHORYLATION.

nli POTENTIAL. CHRONIC EXPOSURE OF MICE TO DRINKING WATER CONTAINING

n 50 MG ARSENIC/ML DAMAGED THE GERMINAL EPITHELIUM OF THE TESTES.

OTHER EXPERIMENTS WITH INORGANIC ARSENICALS HAVE SHOWN

H CHROMOSOMAL CHANGES IN HUMAN LYMPHOCYTES IN VITRO. CELL i< DIVISION DEFECTS AND OTHER CHROMOSOMAL ABNORMALITIES OCCURRED c IN HUMANS TREATED WITH DRUGS CONTAINING ARSENIC. IT IS BELIEVED THAT ARSENIC INTERFERES WITH NORMAL CHROMOSOME REPAIR BY

BLOCKING SULFHYDRYL GROUPS OF KEY ENZYMES. (DOSS** 0001)

OCCUPATIONALLY AND MEDICALLY EXPOSED HUMANS HAVE A HIGHER

INCIDENCE OF GAPS, CHROMOSOME ABERRATIONS, CHROMATID

* ABERRATIONS, LESIONS, AND ANEUPLOIDY. IN VITRO HUMAN

. LYMPHOHOCYTE CULTURES SHOWED ADVERSE EFFECTS DURING METAPHASE

AT 0.1 PPB. LEUCOCYTE CULTURES SHOWED CHROMATID BREAKS WITHIN 48

HOURS AT 1.8 E-8 MOLAR.

HER) Teratogenicity: TERATOGENIC WHEN INJECTED ON CERTAIN DAYS OF

GESTATION ( XNRNBT 0002). TERATOGENIC EFFECTS ATTRIBUTABLE TO

SODIUM ARSENATE HAVE BEEN NOTED IN STUDIES WITH HAMSTERS, IN

MICE, AND IN RATS. THE DOSE OF DIBASIC SODIUM ARSENATE WAS 15 TO

25 MG/KG AND GIVEN ONCE INTRAVENOUSLY ON DAY S OF GESTATION TO

THE HAMSTERS. SLIGHTLY HIGHER DOSES WERE GIVEN TO THE RATS AND MICE. TISSUE MALFORMATIONS INCLUDED EYE DEFECTS (ANOPHTHALMIA

AND MICROPHTHALMIA), EXENCEPHALY, AND RENAL AND 60NADAL

AGENESIS. RIBS AND VERTEBRAE WERE OFTEN MALFORMED. UHEN TRI- OR

PENTAVALENT ARSENIC COMPOUNDS WERE INJECTED INTO FERTILIZED

CHICKEN EMBRYOS, BEAK AND BRAIN MALFORMATIONS OCCURRED. (DOSS**

0001 )

(TRT) Major Species Threatened: BEANS AND CUCUMBERS EXTREMELY

SENSITIVE. MOST LIFE FORMS.

(INK) Inhalation Limit (Value): 10 (.MU.S/CU M); 0.5 (M6/CU M)

(INT) Inhalation Limit : RESULATIONS-- OSHA PEL CTUIA) .310 M6/M3 v I! (29CFR* 1910). RECOMMENDATIONS— NIOSH CEILING .002 MG/M3/1E II MIN (CRSOE* 75-149,75/NIOSH > ACGIH TLV (TUA).2 MG AS/M3 < TLVADM 83/ACGIH) UPDATED 3/84 i; (DRC) Direct Contact: ARSENIC ENTERS THE BODY PRIMARILY BY INHALATION AND INGESTION; SKIN ABSORPTION IS A MINOR ROUTE. (DOSS** 0021) o CJNS) General Sensation; IRRITATION OF GASTROINTESTINAL TRACT, NAUSEA, VOMITING, DIARRHEA, WEAKNESS, LOSS OF APPETITE, LIVER DAMAGE,

SKIN ABNORMALITIES. THROAT CONSTRICTION; HEMOLYSIS; ABDOMINAL

PAIN; THIRST; MUSCLE CRAMPS; HEADACHE; DIZZINESS; RESTLESSNESS;

DECREASED URINARY FLOW; CONVULSIONS; COMA. (AUQCD* 0007)

(DHI) Direct Human Ingestion (Mg./KGwt.): 3.5

(SAF) Personal Safety Precautions: EMITS HIGHLY TOXIC FUMES UHEN

HEATED. UEAR SELF-CONTAINED BREATHING APPARATUS. COVERALLS OR

SIMILAR FULL-BODY WORK CLOTHING; GLOVES, AND SHOES OR

COVERLETS; FACE SHIELDS OR VENTED GOGGLES UHEN NECESSARY TO

PREVENT EYE IRRITATION, UHICH COMPLY UITH THE REQUIREMENTS.

CAUTION: FOR CLOTHING CONTAMINATED UITH INORGANIC ARSENIC DO NOT

REMOVE DUST BY BLOWING OR SHAKING. DISPOSE OF INORGANIC

ARSENIC CONTAMINATED WASH UATER IN ACCORDANCE UITH APPLICABLE

LOCAL, STATE., OR FEDERAL REGULATIONS. OSHA RESPIRATOR 00-241 REQUIREMENTS FOR INORGANIC ARSENIC PARTICIPATE EXCEPT FOR THOSE

WITH SIGNIFICANT VAPOR PRESSURE: FOR UNKNOWN OR GREATER OR

LESSER THAN 20,300 .MU.G/CU M (20 MS/CU M> OR FIREFISHTING USE

ANY FULL FACEPIECE SELF-CONTAINED BREATHING APPARATUS OPERATED

IN POSITIVE PRESSURE MODE. FOR CONCENTRATIONS NOT GREATER THAN

20,000 .MU.G/CU M (20 MG/CU M) USE SUPPLIED AIR RESPIRATOR WITH

FULL FACEPIECE, HOOD, OR HELMET OR SUIT AND OPERATED IN POSITIVE

PRESSURE MODE. FOR CONCENTRATIONS NOT GREATER THAN 10,030 j .MU.G/CU M <10 «G/ CU M) USE.POWERED AIR-PURIFYING RESPIRATORS

WITH HIGH EFFICIENCY FILTERS OR HALF-MASK SUPPLIED AIR

RESPIRATORS OPERATED IN POSITIVE PRESSURE'MODE. FOR

CONCENTRATIONS NOT GREATER THAN 500 .MU.G/CU M USE FULL

FACEPIECE AIR-PURIFYING RESPIRATOR EQUIPPED WITH HIGH EFFICIENCY

FILTERS OR ANY FULL FACEPIECE SUPPLIED AIR RESPIRATOR OR ANY

FULL FACEPIECE SELF-CONTAINED BREATHING APPARATUS. FOR c CONCENTRATIONS 'NOT GREATER THAN 100 .MU.G/CU M USE HALF-MASK n AIR-PURIFYING RESPIRATOR EQUIPPED WITH HIGH-EFFICIENCY FILTER OR ANY HALF-MASK SUPPLIED AIR RESPIRATOR. HIGH-EFFICIENCY

FILTER-99.972 EFFICIENCY AGAINST 0.3 MICROMETER MONODISPERSE

DIETHYL-HEXYL PHTHALATE (OOP) PARTICLES. <29CFR« 0001)

Acute Hazard Level: 130 MG OF ARSENIC INGESTED PROVES FATAL IN

HUMANS. SMALL DOSES MAY BECOME FATAL IN TIME SINCE ARSENIC

ACCUMULATES IN THE BODY. SUBLETHAL DOSES CAN AFFECT LIVER. 10

PPM IN WATER ACUTE HAZARD. FOR IRRIGATION, 1 PPM IS CONSIDERED

THE THRESHOLD CONCENTRATION (E188** 0001). THRESHOLD

CONCENTRATION FOR FRESH AND SALT WATER FISH, 1 PPM (E188** 0001).

(CHL) Chronic Hazard Level: ACCUMULATIVE POISON - DAMAGES LIVER AND

KIDNEYS 1.4 PPM AFFECTS REPRODUCTION IN DAPHNIDS OVER A 3 WEEK

PERIOD.(R132»* 0001); APPLICATION OF 5 MG/L AS IN DRINKING

WATER LED TO RAPID DIEOFF OF RAT AND MOUSE BREEDING COLONIES 000242 CR120»* 8001) ANOTHER OBSERVER SAW NO EFFECT IN THREE

6ENERATIONS OF MICE AT THAT LEVEL

POISONING HAS BEEN REPORTED -FROM CONSUMPTION OF DRINKING WATER

CONTAINING .21-10 MG/L WHILE LEVELS OF .05-. 25 MG/L HAVE BEEN

USED SAFELY (UATRAG 0028); MARINE WATERS SHOULD NOT EXCEED

1/100 OF 9B HOUR LC50

ARSENIC AT LEVELS OF 0.35 PF/M AND HIGHER IN COMMUNITY DRINKING

WATER SUPPLIES HAS BEEN ASSOCIATED WITH BLACKFOOT DISEASE

PERIPHERAL VASCULAR DISORDER ASSOCIATED WITH GANGRENE), OTHER

CARDIOVASCULAR DISORDERS, SKIN LESIONS, SKIN CANCER,

HYPERPIGMENTATION, KERATOSI3,. CHRONIC HERPES, BRONCHOPULHONARY

DISEASE, CHRONIC COUGH, ABDOMINAL PAIN, AND CHRONIC DIARRHEA. A

SOPHISTICATED MULTIVARIATE ANALYSIS SHOWED REDUCED NEUROLOGICAL

FUNCTION ASSOCIATED WITH OCCUPATIONAL INHALATION EXPOSURE TO

ARSENIC TRICXIDE AT THE TACOMA, WASHINGTON, COPPER SMELTER.

L CEPIAS* 3301)

(HEL) Degree of Hazard to Public Health: IN WATER TAKEN OVER LONG

PERIODS OF TIME THE FOLLOWING CONCENTRATIONS OF ARSENIC HAVE

BEEN REPORTED AS POISONOUS TO HUMAN BEINGS: .21 MG/L, .3-1 MG/L

AND .4-10 MG/L. HIGHLY TOXIC. MAY BE CARCINOGENIC. ARSENITE (+3)

FORMS ARE MORE TOXIC THAN ARSENATE (+5) FORMS.

(AIR) Air Pollution-. HIGH AT AROUND 10 TO 40 MS AS/CU M MINIMAL,

SYMPTOMS AFTER SEVERAL HOURS-EXPOSURE. AT AROUND 25 TO 125 MG

AS/CU M MAXIMUM CONCENTRATION FOR 1 HOUR WITH REVERSAL OF

EFFECTS. AT AROUND 50 TO 250 MG AS/CU M HIGH RISK TO HEALTH

FROM 1 HOUR EXPOSURE. AT AROUND 1,000 MG AS/CU M LCS0, FROM 1

HOUR EXPOSURE. SOURCE: REEVES, 197B, CITED IN (DOSS«* 0001). EPA

LISTS ARSENIC AS A HAZARDOUS AIR POLLUTANT AS DEFINED UNDER THE

CLEAN AIR ACT AND THE AGENCY'S PROPOSED AIRBORNE CARCINOGEN

POLICY. CCENEAR 0010) Q 0024 3 (ACT) Action Levels: NOTIFY FIRE AUTHORITY. ENTER FROM UPWIND SIDE.

NOTIFY LOCAL AUTHORITIES IN CASE OF WATER POLLUTION.

(AMD In Situ Amelioration: SEEK PROFESSIONAL ASSISTANCE FROM EPA'S

ENVIRONMENTAL RESPONSE TEAM (ERT) EDISON, NJ, 24-HOUR NUMBER

(201>321-66G0. ALUM FLOC TIES UP IN INSOLUBLE FORM. ANION

EXCHANGERS WILL PICK UP ARSENATES. FOR SMALL SPILLS OF

ARSENICAL DUSTS, TAKE UP WITH SAND OR OTHER NONCOMBUSTIBLE

ABSORBENT MATERIAL. THEN FLUSH AREA WITH WATER. FOR SMALL DRY f SPILLS, SHOVEL INTO DRY CONTAINERS AND COVER, MOVE CONTAINERS,

AND THEN FLUSH AREA WITH WATER. NOTE THAT RUNOFF FROM FIRE

! CONTROL OR DILUTION WATER MAY CAUSE POLLUTION. FOR LARGE

JT SPILLS, DIKE FAR AHEAD OF SPILL FOR LATER DISPOSAL. (S5EWAF 0031) 1 (AVL) Aval, of Counter-measure Material: ALUM - WATER TREATMENT PLANT;

[i ANION EXCHANGERS - WATER SOFTENER SUPPLIERS.

(DIS) Disposal Method: FOR SMALL SPILLS DISSOLVE IN MINIMUM

L CONCENTRATED HYDROCHLORIC ACID. DILUTE WITH WATER UNTIL WHITE n PRECIPITATES FORM. ADD JUST ENOUGH BM HCL TO REDISSOLVE. SATURATE WITH H2S. FILTER, WASH DRY AND SHIP TO SUPPLIER. FOR

LARGE SPILLS—AFTER THE MATERIAL HAS BEEN CONTAINED, REMOVE IT

AND THE CONTAMINATED SOIL AND PLACE IN IMPERVIOUS CONTAINERS. IF

PRACTICAL, TRANSPORT MATERIAL BACK TO THE SUPPLIER OR CHEMICAL

COMPANY TO RECOVER THE HEAVY METAL CONTENT. IF THIS IS NOT

PRACTICAL, OR FACILITIES NOT AVAILABLE, THE MATERIAL SHOULD BE

ENCAPSULATED AND BURIED IN A CALIFORNIA CLASS 1 LANDFILL. SUCH A

LANDFILL OFFERS NO DANGER OF USEABLE SURFACE OR UNDERGROUND

WATER CONTAMINATION. NOT ACCEPTABLE AT MUNICIPAL SEWAGE

TREATMENT PLANT.

Industrial- Fouling Pot.: SHOULD NOT BE PRESENT IN FOOD

PROCESSING WATERS. (WAT) ilajor Water Use Threatened: POTABLE SUPPLY, FISHERIES, 000244 i IRRIGATION.

METAL. TURNS BLACK ON EXPOSURE TO AIR. WILL DISSOLVE. SALTS MAY

DECOMPOSE TO ARSENIC ACID. SOME SALTS ARE SOLUBLE.

CDRT) Soil Chemistry: ARSENIC IS STRONGLY HELD BY SOILS AND LONG IN

MOVING THROUGH THE SOIL COLUMN

LOW AS 1 M6/L MAY INJURE SOME PLANTS; CONCENTRATIONS IN EXCESS

OF 75 PPM WILL DAMAGE FOLIAGE CR174** 0001); ARSENIC SHOULD NOT

I EXCEED 328 PPM IN THE TOP 12 INCHES OF SOIL. ARSENIC IS ADSORBED

STRONGLY IN SOIL, PARTICULARLY IN SOILS RICH IN IRON AND I: ALUMINUM ABSORPTION SITES SUCH AS CLAY. REPEATED APPLICATIONS TO Ij SUCH SOILS LEADS TO ACCUMULATION. AS IN WATER, ARSENIC IN SOIL

EXISTS IN SEVERAL FORMS DEPENDING ON OXYGEN LEVELS, REDUCING T II ABILITY, AND MICROBE ACTIVITY. ARSENIC COMPETES WITH PHOSPHATE FOR ADSORPTION SITES. THUS PHOSPHATE FERTILIZERS RELEASE SOLUBLE

« ARSENIC IN SOIL, WHICH IS THE PHYTOTOXIC FORM. EFFORTS TO LOUER

PHYTOTOXICITY INCLUDE LEACHING SANDY SOILS AFTER PHOSPHATE n • ADDITION AND DEEP PLOWING TO EXPOSE THE ARSENIC TO MORE

|{ ADSORPTION SITES. (EVHPAZ 0017) UOOLSON (1977) ESTIMATED THAT j- APPROXIMATELY 12% OF THE ARSENIC APPLIED IN PESTICIDES TO THE

. SOIL IS LOST THROUGH VOLATILIZATION OF ALKYLARSINES EACH YEAR,

1 WITH TOTAL LOSSES BEING 14 TO 15%. SANDBERG AND ALLEN (1S75)

ESTIMATED VOLATILITY LOSSES FROM SOILS OF 17 TO 35% PER YEAR.

THEORETICALLY, ARSENIC ACCUMULATION IN THE SOIL UILL REACH

EQUILIBRIUM AFTER APPLICATION FOR 25 TO 30 YEARS. (UEE3A6 '0002)

OXIDATION STATES. BASED ON AVAILABLE THERMODYNAMIC DATA, THE

PENTAVALENT STATE IS THE STABLE STATE IN AERATED WATER, BUT IN

VERY REDUCING SEDIMENTS AS<0> AND AS

MODERATELY REDUCING SEDIMENTS, THE TRIVALENT STATE CAN EXIST. 000245 AN EH-PH DIAGRAM HAS RECENTLY BEEN CONSTRUCTED FOR THE SYSTEM

INVOLVING ARSENIC, OXYGEN, WATER AND SULFUR. BESIDES THE

INORGANIC FORMS OF ARSENIC, ORGANIC DERIVATIVES NUMBERING IN THE

THOUSANDS HAVE BEEN PREPARED, SOME OF WHICH MAY CONTRIBUTE TO

THE BEHAVIOR OF ARSENIC IN NATURAL WATERS. THE HYDROLYTIC

BEHAVIOR OF AS(V) IS SIMPLE SINCE IT FORMS AN OXYACID, H3AS04,

WHOSE PROPERTIES RESEMBLE VERY CLOSELY THOSE OF H3P04. ARSENATE

FORMS INSOLUBLE SALTS WITH MANY CATIONS, AND SOLUBILITY

PRODUCTS, PROBABLY GOOD TO .5 LOG UNITS WERE REPORTED FOR

SIXTEEN ARSENATES BY CHUKHLANTSEV. ARSENATE IS EXPECTED TO BE

ENRICHED IN PHOSPHATE MINERALS BY EXCHANGE WITH THE PHOSPHATE

ION, AS WAS POINTED OUT BY FERSUSON AND 6AVIS (1272). ftRSENITE

L (+3) IS FOUND IN ABOUT EQUAL AMOUNTS WITH ARSENATE IN OCEAN

WATER. IN DILUTE SOLUTIONS (LESS THAN APPROXIMATELY 3.1

MOLAL), ASCII!) EXISTS AS MONONUCLEAR SPECIES BELIEVED TO BE

C AS!OH)3, AS3 RESEMBLE MORE CLOSELY THOSE OF BORIC ACID THAN OF PHOSPHOROUS ACID. THE

IONIZATION CONSTANT FOR ARSENIOUS ACID IS KNOWN AS A FUNCTION OF

KCL CONCENTRATION FROM THE WORK OF ANTIKAINEN AND ROSSI <1959> r AND AS A FUNCTION OF TEMPERATURE FROM THE WORK OF ANTIKAINEN AND r TEVANEN (1961). AS40B HAS A SOLUBILITY OF .103 M (AS) AT 25 DEGREES CELSIUS AND THERE IS EVIDENCE FOR POLYMER FORMATION IN

SATURATED SOLUTIONS IN THE PH RANGE 9 TO 10; POSSIBLE SPECIES

AS2(OH)7 SUPER - AND AS3(OH)10 SUPER -. THE FORMATION OF

CHELATES WITH POLYOLS. (MANNITOL, MANNOSE, CATECHOL, AND

PYR06ALLOL) MAY BE AN IMPORTANT PROCESS IN NATURAL SYSTEMS. A

SOLUTION AT PH 9 CONTAINING 10-3 M OF THE POLYOL HAS AS MUCH AS

ONE-THIRD OF THE AS(III ) IN THE FORM OF THE ARSENITE-POLYOL

COMPLEX. THERE IS READY INTERCONVERSION OF ARSENIC COMPOUNDS BY OOQ24R THE ACTION OF ORGANISMS, 'AND BOTH AS(III) AND AS(V> FORM

COMPOUNDS CONTAINING C-AS BONDS. THE PK1 FOR DISSOCIATION OF

ALKYL ARSENIC ACIDS, RASO(OH>2 IS TYPICALLY ABOUT 4 AND PK2 IS .

ABOUT EQUAL TO 8. ACID DISSOCIATION CONSTANTS FOR A NUMBER OF

ALIPHATIC ARSENIC ACIDS ARE SUMMARIZED BY DOAK AND FREEDMAN

(1970). THE HYDROLYTIC BEHAVIOR OF THE IMPORTANT GROUP OF ALKYL

ARSINES (R3***» 0001 AS) IS UNKNOWN, BUT (CH3)3AS IS FORMED EY

MICROORGANISMS FROM INORGANIC COMPOUNDS. THE ORGANIC SALTS RISE

IN THE WATER, ARE OXIDIZED AND SOON PRECIPITATE COMPLETING A

CYCLE FROM SEDIMENT TO WATER.

(COL) Color in Water: COLORLESS

(DAT) Adequacy of Data; GOOD

000247 type 3/msds.ohmr XXX

Option? type 3/msds.ohmtads

Conversion to local identifiers re.sulted in 1 unique occurrences.

Conversion Entry 1; Accession No. 7216622

(CAS) CAS Registry Number: 7440-43-9

(SIC) SIC Code-- 2899; 3471; 3B91

(MAT) Material Name= CADMIUM

(FML) Chemical Formula: CD

CUSS) Common Uses: SOLDERING ALUMINUM; ELECTROPLATING BATTERIES.

(BIN) Binary Reactants= TELLURIUM, ZINC.

(SGM) Synergistic Materials: CADMIUM ACTS WITH OTHER SUBSTANCES TO

INCREASE THE TOXICITY ZN AND CU, CD AND CN IONS ACT

SYNERGISTICALLY 5 MG/L CO INCREASED MORTALITY OF RATS ON A DIET n CONTAINING 11 MG/L SE. SOIL DECREASES TOXICITY OF CADMIUM TO EURASIAN UIATER MILFOIL .( AECTCU 0006)

(ANT) Antagonistic Materials: DEFINITE ANTAGONISTIC ACTION OF CA, MG,

AND PERHAPS OTHER SALTS TOWARD CD TOXICITY. CANA2 EDTA IS

EFFECTIVE ANTIDOTE FOR CD.

(FDD Detection Limit (Field; Techniques,Ref) Cppm): 10005, CADMIUM

(BNU10« 0010)

(LDL) Detection Limit (Lab; Techniques,Ref ) (ppm)= .0005 MG, CADMIUM

CBNU10* 0010)

(STD'l Standard Codes'- NFPA - 3,2,-; ICC, USCG - NO.

(FLU) Flammability: MODERATE - DUST WHEN EXPOSED TO HEAT A FLAME OR BY

CHEMICAL REACTION WITH OXIDIZING AGENTS.

(TCP) Toxic Combustion Prod.: HIGHLY TOXIC, ENTER WITH GREAT CAUTION. OC0248 (EXP) Explosiveness; SLIGHT - DUST WITH FLAME. REACTIVE ONLY UNDER

EXTREME CONDITIONS.

Melting Point (C.) = 321

(BLP) Boiling Point : 765

(SPG) Specific Gravity: 8.642

(VPN) Vapor Pressure (mm Hg>: 1

(PER) Persistency: NATURAL CARBONATE MAY SLOULY PRECIPITATE CADMIUM,

BUT LEVELS WILL REMAIN ABOVE ACCEPTABLE LIMITS.

i (PFA) Potential for Accumulation-- CONCENTRATES IN LIVER, KIDNEY,

PANCREAS, AND THYROID. POSITIVE. CONCENTRATION FACTORS FOR CD -

j MARINE AND FRESHWATER PLANTS 1200; SHELLFISH CONCENTRATE

CADMIUM 900-1600 TIMES. FISH 3000, MARINE INVERTEBRATES 250,000

li AND FRESHWATER INVERTEBRATES 4000: HALF-LIFE IN TOTAL HUMAN uI1 BODY 200 DAYS

L FORCING BODY TO EXCRETE CALCIUM AND THUS WEAKENING BONES. ALSO p CAN CAUSE BRONCHOPNEUMONIA IF DUST IS INHALED.

': (TER) Teratogenicity. POSITIVE. STUDIES SHOW EMBRYOTOXICITY AT LEVELS

] (10 PPB OR LESS) BELOW THOSE TOXIC TO ADULTS (R181«* 0001) 1 ! ! PPB TOXIC TO 24-32% OF CHICK EMBRYOS (XNRNBT 0002).

I! (TRT) Major Species Threatened: ALL FORMS OF LIFE. ESPECIALLY CROPS. i- (INH) Inhalation Limit (Value): 40 (MG/M3; IDLH)

(INT) Inhalation Limit (Text): REGULATIONS— OSHA PEL (TUA) .2 MG/M3

(DUST)? 0.1 M6/M3 (FUME) (29CFR* 1910) OSHA CEILING .6 MG/M3

(DUST)i 0.3 MG/M3 (FUME) (29CFR* 1910), RECOMMENDATIONS—

NIOSH TWA 0.04 MG/M3 FOR 10 HOURS (CRSOE« 76-192,77/NIOSH) NIOSH

CEILINS .2 MG/M3/15 MIN (CRSOE* 76-192,77/NIOSH) NIOSH IDLH 40

MG/M3 (PKTGD* 80/MAC) ACGIH TLV (TWA).05 MG CD/M3 (TLVADM

83/ACGIH) ACGIH STEL .2 MG CD/MS/IS MIN (TLVADM 83/ACGIH)

UPDATED 3/84 Q0024B (JNS) General Sensation: IRRITANT. HEADACHE, NAUSEA, VOMITING,

DIARRHEA, AND ABDOMINAL PAIN FOLLOW INGESTION. INHALATION CAUSES

DRY THROAT, COUGHING, CONSTRICTION OF THROAT AND CHEST PAINS.

(DHI) Direct Human Ingest ion (Mg./KGwt.): 300

(SAF> Personal Safety Precautions: WEAR EYE PROTECTION AND SELF-

CONTAINED BREATHING APPARATUS, WEAR FULL PROTECTIVE CLOTHING.

(AHL) Acute Hazard Level: RESPONSE IN FISH IS SLOW AT EVEN HIGH

EXPOSURE EVEN THOUGH 7 DAY TLM APPEARS QUITE LOU. HIGHLY TOXIC

TO ALL FORMS OF LIFE. ESPECIALLY TOXIC OVER LONGER EXPOSURES.

.01 PPM RECOMMENDED FOR FISHERIES USE (E188** 0001). n (CHL) Chronic Hazard Level: EXTREMELY DANGEROUS. CHRONIC STUDIES WITH FISH SHOW FRY AND EGG SURVIVAL OVER 30 DAYS AFFECTED BY LOU

[[ LEVELS OVER EXTENDED PERIODS OF TIME CAN BE HAZARDOUS TO ALL

•r LIFE FORMS. .0006-.Ill PPM CD (R182«* 0001) DAPHNID REPRODUCTION

'J IS REDUCED 1SX AT .17 PPB

I' -EXCEED .03 PPM CD IN HARD WATER, .004 IN SOFT; MARINE WATERS

SHOULD NOT EXCEED 1/100 OF 9G HOUR LC50 (R184** 0001);

I! APPLICATION FACTOR TO CONVERT 96 HOUR LC50 TO SAFE CHRONIC LEVEL

IF FOR CD - .001; FOR FATHEAD MINNOW, .0015 FOR BLUEGILL, AND .0025 li FOR GREEN SUNFISH (R131«« 0001); RETARDATION, SOMNOLESCENCE, '1 I . DECREASE IN APPETITE, MUSCLE RIGIDITY AND; PARTIAL TETANUS IN RATS GIVEN 3 MG/KG CDCL2 IP 3 X WEEK FOR 3 WEEKS (R120** 0001);

» MAXIMUM ALLOWABLE CONCENTRATION (MATC) FOR FATHEAD MINNOWS .037-

.057 PPM; APPLICATION FACTOR FOR EXTRAPOLATION OF 96 HOUR IL50 -

.005-.008 (JWPFA5 0019).

(HEL) Degree of Hazard to Public.Health: CADMIUM POISONING OF HUMANS

HAS RESULTED FROM THE CONSUMPTION OF FOODS OR LIQUIDS PREPARED

AND LEFT IN CADMIUM-PLATED CONTAINERS. THE DAILY INTAKE IN MAN

CAN VARY FROM 4-50 MICROGRAMS, DEPENDING ON THE FOOD CHOSEN. 000250 HIGHLY TOXIC. (AIR) Air Pollution: HISH

(ACT) Action Levels'- NOTIFY LOCAL AIR AUTHORITY. SUPPRESS SUSPENSION

OF DUSTS IN AIR. IF FIRE IS EVIDENT, EVACUATE IMMEDIATE AREA.

(AMD In Situ Amelioration: CARBONATE IS INSOLUBLE. ADD C02. CATION

EXCHANGES WILL RETAIN CADMIUM. SEEK PROFESSIONAL ENVIRONMENTAL

ENGINEERING ASSISTANCE THROUGH EPA'S ENVIRONMENTAL RESPONSE

TEAM (ERT), EDISON, NJ, 24-HOUR NO. 201-321-6SE0.

(AVL> Aval, of Counter-measure Material: C02 - SOFT DRINK DISTRIBUTORS;

CATION EXCHANGE RESINS - WATER SOFTENER SUPPLIERS.

(DIS) Disposal Method: ROUTE TO METAL SALVAGE FACILITY

(IFP) Industrial Fouling Pot.: MAY CAUSE SCALING PROBLEMS n ' (WAT) Major Water Use Threatened: ALL USES li (LOO Probable Location and State of Material: SILVER-WHITE METAL WILL SINK. MOST SALTS HAVE LIMITED SOLUBILITY. NATURAL CARBONATE MAY c CAUSE WHITE PRECIPITATE TO FORM. c

I j INCHES OF SOIL MAY LEAD TO TOXIC LEVELS IN PRODUCT CROPS

.. (UWAEA2 0001).

1 ' .(HOH) Water Chemistry: CADMIUM EXHIBITS ONLY THE +2 VALENCE STATE IN

AQUEOUS SOLUTION. THE CD+2 ION FORMS IMPORTANT SOLUBLE AQUEOUS

COMPLEXES WITH AMMONIA AND WITH CYANIDE, HALIDE, AND HYDROXIDE

IONS. LIKE H6, IT IS VERY TOXIC, PRESUMABLY BECAUSE IT FORMS A

STRONG BOND WITH SULFUR AND HENCE CAN DISPLACE ESSENTIAL METALS

(SUCH AS ZN+2 ) FROM THE BINDING SITES OF CERTAIN ENZYMES. THE

CD+2 ION HAS SLIGHTLY LESS TENDENCY TO HYDROLYZE THAN DOES ZN+2

ION. HYDROLYSIS BECOMES SIGNIFICANT ABOVE PH 7 IN CONCENTRATED SOLUTION ( > .1 M), WHERE THE POLYNUCLEAR SPECIES CD20H+3 AND

PROBABLY CD4COH>4+4 ARE FORMED IN SMALL AMOUNTS BEFORE

PRECIPITATION OF A CADMIUM HYDROXIDE OCCURS. MONONUCLEAR

HYDROLYSIS PRODUCTS APPEAR ABOVE PH 8, BUT THE LOW SOLUBILITY OF

THE HYDROXIDE LIMITS THE CONCENTRATION OF CADMIUM, PRESENT AS

CDOH+ AND CD(OH>2, TO LESS THAN 10-5 M UNTIL PH 13 IS REACHED.

IN MORE BASIC SOLUTIONS, THE HYDROXIDE SHOWS AN INCREASING

SOLUBILITY WITH PH RESULTING FROM THE FORMATION OF CD(OH)4-2.

(COL) Color in Water= GENERALLY COLORLESS

(DAT) Adequacy of Data= GOOD

L f. r

000252 type Z/,,\«sds.ceE\C\ohmtads

Warning: No responses for: TPE

Continue vY/N/Expand HY )? n

Opticn7 type 2/msds.ohmtads

Conversion to local identifiers resulted in

Conversion Entry 1; Accession No. 721554."

CAS Registry Number: 744C-47-3

Material Name; CHROMIUM

Chg-iicai Formula: OR

Cor.ncr, Uses: ALLOYS

Binary Resctants: HYDROGEN PEROXIDE, NITRIC OXIDE, ROTASEI-;-; f r LJ i •**• M ~* * IT" C 1 11 C 1 IEZ n T P.'.' T T"i C" W I* ±m W f\ I ' ' ^ • ——' W *—— ' "——' I • I—' A *P/ i'\ » ta^ C. • p TOWARD EACTERIA AS WELL AS TYPE OF ORGANISM, AMOUNT OF OFSA;.:; ; ,,rw'TT-, i '.£.?(c "iiCwtliJccr^rMTi , nuA^lL p iPCtitlnwtDDircct.i^cl v-/rnc , ncit.JLtACCCMTC. Oncr L.^ZCL'U.vtr.fcrr.i ; icb n Vj..~i'.. I v."~..w C ^ <. .

SOIL DECREASED THE TOXICITY OF CRZ07 TO EURASIAN WATER MILFOIL

Detection Limit (Field; Techniques ,Ref > >. ppm i: .005, CHROMIUM

COLORIMETRIC, ;5NU10* 3SS9)

Standard Cedes: NFFA-S,2,-.

"iampiafciiity: MODERATE. COMBUSTION WITH MODERATE HEATINS

: i C •. =-.:.-_ c . . - i .' . ... . -_•»**..!., W A I . ^ ••

000253 CHROMIUM EVEN AT LEVELS OF .001 FPM. POSITIVE ; BARLEY AESCRES

CHROMIUM. CONCENTRATION FACTORS FOR CR - MAR I WE PLANTS 2ES2,

FRESHWATER AMD; EROWN ALSAE CONCENTRATES 100-520 TIMES. MARINE

INVERTEBRATES - 2080, MARINE FISH 4S0 AND FRESHWATER FISH ZS3

{Ri7S*» 20S1>; HALF-LIFE IN TOTAL HUMAN BODY E15 DAYS (R172-*

/V?. 1 \ 3 (Ui/ A / *

, " I C i G

nuc L .v A A n 1w 1n Aw i c .CM i •« iT wr'u n fCt w riM l .C £ . ~u An MI J Pw A n! iUc -c • n -^uw nc rnMC\ u i "* t. in wTC L. wD -d r. ^ •

Carcinoge-icity- HEXAVALENT CHROME DUST CAN CAUSE CANCER .

POTENTIAL.

Dr Spe-155 Threatened;; ALL L N HEXAVnLENT FOR:':. r.~^-j~

L 1 r L r** i *

L 1 .' *"' O.~ CD * 1 O ' ."*- ' DZT i" r.MMp i.;r, i T T OM -. — — f 1 " "• - W PC T ' T *•'•*£ ffiC T- MC / rvi~ . •; C

MIN -CRSOE*- 75-129, 7B/NIOSH; NIOSH TUA .025 MS/M2 ;CR=CE* ~b-

l2S,7t/NlO£H; NIOSH IDLH 52S Mc/MZ (PKT6D* SS/MAC ; ACEIH TL;J

.«' Ti-on^. : ! ^ \ j C ilO'ttM ." /~ M T ^ l /i- Tv -I —I wI 1i 1 P is«/'nL.o.i.n M C T .' i ^ /i " Twru>nit. LJ S I I Dw H A ^-•o-">" C f~*i ~? / G -•(

n.....^ r - — •". - - A • CA> T- — SP rncpne TI it: rn CL'TM AMH MIIP.-.I;- sicrMCciNir w * • S *^ t. w -- 1 i *. a w *. • w n u. ! _- . i r, t L w r\ — w - * v t i w ~- r\ i i * n 1 4 u i • ^ w w w -^ i I u ( i ^ i - . i . ^ i_

r~,--,_..a £ T; c r ai 4 . Ce-i~~-*-~i £ n a a t * w— »• i • c —w .i tT fcC_ i 3iC Ci , — tT r, i* w T A r A w&t .i t 1n 1 4.^ApsncTM LJ w u r* r\ wC w ^ Tr*v ^ . TL-Tt « «M• TV i » *

Tsste Threshold, Lower i ppm > ; 1.4

Taste Threshold, Upper

Body Contact E.-.p.

Fro longed Human Contact {pppi): .05

Personal Safety Precautions; FULL RUBBERIZED SAFETY CLOTHING AU

SELF-CONTAINED ==EATHING AFFARATUS SHOULD EE wORN.

'1 " '5C 000254 GREAT THREAT. THRESHOLD CONCENTRATION FOR FRESH AND SALT WATER

FI3H, .05 PPM CR(VI) (E1SS** (30(31).

Chronic Hazard Level- HEXAUALENT CHROMIUM IS A CHRONIC TOXICANT

VIA INGESTION OR INHALATION. CHRONIC RAINEOU TROUT 5TUDIEE SHOW

IMPAIRED REPRODUCTION OVER A 2 YEAR PERIOD; CHROMIUM METAL

FOSES NO GREAT THREAT. AT .4 PPM FOR +5 STATE. FRESHWATER SHOUL:

NOT EXCEED .23 PPM CR, MARINE WATERS: 1/100 3E HOUR LC = 2 •:Ri54«« 0001); APPLICATION FACTOR TO CONVERT SE HOUR LC=£ FOR

* CR-^5 TO CHRONIC SAFE LIMIT .23 FOR FATHEAD MINNOW, .Si FCR

}' BROOK TROUT AND .003 FOR RAINBOW TROUT (R131** SC2j). i ;'HEl_ : Decree cf Hazard to Public Health: NO REAL HAZARD AS METAL.

EXTREMELY TOXIC IN HEXAVALENT STATE.

Air Foliation: NO GREAT HAZARD, AVOID DUST-~EXAVAi_ENT DUETI. II

Action Levels: NOTIFY AIR AUTHORITY. RESTRICT ACCESS TO AFFECTED

'.*"•• c

T» r - * . . i*. - i . -».-*,.-. &r,n rn- r.c TitAurr."? rn ccr-^TCTT'Tc- n A. i i w A •• u* t • i • i c * A. w i a k 1 w n - MUW wu*. Ui\ 1 < n i i w w «.' »w i r\w^o.r* tHiu- CARBONATE. SEEK PROFESSIONAL ENVIRONMENTAL ENGINEERING

ASSISTANCE THROUGH ERA'S ENVIRONMENTAL RESPONSE TEAM ( ERT !• ,

A.-al. of Counter-essure Material: C02 - SOFT DRINK DISTRIBUTORS;

NAHC03-GROCERY STORES, LARGE BAKERIES.

Disposal Method: DUMP INTO LANDFILL

Disposal Notification: CONTACT- LOCAL LANDFILL AUTHORITY

Effects on water Treatment Process'- 5 PPM HEXAVALENT IS

THRESHOLD FCR RETARDATION OF DIGESTION 2220 PPM TRIVALENT

«atar Use Threatened: HEXAVALENT CHROMIUM THREATENS AL.L

"r^rz^ii L.^ation snc State of Material: i-i-RD IRAi i-lETA.L. *I^- .•0002 SINK IN WATERWAY. MOST SALTS ARE SOLUBLE.

(CRT) Soil Chemistry: UP TO 308 PPM WERE REMOVED BY ALL TYPES OF SOIL

IN COLUMN STUDIES CR17*** 2001); SOIL PH IS A MAJOR FACTOR FOR

UPTAKE. CR175** 0201); PLANT DAMAGE TO CROPS MAY RESULT FROM

LEVELS ABOVE .5 PPM FREE CHRCMATE IN SOLUTION. AN APPARENT

TuoccLini ntMi wti WL.i U n rjrrririrrcwr AT) UnA» i*.c - AHu' c. w\A J CETDc-irM* MATCi*w i £.*-H• . DPCLT1 »MA UuT i m wwnNij-riCuJAMT T c rprr. * , c•.••.*•.£ : *?c « •„

ESDI;; TOXIC CROPS FROM UPTAKE CAN BE AVOIDED 5Y KEEPING THE

CONCENTRATION OF CHROMIUM BELOW 164 PPM IN THE TOP 12 INCHES r~

Water Chemistry: GENERALLY SPEAKING HEXAVALENT CHROMIUM EXISTS

IN TRUE SOLUTIONS, REGARDLESS OF THE PH OR PRESENCE OF OT-ER

T .". M c p. ^ c c M n T K i c p. ^ i !S u fc, M n ,"* r. h i r c s i T c A T T n N i A cr .*"* c T A r . : T — j* T T ,~i -- ; .* c 4.wiM-. I* Jl » i. .. < u.- i i * u* w i •-* 1(1 rlivu/ wwtJUu-liti^nixwi-I wr u n. i w i ^ *. *. • . i A -• i * . w» t

C i^ -1 1T- C' w mpi M-'"i tA vtir\w.iiiii- US AM ATE" C— ' . U\'T.i i ; wp1 ~A. u- wU Pi i A• «M w A' Ti i :ET i Ci u.AM — Hi 1 1A 4 T u A/ LJu/Au.rn'W'niiu.wC A M £. T C ~ T.^- Ti.

SCLUEILITV OF TRI'JnLENT CHROMIUM 13 DEPENDENT OH UnTER

CH^RnCTERIETICE LIKE FH, HnRDNESS, AND ALKftLINITY. TRTVf.LENT

A-.JC ArviT ; '.M UAC A c TC Af,;- rr^i^.cr^!r v Tn pr.p w rnACr.TuATT MC .-A we A; ir.:r. r %„• » t i \ W t i * 'W I i liii^' II „ i ( \ '— ' I J \J 1 U. I « W I— * 4 W I IW r W F, M wUwiNw-iiJliiiiiiW Wwili b W t • i. w .

• A M D i c v r c A f- i n r* u cr i A T c r, r A M M A t, i c A i T ~ A c c c A i tip; cr LJ C".- ' « i i — ; rr .- : T r _. •-- • . t- H. •' v £1 « , ^ I 1 LJ !w fi t U n I t. Hi . w wJ I 1 1 i W U « ri i_ r w i > ' S 1^ Z> W U. W U L. t. . t I w- ' • > ; •-. i i i_ i- i • i : i M T ~ A z "r n A M i" A v T r*> T n M Is r, sihUN- •• b THE TRIVALENT STATE.

Color in vister-- GRANGE OR RED AS DISSOLVED SALT r Aceq-s^'- of Data; PAIR

000258 type 5/msds.ohrotads

Conversion to local identifiers resulted in 1 unique occurrences.

Conversion Entry 1; Accession No. 7216752

(CAS> CAS Registry Number: 7783-06-4

(MAT) Material Name= $$$ HYDROGEN SULFIDE $$$

CFML) Chemical Formula'- H2S

CUSS) Common Uses: CHEMICALS IN METAL; REAGENT; PURIFICATION OF HCL

AND H2S04; PRECIPITATING SULFIDES OF METALS; MANUFACTURE OF

ELEMENTARY SULFUR

(CON) Containers: STEEL PRESSURE CYLINDERS, TANK CARS.

CSTQ) Seneral Storage Procedure: PROTECT AGAINST ANY PHYSICAL DAMAGE.

STORAGE SHOULD BE WELL ISOLATED, DETACHED, VENTILATED AND OF

FIRE RESISTIVE CONSTRUCTION. STORE AUAY FROM NITRIC ACID,

C STRONG OXIDIZING MATERIALS, CORROSIVE LIQUIDS OR GASES,

CYLINDERS OR OTHER CONTAINERS UNDER HIGH PRESSURE AND POSSIBLE

SOURCES OF IGNITION. PROTECT AGAINST STATIC ELECTRICITY, DIRECT

SUNLIGHT AND EXCESSIVE HEAT.

(BIN; Binary Reactants: ACETALDEHYDE (BARIUM OXIDE, MERCUROUS OXIDE

AND AIR), (BARIUM OXIDE, NICKEL OXIDE AND AIR), CHLORINE

MONOXIDE, CHROMIUM TRIOXIDE, COPPER, FLUORINE, LEAD DIOXIDE,

NITRIC OXIDE, NITROGEN IODIDE, NITROGEN TRICHLORIDE; PHENYL

DIAZONIUM CHLORIDE, SODA LIME (SODIUM HYDROXIDE AND CALCIUM

HYDROXIDE) AND AIR, SODIUM PEROXIDE; NF3; OF2; CLF3; BRF5;

HYDRATED IRON OXIDE; AND SODIUM. DANGEROUSLY REACTIVE WITH

FUMING OR STRONG NITRIC ACID AND POWERFUL OXIDIZING MATERIALS.

(HFICAM 3S01 )

(COR; Ccrrosiveness: ATTACKS METALS' FORMING SULFIDES

•;ANT) Antagonistic Materials: ONLY AT PH 13 AND ABOVE IS SULFIDE ION 000257 PRESENT IN APPRECIABLE PROPORTIONS. TOXICITY TO AQUATIC LIFE IS

PRIMARILY DUE TO UNDISSOCIATED H2S, SO THE TOXICITY OF A GIVEN

AMOUNT OF H2S WILL DECREASE AS PH INCREASES. (ENVIDV 0001)

(FDD Detection Limit (Field; Techniques,Ref> (ppm): .05, SULFIDE,

(BNU10* 0021) H2S AND SULFIDE CAN BE DETECTED BY SEVERAL

COMMERCIALLY AVAILABLE KITS. DETECTION LIMIT FOR SULFIDE IN

WATER IS 0.2 TO 20 PPM. (FDDAM* 0001)

(LDL) Detection Limit (Lab; Techniques,Ref ) (ppm); .05, SULFIDE,

CBNU10» S021)

(STD) Standard Codes: SUPERFUND DESIGNATED (HAZARDOUS SUBSTANCES) [ LIST; NIOSH NO. MX122S000; HAZARDOUS WASTE NO. U135. STCC NO. 4905410. IATA—CLASS FLAMMABLE BAS, NOT ACCEPTED FOR AIR

TRANSPORT. (RARAD5 0002) IMCO--UN NO. 1053; CLASS 2 GASES. D REQUIRES POISON GAS AND FLAMMABLE GAS LABELS, STOW AWAY FROM FOODSTUFFS AND LIVING QUARTERS, STOW ON DECK FOR CARGO SHIPS AND

L PASSENGER SHIPS CARRYING EITHER 25 OR FEWER PASSENGERS, OR 1 QR fl FEWER PASSENGERS PER 3 METERS LENGTH, PROHIBITED ON OTHER PASSENGER SHIPS. (85E2AO 0001) CFR—ID NO. UN 1053; CLASS I! FLAMMABLE GAS, REQUIRES FLAMMABLE GAS AND POISON LABEL,

-n PACKAGING REQUIREMENTS 173.304 AND 173.314, PROHIBITED ON

' PASSENGER AIRCRAFT OR RAILCAR, 300 POUND MAXIMUM NET WEIGHT PER

(" PACKAGE FOR CARGO AIRCRAFT. (FEREAC 0017)

(FLM> Flammafaility: VERY FLAMMABLE, COMBUSTION IMMINENT. MAY TRAVEL

CONSIDERABLE DISTANCE TO A SOURCE OF IGNITION AND FLASH BACK.

(NFICAM 0001)

(TCP) Toxic Combustion Prod.= EXTREME DANGER, ENTER WITH GREAT CARE.

WHEN HEATED TO DECOMPOSITION, EMITS HIGHLY TOXIC FUMES OF OXIDES

OF SULFUR. CDPMADX 0001)

IMMEDIATELY. USE WATER TO KEEP CONTAINERS COOL AND TO PROTECT 0,00258 MEN EFFECTING THE SHUT-OFF. FOR LARGE FIRES, USE WATER SPRAY,

FOG, OR FOAM. FOR SMALL FIRES, USE DRY CHEMICAL OR C02. WEAR

GOGGLES AND SELF-CONTAINED BREATHING APPARATUS. (85EUAF 0001)

(NFICAM 0001)

(AIP) Auto Ignition Point(C-): 500 (DEGREES FAHRENHEIT) (DPMADX 0001)

RANGE. DANGEROUSLY REACTIVE WITH FUMING OR STRONG NITRIC ACID

AND STRONG OXIDIZING MATERIALS. I i (LED Explosive limit(X), Lower: 4.3

p (UEL) Explosive Limit(X), Upper: 45

'• (MLT) Melting Point (C.): -85.49

J (BLP) Boiling Point (C.): -50.33 I.1 (SOD Solub.ility (ppm 0 25C)-- 5000

[• (SP6) Specific Gravity: .0015 p (VPN) Vapor Pressure (mm Hg>: 300; 80; 400; 43.4

(VDN) Vapor Density: 1.19

F (PER) Persistency: D.O. CONVERTS TO ELEMENTAL SULFUR UPON STANDING IN

WATER. (DPIRDU 0001) RAPIDLY OXIDIZED IN OXYGENATED WATERS. THE

IJ HALF-LIFE OF H2S IN WATER CONTAINING S MG/L D.O. IS ABOUT 17

I j MINUTES. H2S03, H2S04 AND S04 ION ARE POSSIBLE PRODUCTS.

(PFA) Potential for'Accumulation: NEGATIVE

[ (EDF) Etiological Potential •• BRONCHITIS

(TRT) Major Species Threatened: AQUATIC AND ANIMAL LIFE. PLANTS MAY BE

INJURED IF EXPOSED TO > 5 PPM IN AIR OVER 24 HOUR(R175*» 0001).

(INH) Inhalation Limit (Value): 300 (PPM; IDLH)

(INT) Inhalation Limit (Text): REGULATIONS— OSHA PEAK 50 PPM/10 MIN

ONCE ONLY IF NO OTHER MEASUREABLE EXPOSURE OCCURS (2SCFR* 1912)

Q5HA CEILING 20 PPM (29CFR» 1910). RECOMMENDATIONS— NIOSH

CEILING 15 MG/M3/10 MIN 10 PPM/10 MIN (CRSOE* 77-158,77/NIOSH )

EVACUATION REQUIRED IF CONCENTRATION IS EQUAL TO OR GREATER THAN 70 MG/M3 (CRSOE* 77-158,77/NIOSH) NIOSH IDLH 300 PPM

83/ACGIH) AC6IH STEL 21 MG/M3/15 MIN 15 PPM/15 MIN (TLVADM

83/ACGIH) UPDATED 3/84.

(IRL) Irritation Levels (Value): 5 TO 20; 50

CRT) Irritation Levels (Text): PPM; IRRITATION BEGINS; SYMPTOMS OP

EXPOSURE BEGIN (85PHA9 0001)

(DRC5 Direct Contact: INHALATION WARNING PROPERTIES ARE NULLIFIED BY

I EVENTUAL DEADENING OF SENSES. FREEZING TYPE BURNS TO SKIN WITH

LIQUID. (CEAM»* 80/AME) LOCAL: CONJUNCTIVITIS, KERATITIS, SKIN

I ; BURtMS, PHOTOPHOBIA, LACRIMATION, CORNEAL VESICULATION.

j (JNS) General Sensation: RESPIRATORY: RHINITIS, PHARYNGITIS, OLFACTORY

FATIGUE, BRONCHITIS, PNEUMONIA, PULMONARY EDEMA, APNEA, COUGH.,

|; CYANOSIS, DYSPNEA. SYSTEMIC: ANOREXIA, ATAXIA, DIARRHEA,

, NAUSEA, VOMITING, HEADACHE, DIZZINESS, FATIGUE, INSOMNIA,

" IRRITABILITY, HYPERREFLEXIA, PARASTHE3IAS, WEAKNESS, TREMORS, n AND NUMBNESS IN EXTREMITIES, SHOCK, CONVULSIONS, UNCONSCIOUSNESS. <85EUA9 0001) (PKTGD» 0001) (THIDDB 0002) IN

HUMANS (INHALATION); 800 PPM IMMEDIATELY LETHAL, B00 PPM FOR 30

MINUTES LETHAL, 200 PPM SEVERE TOXIC EFFECTS IN ONE MINUTE, 50

PPM SYMPTOMS OCCUR, 20 PPM UNSATISFACTORY. (85FHA9 0001) 300

MG/CU M INHALED, NEAR FATAL, 60 PPM FOR 10 MINUTES INHALED,

FATAL. 20 TO 150 PPM CAUSES EYE IRRITATION, RESPIRATORY TRACT

IRRITATION, AND PULMONARY EDEMA IF EXPOSURE IS PROLONGED. 503

PPM FOR 30 MINUTES CAUSES HEADACHE, DIZZINESS, STAGGERING,

DIARRHEA, DYSURIA, BRONCHITIS, AND BRONCHOPNEUMONIA. 800 TO

1000 PPM IS FATAL IN 30 MINUTES. H2S IS BOTH AN IRRITANT AND AN

ASPHYXIANT. IN SMALL AMOUNTS IT DEPRESSES THE NERVOUS SYSTEM;

IN LARGER AMOUNTS IT STIMULATES; "AND IN VERY HIGH AMOUNTS IT

PARALYSES THE RESPIRATORY CENTER. REPEATED EXPOSURE TO LOU 000260 LEUELS CAUSES CONJUNCTIUITIS, PHOTOPHOBIA, LACRIMATION, PAIN,

AND BLURRED VISION. CHRONIC POISONING CAUSES HEADACHE,

INFLAMMATION OF CONJUNCTURE AND EYELIDS, DIGESTIVE

DISTURBANCES, WEIGHT LOSS, AND GENERAL DEBILITY. (DPMADX 0081 )

(LOT) Odor Threshold, Lower (ppm): 0.008 TO 0.35

(LTT) Taste Threshold, Lower (ppm) = .001

(SAF) Personal Safety Precautions •• SELF-CONTAINED BREATHING APPARATUS

(INCLUDING FULL EYE PROTECTION) AND FULL BODY SUIT WITH ft

MATERIAL OF RUBBER, NEOPRENE, OR PLASTICIZED PVC. ALSO GLOVES

OF THE SAME MATERIAL. (CEAM*« 80/AME)

(AHL) Acute Hazard Level: TOXIC TO AQUATIC LIFE AT LOW CONCENTRATIONS.

STRONG IRRITANT. HIGHLY TOXIC VIA INHALATION. EMITS HIGHLY TOXIC

VAPORS WHEN BURNED. WILL CAUSE TASTE PROBLEM IN DRINKING WATER.

APPROXIMATE LC IN AIR FOR RATS, 1500 MG/M3 < SLHPAH 0001' >.

THRESHOLD CONCENTRATION FOR FRESH OR SALT WATER FISH - .5 PPM L SULFIDE (E188*« 0001 ). (CHL) Chronic Hazard Level= PROLONGED EXPOSURE EFFECTS EYES AT 20 PPM.

SAFE LEVEL IS LIKELY TO BE BELOW .006 MG/L(WATRAG 0027);

SYMPTOMS INCLUDE HEADACHE, INFLAMMATION OF CONJUNCTIVAE, AND

EYELIDS, DIGESTIVE DISTURBANCES, LOSS OF WEIGHT AND GENERAL

DEBILITY. NO EFFECT'LEVELS FOR STRONG IRRITANT. AQUATIC LIFE

ARE AT 8-12% OF.35-HOUR LC50(UATRAG 0023); HIGHLY TOXIC WHEN

INHALED CHRONICALLY; HOWEVER, IT MAY NOT PERSIST LONG ENOUGH

FOR CHRONIC EFFECTS TO BE OBSERVED.

(HEL) Degree of Hazard to Public Health: 'STRONG IRRITANT WITH BOTH

ACUTE AND CHRONIC EXPOSURE. HIGHLY TOXIC VIA INHALATION ACUTE OR

CHRONIC. EMITS TOXIC VAPORS WHEN BURNED.

(AIR) Air Pollution: HIGH; TO AVOID SYSTEMIC EFFECTS OF SHORT-TERM

EXPOSURE TO GREATER THAN E00 PPM H2S, THE AVERAGE 10-MINUTE AMBIENT LEVELS SHOULD BE LESS THAN 120 PPM. SEVERAL EQUATIONS 000261 AND GRAPH? ARE PRESENTED TO DETERMINE THE RADIUS OF EXPOSURE TO

THIS LEUEL GIVEN DIFFERENT CONDITIONS AND H2S EMISSION RATES.

(4-2IIAU 0001 )

(ACT) Action Levels: NOTIFY FIRE AND AIR AUTHORITY. WARN CIVIL DEFENSE

OF POSSIBLE EXPLOSION. VAPOR ENTERINS SEWERS OR CLOSED SPACES

MAY CREATE POISON, EXPLOSION, OR FIRE HAZARD. EVACUATE IF

NECESSARY; FIRE-2003 FEET MINIMUM IN ALL DIRECTIONS, NONFIRE

1500 FEET MINIMUM IN ALL DIRECTIONS. (CEAM** 30/AME) FOR SMALL

SPILLS, ISOLATE 120 FEET IN ALL DIRECTIONS; FOR SPILLS FROM A

TANK. FIRST ISOLATE 240 FEET IN ALL DIRECTIONS, THEN EVACUATE r DOWNWIND 0.B MILES IN WIDTH FOR 0.9 MILES. (B5EWAF 0-001) SHUT OFF ISNITION SOURCES AND CALL FIRE DEPARTMENT. IF SPILL ENTERS A

BODY OF WATER, NOTIFY LOCAL HEALTH AND WILDLIFE OFFICIALS AND

OPERATORS OF NEARBY WATER INTAKES. (CGCH** 0001)

(AMD In Situ Amelioration; CARBON WILL REMOVE SOME H2S. ANION

EXCHANGERS MAY ALSO BE EFFECTIVE. DISSOLVED OXYGEN CAUSES

PRECIPITATION OF ELEMENTAL SULFUR.' AERATE OR OXYGENATE WITH

COMPRESSOR. SPILLS WILL NOT BE CONTAINED BY OVERLAYS OF FOAM,

WATER, OR FILM BECAUSE THE AMBIENT VAPOR PRESSURE IS TOO

LARGE. GOOD ADSORBABILITY. CONTROL VAPORS WITH LIQUEFIED

NITROGEN OR SOLID CARBON DIOXIDE.

PROFESSIONAL ENVIRONMENTAL ENGINEERING ASSISTANCE THROUGH EPA'S

ENVIRONMENTAL RESPONSE TEAM

321-BBS0.

(AVL) Aval, of Counter-measure Material: CARBON - WATER TREATMENT

PLANTS, SUGAR REFINERIES; ANION EXCHANGERS - WATER SOFTENER

SUPPLIERS; COMPRESSORS - CONSTRUCTION CONTRACTORS.

'.DIS> Disposal Method: CAN BE ABSORBED IN SODIUM PHENOLATE, POTASSIUM

PHOSPHATE, OR ETHANOLAMINES AND SUBSEQUENTLY CARBONATE, SODIUM

HYDROXIDE, OR SODIUM THIOARSENATE. WATER SOLUTIONS CAN BE 000282 REACTED UITH-DILUTED SULFUROUS ACID AND THE BOILER FLUE GAS IS

USED TO PRODUCE MORE READILY DISPOSABLE FORMS OF SULFUR. (DPIRDU

0031 >

(IFP) Industrial Fouling Pot.: EXPLOSIVE. DANGEROUS IF CONFINED IN

BOILER FEED OR COOLING SYSTEM WATER.

CUTP) Effects on Water Treatment Process: SLUDSE DIGESTION INHIBITED

AT 73 TO 120 MG/L. (85FHA9 3001)

(WAT) Major Water Use Threatened: RECREATION, FISHERIES, INDUSTRIAL,

POTABLE SUPPLY.

(LOO Probable Location and State of Material: COLORLESS GAS. WILL BE

DISSOLVED IN WATER OR CLINGING NEAR GROUND. WHEN RESULTS FROM

HYDROLYSIS, IT WILL NORMALLY BE IN WATER. WHEN IT RESULTS FROM

SPILL OF PURE H2S, WILL BE FOUND IN GASEOUS STATE.

• (HOH) Water Chemistry: SULFIDE FORMS INSOLUBLE SALTS WITH HEAVY METALS

AND IRON WHICH MAY BE PRESENT IN WATER BUT WILL SETTLE OUT FOR

I MOST PART. SOLUBLE H2S WILL BE IN EQUILIBRIUM BETWEEN r UNDISSOCIATED FORM, HS- AND H+ .FORMS. THE SECONDARY S— IS IMPORTANT ONLY AT VERY HIGH PH LEVELS. LESS THAN .05% OF H2S IS

| | PRESENT AS S— AT PH 11 AND < .5% AT PH 12. ESCAPE INTO THE

. ATMOSPHERE OCCURS MOSTLY AT LOW PH. AT PH ? ESCAPE IS 502 OF

THAT IN STRONG ACID. AT PH 9, ESCAPE IS 1% OF THAT IN STRONG

I ACID.

(DAT) Adequacy of Data: GOOD

000263 go ohmtads

OHM/TADS (Version 7.14/9.5 December, 1985) ($55/Hr.)

Latest Data Base Update-. 12/85 - 1,402 Entries Total (See 17 Dec NEUS Me

ssage )

Latest news for OHMTADS . . .

17 Dec 35; Database Updated - B8 New Records; 13 Updated Records

Option'? type 1/msds .ohmtads

Conversion to local identifiers resulted in 1 unique occurrences.

Conversion Entry 1; Accession No. 7Z1677B c (CAS) CAS Registry Number: 7439-92-1 C5IC) SIC Code: 3693; 35B2; 2316; 3323; 3631 r CMAT) Material Name: LEAD

1 CUSS) Common Uses'- X-RAY PROTECTION; PAINT PIGMENT; BEARING METAL AND

( ALLOY STEEL BATTERIES i: (BIN) Binary Reactants: HYDROGEN PEROXIDE, ZIRCONIUM,.

| CSGM) • Synergistic Materials: AS DISSOLVED OXYGEN LEVELS DECREASE LEAD

BECOMES MORE TOXIC TO FISH. SOFT WATER ALSO INCREASES TQXICITY.

(ANT) Antagonistic Materials: THE CHARACTERISTICS OF WATER SOFT OR

' HARD THAT APPEAR TO BE COND'ICTIVE TO PLUMBO-SOLVENCY INCLUDE

COMPARATIVE ABSENCE OF CA AND MG BICARBONATES, LOW PH, HIGH

DISSOLVED OXYGEN AND HIGH NITRATE CONTENT, INSOLUBLE LEAD IS NOT

HIGHLY TOXIC TO FISH. LEAD IS MORE TOXIC IN SOFT WATER. 58 PFM

Cft HAS DESTROYED THE TOXIC EFFECT OF 1 PPM LEAD.

iFCL.-. Detection Limit (Field; Techniques ,Ref > (ppm;-- .35, LEAD, • (BNU10* 000E3

000E)

(STD) Standard Codes'- NFPA - 3,2,-; ICC, USCS - NO.

(FLM) Flammability: MODERATE IN FORM OF DUST EXPOSED TO HEAT OR FLAME.

(TCP) Toxic Combustion Prod.: WHEN HEATED EMITS HISHLY TOXIC FUMES.

ENTER WITH GREAT CARE.

(EXP) Expiosiveness: MODERATE IN FORM OF DUST EXPOSED TO HEAT OR

I FLAME. REACTIVE AT HIGH TEMPERATURE AND PRESSURE; CAN REACT

VIGOROUSLY WITH OXIDIZING MATERIALS. » II (MLT) Melting Point : 327.4

I' <8LP) Boiling Point (C.): 1740

(SPG) Specific Gravity- 11.34 r[ (VPN) Vapor Pressure (mm Hg): 1; 1; 5; 10; 100

._ (PER) Persistency- WILL-SLOWLY BE PRECIPITATED BY NATURAL CARBONATES.

•"• (PFA) Potential for Accumulation: ACCUMULATES IN BONES. POSITIVE. n CONCENTRATION FACTORS FOR LEAD - MARINE AND FRESHWATER PLANTS AND INVERTEBRATES 200 AND FISH - 80 (-170). HALF-LIFE IN TOTAL

HUMAN BODY - 14B0 DAYS (R172«* 0001).

(CAG) Carcinogenicity: NEGATIVE. NO TUMORI6ENIC EFFECTS NOTED IN

RODENTS ADMINISTERED 25 M6/L PB IN DRINKING WATER (R120*» 0001).

Mutagenicity: POTENTIAL. CHROMOSOME DAMAGE HAS BEEN NOTED FOR

LEAD IN OCCUPATIONALLY EXPOSED PERSONS (R120»« 0001).

(TER) Teratogenicity: 1 PPB TOXIC TO 24-32* OF CHICK EMBRYOS (XNRNBT

0002). POTENTIAL. (TRT) Major Species Threatened: ALL LIFE

(INH) Inhalation Limit (Value): .15

(INT5 Inhalation Limit (Text): REGULATIONS— OSHA PEL (TWA) .05 M6/M3

<2SCFR* 1910;. RECOMMENDATIONS— NIOSH TWA -:.100 MG/M3 (CRSCE*

73-153,78/NICSH) ACGIH TLV (TWA) .15 MG/M3 (TLVADM 33/ACSIH; 00026? AC6IH STEL .45 MG/M3/15 MIN (TLVADM 83/ACGIH)

(JNS) General Sensation: COMPOUNDS CAN BE ABSORBED THROUGH SKIN AT

TOXIC CHRONIC LEVELS. SYMPTOMS INCLUDE PICA, ANOREXIA, VOMITING,

MALAISE AND CONVULSIONS. MAY LEAVE PERMANENT BRAIN DAMAGE.

(DHI) Direct Human Ingestion (Mg./KGut. ); 15

(AHL) Acute Hazard Level: THRESHOLD CONCENTRATION FOR FRESH AND SALT

WATER FISH, .1 PPM (E188»* 0001). .2 6M LEAD/KG BODY WEIGHT

I CAUSED DEATH WITHIN A FEW DAYS IN CALVES. BACTERIAL S DECOMPOSITION OF ORGANIC MATTER IS INHIBITED BY .1 PPM LEAD.

I LOBSTERS DIED IN 20 DAYS WHEN KEPT IN LEAD LINED TANKS. REPORT r OF CHRONIC LEAD POISONING AMONG ANIMALS BY 1.8 PPM OF LEAD IN I! SOFT WATER. LEAD COMPOUNDS ARE HIGHLY TOXIC IF INGESTED OR

INHALED. LEAD METAL IS AN INHALATIVE HAZARD.

(CHL) Chronic Hazard Level: MORE OF A CHRONIC PROBLEM THAN ACUTE.

L APPLICATION FACTOR TO CONVERT 36 HOUR LC50 TO CHRONIC SAFE LIMIT

P' - .013 BROOK; LEAD METAL IS A CHRONIC HAZARD VIA INGESTION OR

INHALATION. TROUT, .043 FOR RAINBOW TROUT. (R131** 0001)

[ ! DEFORMITY AND SUB-ADULT MORTALITY HAS BEEN NOTED IN TROUT

,, EXPOSED TO .012-.14 PPM PB FOR 19 MONTHS AND 18 DAYS; CHRONIC

' POISONING SYMPTOMS INCLUDE, WEIGHT LOSS, WEAKNESS, AND ANEMIA.

I" RESPECTIVELY. (R182** 0001) FRESHWATER SHOULD NOT EXCEED .03 PPM

PB AND MARINE WATERS 1/50 OF 96 HOUR LC50. (R184** 0001)

DAPHNID REPRODUCTION REDUCED li% FROM 3 WEEKS EXPOSURE TO .030

PPM PB. (JFRBAK 0010); ADMINISTRATION OF 25 MG/L PB IN DRINKING

WATER LED TO RAPID DIE-OFF OF BREEDING COLONIES OF MICE AND

RATSCR120»« 0001 ).

CHEL; Degree of Hazard to Public Health: LEAD IS AN ACUTE INHALATIVE

TOXIN AND A CHRONIC INGESTIVE AND INHALATIVE TOXIN. COMPOUNDS

ARE GENERALLY MORE TOXIC DUE TO SOLUBILITY. LEAD COMPOUNDS CAN 00026?} ALSO BE ABSORBED THROUGH SKIN AT HIGHLY TOXIC LEVELS.

(AIR) Air Pollution: HIGH

(ACT) Action Levels: ATTEMPT TO SUPPRESS SUSPENSION OF DUSTS.

(AMD In Situ Amelioration: ADD LIME TO PRECIPITATE BASIC LEAD

CARBONATE. POSSIBLE TO ADD COMPLEXING AGENT (EDTA) AND ADSORB ON

CARBON. SEEK PROFESSIONAL ENVIRONMENTAL ENGINEERING ASSISTANCE

THROUGH EPA'S ENVIRONMENTAL RESPONSE TEAM (ERT>, EDISON, NJ, 24-

HOUR NO. 201-321-66B0.

(AVL) Aval, of Counter-measure Material •• LIME - CEMENT PLANTS

COMPLEXANTS - DETERGENT MANUFACTURERS, ANALYTICAL LABS; CARBON -

UATER TREATMENT PLANTS, SUGAR REFINERIES.

(IFP) Industrial Fouling Pot.: TRACES OF LEAD IN METAL-PLATING BftTHS

WILL AFFECT THE SMOOTHNESS AND BRIGHTNESS OF DEPOSITS.

(WAT) Major Water Use Threatened: POTABLE SUPPLY. FISHERIES.

L (LOO Probable Location and State of Material: METAL WILL SINK. MANY r SALTS INSOLUBLE. MAY GET DISPERSIONS. (DRT) Soil Chemistry: SOIL ORGANIC MATTER, PH, AND PHOSPHATE CONTENT

CONTROL THE MOBILITY OF LEAD; EFFLUENT HOLDING 173 MG/L PB HAS

BEEN NOTED TO UNDERGO A 98% REDUCTION IN 3 INCHES OF SOIL

£R174*« 0001); LEAD CONCENTRATIONS SHOULD NOT EXCEED 2 PPM AS

THE SOLUBLE FORM IN THE SOIL S.OLUTION FOR PHYTO TOXIC

CONSIDERATIONS; CALCIUM MAY COUNTERACT SOME LEAD TOXICITY

(R175** 0001); LEAD CONCENTRATIONS OF UP TO 1B32 PPM IN THE TOP

12 INCHES OF SOIL CAN BE TOLERATED FROM THE STANDPOINT OF

ACCUMULATION AND BIOMAGNIFICATION (UUAEA2 0001).

(HOH) Water Chemistry: LEAD IS STABLE IN OXYGENATED UATER AS THE

CARBONATE, HYDROXIDE, OR; CARBONATE-HYDROXIDE SALTS. UNDER

REDUCING CONDITIONS AND IN THE PRESENCE OF SULFUR, LEAD SULFIDE

WILL PREDOMINATE. LEAD IS LEAST SOLUBLE AT PH 9-10 WITH CARBON DIOXIDE LEVELS AT 10-3 M. AT CARBON DIOXIDE LEVELS OF 10-2 M

SOLUBILITY IS LOWEST AT PH 8-10. AT PH 7-8, SOLUBILITY OF TOTAL

LEAD IS .001-.01 MG/L (JAUUA5 0013).

(DAT) Adequacy of Data; GOOD r

000288 type 3/rosds.ohmtads

Conversion to local identifiers resulted in 1 unique occurrences.

Conversion Entry 1; Accession No. 721B810

(CAS) CAS Registry Number: 7440-02-0

(SIC) SIC Code: 3312; 3B91; 3499; 3B43; 2819

(MAT) Material Name= NICKEL

I (FMD Chemical Formula: NI

(USS) Common Uses: STAINLESS STEEL; NICKEL-CHROME RESISTANCE WIRE;

I SPARK PLUGS; COINS; STORAGE BATTERIES; MAGNETS; LIGHTNING ROD

TIPS; CATALYSTS

(BIN; Binary Reactants: SELENIUM, SULFUR I I j CSSM) Synergistic Materials: AT NUTRIENT LEVELS FOR NI, UTA AND EDTA

REMOVE REQUIRED METAL CAUSING MORTALITY.

(ANT) Antagonistic Materials: MOLYBDENUM REDUCED SOMEWHAT THE TOXICITY F TO SOME PLANTS. NA2HNTA; NTA AND EDTA AT TOXIC LEVELS OF NI, REMOVE ENOUGH NICKEL TO RENDER UATER SAFE. i: (FDL5 Detection Limit (Field; Techniques,Ref> (ppm): 2.5, NICKEL CCLORIMETRIC, (BNU50* 0002)

(LDL) Detection Limit (Lab; Techniques,Ref ) (ppm): .0025, HEFTORIME

METH-NICKEL, (BNU10* 0018) (STD) Standard Codes: NFPA - -,2,-; NO ICC; NO USCG.

(FLM) Flammability: MODERATE AS DUST EXPOSED TO HEAT OR FLAME.

CEXP) Explosiveness: SLIGHT AS DUST EXPOSED TO FLAME REACTIVE ONLY

UNDER EXTREME CONDITIONS.

(MLT) Melting Point (C.): 1555

(EL?1- Soiling Point < C . ) = 2837

C£FS> Specific Gravity: S.S

'.?£R> Persistency: CAN PERSIST IN NATURAL WATERS INDEFINITELY. 00026$ (PFA) Potential for Accumulation: POSITIVE. CONCENTRATION FACTORS FOR

NI - MARINE PLANTS AND INVERTEBRATES -250; FISH - 100;

FRESHWATER PLANTS AND INVERTEBRATES - 100, FISH 40 (R170** -

3001). HALF-LIFE IN TOTAL HUMAN BODY - SB7 DAYS (R172** 0001).

(EOF) Etiological Potential: MAY CAUSE DERMATITIS IN SENSITIVE

INDIVIDUALS.

(TRT) Major Species Threatened: ALL SPECIES ESPECIALLY CITRUS PLANTS.

(INH) Inhalation Limit (Value): .001

<29CFR* 1910). RECOMMENDATIONS— NIOSH TWA .015 MS NI/M3

(CRSOE* 77-164,77/NIOSH) ACGIH TLV (TUAH MG/M3 (TLVADM

83/ACBIHJ UPDATED 3/84

!DRC> Direct Contact: ALLERGEN, MILD IRRITANT SKIN.

VOMITING, AND DIARRHEA.

Personal Safety Precautions: WEAR SKIN PROTECTION AND FILTER '

MASK.

(E188*« 0001). NICKEL IS EXTREMELY TOXIC TO CITRUS PLANTS. MILD

IRRITANT AND ALLERGEN. SLIGHTLY TOXIC WHEN INHALED OR

INGESTED. TOXIC TO ACUATIC LIFE ABOVE NUTRIENT LEVELS.

(CHL) Chronic Hazard Level= MODERATELY TOXIC WITH CHRONIC INHALATION.

OAPHNID REPRODUCTION AFFECTED BY EXPOSURE TO .095 PPM NI IN 3-

WEEKS. IRRITANT AND ALLERGEN. FATHEAD MINNOW WERE SIMILARLY

AFFECTED BY .73 PPM NI OVER 11 MONTHS (R182*« 0001). FRESH AND

MARINE UATER SHOULD NOT EXCEED 1/50 OF 3B HOUR LCS0. MAXIMUM

ALLOWABLE TOXICANT; CONCENTRATION (MATC) FOR FATHEAD MINNOU .33-

.73 PPM. APPLICATION FACTOR FOR .96 HOUR TL53 EXTRAPOLATION

.314-.227 (JUPFA5 3015).

'.HEL/ Degree of Harard to Put lie Health: SYSTEMIC POISONING OF HUMANS 000270 BY NI OR ITS SALTS IS ALMOST UNKNOUN. MILD IRRITANT AND

ALLERSEN. SLIGHT HAZARD WHEN INGESTED OR INHALED. CHRONIC

EXPOSURE IS MORE DANGEROUS, NI BEING A MODERATE INHALATIVE TOXIN

UITH PROLONGED DOSING.

(AIR) Air Pollution: SLIGHT HAZARD FROM OUST LOW.

(ACT) Action Levels: PREVENT SUSPENSION OF DUSTS.

2 OR USE

CATION EXCHANGERS. SEEK PROFESSIONAL ENVIRONMENTAL ENGINEERING

ASSISTANCE THROUGH EPA'S ENVIRONMENTAL RESPONSE TEAM (ERT;,

EDISON, NJ, 24-HOUR NO. 201-321-6550.

(AVL) Aval, of Counter-measure Material: LIME - CEMENT PLANTS; CATION

EXCHANGERS - WATER SOFTENER SUPPLIERS.

(CIS; Disposal Method' ROUTE TO METAL SALVAGE FACILITY.

;WTP> Effects on Water Treatment Process: 530 PPM RETARDED SEUnGE

DIGESTION 9.4X A NICKEL CONCENTRATION OF 3.S PPM CAUSED 52%

I REDUCTION IN OXYGEN UTILIZATION FROM SYNTHETIC SEWAGE. r !'JAT) Major Water Use Threatened: IRRIGATION, FISHERIES, RECREATION (LCC) Probable Location and State of Material •• METAL WILL SINK. MANY

SALTS ARE SOLUBLE. MAY GET HYDROXIDE PRECIPITATES.

;DRT) Soil Chemistry: NICKEL MOBILITY IS CONTROLLED BY SOIL CATION

EXCHANGE CAPACITY, ORGANIC CONTENT (ESPECIALLY CHELATES), THE

PRESENCE OF OTHER CATIONS, PHOSPHATE CONTENT, AND PH, (R175**

0001 ) FREE OR EXCHANGEABLE NICKEL SHOULD NOT EXCEED 2 PPM IN

SOIL SOLUTION TO PREVENT PHYTO TOXIC EFFECTS ON PLANTS. IRON

MAY MINIMIZE NICKEL TOXICITY

NOT EXCEED 328 PPM IN THE TOP 12 INCHES OF SOIL IF CROPS ARE TO

BE USED (WUAEA2 0001 ).

PHOSPHATE PRECIPITATE DEPENDING ON PH, HARDNESS, AND ALKALINITY.

!CCL) Color in Water: OFTEN BLUE OR GREEN (DAT) Adequacy of Data: GOOD

I. L P! f type S/fflsds.ohmtads

Conversion to local identifiers resulted in 1 unique occurrences.

Conversion Entry 1; Accession No. 7216947

CCAS) CAS Registry Number: 75-01-4

(SIC) SIC Code: 2313

(MAT) Material Name: VINYL CHLORIDE

[ (FML) Chemical Formula: CH2:CHCL i CUSS) Common Uses: PLASTICS, REFRIGERANT, ORGANIC COUP GUILDS. j (CON) Containers-- PRESSURE CYLINDERS, TANK CARS, TANK BARGES. j (STO) General Storage Procedure: PROTECT AGAINST PHYSICAL DAMAGE.

OUTSIDE OR DETACHED STORAGE IS PREFERABLE. INSIDE STORAGE SHOULD

I . BE IN ft FIRE RESISTIVE STORAGE ROOM, PROVIDED WITH ADUATE

VENTILATION AND FREE OF SOURCES OF IGNITION AND HEAT.

L General Handling Procedure: GUARD AGAINST ALL SOURCES OF r1 IGNITION.

CSTD) Standard Codes: NFPA - 2,4T,1: ICC - FLAMMABLE GAS, RED GAS

[ LABEL, 380 LBS IN AN OUTSIDE CONTAINER; USCG - LIQUEFIED

NONFLAMMABLE GAS; IATA -

' NOT ACCEPTABLE PASSENGER, 140 KG CARGO, (INHIBITED) FLAMMABLE

! GAS, NOT ACCEPTABLE.

(LFL) Fiammability LimitCX), Lower: 3.6

(TCP) Toxic Combustion Prod.= HCL, PHOSGENE, CO; HAZARDOUS, EMPLOY

SELF-CONTAINED BREATHING APPARATUS.

CONTAINERS COOL. DO NOT EXTINGUISH UNLESS NECESSARY TO EFFE

IMMEDIATE ShUTOFF OF FLOW. DRY CHEMICAL AND CARBON DIOXIDE CAN BE USED TO EXTINGUISH VINYL CHLORIDE FIRES.

(FLP) Flash Point

(AIP) Auto Ignition Point(C.): 472.22

POLYMERIZES BY EVOLUTION OF HEAT, IN; PRESENCE OF AIR, OXYGEN,

SUNLIGHT OR HEAT.

(LED Explosive limit(Z), Lower•• 4

(UEL) Explosive LimitCX), Upper: 22

Melting Point (C.)' -153.8

Boiling Point (C.)-- -13.37 (IGNITES)

,(SP6> Specific Gravity: .9106

(VPN) Vapor Pressure (mm Hg): 403

(PER) Persistency: POLYMERIZES IN PRESENCE OF AIR, OXYGEN, SUNLIGHT CR

HEAT. VOLATILIZES AND WILL LEAVE WATER QUITE SOON.

(CAG) Carcinogenicity: STUDIES INDICATE POSITIVE DEVELOPMENT FROM

OCCUPATIONAL EXPOSURE.

(TRT5 Major Species Threatened: TERRESTRIAL LIFE

(INH) Inhalation Limit (Value): 300

Cir4T) Inhalation Limit (Text): REGULATIONS--

OSHA CARCINOGEN. (29CFR« 1910)

OSHA PEL (TUA) 1 PPM (29CFR* 1910)

OSHA PEAK 5 PPM/15 MIN <29CFR« 1910)

RECOMMENDATIONS--

NIOSH CEILING 2.55 M6/M3/15 MIN

1 PPM/15 MIN (CRSOE* PB-24EE19/NIOSH)

ACGIH HUMAN CARCINOGEN (TLVADM 83/AC6IH)

ACGIH TLV (TUAU0 M6/M3 5 PPM (TLVADM 83/ACGIH)

UPDATED 3/84

(DRC;> Direct Contact: ACTS AS REFRIGERANT UNDER PROLONGED CONTACT ANDA Ar

AS SUCH CAN CAUSE SKIN BURNS. (JNS) General Sensation' SWEET SMELLING GAS. PROPOSED LIMITS WILL BE 1 PPM FOR 8 HOUR WORKING DAY, 5 PPM FOR 15 MINUTE AVERAGE; MAY BE

ANESTHETIC ABOVE 500 PPM. HANDLING OF UNINHIBITED MATERIAL HAS

CAUSED CIRCULATORY AND BONE CHANGES <302NA5 0001).

Personal Safety Precautions: GAS TIGHT GOGGLES AND BREATHING

APPARATUS IS REQUIRED IN FIRE AREAS OR WHERE CLOSED ENVIRONMENT

OR POOR VENTILATION CAUSES HIGH VAPOR CONCENTRATION. EYE

GOGGLES AND IMPERVIOUS OUTERWEAR ARE RECOMMENDED FOR AREAS WHERE

| LIQUID VINYL CHLORIDE MAY BE ENCOUNTERED.

SHOULD CAUSE NO PROBLEM IN WATER. EMITS TOXIC VAPORS WHEN HEATED

j; TO DECOMPOSITION.

CCHL) Chronic Hazard Level: CHRONIC EXPOSURE HAS SHOWN LIVER INJURY IN

I RATS AND RABBITS. CHRONIC IRRITANT.

CHELJ Degree of Hazard to Public Health: IRRITANT. MODERATELY TOXIC

L UITH INHALATION. EMITS HIGHLY TOXIC VAPORS WHEN HEATED TO r DECOMPOSITION. (AIR) Air Pollution: HIGH

(ACT) Action Levels: EVACUATE AREA. ENTER FROM UPWIND AFTER GAS LEVELS , HAVE SUBSIDED. NOTIFY FIRE AND AIR AUTHORITY. REMOVE IGNITION i SOURCES.

| In Situ Amelioration: USE CARBON OR PEAT ON DISSOLVED PORTION. * SEEK PROFESSIONAL ENVIRONMENTAL ENGINEERING ASSISTANCE THROUGH EPA'S ENVIRONMENTAL RESPONSE TEAM (ERT), EDISON, NJ, 24-HOUR

NO. 201-321-BSS0. fAVL) Aval, of Countermeasure Material •• CARBON - WATER TREATMENT PLANTS, SUGAR REFINERIES; PEAT - NURSERIES, FLORAL SHOPS

CDIS) Disposal Method' DILUTE TO 1% SOLUTION AND REMOVE PHENOL INHIBITOR AS SODIUM 1. POUR ONTO UERMICULITE, SODIUM BICARBONATE

OR A SAND-SODA ASH MIXTURE (30/10).

STAY UPUIND. OR DUMP IN CLOSED INCINERATOR WITH AFTERBURNER 2.

DISSOLVE IN FLAMMABLE SOLVENT AND SPRAY IN INCINERATOR FIREBOX

UIPPED WITH AFTERBURNER AND ALKALI SCRUBBER.

(DSN) Disposal Notification: LOCAL AIR AUTHORITY

Major Water Use Threatened: RECREATION

(LOO Probable Location and State of Material: COLORLESS SAS. HEAVY

VAPORS WILL CLIN6 NEAR GROUND. SOME WILL DISSOLVE. POLYMERIZES READILY IN AIR OR SUNLIGHT.

CHOH) Water Chemistry: SUBJECT TO POLYMERIZATION.

(COL) Color in Water: COLORLESS

000276 GERAGHTY '& MILLER, INC. Ground- Water Consultants

November 11, 1986

Ms. Nicolleta DeForte Environmental Engineer United States Environmental Protection Agency * Region II 26 Federal Plaza I New York, New York 10278 Dear Ms. DeForte: i: Pursuant to Paragraph IIB of the Administrative Order, Y we have responded to the USEPA comments pertaining to the Site Operations Plan (SOP) for the Syosset Landfill received '- on October 17, 1986. As agreed during the conference call F on November 1, 1986, this letter is intended to serve as an n amendment to the SOP submitted on August 7, 1986. Our responses have been prepared specifically to ad- • dress your comments and are presented in a format to indi- I cate our reply to each of your comments.

EPA Comment No. 1 (a) "...justification... for the use of I mud-rotary as a drilling method ...". Response; Overview

The Syosset Landfill overlies a sand and gravel aquifer consisting primarily of glacial outwash and deltaic sands and gravel. The depth to ground water ranges between 90 and

125 East Bethpage Road • Plainview, New Vbrk 11803 • (516) 249-7600 p n f\ O 7 * Cable: VUATER • Telecopy: (516) 249-7610 ° '"* GERAGHTY # MILLER, INC. -2-

100 feet below land surface. The monitoring well installation program referenced in the SOP requires that the monitoring wells should be drilled to depths so that the well screens can be installed at depths approximately 30 feet • (shallow wells) and 100 feet (deep wells) below the water 4 table. i•-; Well Installation Methods Penetration of a sand and gravel formation to depths 11 required by the SOP limits the methods of well installation I.: to two general approaches: 1. Hydraulic and air rotary consisting of: I r a. air as a circulation medium, 11 b. reverse circulation using water as a medium, and

i c. mud rotary using a mixture of water and bentonite as a drilling medium.

2. Cable tool method consisting of:

a. advancing black steel casing by percussion driving, and ' C00278 GERAGHTY & MILLER, INC. -3-

b. bailing a mixture of water and drill cuttings. The water must be added to the boring to allow removal of the cuttings. In addition, a head of water must be maintained in the casing to prevent sand heaving problems. i

Il> Analysis of the benefits and limitation of each method indicates that the mud rotary method is the most preferred [j technique due to several limitations of other methods. The I II drawbacks of these methods are as follows:

'- Air Rotary Method - The air rotary method is designed r for drilling consolidated (bedrock) formations and uses compressed air as a medium for removing drill cuttings and for Ij cooling the drill bit. It is not suitable for drilling un- consolidated formations such as sand and gravel which col- Li lapse when unsupported by a fluid-filled borehole. Another | major drawback of this method is the injection of compressed air into the formation and ground water. Ground-water sam- ^ pies collected for this study will be subjected to laboratory analysis which Include VOC's, the potential aeration of ground water during drilling caused by this method should be avoided if water samples are to be collected soon after well installation.

The air rotary method requires the addition of drilling foam in some circumstances for borehole stability anGOQ27a dust 9 GERAGHTY^ MILLER, INC. -4- i control. The organic additives present in the drilling foam could possibly alter the analytical results of ground-water samples and such interferences are not in accordance with QA/QC requirements of the SOP.

Reverse Circulation - Reverse circulation requires the I addition of large volumes of water in order to ensure stability of the borehole. Boreholes drilled to the depths 1. similar to those proposed in the SOP on Long Island have re- | quired volumes of water in the range of 100,000 to 150,000 gallons to achieve borehole stability. The addition of such [j large quantities of water to the borehole could possibly in- terfere with collecting ground-water samples for an indefi- L nite period of time even with extensive well development and p| purging.

i Cable Tool Method - The cable tool method advances Ij steel casing by using a combination of percussion and bail- 1 ing. The method is extremely slow and installation time I for boreholes to depths anticipated is approximately 10 months based on drilling rates from recent Long Island work. The use of this method for installing the monitoring wells would extend the drilling schedule from an estimated 7 weeks to at least 10 months (40 weeks).

The cable tool method also requires the removal of the black steel drill casing after the monitoring well GERAGHTY & MILLER. INC. -5-

installed. It may be impossible to remove the black steel casing from the borehole thereby leaving black steel casing in contact with the aquifer. This is not desirable if interference with metals analyses is a concern and drill casing suitable for the cable-tool method is not manufactured in stainless steel. I Mud Rotary Method - As indicated in the SOP, the mud I rotary method can be used to.install the monitoring wells in i accordance with the schedule contained in the SOP. Ii J i The bentonite/vater fluid used in the drilling process r will consist of polymer free, 100% bentonite and water from y an approved source. This will be verified by sampling the p drilling fluid and analysis prior to beginning the drilling program and the drilling rig equipment (including the mud . pump) will be decontaminated using a steam cleaner prior to I L. use.

EPft 7?7"'ment No. l (b) "...justification... for the use of ... submersible pumps for sample collection....".

Response;

The SOP requires that the monitoring wells be constructed of four-inch diameter casings. The depths to water in the wells will range between 90 and 100 feet below land surface. Considering that large volumes of water GERAGHTY # MILLER, INC. -6-

removed prior to sampling and that the water must be lifted from depths as great as 100 feet, the submersible pump is considered the best method for purging. The submersible pumps are preferred because:

* - the pump delivers a steady pumping rate; ! r - the pumping rate can be adjusted to prevent a I; purging rate which is either to fast or too slow; I and La |; - pumps set near the top of the water column in the well can effectively exchange all ground water in b the well casing. Pump settings can be easily p changed to accommodate water-level fluctuations. ji In addition to purging, the submersible is preferred for sampling over bailing because: I' r- - pumping with a submersible limits the potential of aeration of samples because no air to water interface occurs within the pump and discharge tubing.

- permanent pump installations eliminate cross-contamination by sampling equipment and the need for pump decontamination.

000282, GERAGHTY # MILLER, INC -7-

The submersible pumps referenced in the SOP are entirely constructed of stainless steel and separate pumps will be permanently installed in each well. The water level in the well will be checked periodically in order to determine if the pump setting should be changed due to fluctuations of the water table. I The selection of the permanent submersible pump instal- I lation was based on Geraghty & Miller, Inc. experience at r other Long Island landfills and a comparison of analytical results of both bailing and submersible pump sampling. f•: Guidance presented by Barcelona et al. (1985) indicates that IU a sampling device should be selected based on the following L criteria:

1. Ease of operation to minimize the possibility I: for operator error;

L 2. Dependability;

3. Variable flow rates to permit rapid well purging, but controlled sampling for volatile constituents; and

4. Minimization of effects on sample chemistry.

000283 GERAGHTY & MILLER, INC. -8-

The dedicated submersible pimp method satisfies the first three criteria. In order to demonstrate compliance with the fourth criterion, duplicate samples for volatile organic compounds (VOCs) were taken from selected wells by two different methods. VOCs are analytical parameters with generally high sensitivity to sampling affects by aera- | tion/volatilization. Samples were taken simultaneously from the sampling discharge of the pump and directly from the I well with a bailer. The results of this duplicate sampling are attached. A certain amount of variation between these ' L results is to be expected due to the following limitations: I n 1. Temporal - samples were not collected at pre- L cisely the same moment,

P 2. Spatial - due to the close fit of the pump in II the casing, the bailer sagmple had to be taken a few feet above the pump intake. I | While it was not possible to quantify the amount of variability introduced by these two limitations within the scope of this investigation, the attached results show generally good agreement between pumped and bailed samples. Furthermore, neither method achieved consistently higher recovery of VOCs. It was concluded that the selected method for sample collection is acceptable for yielding repro-

000284 GERAGHTY & MILLER, INC. -9-

ducible, consistent results based on the duplicate samples for VOCs.

EPA cfc NO. l(c) ".. .justification... f or the use of...PVC well casing for the subsurface gas study...".

Response;

In order to demonstrate the suitability of FVC for use in construction of gas monitoring wells, the following experiment has been designed. The experiment is intended to simulate sampling conditions in the field.

C A four foot length of FVC, representative of the lot which is to be used in 0 the project, will be capped (PVC caps) P| on both ends. A 1/4" hole will be drilled in each cap and a short length I1I1 of 1/4" polyethylene tubing will be r pressure fit (no adhesives) into each end. The PVC casing will then be purged I • for five minutes, at a flow rate of approximately one L/min with Zero-Grade Air (less than 0.2 ppm total hydrocarbons) . After this time period, the trap (described in the next section) and pump will be attached to the discharge end of the casing. A one-liter Tedlar air bag filled with Zero-Grade Air will be at- OOQ°S5 GERAGHTY^ MILLER, INC. -io-

tached to the inlet of the casing and the air pumped through at about 100 ml/min. After this sampling, the trap will be removed, capped and sent to the laboratory specified in the SOP. The absence of detectable levels of volatile * organic compounds (specifically vinyl £ r chloride) will then be considered as am- i pie evidence of the suitability of PVC t for this application. In the event de- *l tectable levels are found, other materi- r als will be considered for casing mate- 1 rial.

L EPA Comment No. Ifd^ "...the 'laboratory trap' technique for *re collecting gas samples needs to be described in more de- f ] tail."

* Response; I; The trap is the standard trap, containing activated | carbon, silica gel and tenax. This technique is currently in use by several groups, including the Nassau County De- partment of Health, the Suffolk County Department of Health, and a USEPA researcher named Karta Richarda (513 569-7881, Cincinnati). Standards will be run in the same manner as USEPA Methods 601/602, i.e., known concentrations of analytes in methanol will be introduced into the glass wood plug and purged with helium, and then analyzed by GERAGHTY # MILLER. INC. -11-

matography. In a conversation with Mr. Thomas Treutlein (Director, EcoTest Laboratories), he indicated that the minimum detectable quantity of vinyl chloride is 0.0025 ug, and that approximately one liter of sample pumped through the trap is sufficient to obtain a one (1) ug/M3 detection limit for most of the analytes of interest. i In order to verify the reproducibility of this method, FI we propose the following exercise:

One gas monitoring veil will be equipped j with a tee connector splitting to two discharge tubes. A trap and pump will {. be connected to each of the tubes and a « sample drawn through each trap during the same time period. It is recognized I that it is difficult to get precisely I i accurate splits for gaseous samples due 1 to different flows (caused by differ- i ences in pump calibration and trap pack- ing) . However, we believe this is the best way to assess the reproducibility of sample collection. This is also the method we recommend for collecting split samples for USEPA or its contractor.

000237 GERAGHTY & MILLER, INC. -12-

EPA coFFtept1 No. 2 - methods for preparation and analysis of soil samples.

Response;

For soil samples, Method 5030 will be used for sample preparation and Method 8240 will be used for analysis. These methods are given in "Test Methods for Evaluating Solid Waste", SW-846, April, 1984.

EPA coffTnejyfr NO. 3 - "Split-spoon samplers should be made of { | stainless steel." C Response;

L Stainless steel split-spoon samplers are not commercially available; the usual split spoon is made of hardened n tool steel. As agreed during the November 1 conference j call, the split-spoon samplers used during the SOP investigation will be in good condition meaning that the samplers I will not be rusted and will be free of lubricants, greases, r and oils. The spoons will be cleaned prior to use according to the protocol in SOP Appendix F.

Cfr^ent No. 4 - Definition of trip blanks.

Response :

We are in agreement with EPA's definition 'of trip blanks, namely: 000238 ' GERAGHTY # MILLER, INC -13-

• "Trip blanks consist of water which is demonstrated analyte free and sealed in 40 ml vials in the laboratory. The trip blank is taken out into the field during sampling and is shipped back to the laboratory with the samples.**

C^PPynt N°- 5 " Frequency of duplicate samples.

II Response;

Duplicate samples will be taken at a frequency of at least five per cent.

EPA Comment No» 6 — Parameter table.

Response;

See EPA Comment No. 13.

EPA Comment No. 7 - Laboratory certification.

Response t

EcoTest will obtain Performance Evaluation (PE) samples from USEPA, analyze the samples and then submit results for the three parameters. It is understood that the performance analyses must be acceptable to USEPA prior to analysis of actual site samples. 000289 GERAGHTY & MILLER. INC. -14-

EPA CoTwent No. 8 — Wording change.

Response:

; We are in agreement with the EPA wording change: page • 20 "...used to evaluate venting systems for capping and clo- r sure options for the site." EPA Comment No. 9 - Data validation. li Response; C Subcontracted laboratories (EcoTest and York) will sub- L mit QA sheets with analytical results and a narrative ex- pi plaining rejection or acceptance of results.

I As explained during the November 1, 1986 conference call, all aspects of this program will be carefully monitored by Geraghty 6 Miller, Inc. project management. This monitoring includes, but is not limited to, the following:

- Start-up meeting with field personnel and subcontractors

- Frequent field inspections throughout all phases of site work

EPA Comment No. 10 - Cleaning of containers for soil samples to be subject to headspace analysis.

Response; L

I As noted, these samples are subject only to a headspace analysis for VOCs using a field instrument. This analysis 1 is only a screening, and the results are generally regarded I as semi-quantitative. Consequently, the cleaning of sample containers is not critical; containers will be cleaned with [;. a detergent solution and rinsed with distilled water. C EPA Comment No. 11(a) - Cleaning of containers for samples irrj to be submitted for laboratory analysis.

I Response; I i I Containers for samples which will be submitted for laboratory analysis will be cleaned according to EPA guide- | lines, as follows: ;

Organics

Hot weter/low phosphate detergent wash Tap water rinse (3 times) De-ionized water rinse (3 times) Kethylene chloride or hexane rinse (assumes that neither of these C00°91 solvents is an analyte of concern) ***** 1 GERAGHTY ©'MILLER, INC -16- I

i Dry at 125°C : Store in clean area

Inorganics

Rot water/low phosphate detergent wash i Tap water rinse (3 times) i 10% nitric acid rinse n De-ionized water rinse (3 times) Air dry Store in clean area Ii ' EPft C?F^s"'t 11 fb) - Use of polyethylene tubing. I.1 r Response:

rj During the November 1, 1986 conference call, it was determined that this issue was not applicable in light of pre- lii ceding discussions.

I EPA Comment life) - Cleaning of filtration apparatus, pH of i acidified samples. t Response;

Funnels and flasks used in preparation of metals samples will be pre-cleaned in the laboratory prior to each use using the following protocol:

OH0292 GERAGHTY & MILLER, INC. -17-

Low phosphate detergent wash Tap water rinse 10% nitric acid rinse Methanol rinse followed by hexanc rinse De-ionized water rinse Air dry I The pH of acidified samples will be verified to be less {r: than 2 by pouring a few drops of sample across colorimetric ., pH paper.

No. 12 fa) - Bailer construction.

Response; L ., Only bailers constructed of Teflon and/or stainless lii steel will be used for ground-water monitoring well sample f collection.

I EPA Comment No. 12 fbl - Bailer wire.

' Response :

••

A ten foot length of Teflon-coated wire will be attached to the bailer. The remainder of the cord will be braided polyethylene (or .equivalent) . the polypropylene cord will be discarded after each use. Teflon wire will be decontaminated according to the procedure given under re- 000293 GERAGHTY # MILLER, INC. -18-

sponse to EPA Comment 11 (c), using a Kimwipe soaked in a solvent not part of the analytical suite and deionized water rinse .

12 (cl - Location of cleaning area.

Response ;

Ir All sampling equipment - bailers, cords, funnels and I flasks will be cleaned in the laboratory according to speci- •'' fied protocols. II

L EPA Comment 12 fd^ - Container cleaning

P *-' Response t II Sample containers will be cleaned according to the ap- f | propriate method given in the response to EPA Comment 11 (a).

EPA Co^en^ 12 fe) - Collection of VOC samples.

Response ;

When collection ground-water monitoring well samples, whether by pump or bailer, samples for VOCs will be collected first. 000294 GERAGHTY & MILLER, INC. -19-

EPA Com-merit 12(f) - Cleaning for filtration apparatus, verification of pH of acidified samples.

Response t

Filtration apparatus will be pre-cleaned in the labora- | tory according to the protocol given in the response to EPA Comment 11 (c). The pH of acidified samples will be verified [F following the method given in the response to EPA Comment

^ EPA Comment No. 13 (al - Parameter table.

L Response :

fl A complete parameter table is attached. Methods cited ! are given in 40CFR Part 136, October 26, 1984 and/or "Test | .1 Methods for Evaluating Solid Waste", SW-846, July, 1982. I; 13 fb) * Sediment analysis methods.

Response!

Methods for preparation of soil/sediment samples are given in the parameter table.

000295 GERAGHTY # MILLER, INC. -20-

EPA congnept: 13 fcV - Analytical method for phenols.

Response;

EFA Method 420.1 will be used to analyze for phenols.

EPA Copm?]Tt No. 14 fa) - Split spoon construction and cleaning.

Response:

See response to EPA Comment No. 3.

EPA Comment 14 (b) - Sample container size, type, and clean' ing requirements.

I! Response; fl Sample container size and type are as follows:

Analysis Container Material Approximate Volume [ij VOCs Glass, Teflon-lined cap 40 ml ( septum) Acid, Glass, Teflon-lined cap 1 liter F Base/Neutral t Extractables, PCBs Metals Polypropylene 500 ml (bottle & cap/liner) Cyanide Polyethylene, Polypropylene 500 ml (bottle & cap/liner) Phenols Glass (Teflon-lined cap) 1 liter Ammonia Glass 1 liter Remaining Polyethylene, Polypropylene 1 liter parameters (bottle & cap/liner) 000296 GERAGHTY & MILLER, INC. -21-

Containers will be cleaned according to the appropriate protocol given in response to EPA Comment 11(a).

EPA Comment 14(c) - Spatula construction and cleaning.

Response; !» The spatula will be made of stainless steel and will be [ dedicated and pre-cleaned in the laboratory. Cleaning will be according to the protocol given in the response to EPA * Comment 11(c). iL" EPA Comment No. 15 - Decontamination procedure.

L Response; n1 Cleaning of sampling equipment is specified under re- I sponse to EPA Comment 11(c).

| EPA Comment No. 16 - Solvent quality.

I Response;

f Solvents used for cleaning equipment will be residual pesticide analysis grade, or better. The same solvent will be used for all cleaning operations which require a solvent wash in case persistence of the solvent on the cleaned ob- ject introduces an observable bias in the data. Cf 0* GERAGHTY# MILLER, INC -22-

EPA CoTurcnfnt |*o. 17 - Transportation of sampling equipment.

Response ;

Sampling equipment will be wrapped in heavy gauge alu- ' minum foil for transport. i r EPA Comment No. 18 •• Cleaning procedures. . Response ; l-i [T • Drilling equipment will be cleaned between holes by steam cleaning. Well casings and screens are constructed L using Schedule 40 PVC. Steam cleaning will deform and ~ weaken the structure of the casing and screen. .Steam clean- ' ing will be substituted with a detergent wash and rinse with r deionized water.

|i EPA Comment No. 19 - Bottle labels. i; Response; Bottle labels will carry the following information:

site name sample number/identification date and time of collection place of collection type of sample (composite, grab, etc.) sample volume - required analysis 00029fi preservative GERAGHTY^ MILLER. INC -23-

The following responses are made to additional comments prepared by the USEPA and received in our offices on Novem- ber 4, 1986. All responses are made in a similar format to those responses addressing the comments received from the USEPA on October 17, 1986.

' EPA Comment No. it "P7, bentonite pellets should be used to form a seal....".

'" Response: li .., Bentonite pellets will be installed immediately above >' the well sand pack and below the grout. A weighted tape P will be placed down the borehole to "sound" the pellets to ensure that at least two feet of pellets have been emplaced [I before swelling. rIJ EPA Comment No. 2 - "P7, 100% bentonite should be used to grout the well." r Response; , We agree with this type of well seal. No cement will be added to the bentonite. A cement cap will be placed above the bentonite seal after it has been selected.

000299 GERAGHTY # MILLER, INC. -24-

EPA Comment No. 3 - "P44, Health and Safety Plan...".

Response;

We have revised our procedure for doffing equipment to be consistent with USEPA procedures. The procedure for doffing is as follows: hard hat, safety glasses, coveralls, « gloves, then respirator.

n )SPA Comment No. 4 - "VOA samples should be collected prior to metal samples'*. (L Response: L r We agree with this comment and will collect VOA samples . prior to metal samples. i EPA Comment No. 5 - "Appendix I, the mud used for drilling [ should be 100% bentonite". IJ I; Response: We will specify in the drilling specifications that the drilling mud must be 100% bentonite.

000300 GERAGHTY & MILLER, INC. -25-

EPA Cofymgr^ No. 6 - "Provisions should be made to obtain duplicate samples from subsurface gas monitoring veils".

Response :

We will prepare the gas monitoring well sampling apparatus in accordance with the design recommended by the EPA | contractor (Versar, Inc.)* We request that the EPA provide us with a written description and a diagram of the Versar Ir . design in order to avoid any discrepancies in the gas moni- I toring well design and sample collection (see our response to EPA Comment No. l(d), p. 10 of this document. 0 Sincerely, L GERAGHTY & MILLER, INC.

Christopher G. Creed Senior Hydrogeologist/Project Manager

[ealth & Safety

Michael y. McEacnem OfficerAssbciate CGC/AJB/MJM:vk

000301 Parameter Table

No. of Analytical Sample Holding Parameter Matrix Samples Method Preservation Time

Volatile Water 24 (each round, EPA 624 Cool to 4°C 14 days Organics see SOP text) EPA 601/602 (see SOP text) Base/Neutral Hater 16 (each round, EPA 625 Cool to 4°C 7 days until Extractables see SOP text) extraction; 40 days after extraction Acid Water 16 (each round, EPA 625 Cool to 4°C 7 days until Extractables see SOP text) extraction; 40 days after extraction PCBs Water 16 (each round, EPA 608 Cool to 4°C 7 days until see SOP text) extraction 40 days after extraction

O o O CO O i•• —i•*

Parameter Table (Cont'd) No. of Analytical Sample Holding Parameter Matrix Samples Method Preservation _ Time Metals Antimony Wat 16 (each round, EPA 204.2 Cool to 4°C 6 months see SOP text) HN03 to pH 2 Arsenic n n EPA 206.3 « n Beryllium n w EPA 210.2 n n Cadmium « n EPA 213.2 n it Chromium H n EPA 218.2 n n Copper N • M EPA 220.1 it Lead N fl EPA 239.2 N Mercury If n EPA 245.1 n 28 days Nickel N n EPA 249.1 n 6 months Selenium N N EPA 270.3 N n Silver n n EPA 272.2 n n Thallium H it EPA 279.2 it n Zinc N it EPA 289.1 it Additional Parameters Total Cyanide Water tt SM 412D,BPA 335.2 Cool to 4°, 14 days pH>12 with NaOH Total Phenols " N EPA 420.1 Cool to 4°C 28 days pH<2 With H2S04 TDS « If SM 209D Cool to 4°C 7 days (Total Dissolved Solids} Spec. Cond. " n SM 205 Cool to 4°C 28 days (Specific Conductance) pH • H SM 423 None Analyze immediately ^Chloride " n SM 407A None 28 days CD O

CO Parameter Table (Cont'd) No. of Analytical Sample Holding Parameter Matrix Samples Method Preservation Time _ Nitrate M " SM 4 18 F, EPA 353.2 Cool to 4°C 48 hours Ammonia H " SM 417B,EPA 350.2 Cool to 4°C, 28 days pH<2 with H2SO4 Hardness N " SM 3 14 B, EPA 130.2 Cool to 4°C 6 months Bicarbonate N " SM 403, EPA 310.1 Cool to 4°C 14 days Carbonate N " SM 403, EPA 310.1 Cool to 4°C 14 days Sulfate " SM 426C,EPA 375.4 Cool to 4°C 28 days Sodium " SM 303A,EPA 273.1 Cool to 4°C, 6 months pH<2 with HNO, Potassium " SM 3 03 A, EPA 258.1 n 6 months Iron " SM 303B,EPA 236.1 M 6 months Barium " SM 3OA. FPA 508.2 n 6 months

Volatile organics Soil 13 EPA 5030 Cool to 4°C 14 days (sample prep) EPA 8240 (analysis) Base/Neutral Extractables EPA 625 Cool to 4°C 7 days until extraction; 40 days after extraction

Acid Extract, n " EPA 625 n PCBs N " EPA 608 n Metals N " EPA 1310 for n 14 days until extraction extraction, O same list of metals 40 days after O and methods as extraction O aqueous samples olatile Organics Air EPA 601 and 602 14 days ^GERAGHTY '& MILLER, INC. Ground-Water Consultants

December 18, 1986

Ms. Nicolleta DeForte Environmental Engineer United States Environmental Protection Agency Region II 26 Federal Plaza New York, New York 10278 Re: Syosset Landfill - Site Operations Plan Project No. N0340SL2 Dear Ms. DeForte: This letter has been prepared in response to the Decem- ber 5, 1986 letter from John Czapor of your office regarding the above-referenced project. The letter contained specific comments on the analytical procedures to be used. We have been in contact with Barbara Finazzo of the Monitoring & Management Branch in order to expedite the process. Our responses are presented in the same order as the comments in Mr. Czapor's letter. 1. The decontamination procedure for sampling equipment is hereby amended to include a distilled water rinse after the 10% nitric acid rinse. 2. An amended parameter table is attached, reflect- ing the following changes. a. The method for total dissolved solids is SM 209B. b. Method 353.2 will be employed for nitrate, recognizing however that this method (cadmium reduction) actually is for nitrate and nitrite. In practice, nitrite is generally neglible in comparison to nitrate. Discussions with our laboratory indicate that Method 352.1 is somewhat ar- chaic. The parameter table (and future analytical results) has been changed to indicate "nitrate-nitrite". c. Preservation of samples for analysis of hardness is adjustment of pH to less than 2 with nitric or sulfuric acid.

125 East Bethpage Road • Plainview, New York 11803 • (516) 249-7600 A A n o rt c Cable: WATER • Telecopy: (516) 249-7610 U U U v> U D GERAGHTY & MILLER. INC. -2-

d. The methods for sample preparation and extraction for acid and base/neutral extractables is EPA 3550 (sonication) for solid samples; the analytical method is EPA 8270 (capillary column). e. The methods for sample preparation and extraction for PCBs is EPA 3540 (soxhlet) for solid samples; the analytical method is EPA 8080. f. As stated on page 16 of the SOP, we had planned to use the EP procedure for extraction of metals from solid samples. This method was selected because the importance is on the concentration of metals which might be leached from the sample and become potential ground-water contaminants. The alternate is total digestion of the sample with concentrated acid; this method was not selected because the entire sample matrix is destroyed, which puts all metals into solution, even metals which are part of the crystalline matrix of soil particles and unavailable to leaching mechanisms. It has been our experience that the total digestion method leads to analytical results which cannot be meaningfully analyzed relative to potential impacts to ground water. The concern was raised that EP Method 1310 includes eight metals (regulated by the Safe Drink- ing Water Act - SDWDA, but we intended to analyze for the thirteen priority pollutant metals; Method 1310 is not certified for the extra five metals. Although the EP method is not specifically certified for these extra metals, it can clearly be used for them, as will be explained. Attached is a copy of the June 13, 1986 Federal Register (copied from the Environment Reporter which describes the new Toxicity Characteristic Leaching Procedure (TCLP) which will soon replace the EP procedure under requirements of the Resource Conservation and Recovery Act (RCRA). The development of the EP procedure is described in depth in this document. Briefly, the EP procedure was designed to simulate a strong leaching medium to ascertain whether a waste might leach hazardous constituents under a worst-case waste mismanagement scenario. The eight SDWA metals were chosen because they were the only metals for which the toxicological database was adequate; other criteria were proposed (which would have expanded the list of compounds) , but were with- drawn after a comment period. Thus the inclusion of only eight metals was not based on the ability of the EP procedure to mobilize only these metals, but on the toxicological database in estab- 000306 GERAGHTY & MILLER, INC. -3-

lishing potentially harmful leached concentrations. In fact, the EP procedure was designed and is conducive towards mobilizing a range of metals. Thallium and nickel may soon be included under the TCLP procedure. Underlined sections on pages 308, 310, 311 and 312 document our summary. Consequently, we believe this preceding discussion adequately supports the applicability of the EP procedure to this particular situation. g. Pursuant to conversations with the Monitoring & Management Branch, Methods 601/602 are suitable for analysis of air samples because of our collection procedure described in the SOP (collection directly on the laboratory trap); the parameter table lists this as a modified 601/602. We believe that we have addressed all of USEPA's comments. As the expeditious initiation of this project is of mutual concern to both USEPA and the Town of Oyster Bay, we respectfully request that this letter be given priority. Your cooperation in this matter is appreciated and we look forward to a good working relationship with USEPA and its contractors throughout the project. Sincerely, GERAGHTY & MILLER, INC.

- ^_x """"Andrew jy--lJai Senior Scientist

AJB/MJM:vk cc: Ms. Barbara Finazzo - Monitoring & Management Branch Mr. John Lekstutis - Lockwood, Kessler & Bartlett

000307 00 o Parameter Table o

No. of Analytical Sample Holding Parameter Matrix Samples Method Preservation Time

Volatile Water 24 (each round, EPA 624 Cool to 4°C 14 days Organics see SOP text) EPA 601/602 (see SOP text) Base/Neutral Water 16 (each round, EPA 625 Cool to 4°C 7 days until Extractables see SOP text) extraction; 40 days after extraction Acid Water 16 (each round, EPA 625 Cool to 4°C 7 days until Extractables see SOP text) extraction; 40 days after extraction PCBs Water 16 (each round, EPA 608 Cool to 4°C 7 days until see SOP text) extraction 40 days after extraction Parameter Table (Cont'd) Ofot CO No. of Analytical Sample Holding o Parameter Matrix Samples Method Preservation Time o Metals o Antimony Wat 16 (each round, EPA 204.2 Cool to 4°C 6 months see SOP text) HNO3 to pH 2 Arsenic M n EPA 206.3 •* H H Beryllium II n EPA 210.2 II H Cadmium II N EPA 213.2 II H Chromium II n EPA 218.2 H H Copper II w EPA 220.1 H Lead II n EPA 239.2 H Mercury II H EPA 245.1 II 28 days Nickel II H EPA 249.1 II 6 months Selenium n II EPA 270.3 II H Silver H H EPA 272.2 II II Thallium n H EPA 279.2 II H Zinc N N EPA 289.1 II N Additional Parameters Total Cyanide Water N SM 412D,EPA 335.2 Cool to 4°, 14 days pH 12 with NaOH Total Phenols " II EPA 420.1 Cool to 4°C 28 days pH 2 With H2SO4 TDS " H SM 209B Cool to 4°C 7 days (Total Dissolved Solids) Spec. Cond. " II SM 205 Cool to 4°C 28 days (Specific Conductance) pH " II SM 423 None Analyze immediately Chloride " II SM 407A None 28 days en Parameter Table (Cont'd) o o No. of Analytical Sample Holding o Parameter Matrix Samples Method Preservation Time Nitrate-Nitrite " n SM 418F ,EPA 352.1 Cool to 4°C 48 hours Ammonia " H SM 417B ,EPA 350.2 Cool to 4°C, 28 days pH 2 with H2S04 Hardness " II SM 314B ,EPA 130.2 Cool to 4°C, pH <2 6 months with H2SOA or HN03 Bicarbonate n II SM 4 03, EPA310. 1 Cool to 46C 14 days Carbonate n II SM 403, EPA 310. 1 Cool to 4°C 14 days Sulfate n II SM 426C,EPA 375.4 Cool to 4°C 28 days Sodium n II SM 303A,EPA 273 .1 Cool to 4°C/ 6 months pH 2 With HNO3 Potassium n n SM 303A,EPA 258.1 H 6 months Iron n n SM 303B,EPA 236.1 II 6 months Barium n N SM 304, EPA 208.2 N 6 months

Volatile Organics Soil 13 EPA 5030 Cool to 4°C 14 days (sample prep) EPA 8240 (analysis) Base/Neutral EPA 3550 (extraction) Extractables EPA 8270 (analysis) Cool to 4°C 7 days until extraction; 40 days after extraction Parameter Table o

No. of Analytical Sample Holding Parameter Matrix Samples Method Preservation Time

Acid Extract. " EPA 3550 (extraction) H II II EPA 8270 (analysis) II H H PCBs " EPA 3540 (extraction) H EPA 8080 (analysis) II Metals " EPA 1310 (extraction) 14 days until extraction, 40 days after Antimony EPA 7041 extraction Arsenic EPA 7061 Beryllium EPA 7091 Cadmium EPA 7131 Chromium EPA 7190 Copper EPA 7210 Lead EPA 7421 Mercury EPA 7470 Nickel EPA 7520 Selenium EPA 7741 Silver EPA 7760 Thallium EPA 7841 Zinc EPA 7950 Volatile Organics Air EPA 601 and 602 (modified) 14 days 307

Appendix B shall be submitted to the (5) Identification of the times when (3) The lower confidence limit for the Administrator by the owner or operator emissions data have been excluded from saean outlet emission rate and the upper of the affected facility. ' ' ... the calculation of average emission confidence limit for the mean inlet rates; justification for excluding data; •mission rate, as calculated in Method (i) The owner or operator of any and description of corrective action 19. Section 6. affected facility subject to the SOt .'- taken if data have been excluded for (4) The applicable potential SO» standards under ( 60.42b shall submit periods other than those during which •mission rate(s). written reports to the Administrator Tor • nonsulfur-bearing fuels were, combusted (5) The ratio of the lower confidence ever}' calendar quarter. All quarterly ID the steam generating unit limit for the mean outlet emission rate reports shall bjp postmarked by the 30th (6) identification of "F" factor used for and the allowable emission rate, as day following the end of each calendar calculations, method of determination, determined in Method IB, Section 7. quarter. and type of fuel combusted (1) If fuel pretreatment credit toward (i) For each affected facility subject to (7) Identification of times when hourly the SOt emission standard under the reporting requirement in paragraph averages have been obtained based on 160.42b is claimed, the owner or (i) of this section, the following manual sampling method*. operator of the affected facility shall information shall be reported to the ' submit a signed statement with the (8) Identification of the times when quarterly report Administrator. the pollutant concentration exceeded (1) Indicating what percentage fuel (1) Calendar dates covered in the fall span of the GEMS. reporting period. pretreatment credit was taken for the (2) Each 30-day average SOt emission (9) Description of any modifications to calendar quarter; rate measured during the reporting tin GEMS which could affect the Ability (2) Listing the quantity, heat contest. period, ending with the last 30-day of the CEMSte comply with and date each untreated fuel shipment period in the quarter; reasons for Performance Specifications 2 or S. was received during the previous noncompliance with the emission (10) Results of daily GEMS drift tests calendar quarter, 'the name and location standards; and a description of and quarterly accuracy assessments •• of the fuel pretreatment facility; and the corrective actions taken. required under Appendix F, Procedure 1. total quantity and total heat content of (3) Each 30-day average percent (k) For each affected facility subject to all fuels received at the affected facility reduction in SO- emissions calculated the SOi standards tinder 180.42b for during the previous calendar quarter; during the reporting period, ending with which the «»<«

EPA PROPOSAL TO ALTER, EXPAND EXTRACTION PROCEDURE TEST USED UNDER RCRA TO FIND LEACHINQ POTENTIAL OF WASTE CONSTITUENTS (51 FR 21648; Jurw 13,1986)

ENVIRONMENTAL PROTECTION additional chemicals and by introducing in Washington DC Requests to present AGENCY . - • _ . a new extraction procedure to be used oral testimony must be received 10 days in the Toxicity Characteristic. EPA is before each public hearing. 40 CFR Parts 261,271, and 302 also proposing to incorporate the ADDRESSES: One original and three (FRL2940-4] changes made pursuant to this rale into copies of all comments on this proposed the lists of hazardous substances under rule, identified by the docket number F- Hazardous Wa»te Management the Comprehensive Environmental B6-TC-FFFFF. should be sent to the System; Identification and Listing of Response, Compensation, and Liability following address: EPA RCRA Docket Hazardous Wast*; Notification Act (CERCLA) of 1980. Today's action, is (S-212), U.S. Environmental Protection Requirement*; Reportabt* Quantity necessary both to define further the Agency (WH-562), 401M Street SW.. Adjustment*; Proposed Rula scope of the hazardous waste Washington DC 20460. The EPA RCRA regulations and to meet a specific docket is located in the sub-basement AOENCY: Environmental Protection mandate of the Hazardous and Solid area at the above address, and is open Agency (EPA). Waste Amendments of 1984 (HSWA). from 9:30 a.m. to 3:30 pjn., Monday ACTION; Proposed rule. ______This amendment will bring additional through Friday, excluding Federal wastes under regulatory control, holidays. To review docket materials, SUMMARY: The EPA is proposing to providing for further protection of public the public must make an appointment by amend its hazardous waste health and the environment. calling Mia Zmud at 475-9327 or Kate identification regulations under Subtitle DATES: Comments on this proposed rule Blow at 382-4675. A maximum of 50 C of the Resource Conservation and must be submitted on or before August pages of material may be copied from Recovery Act (RCRA) by expanding the 12.1986. A public hearing has been any one regulatory docket at no cost. Toxicity Characteristic to include scheduled for July 14,1986 at 9-tt ajn.. Additional copies cost $.20/page. e-27-w Envtn nt Report* 000312 306 ENVIRONMENT REPORTER

Documents identified in Section IX of L Background evaluation of specific wastes from the Supplementary Information action specific industries, decide to list such of this preamble are available in the Under section 3001 of the Resource wastes as hazardous based on the docket The public hearing will.be held Conservation and Recovery Act criteria defined in 40 CFR 261.11(a)(3). on July 14,1966 at the following location: (RCRA), EPA was charged with This reflects the Agency's philosophy, Vista International Hotel. 1400 M Street* identifying those wastes which pose a first articulated in May of 1980, that the NW.. Washington, DC 20460. The hazard to human health and the characteristics define broad classes of hearing will begin at 930 a.BL. with einrffonment if improperly managed. It wastes that are dearly hazardous, while registration at 9£0 ajn« and wiUrun farther called on EPA to identify such the listing process defines some wastes until 4:00 p.m. unless concluded earlier. wastes through development of lists of that may pass the characteristic, but are Anyone wishing to make a statement at hazardous waste and through • nonetheless hazardous wastes (45 FR the hearing should notify, in writing, Ms. characteristics of hazardous wastes. 33111). Geraldine Wyer. Public Participation These two means of identifying Officer, Office of Solid Waste (WH- hazardous wastes employ In carrying out the RCRA mandate. 562), U.S. Environmental Protection fundamentally different approaches. EPA identified a number of Agency, 401M Street, SW.. Washington. characteristics which, if exhibited by a DC20460. Persons wishing to make oral To list a waste as hazardous, EPA waste, would indicate that the waste is presentations must restrict them to 15 conducts a detailed industry study.. .'.' a hazardous waste and should be minutes and are encouraged to have filacmd particular emphasis on the : managed as such. One of these written copies of their complete fcazardous constituents contained in' characteristics, the Extraction Procedure comments for inclusion in the official ipacific wastes from the industry being (EP) Toxidty Characteristic (EPTC) (40 record, studied (See 40 CFR 261.11(a)(3)). This CFR 281.24)* was intended to identify POH njKTHtft INFORMATION CONTACT; process involves literature reviews, wastes which pose a hazard due to their For general information contact the engineering analyses, surveys and ' potential to leach significant RCRA Hotline, Office of Solid Waste questionnaires, and site visits, including concentrations of specific toxic species. (WH-562), U.S. Environmental sampling and analysis of wastes. As Protection Agency. 401M Street. SWM each, the listing process may require The EPTC is the only characteristic Washington, DC 20480. (800) 424-9346 from 1 to 3 years or more, depending on which directly relates to the toxicity of a toll-free or (202) 382-3000. the complexity of the industry being waste. This characteristic entails use of For information on specific aspects of Investigated. a leaching test the EP. which is used in this proposed rule contact Todd A. determining if an unacceptably high KimmelL Office of Solid Waste (WH- The process of identifying wastes as level of ground water contamination > S62B). U.S. Environmental Protection "hazardous" by reason of a might result from improper waste Agency. 401M Street, SW, Washington. characteristic is fundamentally different. management The EP results in a liquid DC 20480, (202) 382-4770. Characteristics are those properties extract which is analyzed for eight MmCMINTAIIY INFORMATIONS which, if exhibited by a waste, identify metals (arsenic, barium, cadmium, L Background tiie waste as a hazardous waste. It is a chromium, lead, mercury, selenium and 0. Oevtlopnent of Toxidty Characteristic generic process whereby EPA identifies silver), four insecticides (endrin. A. Introduction properties that might be possessed by a lindane, methoxychlor and toxaphene). & Chronic Toxidty Reference Levels waste which would cause the waste, // and two herbicides (2,4-D and 2,4,5-TP). C Dilution/Attenuation Factor improperly managed, to cause harm to Regulatory thresholds were established D. Proposed ToxicanU and Regulatory human health or the environment The • for these 14 species taking into account Levels E. Analytical ConstninU Agency then determines a reasonable the attenuation and dilution expected to DL Development of the Leeching Procedure mechanism by which such harm might . occur during migration of the leachate to A, Introduction occur, develops a quantitative model to the ground water, through use of a & Objectives identify hazard levels, and whenever generic dilution/attenuation factor of C. Disposal Environment and Mode) possible, test methods for use in lOp (Ref. 26). D. Leeching Procedure determining if a specific waste E. Leeching Procedure Issues possesses hazardous levels of the At the time of promulgation. EPA IV. Other Aspects of Proposal property. Once EPA promulgates a A. Testing Frequency end Recordkeepina racojgrazed two maior shortcomings of E Relationship to Multiple EP and Oily characteristic it becomes self ffiFEPtC The first was that theonly Waste EP implementing. Any solid waste which Benchmarks for establishing toxicity C Analytical Methods exhibits the characteristic is a levels of »pecific chemicals, which were D. Notification Requirements hazardous waste, and when treated so both scientifically recognized and which V. Relationship to Other Regulatory that it no longer exhibits the addressed chronic exposure, were the Authorities characteristic, is no longer subject to rational Interim Primarv~PrTriting VL State Authority RCRA regulation as a hazardous waste. A. Applicability of Rutes in Authorized Water Standards (DWS). The Agency States Solid wastes which do not exhibit a considered incorporating otfier B. Effect on State Authorizations characteristic, however, are not standards, such as the Water Quality V1L Economic and Regulatory Impacts necessarily non-hazardous. Criteria that were being developed A. Regulatory Impact Analysis Characteristics are established at levels under the Clean Water Act. Preliminary B. Regulatory Flexibility Act at which there is a high degree of drafts o these criteria, however. C Paperwork Reduction Act certainty that a waste which exhibits receivec1 substantial negative comment VUL Additional Information A. Chronic Toxicity Reference Levels these properties needs to be managed iff' from the scientific community. The B. Ground Water Transport Equatioa a controlled manner (i.e.. is a hazardous Agency thus put off expansion of the C Tables or Proposed Contaminants and waste). The Agency realizes that not all EPTC pending development of Data Used to Develop Regulatory Levels wastes which exhibit properties at acceptable standards. The second D. Development and Evaluation of the levels below the characteristic are safe shortcoming was that the F.P was TCLP for disposal as nonhazardous waste. optimized to evaluate the leaching of DC. References The Agency may therefore, upon elemental rather than organic «-27-ee Published by THE BUREAU OF NATIONAL AFFAIRS, INC.. Washington. O.C. 20037 000313 CURRENT DEVELOPMENTS 309 constituent!. Hence, the leaching of It is important to point put that white approach, described below, uses chronic organic! needed to be investigated. . this proposed rule fulfills the toxicity reference levels, combined with bi addition to addressing the leaching • Congressional mandate to add a compound-specific dilution/ of organic*, EPA believes that other additional characteristics of hazardous attenuation factor (derived from aspects o! the EPTC can be improved. '••. 'waste, considerably more work is now application of a ground water transport For example, ground water modeling •, underway within EPA to look at equation), to calculate the regulatory and knowledge of leaching and fate and . additional constituents that could and level concentrations for individual transport mechanisms have advanced to should be added to the proposed rule, toxicants. the point that mathematical models can and to explore other characteristics that B. Chronic Toxicity Reference levels be used to identify species-specific will deal with toxidty. dilution/attenuation factors, rather, than On January 14,1988 (51 FR 1602). the Implementation of the Toxicity reiving on the generic100 times level Agency proposed the framework for • Characteristic level setting approach now employed in the EPTC Also, the EP regulatory program to implement the described below, requires the initial protocol is known to suffer • number of eongressionally mandated land disposal input of a toxidty limit to establish a operational shortcomings that while not prohibitions. The action proposed regulatory level for each contaminant. critical, warrant attention. These procedures to establish treatment Limits set for protection against chronic shortcomings and their solutions an standards for hazardous waste and toxicity effects are the reference detailed in further sections of this standard of choice since this level will procedures by which EPA will usually be protective for both chronic preamble. determine whether to allow continued and acute effects. The first step in • Congress also recognized the land disposal of specific hazardous developing regulatory levels is therefore shortcomings of the EKIX*, and amended wastes. the development of a measure of RCRA in 1884 (section 3001 (g) and 00), In Implementing these procedures, the "acceptable" chronic exposure for directing EPA to make changes In the EP Agency has proposed to employ the Individual toxicants in drinking water.. to insure that it accurately predicts TCLP to estimate the leaching hazard EPA. under other statutory mandates, leaching potential and to identify . posed by waste placed in Subtitle C bat investigated the adverse health additional characteristics of hazardous facilities. The same subsurface transport effects due to specific chemicals with a waste, including measures or indicators model is used in both the land disposal view toward controlling exposure . of toxidty. EPA intends to address both regulation and this proposed regulation. through different media. Human health of these mandates through expansion of However, minor modifications to criteria and standards have been the EPTC to include additional account for disposal In •non-hazardous proposed or promulgated for certain chemicals, and through the introduction versus a hazardous waste landfill have substances in particular media. Since of an improved leaching test to replace been made in the transport equation for these have received Agency and public the current EP protocol. . .. . , • . use in this proposed rule, m addition, review and evaluation, EPA is proposing EPA is also planning to add another different risk levels art used to establish to use such standards as the starting beet to the hazardous waste the regulatory level for carcinogens, and point for the back calculation model, characteristics. Specifically, EPA la • different confidence Interval for the where such standards are available. working on a mechanism by which to ground water transport simulation it EPA used the DWS for the a elements identify wastes as hazardous by virtue used to establish the dilution/ and 8 pesticides as the basis of the of their ability to mobilize other attenuation factors. However, to tne Extraction Procedure Toxidty toxicants. This component would extent that commenters have provided Characteristic. primarily affect solvent-containing us with their views on the model either Drinking water standards are based wastes, and will complement • in the context of the land disposal upon toxidty, treatment technologies, regulation EPA promulgated on restrictions program or its delisting costs, and other feasibility factors such December 31.1965 that redefined the programs, those comments need only be as availablity of analytical methods. In universe of solvents considered listed referenced in response to this proposed developing DWS1*, the ihtital step Is the hazardous wastes to include certain • rule. More information on the identification of non-enforceable health solvent mixtures (50 FR 53315). EPA differences between the models is limits. The assessment process for indicated that this was an interim provided in Section V of this preamble. establishing these health goals includes measure which would be modified or evaluation of the quality and weight-of- superseded when further work was U. Development to Toxktty evidence of supporting lexicological completed. More detail regarding the studies, absorption rates of specific . approach the Agency is considering is" A. Introduction toxicants, the possibility that a provided in section n(E). compound or element is nutritionally EPA is today proposing to amend the In establishing a scientifically essential at certain levels, route of Extraction Procedure Toxidty Justifiable approach for arriving at. exposure, and exposure medium, Characteristic by (1) expanding the threshold concentrations, EPA wanted apportionment. characteristic to include 38 additional to assure • high degree of confidence For noihcardnogens. these health compounds. (2) applying compound- that a waste which releases toxicant* at limits are denoted as Reference Doses specific dilution/ajtenuation factors concentrations above the regulatory (RfD's): The RfD is an estimate of the generated from a ground water transport threshold level would pose a hazard to daily dose of a substance which will model and (3) introducing a second human health. __ result in no adverse effect even after a generation leaching procedure, the The existing EPTC uses the National lifetime of such exposure. It is thus a' Toxidty Characteristic Leaching Interini Primary Drinking Water chronic toxidty limit The establishment Procedure {TCLP}. that has been Standards (DWS) as toxicity thresholds of a chronic toxidty reference level for developed to address the mobility of for individual pollutants, and combine* carcinogens requires setting a specific both organic and inorganic compounds, these with a generic dilution/ risk level which is then used to calculate and to solve the operational problems of attenuation factor (100 times] to yield the Risk Specific Dose (RSD). The RSD the EP protocol. the regulatory threshold. The new is the daily dose of a carcinogen over a

6-Z7-M •wntfUporwr 000314 310 ENVIRONMENT REPORTER

lifetime which will result in an. incidence figure It Illustration ef Dtlutton/Atttnuatioft of cancer equal to the specific risk leveL An RSD established at the 1(T» risk. level translates to a probability of one in one hundred thousand that an individual might contract some form of cancer in his or her lifetime. In developing toxicity levels for r\ carcinogen* EPA is further proposing a weight-of-evidence approach which involves categorizing carcinogens according to the quality and adequacy Diaoosal Drinking of the supporting toxicdogical studies. Unit water This approach was proposed by EPA in Nell its Carcinogen Risk Assessment • guidelines published in the Federal Register on November 23,1984 (49 FR Saturated 48294). Zone fa order to account for toxicant Dilution/Attenuation exposure from other sources (i.e., air Occurring During and food), EPA is also proposing to limit Migration of 'the RfD value to some fraction, as is . Contaminant done in developing drinking water To Mell ... standards. The fraction of the toxicity level used in these standards is compound-specific, and is apportioned •*- [11 according to exposure assessment data, if adequate data exist, or by use of an arbitrary value of 20 percent if adequate exposure assessment data do not exist EPA is proposing a similar approach for the Toxicity Characteristic. Note, however, mat EPA is not (A) Refers to the concentration of the contaminant in the proposing this approach for the at the, bottom of the diaoosal aait. carcinogens, as it appears that a small reduction in the RSD would still be well ftetera to the concentration of the contaminant In the within the margin of uncertainty- of the drinking water well, which ia calculated using a ground estimated RSD. Rather, EPA is water transport equation, and is expected to be' lower proposing to use 100 percent of the RSD than the concentration at (A) due to !»tenuatibf» and value. Section VIO(A) of this preamble dilution.- • provides detailed information as to the identification of chronic toxicity reference levels. This equation relies on compound compounds. Unfortunately, this model One area: that the Agency solicits specific hydrolysis and soil absorption could not be fully developed m time for comment on is •whether, as an data, coupled with parameters. today's proposal. Accordingly. whtle~ alternative to using the DVVS's, the describing a generic underground EPA is continuinInuingtg to work on modeling Agency should consider using the RfD or environment (e.g., ground water flow metal- transporportEPt EPA_/ Is retaining tne RSD values asthe starting point for the rate, soil porosity, ground water pH), to Preseent EP Toxicity Characteristic levels back calculation model even when calculate die degree of attenuation and for tthhe elemental toxicants. DWS's are available. dilution a compound would be expected Details of the ground water transport C Dilation/Attenuation Factor to undergo as it migrates to an equation to be used for organic underground drinking water source. After a toxicity level has been compounds are provided in section identified, the degree of attenuation and Values for environmental parameters VIII(B). Note that in the Federal Register dilution that a compound is expected to have been selected based on review of of January 14, 1986. the Agency undergo during transport through the subsurface geological conditions at proposed to use the same basic ground ground wateMo an underground existing landfills across the continental water transport equation for use in the drinking water source is determined. United States. Boundary conditions and Land Disposal Restrictions Rule (51 FR The ground-water transport equation interrelationships between the above 1602). The proposed Land Disposal EPA is intending to use to estimate parameters have been established based Restrictions Rule equation, however. dilution and attenuation, estimates the on a sensitivity and an uncertainty contains minor differences to account reduction in toxicant concentration that, analysis. for.the additional engineering controls would occur as toxicants are Originally. EPA had also hoped to (e.g.. landfill caps), required of Subtitle transported in ground water over a develop dilution/attenuation factor's for Q hazardous waste facilities, and the specified distance from the disposal unit metal species through use of a second ' ' higher standard of confidence required to the point of exposure (i.e., drinking model, since these species generally . under HSWA for determining that a water well), as depicted in the following behave differently in the ground water • •hazardous waste is suitable tor land figure (Figure 1): environment than do the organic disposal. As noted previously, different

*-a?-aa by THE BUREAU OF NATIONAL AFFAIRS. INC.. Washington. O.C. 20037 000315 CURRENT DEVELOPMENTS 311 risk l«vel» are used to establish the These efforts have resulted in the inherent toxicity, but also because they characteristic regulatory threshold for. ••identification of a total of 52 compound* can mobilize hazardous constituents carcinogens, and a different confidence for the Toxicity Characteristic. This from codisposed non-hazardous waste. interval Is used for the ground water , includes the existing 14 EPTC Since solvents exhibit this property, the transport simulation to establish the •. " compounds, and 36 compounds whose Agency is working to.identify such dilution/attenuation factors. While '• thresholds are driven by their toxicity, wastes through use of a solvent section V1H(B) provides additional • as shown to the following table (Table override. information concerning the equation 1> The Agency intends to set regulatory proposed for use in the Toxicity levels for solvents based on the total Characteristic, considerably more detail TAKE 1: PROPOSED Toxicrrv CHARACTERIS- amount of solvent observed in the TCLP concerning this equation is provided in TIC CONTAMNANT8 AND REGULATORY LEV- extract Thus, wastes whose TCLP the preamble section to the proposed extract contains more than a specified Land Disposal Restrictions Rule (51FR •mount of total solvent would be 1KB, January 14.1986). . identified as a hazardous waste even if Knee many aspects of the ground none of the health criteria based water transport equation an similar thresholds for the individual solvents 001 S.O are exceeded. The Agency is also between the two rules, commenters 7440-3*4 need not repeat relevant comments that 8006. wo exploring the possibility of developing a have already been made in response to OBIS. 047 solvent power test which would be die Land Disposal Restrictions Rule. designed to determine the actual ability us of a waste to mobilize hazardous These earlier comments may be IS-1S-0 144 referenced, although all relevant BE- •JOT 'constitutents for non-hazardous wastes. comments will be considered in 008. CMM sr-74-s MS Hie Agency solicits ideas, data and developing theToxicity Characteristic 14 comments on these and other • * 0007. approaches. final rule. Comment specific to EPA's ws*r The next section presents a discussion use of the equation for this rule, should oat. too regarding some of the analytical . however, be submitted. tM OOW-, •4-n-T 14 constraints EPA faced in establishing SS-SS-1 regulatory levels. Section VH1(C) W74S-S 1.1 TlOfr* 0.1 compound and the data that EPA has S4 1S1-M* •is OBtt. •Wt •on used to calculate the regulatory level A Proposed Toxicant* and Regulatory 0401 EPA anticipates that the list of toxicants Levels ' • 11S-74-1 •vtS to be included in the Toxicity In order to establish a Toxicity Characteristic will be periodically Characteristic regulatory level for . COST. •7.71-1 44 expanded as more Information on the .1 ss Appendix VHI compounds is developed. individual compounds, adequate and S4 verified data most exist for EPA to (1) •4* E. Analytical Constraintt identify a loxicHy level (Le, DWS, RID. 743S47.4 TS-4S-S 14 As illustrated in Table 1 (and further or RSD), and (2) calculate a dilution/ cot. i*«o*>* •4 OMO. 74 in section VUI(C)), the regulatory levels attenuation factor through application of e.i» for the proposed compounds span about the ground water transport equation. Aa 94 8 orders of magnitude (i.e., from the low discussed previously, EPA will retain ' DBtt- 144 SJB parts per billion to 100 parts per million). the 100 times factor used in the current 14 This is not so much a function of the BP Toxicity Characteristic for the S4 MA individual dilution/attenuation factors, elemental drinking water toxicants. Due but rather due to the great range in to the Agency's continuing efforts to 1J develop an adequate ground water • toxicjry levels of the individual transport equation for the metals, 0.1 toxicants. Since many of the toxicity addition of elemental and anionic levels for the carcinogens (and some of toxicants to the Toxicity Characteristic the non-carcinogens) (see section is being delayed The Agency experts to VT1I(A]J are very low, depending on the Toxidtv ( magnitude of the dilution/attenuation 14 factor, the calculated level will also be •47 very low. This presents a problem for • M the Agency since some of these calculated thresholds are below the In selecting additional organic analytical level measurable using toxicants to incorporate in today's currently available methodology. This proposal, the Agency identified those affects 7 of the compounds (See section Appendix VIII compounds for which, Vm(C)). there existed a promulgated or proposed There is one group of chemicals For EPA believes that the appropriate drinking water standard, or an RID or which the Agency considers use of the way to deal with this problem is to RSD. The compounds identified as a health criteria/ground water transport establish technology based regulatory result of these efforts were then approach to setting threshold levels,1 The lowest level that can be examined to determine if adequate fate concentrations as being inappropriate in and transport data were available to some cases. These are solvents. 1 Such levels could be *et »t the anniyiicil establish a compound-specific dilution/ Solvents need to be managed in a dvttr.tion limil or. M an altctniiivr. Ihey coutd be attenuation factor. controlled manner not only because of Ml Hi the limit* of •ecurate quanliution |i*~ •

Envta tflaporu 000316 312 ENVIRONMENT REPORTER

reliably achieved within specified limits methods for the Toxicity Characteristic initary landfill. The EP was intended to of precision and accuracy during routine compounds are discussed more fully in (a first order approximation of the laboratory operating conditions is the section (V(D) of this preamble.) The leachina action of the ow molecular quantitation limit The quantitation limit quantitation limits used are based on weiahl carboxvlic acic s generated in an thus represents the lowest level the presence of these compounds in a active y decomposing sanitary landfill. achievable by good laboratories within water matrix. Since TCLP extracts specified limits during routine would also be aqueous in nature, EPA is carboxylic acids present in municipal laboratory operating conditions. The proposing to use the quantitation limit waste leachate. is added to delbnized quantitation limit is determined through as observed in water* EPA recognizes, • distilled water to make up the extracting mterlaboratory studies, such as however, that while these quantitation medium used in the EP. The acetic acid performance evaluation studies. limits would be attainable for most models primarily the leaching of metals If data are unavailable from wastes, other wastes wilt produce an from an Sduatrial waste. The impetus interiaboratory studies, quantitation extract that is qualitatively different behind development of the Toxicity limits are estimated based upon the and may not allow quantitation to the Characteristic Leaching Procedure detection limits and an estimate of a same low level as water. This, however, (TCLP) was the need also to address the higher level which would represent a will be waste specific and difficult to leaching of organic compounds (Ref. 28). practical and routinely achievable level predict beforehand. While specifying a In addition, EPA believes that the EP with relatively high-certainty that the higher quantitation omit is an option. protocol can be improved in certain reported value is reliable. EPA EPA is reluctant fb do so due to the •teas. For example, the EP involves estimated this level to be 5 to 10 times . degree of environmental protection that continual pH adjustment (titration) with the detection limit in their final rule on might be sacrificed. EPA is, however, 05 N acetic acid to a pH of SJ)±0.2. This National Interim Primary Drinking working to determine- actual can involve more man 6 hours of Water Standards for Volatile Synthetic quantitation limits on real wastes, which operator attention and can be difficult Organic Chemicals (50 PR 48880, may result in increases in the tot some waste types, particularly oily November 13,1985). EPA believes that quantitation limit and the wastes. In developing the TCLP, EPA setting the quantitation limit at 5 times corresponding regulatory level for some bit that elimination of the need for the detection limit is a fair expectation of the contaminants. EPA solicits continual pH adjustment would be a tot most regulatory and commercial comments and suggestions on how to desirable improvement: As another laboratories. Public comment is deal with this issue. example, the EP involves separating the specifically requested on the use of 5 Three of the phenolic compounds that initial liquid from the solid phase of the times the detection limit as a general are included in today's proposal ortho-, waste, as well as separation of the rule as to what levels can be expected to meta-. and para-cresoL also pose an liquid (extract) derived from the be measured routinely by commercial analytical problem. Specifically, meta- leaching test These steps, involving laboratories with reliability. and para-cresol cannot be analytically . pressure filtration through a 0.45 urn Use of either detection limits or separated using readily available filter, cad be difficult and time quantitation limits would allow for techniques. In order to overcome this consuming for certain waste types, and regulatory levels that fall below the problem,'and given that these isomers warrant simplification. In addition, other analytically measurable level to be all act in an additive manner, the minor changes in the EP protocol, .such periodically updated as advances are Agency is proposing to establish a single as shortening the duration of the test made in analytical methodology. EPA is level for total o-. m- and p-cresoL and accounting for the loss of waste Public comment and information on materials to the sidewalls of sample proposing the use of the quantitation containers, were felt to be of use in limits because the determination that a all aspects of the issues presented in compound is present (in the extract this section are requested to assist EPA towering the cost of the test and in making a final choice of analytical improving the overall precision of the above a specified value) conclusively method. Thus, the Agency believes that demonstrates the presence of a hazard. methods and the specific performance requirements in the final rule. development of a second generation EPA is seeking comment however, on extraction procedure was of value even both approaches. Supporting data/information is requested for any comments provided. if the EP were found to be acceptable for The tables in section VUI(C) indicate Specifically, public comment is organic*. the quantitation limits for each of the requested on the following questions: 6 Objectives elements and compounds, as well as the • Are the proposed analytical appropriate EPA SVV-848 analytical methods technically and economically EPA's intent men, was to develop an method numbers (Ref. 27). (Analytical available (see section IV(D) of this improved leaching test method suitable preamble)? for use in evaluating wastes containing quantilatlon limit). In general EPA define* UM organic toxicants. It is important to note method detection limit u the minimum • What is the precision/accuracy of that the purpose of the EP. as well as concentration oft substance thai e*n be measuml the analytical methods at the proposed this new method, is as a means of and reported with M percent confidence that the quantitation levels? determining whether a waste, if true value it greater than sera. The specifications of • Are there sufficient qualified such a concentration are limited by the fact thai laboratories capable of measuring at mismanaged, has the potential to pose a detection limit* are a variable affected by the significant hazard to,human health or performance of a given meeiuremenl «y*tem. proposed quantitatioa levels? the environment due to its propensity to Detection limit* are not necessarily reproducible leach toxic compounds. EPA believes over time in a given laboratory, even wb*n the same III. Development of th* Leaching analytical procedures, instrumentation and sample Procedure thai the EP adequately accomplished matrix are used. Differences between delation 4ml A. Introduction this goal for tt* currently regulated quanlitation limit* an expected since lh« detention { toxicants. limit* represent the lowest achievable level utidnr The Extract'on Procedure (EP) was When the EP was developed, the ideal laboratory condition*, whereas the quantitation limit represents the lowest iichnw designed to simulate the leaching thai •.Agency had little empirical data upon level under practical and routine tabuniliiry would result when a solid waste is co- ' which to base its assumptions regarding conditions. disposed with municipal wastes in a accuracy (Ref. 28). Hence, while the few 6-27-M Published by THE BUREAU OF NATIONAL AFFAIRS. INC., Washington, D.C. 20037 r rr3Tr ? CURRENT DEVELOPMENTS 313 data that were available regarding , Briefly, the research involved leaching In an effort to better quantify how accuracy were used in developing the ; these wastes in a pilot-scale field well the TCLP compares to (he field EP. it was primarily based on what was facility with sanitary landfill leachate. model, the distributions of the actual reasonable, as well as what would *.. 'measuring the concentration of the and absolute percent differences provide a reproducible (precise] lest'. compounds which leached from the • between concentrations observed in the protocol. While improved V wastes, and attempting to duplicate field model and those observed in the reproducibility is one objective of the these concentrations in a laboratory acetate buffer system chosen for the TCLP, the major objective was to tost, the TCLP (Ref. 8 and 7). TCLP (see section Vill(DJ). have been accurately model the mobility of A TCLP has ben developed as a result examined. Results of these comparisons constituents from wastes, particularly of this work. EPA believes that this test indicate that roughly half of the 95 organic constituents. Other objectives method is reasonably accurate in terms individual target compounds (from the were that the test be relatively of modeling a field-scale co-disposal H wastes examined in both Phases I inexpensive to conduct that, if possible. scenario for both-organic* and and II), wen within —32 percent and it yield an extract amenable to inorganics. In addition, it appears that 4-78 percent of their respective field •valuation with biological toxidty tests; many of the operational problems lyshneter target concentrations. Roughly and that it also model the mobility of associated with the EP protocol have three-fourths of the 95 individual target inorganic species. This last objective been overcome in the process of compounds were within -80 percent would permit EPA to expand the toxidty developing the TCLP. The test has also and +88 percent of their respective field characteristic to encompass organics. been subjected to ruggedness and lysimeter target concentrations (Ref. 25). yet require only one leaching test for precision evaluations, and a limited . The standard deviation of the total loth organics and inorganics. multi-laboratory collaborative distribution (which is skewed) in this. case is 182 percent These preliminary C Dispota! Environment and Model •valuation, and is currently being evaluated in a more comprehensive ' numbers indicate that the acetate buffer The specific environment modeled by collaborative evaluation. . • system duplicates field lysimeter target both the current EP and the TCLP is co- Section VT1KD) of this preamble concentrations for approximately three- disposal of industrial waste with refuse provides detailed information with fourths of the target compounds within in a sanitary landfill The Agency's respect to the TCLP development and one standard deviation of the concern was that potentially hazardous •valuation program. The regulation distribution. This is particularly waste, if not brought under the control section provides the actual TCLP significant since the laboratory test of the RCRA hazardous waste system, protocol, as Appendix It to Part 281. A duration is 18 hours, whereas the field might be sent to sanitary landfills, with more detailed discussion pertaining to lysimeter experiments were run for a resulting high level of leaching the TCLP is provided in a background approximately 3 months. EPA believes activity. This concern'has not changed. document that EPA has prepared (Ref. that the accuracy of the TCLP is Although the Agency believes that fewer S3). .. . adequate in terms of indicating the industrial solid wastes are being potential for wastes to pose a hazard if disposed in this manner as compared to E. Leaching Procedure luuet '" • mismanaged. a few years ago, the Agency also In an effort to identify and resolve any e. U*e of TCLP for sewage sludge believes that the co-disposal scenario potential problems associated with the disposal EPA expects to propose in still represents a reasonable worst-case TCLP prior to proposal, and also to September 1988 sewage sludge mismanagement scenario. In addition, management standards under Section inform the public of EPA's activities in 405(d) of the Clean Water Act Once the die Agency believes that the predicted this area, EPA held a number of Section 405(d) standards an degree of contaminant migration, as meetings at which various aspects of the promulgated. EPA is considering indicated by the TCLP, could reasonably procedure wen reviewed and draft exempting sewage sludge from RCRA occur in the course of other types of procedures circulated. These included regulation. The section 405(d) standards land management of wastes (see section public discussions ajt meetings of the wfll tailor. EPA's control strategy to the Assodation of Offidal Analytical management of specific risks to human Hence, the experiments used to Chemists and the American Society for health and the environment from each of develop the TCLP were set up to Testing and Materials (ASTM). the sludge use and disposal practices. conform as closely as possible with'the As a result of these meetings and as a The Agency solicits comments on this co-disposal model Specific features of result of the Agency's own efforts in potential approach to regulating sewage this model were that the landfill Is these areas, a number of issues have sludge. composed of 5 percent industrial solid been identified and some minor changes c. Extent of experimentation. Another waste and 95 percent municipal waste, to the TCLP protocol have also been issue related to accuracy is whether and that the character of the leaching made. Following is a discussion of these EPA has examined enough fluid that the waste will be exposed to to issues, and how they have been contaminants and waste types in its • predominantly a function of the addressed in the proposed TCLP. TCLP development program. The TCLP decomposing refuse in the landfill In 1. Overall Issues was developed based on data from 11 expanding the Toxidty Characteristic, wastes and 95 target compounds Which the models and assumptions used in • a. Accuracy of TCLP. As indicated leached from these wastes (Ref. 8 and developing the EP have been retained. previously. EPA was directed by the 7). The amount of work involved hen is D. Leeching Procedure HSWA to make the EP more accurate. substantial EPA is aware, however, of EPA|i experimental program to develop one waste type, specifically wastes of The work undertaken to develop and the TCLP was intended to provide an moderate to high alkalinity, that was not evaluate the new leaching test was accurate extraction method, in terms of adequately represented by the 11 carried out in three phases', and ability to model a field co-disposal wastes, and has included provisions in involved 11 wastes and close to 100 situation. One of the issues assodated the TCLP. to insure that the potential organic end inorganic components with the TCLP is whether the method is environmental damage that may be which leached from these wastes. adequately accurate in this respect. caused by such a waste was not

S-27-86 Envi 000318 314 ENVIRONMENT REPORTER

underestimated. (These changes arc simpler and the operator has much more discovered an uncontrolled waste detailed further in this section). information on the properties of the situation (e.g.. waste disposed in an Additional testing aimed at evaluating wastes before and while the facility is in open pit) it might be difficult to the need to modify the TCLP extraction operation. To insure that industrial determine what characteristic test fluid to alter its sblubilizing potential is wastes are adequately managed, EPA should apply to the waste because there not believed to be necessary. In addition has proposed to employ the more . may be very little available information to the work described in section VII! (DJ, protective sanitary landfill scenario. •bout how the waste was generated. the Agency-had earlier conducted two The Agency believes that sanitary Moreover, even where some information studies that evaluated the effect that landfills may pose more of a potential existed about the source of the waste, changes la extraction fluid composition hazard than industrial hnrffUV Many the Agency believes that the existence would have on solubilization of organic? States have required some additional of varied toxidty tests would encourage (Ref. 19 and 24). These studies examined protection (e.g^ more stringent siting disputes about which test should apply die effect of adding acetic acid, requirements] at industrial landfills. The to a particular waste. carbohydrates, protein, tannic add. Agency, however, solicits comments on' It is therefore reasonable to use a • citrate. mjosulfate, and a surfactant to die choice of the sanitary landfill Subtitle D sanitary landfill as a general the leaching medium. Both studies scenario,' and specifically requests any model of how industrial wastes might be showed little change in toxicant evidence that another disposal scenario disposed. The Agency, however, solicits solubility and extraction efficiency with may represent the worst-case plausible comments on whether this scenario is the addition of these various solubilizing mismanagement. appropriate for all wastes. Commenters agents. This agrees well with the work The scenario selected for the TCLP, as identifying a different scenario for done to develop the TCLP (Ref. 6 and 7), wen as,for the current EP, was co- particular wastes should explain why which also showed that leaching seems disposal with municipal waste in a tfw Subtitle D sanitary landfill model is to be unaffected by minor changes to sanitary landfill EPA selected this co- inappropriate and what disposal primarily aqueous extraction media. disposal scenario since Subtitle D scenario would be appropriate for those Thus, EPA believes that further testing sanitary landfills have traditionally wastes, induding a discussion of what is unlikely to result in a significant accepted non-hazardous Industrial leaching medium is suggested by that change in extraction fluid composition. wastes. A recent survey conducted for scenario. In response to this the Office of Solid Waste (Ref. 14) information, die Agency may develop d Mismanagement tcenaria. RCRA concluded that "... in general Subtitle apecial management standards for a requires EPA to identify those wastes D landfills accept industrial wastes but class or classes of wastes. which pose a potential hazard to human not organic solvents or liquids." Wastes As an additional matter, the Agency health or the environment // do have the potential to be subject to believes that die predicted degree of mismanaged. In determining what form more aggressive conditions that might contaminant concentration inleachate of mismanagement to model in be better modeled through the use of ' could reasonably occur in die course of developing the TCLP, the Agency strong inorganic adds, alkalies, or odier types of land based waste considered several alternatives. These solvents. • • . ' management (a.gn surface included segregated management co- The survey noted above, however, impoundments). The TCLP, as well as disposal with municipal refuse, co- found that Subtitle D facilities generally die EP, basically Involve mixing the disposal with industrial waste in a take only small amounts of organic waste with an aqueous leaching media, Subtitle D landfill, and co-disposal with solvent wastes (/.aw <1 to 2 percent of and seeing if certain contaminants can industrial waste in a Subtitle C landfill the total waste accepted). In addition. migrate from die waste to a significant which suffers some form of containment EPA will consider listing specific wastes degree. If such mobility is demonstrated, system failure. . as hazardous, when their normal EPA believes that die waste in question For wastes which are not defined as management or their potential for poses a potential hazard to ground hazardous (e.g.. do not exhibit the mismanagement suggests more water, and that proper management proposed toxicity characteristic), the controls need to be instituted to Agency has concluded that disposal in a solicits comments on the fate of predude unacceptable contamination of Subtitle C (hazardous waste) landfill is industrial wastes, the 5% industrial ground water. This applies to die not a reasonable mismanagement waste, 95% municipal waste assumption leaching of both organics and option. In the absence of regulation, used in developing the leaching Inorganics. there is no reason to expect that waste procedure, and the level of solvents First as discussed previously, minor would go to the more expensive Subtitle which can be found at Subtitle D changes to primarily aqueous media do C facilities. The Agency believes that it landfills. not generally affect die leaching of is reasonable to base its regulations on The Agency recognizes that not all organic compounds. For inorganics, die adverse effects when in a non-Subtitle C industrial waste, or even wastes from all addity afforded by die TCLP leaching environment. industries, go to Subtitle D sanitary fluid accounts for die possibility that For the three remaining options, landfills. The Agency believes, however, wastes could be subjected to mild acidic segregated management, co-disposal that this scenario is a reasonable worst- conditions occurring in other types of with municipal refuse, and co-disposal ease and that tome industrial wastes go land disposal environments. with industrial refuse in a Subtitle O to such facilities. In addition, it could be Wastes do have die potential to be landfill, the Agency believes that, in a serious administrative problem to subjected to more aggressive conditions general each is a plausible define hazardous waste characteristics diet might be better modeled through the mismanagement scenario. Industrial based on waste-specific or industry- use of strong inorganic acids, alkalies, or facilities dedicated to the management specific disposal scenarios (including solvents. The survey referred to earlier of only one waste, or the waste from different leaching media) for the many (Ref. 14) found that'Subtitle D facilities only one generator, are likely to pose different wastes generated. Even if generally take only small amounts of less of a hazard than would general different toxicity characteristics could • •' organic solvent wastes (e.g.. <1 to 2 sanitary or industrial landfills, since the be created, difficult enforcement issues percent of the total waste accepted). In design and operation problems are would result For example, if the Agency '. .addition. EPA will consider listing

6-27-46 Publish* by THE BUREAU OF NATIONAL AFFAIRS. INC., Washington, O.C. 20037 000319 CURRfeN I UtVtLUKMtN I» 31 & specific wastes as hazardous, when milliequivalents of acid for a hundred with the TCLP protocol will also their normal management or their gram sample. increase over that of the EP. For these potential for mismanagement dictates ..- As indicated above, steady or reasons, EPA is proposing to establish a more aggressive conditions. .increased leaching of inorganic species pre-screen test for the TCLP protocol. e. Treatment of highly alkaline , , was demonstrated to occur up to and This pre-screen consists of a total wastes. As mentioned previously, highly after the 20 to 1 liquid to solid ratio (Ref. analysis of the waste itself (using SW- alkaline wastes were not adequately, 8). While this data demonstrates that the 846 methods, Ref. 27)). to determine if represented by the 11 wastes used in'the 70 mUliequivalent acetate buffer system the waste contains sufficient amounts of TCLP development program. EPA is is not aggressive enough for most of the specific compounds for the regulatory concerned that the potential hazard inorganic species investigated, it level to be exceeded, assuming that all posed by these wastes may be supports the use of a 200 milliequivalent the compound leaches from the waste. If underestimated by the acetate buffer acetic add solution for only some of the based on such an analysis one can be system initially chosen for the TCLP inorganic spedes. The Agency is. certain that the regulatory level cannot (See section Vill(D)). Specifically, EPA however, proposing use of the 200 be exceeded, then the TCLP does not believes that an increase in the leaching milliequivalent acetic add solution for have to be performed. of inorganic and some organic species alkaline wastes to be protective of This pre-screen is being offered as a may be observed as the alkalinity of human health and the environment cost saving alternative, and is not wastes becomes exhausted doe to when such leaching does occur. The mandatory. It will be especially useful to Agency believes this action is justified those generators who wish to continuous contact with an acidic given the conservative nature of the demonstrate that their waste does not teaching medium. Note that this can Hazardous and Solid Waste • contain sufficient amounts of certain occur well after the 20 to 1 liquid to solid Amendments of 1964. In addition, as compounds, and therefore, that further ratio selected for the EP and TCLP. Data indicated in the report on Phase I of the analysis would be unnecessary. Perhaps from the TCLP development program (on TCLP development effort (Ref. 6). a prime example of this is wastes • moderately alkaline waste), and from municipal waste leachates, both those resulting from a combustion process, subsequent studies on wastes of generated in lysimeters and real like ashes from incineration. Since these moderate to high alkalinity (Ref. 8). leachates, have been observed in other wastes would likely be devoid of demonstrated that the leaching rate of studies to contain higher concentrations volatile components running the TCLP heavy metals was relatively constant. of carboxylic adds (measured as total for volatiles would be unnecessary. •nd in some cases increased slightly, organic carbon, of which approximately over liquid to solid ratios as high as 30 70 percent is made up of carboxylic 2. Technical Issues to 1. Constituents from non-alkaline adds (Ref. 6)), than those measured in o. Use of extraction devices. The EP wastes generally experience a decrease the municipal waste leachate used in the protocol contains a descriptive in leaching rate during this time period TCLP development program. definition of what was considered to be (Ref. 6 and 7J. The TCLP acetate buffer Hence, EPA is proposing a two acceptable agitation. Two types of leaching fluid may therefore not - ' leaching fluid system lor the TOP. As extraction equipment are described adequately account for the leaching of explained above, the Agency has chosen which EPA has determined meet this heavy metals from wastes of moderate to base the strength of the alkaline definition. One is a stirrer type extractor to high alkalinity. waste leaching medium on the basis which uses small fan-like blades to mix To address this problem. EPA ""• behind the EFs limit on the amount of the extraction fluid with the waste. The determined that an increase in the acetic add used. This will involve a 2 other type involves rotary action in acidity of the leaching medium for the milliequivalent of add per gram of which closed bottles containing the alkaline wastes would adequately waste leaching fluid for wastes of waste/extraction fluid mixture are account for the increased leaching of moderate to high alkalinity and a 0.7 tumbled in an end over end fashion (Ref. these species that could eventually milliequivalent per gram of waste 27). This lack of specifidty in agitation occur in landfills. To define this second leaching fluid for other wastes. A simple conditions is a major source of leaching fluid, the basis behind the EFs test of waste alkalinity is proposed as a variability. maximum amount of acetic add (Le.. 2 means of determining the appropriate Today's proposal eliminates this milliequivalent* of acid per gram of leaching fluid. For highly alkaline source of variability by specifying a waste) was used in defining a second wastes (i.e., alkalinity> 0.7 single means of agitation (i.e., rotary leaching fluid to be used when milliequivalents/gm), the more addic tumbler), and a fixed agitation rate evaluating highly alkaline wastes. Data leaching fluid would be used Note that (30±2 rpm). The rotary of tumbler type gathered at EPA's Boone County Field EPA is not proposing this dual leaching of extractor was selected for several Site over a period of 7 years indicated fluid system for the evaluation of reasons. It is widely recognized as a that the leachate generated by volatile compounds, since these reprodudble means of contacting the decomposing municipal waste contains compounds are expected to be liquid and solid, and has been approximately 0,14 equivalents of unaffected by slight changes in acidity. standardized by ASTM in their draft acidity per kilogram of dry refuse. More detail is provided in Section VIU method D3987 (Ret 1). Also, a factor in Applying this data to the hypothetical (D) and in the background document this determination was that the co-disposal environment EPA supporting the TCLP (Ref. 33). Agency's Sdence Advisory Board concluded that 1 gram of industrial /. Use of a pre-tcreen test One (SAB), in reviewing the TCLP waste could potentially be acted upon concern that was raised with the TCLP development program, recommended by 2 milliequivalents of acid. For a was that the protocol for dealing with tbjt EPA develop one device and one hundred gram sample (the EFs minimum volatile compounds is likely to be set of operating conditions (Ref. 29). sample size), this translated to a total of considerably more expensive than the Although EPA recognized that this 200 milliequivalents of acid (Ref. 28). protocol for the non-volatiles. Similarly, would require laboratories to purchase The acetate buffer system originally since this proposal involves additional additional equipment, EPA has opted to chosen for the TCLP supplies only 70 analytes, the analytical costs associated propose the use of rotary agitation only.

6-27-66 Emta nt Rtportsr 000320 316 ENVIRONMENT REPORTER

Another related issue deah with the surface ana of less than 3.1 cmVgm. volatiles will be lost before the waste is extractor vessel As discussed in section The TCLP continues with this introduced into the ZHE. Vm (D). EPA has developed a zero- requirement One difference, however. Herein lies a problem that may headspace extraction vessel (ZHE) for deals with particle size reduction for require a trade-off. Is it more important use when extracting wastes with monolithic type wastes. The EP allows to reduce particle size or to prevent the volatile organic compounds. This device the alternative of using the Structural loss of volatiles? EPA believes that eta accommodate liquid/solid Integrity Procedure (SIP), which particle size reduction is more important separation within the device, and •mounts to pounding the monolithic and has addressed this problem in the obviates the need for an outside waste with hammer-like blows and then draft TCLP protocol by specifying that pressure filtration apparatus. One issue conducting the extraction on the where possible, particle size reduction associated with use of this device is resulting cample, whether In one piece . be conducted to the extent possible on that, due to its 500 ml internal capacity, or in many pieces. The proposed TCLP the sample as it is being taken. it can only accommodate a maximum does not allow use of the SIP (U« .. The protocol does recognize, however, •ample size of 25 grams for a 100 percent requires particle size reduction), for that then will be situations where solids sample. (A device of the normal 2 several reasons. The first reason again . volatile containing samples requiring liter capacity was impractical due to its has to do win precision and the Science luge tin and weight) For a waste of Advisory Board's comment to limit the particle size reduction cannot be less than 100 percent solids, the ' new procedure to one device and set of reduced under these conditions. In this ""!1 sample size the device fltn operating conditions. Secondly, the case, the protocol specifies that the modate is tied to the percent Agency believes that given the' •ample should first be refrigerated to solids of the waste. The device can only uncertainties ooMCTfinj the long terns reduce the vapor pressure of the accommodate the minimal 100 gram environmental stability of solidified volatile*, and then that the particle size sample size for wastes that are 25 wastes, an environmentally should be reduced with minimal percent solids or less. conservative approach is warranted. exposure to the atmosphere to, at least Another problem associated with the The SIP was originally developed is a fninfrntgf the loss of volatile*. Another extractor is that while EPA is proposing means of assessing the degree to which alternative is to require extractions to require the zero-headspace extractor • cementitious process stabilized a under both condition*. Comments and . when dealing with volatile*, EPA is waste to the extent that the waste alternative suggestions regarding this requiring use of regular extraction would remain as a monolithic block issue an solicited. bottles when dealing with metals and even after disposal Such stabilization c. Quality assurance nquinaients. other non-volatile components. Regular processes decrease leaching potential The quality assurance requirements of extraction bottles an much less through reduction of surface area, and the EP are relatively straightforward. expensive and easier to use than the thus the area of potential leachate They require a minimum of one blanket zero-headspace vessel The problem is contact Many processes also provide . pet sample batch, and the method of mat while EPA originally intended the for chemical stabilization by binding standard addition (MSA) to be run for zero-headspace extractor to be allowed heavy metals in insoluble hydroxide and all samples. The Agency has received to be used for metals and non-volatiles other complexes. • comments mat requiring MSA for *11 as well certain features of the device, The Agency believes mat physical extractions, which is very expensive, is and other constraints, have led EPA to stabilization alone is not enough to unnecessary for all situations. This issue allow its use only when dealing with insure diet components do not leach in is particularly significant in determining volatile*, significant quantities from wastes. Then the quality assurance requirements for The problem touches upon the SAB's are two types of actions which may act the TCLP, given the increased number of concern that in the interest of precision, to reduce the physical integrity of analyte*. In addition, the EP protocol is one device and one set of operating stabilized wastes. First the action of felt to need clarification and expansion conditions should be specified (See heavy landfill equipment which the SIP in addressing other aspects of quality section VI1I(D}). There an actually two is designed to simulate, will act to assurance, such as sample holding factors hen which differ between reduce the monolithic blocks into times. regular extraction bottles and the zero- smaller pieces. Secondly, and men The reader is referred to section 9 of headspace vessel which could affect important is the effect of natural the draft TCLP protocol, which appears precision. The first is that since regular weathering forces, such as wet/dry and as Appendix 0 to Part 2&1 in the extraction bottles will provide for at freeze/thaw cycles (Ret 10). The SIP regulation section of this proposed rule 'east some headspace, agitation is likely does not account for such weathering. for review of the quality assurance to be slightly greater than with the zero- The Agency is currently investigating requirement*. One change that deserves headspace vessel the effects of natural weathering on mention here is in the requirement for The second factor is that the two monolithic wastes, and may propose the the method of standard addition (MSA). devices involve different types of liquid/ use of additional predictive Recognizing that MSA is expensive and solid separation techniques. Whereas methodology at some later date. In the not always necessary, EPA is proposing the ZHE requires piston-applied interim, by not allowing use of the SIP, to* require MSA only under certain pressure, use of bottles involves the Agency insures that generators do conditions (See Proposed Appendix II to conventional air pressure filtration. not rely on physical stabilization alone. Part 261). This change recognizes that These two means of applying pressure An unrelated issue regarding particle MSA is necessary only when the to accomplish liquid/solid separation size reduction also involves the measured concentration of a constituent an capable of producing different treatment of volatile compounds. While is dose enough to the threshold, that results for some waste types. EPA is attempting to prevent loss of mairix interferences could yield a wrong 6. Particle size reduction. The EP volatiles (through introduction of the l decision regarding the determination of protocol requires particle size reduction ZHE}. if a.waste containing volatiles hazard, or when there is evidence that in those cases where the waste cannot requires particle size reduction, it is • severe matrix interference may be pass through a 9.5 mm sieve, or has a likely that some portion of these •presfent

«~27-*a Pubttstwd by THE BUREAU OF NATIONAL AFFAIRS, INC., Washington, O.C. 80037 CO CURRENT DEVELOPMENTS 317

IV. Other Aspects of Proposal basis. This approach' would male .only in the context of the Toxicky enforcement of the regulations easier Characteristic program, but also in A. Testing Frequency and and would likely induce a higher level of connecliovwith other waste sampling IRecordkeeping .voluntary compliance since joe requirements. EPA is currently Under the framework being proposed .regulations would beliigbly specific developing a guidance manual on today, the determination of whether^"" regarding what constitutes an representative sampling that will waste is a hazardous waste depend»,on acceptable testing program and what address these concerns and anticipates whether the concentrations of. actions and inactions would constitute publishing that guidance in late 1066. constituents ij» theTCLP extract exceed violations. EPA is proposing to retain the the applicable regulatory levels. Since There are, however, several problems requirement that generators evaluate this determination is critical, EPA is . with such an approach. Pint, then are their wastes as to whether they exceed evaluating whether to require periodic problems inherent in specifying an applicable regulatory thresholds, but not waste testing. appropriate testing frequency. Based on specifically to require periodic testing. EPA has identified .three genera! data from the Office 6f Solid Waste's EPA is, however, requesting comments approaches to testing requirements, Industry Studies Program and data from on the approaches discussed above, as which are discussed nVdetail below. the Office of Water's Effluent Guidelines well as other possible alternatives to Pint, EPA could require generators to Program, it is clear that many waste these approaches. evaluate their wastes as to whether they stream* an extremely variable in A RelaUonthip To Multiple EP and Oify exceed applicable regiriitory levels, but .concentrations of chemical constituents Watte EP art specifically require testing to make from one plant to another, even when As a result of its waste listing this determination. This.epproach is . the same general process 4s employed. program, EPA has listed a number of consistent with tin current application Variability exists not only from one wastes as being hazardous on the basis of the RCRA hazardous waste generator to another, but also spatially that these wastes typically or frequently characteristics. Second. EPA could and temporarily within a-single plant or contain hazardous constituents et tequire testing of wastes at a frequency process. This variability can DC caused significant levels, or that they typically specified by regulation. Third, EPA by plant start-ups and shut-downs, or frequently exhibit one or more of the could require the generatorio test changes in raw materials, changes in characteristics of hazardous wastes. In' documenting the determination of the product specifications, seasonal recognition, however, that individual appropriate testing frequency based on changes, or meteorological events. wastes may not actually be hazardous, guidance provided by die Agency. While these factors tend to indicate the due perhaps to a different process or the As indicated above, existing desirability of requiring testing at use of different raw materials. EPA has regulations (40 CFR 282.11} require frequent specified intervals, the process- established a "delisting program," generators of solid wastes 16 determine specific nature of this variability (among where generators could demonstrate to whether their waste is hazardous. If the others) makes ft difficult to identify a EPA that the particular waste in •olid waste is not specifically excluded genericaliy appropriate testing interval question does not constitute a - from regulation, and it is not Hated as a For example, an appropriate frequency hazardous waste. Although no waste to hazardous waste hi Subpart 0 of 40 CFR for a continuous process might be too date has beea listed because it exhibits Part 281. then the generator must Infrequent for a bitch process. • the EPTC, the delisting program bee determine wðer the waste is • The third possible approach Is to been applying the EP protocol to this hazardous by aj»y of the hazardous require generators to perform testing on determination for the metal waste characteristics included in their wastes, but not to specify a testing- contaminants (win the application of e Subpart C of 40 CFR Part 281. jThis frequency in the regulations. Rather, • more conservative dilution/attenuation determination may be made by either generators would be required to factor). testing the waste or by the application determine an appropriate testing Given that the delisting process of knowledge of the waste in light of the frequency based on guidance developed involves a more waste specific materials or the processes used in its by the Agency and to document, in their approach, a number of situations have generation. Under 40 CFR 282.40. records, this frequency determination. arisen which have led EPA to modify the generators are required to keep records The advantage of this approach is mat EP to address specific situations. The on how the hazard determination was process-specific factors could be taken use of multiple extractions with' •. made. Thus, although generators are Into account in determining the' simulated add rain have been used to held responsible for determining appropriate testing Interval Thus, predict any king-term effects add rain whether their wastes era hazardous, although there would be tome might have on stabilized wastes (the they are not specifically required to additional burden on generators to Multiple Extraction Procedure or MEP), perform testing. determine, based on the guidance, the end the Ofly Waste EP (OWEP) hea Although this approach would place appropriate frequency for testing been used to predict the leaching of ttte least burden on the regulated tailored to specific factors relating to his metals from wastes which contain community. EPA is concerned that mis process, there would be less of a chance significant amounts of oily materials. approach may not promote voluntary of requiring unnecessarily frequent The OWEP was adopted because of the compliance and that it could hamper testing. This approach does, however, Agericy's concern that the oil present in Agency enforcement efforts against present greater enforcement difficulties the wastes may (1) degrade, thus those members of the regulated . than does the approach of specifying permitting the metals to be leached from community that do not comply generic periodic testing intervals. the residue, or (2) migrate itself, end voluntarily with the regulations. Even if testing is specifically required, transport metals present m the organic, Another possible approach is to a problem still remains as to how to phase to the ground water. require periodic testing, specifying in the assure that the weste sample subjected The Agency has a number of s'tudies regulations both the method and the to testing is representative of both the underway to better define the situations frequency of testing. Thus, testing might batch and the process from which they when such modifications are required. be required on a semiannual, or-annual are derived. This probfem -arises not Pending completion of such studies the

»-27-«6 RaporM CO0322 318 ENVIRONMENT REPORTER

Agency will continue to employ the MEP identification number. In the event that through the equation are levels which and OWEP only in the listing and •ny person who generates, transports, EPA is very certain are protective at delisting programs where situation treats, stores, or disposes of these Subtitle Cland disposal facilities. cisions can be made. wastes has not previously notified and Wastes not meeting the screening levels received an identification number, that are not banned outright from land C Analytical Methods person must get an identification disposal, but rather subject to case-by- The analytical methods proposed to number pursuant to 40 CFR 262.12 case evaluations taking into account the be used for TCLP extracts are shown in before he can generate, transport treat, specific characteristics of individual section VI1I(C) (See Table C-2), and also store, or dispose of these wastes. facilities. This-case-by-case appear fat the regulation section of this determination is Initiated by petitions proposal as required methods. These are V. Relationship to Other Regulatory tor exmption from the land disposal SW-846 methods (Ref. 27). Authorities . restrictions. The evlauation of these Analyzing the TCLP extract for As has been pointed out previously, petitions will be based on results of phenolic compounds and phenoxy add die Toxidty Characteristic threshold modeling similar to that used to set herbicides poses a potential analytical setting approach is modeled along the • screening levels, but with site-specific problem. The leaching fluid used in the tame Tines as that used in the January rather than conservative generic factors new leaching procedure is 0.1 M with 14,1966 proposed standards for . included. respect to acetate. Due to potential implementing the Land Disposal. In addiiton, the HSWA requires a very interference from the acetate ion. the Restrictions regulations (51FR1603). high standard of proof for a showing routinely used analytical methods used However, since the Toxidty that a hazardous waste is suitable for ' for these compounds (Lsw GC/MS-SW- Characteristic proposes to use a Subtitle land disposal For mis reason, the • 846 method 8270) may not be sufficient D disposal model a slightly broader Agency believes it is appropriate to use EPA is presently investigating these confidence interval for the Monte Carlo a higher level of confidence and a lower methods to ascertain whether they are simulation, and an order of magnitude cancer risk level in the modeling for the sufficient or, whether it may be higher risk level for the carcinogens, the land disposal restrictions decisions, necessary to modify these methods. One regulatory thresholds may be different man is used for the Toxidty than those proposed for banning wastes Characteristic. However, the Agency modification being investigated is . from land disposal. whether ft .may be possible to remove The reason for the different thresholds requests comment on whether the risk the acetate ion from the extract before. in the Toxidty Characteristic relates to level end confidence level used in the determination of the phenolic* and the nature of characteristics and the Toxidty Characteristic should be the herbicides. relationship between characteristics and same as for the screening levels used in EPA. is also investigating the use of listings, as discussed previously in this the proposed land disposal restrictions high pressure liquid chromatography preamble. Characteristics are designed •rule. (HPLC] using electrochemical and to be self, implementing hazardous Whenever a waste or waste stream is fluorescence detection. HPLC with waste definitions in which waste and determined to be hazardous under fluorescence detection was used in management specific factors are not section 3001 of RCRA, it automatically developing the unproved leaching • considered. For that reason, becomes a hazardous substance under procedure, and has been shown to characteristics are established at levels section 101(14) of the Comprehensive produce acceptable results (Ref. 6 and at which the Agency has a very high Environmental Response, 7). A GC/MS method would be level of certainty that a waste which Compensation, and Liability Act of 1980 preferable since use of the HPLC exhibits these properties, needs to be (CERCLA). CERCLA section 103 method could add significantly to managed in a controlled manner (Le.. is requires that persons in charge of analytical costs. Should the presence of a hazardous waste). The Agency vessels or facilities from which the acetate ion present substantial realizes that not all waste which exhibit hazardous substances have been problems to GC/MS, it is likely that properties at levels below the released in quantities that are equal to HPLC may be specified. characteristic are safe for disposal as or greater than the reportable quantities These methods are currently be'ing nonhazardouS waste. Rather, for those (RQs), immediately notify the National evaluated. The Agency solicits wastes having properties lower than the Response Center (at (800) 424-8802 or comments and data on these or other characteristic levels, and which are (202) 426-2675) of the release. (See 50 FR methods which may be appropriate. On demonstrated to pose a hazard to 13456, April 4,1965). completion of these studies and human health or the environment the The term "hazardous substance" evaluation of data received, a method Agency undertakes waste specific includes all substances designated in for the phenolic! will be selected and evaluations under the auspices of its 1302.4(a) of the April 4.1985 final rule proposed for use with TCLP extracts listing program. Wastes which are (SO FR 13474), as well as unlisted prior to promulgation of this rule. determined to require controlled hazardous wastes exhibiting the characteristics of IgnitabiUty, D. Notification Requirements management after consideration of the factors identified in 40 CFR 261.1l(a)(3), Corrosivity. Reactivity, and Extraction The Agency has decided not to (e.g.. the nature of the toxic constituents, Procedure Toxidty (ICRE). JSee require persons who generate, transport toxicant mobility under various 1302.4(b) of the April 4,1985 final rule). treat, store, or dispose of these environmental management scenarios, There are currently only 14 hazardous waste to notify the Agency volume of waste generated, potential . substances listed under CERCLA as within 90 days of promulgation that they methods of management), are then ICRE wastes on the basis of the EP are managing these wastes. The Agency specifically listed as hazardous wastes Toxidty Characteristic, most of which views the notification requirement to be and subjected to the appropriate RCRA • 'are also specifically designated as unnecessary in this case since we management controls. hazardous substances under 40 CFR believe that most if not all. persons who For the land disposal restrictions ;.. 302.4(a). Under today's proposed rule, art manage these wastes have already program, the screening levels identified additional 38 compounds, which are also notified EPA and received an EPA 000323 6-27-SS by THE BUREAU OF NATIONAL AFFAIRS, INC., WesNngton. D.C. 20037 CURRENT DEVELOPMENTS 319 specifically designated as hazardous VL State Authority promulgated pursuant to HSWA, a State substance* under 40 CFR 3Q2.4(a). would- A. Applicability of Rides in Authorized submitting a program modification may be incorporated under the newly defined Slates apply to receive either interim or final Toxicily Characteristic. Accordingly,, : authorization under section 3006{g)(2) or EPA proposes to this nilemaking to , "• ' Under section 3008 of RCRA, EPA 3006(b}, respectively, on the basis of amend Table 302.4 of 40 CFR 302.4. to may authorize qualified States to requirements that are substantially remove "Characteristic of EP TcxJclty"' administer and enforce the RCRA equivalent or equivalent to EPA's. The and replace it with Toxicity program within the State. (See 40 CFR procedures end schedule for State Characteristic.'' and to list the Part 271 for the standards and program modifications under section requirements for authorization.) 300B(b] are described intfl CFR 271.21. additional Toxicity Characteristic Following authorization, EPA retains The same procedures should be ' contaminants along with their final *RQs enforcement authority under sections followed for section 3006[g)(2). from Table 302.4. MOB. 7003 and 3013 of RCRA, although Applying i 27iU21{e)(2), States that The CERCLA program will also use • authorized States have primary nave final authorization must modify the TCLP procedure tofcelp-delermiae enforcement responsibility. their programs within a year of when waste taken o&aite must be Prior to the HSWA, a State with final promulgation of EPA'a regulations if managed as a hazardous waste. To the authorization, administered to .• only regulatory changes are necessary, extent thsft the TCLP is applicable er • hazardous waste program entirely in. or within tw* years of promulgation if relevant and appropriate, the CERCLA lieu of EPA administering the Federal statutory changes are necessary. These program will apply the TCLPte • program in that State. The Federal deadlines "-tin be extended in manner that is consistent with the requirements no longer applied in the exceptional case* (40 CFR 271.21(eK3}}. National Contingency Plan (NCP) (88 FR authorized State, and EPA could not States with authorized RCRA 47912, November 20,1985J and policy on Issue permits for any facilities tat the programs may already have CERCLA compliance'(SO FR 47946, Stats which the State was authorized to requirements similar to those in today's permit. When saw, more stringent proposed rule. These State regulations November 20,1985) with other Federal requirements were promulgated have not been assessed against the environmental statutes. or enacted, die State was obliged to Federal regulations being proposed As indicated earlier in this preamble, enact equivalent authority within today to determine whether they meet under section 405 «f the Clean Water specified tine frames. New Federal the tests for authorization. Thus, * State Act (CWA). EPA establishes guidelines requirements did not take effect in an is not authorized to carry out these • for the disposal and use-of sewage authorized State until the State adopted requirements in lieu of EPA until (he sludge. The regulation of sewage sludge the requirements as State law. State program modification is approved is necessarily a complex matter because .In contrast, under newly enacted States with existing rules may continue these sludges fell witUo4he Jurisdiction section 30C»(g) of RCRA. 42 UAC ' to administer and enforce their of several Federal environmental eB26(g), new requirements and standards as a matter of State law. fa programs. Under section 1004(27) of ' prohibitions imposed by the HSWA take implementing tae Federal program. EPA RCRA. the definition of "solid waste" effect in authorized States at.the same wfll work with States under cooperative specifically includes."sludgefrom a time that they take effect in agreements to «"<"»«»*«* duplication of waste treatment plant.** In defining nonauthorized States. EPA is directed to enonsMnttjfAM . carry out those requirements end States that submit official applications "sludge." section 1004(26A) Includes prohibitions in authorized States, for final authorization less than 12 wastes from a "municipal wastewater Including the issuance of permits, until months after promulgation of EPA's treatment plant."-Under section 102 of the Stste is granted authorization to do regulations may be approved without ' the Marine Protection, Research and so. While States must still adopt including standards equivalent to those Sanctuaries Act EPA regulates the . HSWA-related provisions as State law promulgated. Once authorized, however, ocean dumping of sludge, including to retain fine! authorization, the HSWA a State must modify its program to .' sewage sludge. applies in authorized States in the include standards substantially Where such overlapping jurisdiction Interim. equivalent or equivalent to EPA's within exists, EPA seeks to integrate and Today's role would be promulgated the time periods discussed above, . coordinate its regulatory actions to the pursuant to sections 3001 (g) and-fh) of extent feasible. Thus, consistent with RCRA. provisions added by HSWA. Vtt Economic and Regulatory Impacts section 1006 of RCRA. the Agency's •Thus, it would be added-to Table 1 to A, Regulatory Impact Analysi* ' . ' strategy for the development of a section 271.10) which Identifies the 1. Executive Order 12291 .. . comprehensive sewage sludge • Federal program requirements mat ere management regulation will result ineJhe promulgated pursuant to HSWA end Executive Order 12291 requires establishment of a separate regulation. net take effect in all States, regardless regulatory agencies to conduct a Once this regulation is In place, *8 of their authorization status. States may Regulatory Impact Analysis (RIA) for apply for either interim or final any. major rule. A major rule is one sewage sludge use and disposal authorization for the HSWA pro visions likely to result in (1) an annual effect en practices will be covered under identified in Table 1. es discussed in the the economy of $100 million or mere, (2) appropriate provisions of section 105 of following section of this preamble. " a mater increase in costs or prices for. the CWA. If appropriate, sewage sludge consumers, individual industries. that would be defined as atazardom S. Effect on Stole Authorization* Federal, State or local government waste will be exempted &om coverage As noted above. EPA wfll implement a (eneies, or geographic regions, or (3) under provisions of Subtitle C of RCRA. today's proposed rule, when s gnlficant adverse effects on once this separate sewage, sludge promulgated, in authorized States until competition, employment, investment, regulation, which will provide an they modify their programs to adopt productivity, innovation, or the ability of equivalent level of protection, is issued. these rules and the modification is United States-based enterprises to approved by EPA. Since the rule will be compete in domestic or export markets.

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EPA conducted an RIA to compare attenuation factors of 10, loo, and 1,000 as part of this RIA. In addition, as in all aaveral regulatory alternative*, aa were applied to estimated chronic . RIAs, a number of assumptions Were explained in the following sections. The toxidty reference levels, to arrive at made in order to predict impact. RIA provide* an analysis based on the three levels of regulation. Thus, Assumptions about potentially affected guidelines contained in the Office of including the status quo (i.e., no wastes were based primarily en Management and Budget's "Interim regulation), a total of four regulatory technical judgment, review of available Regulatory Impact Analysis Guidance" alternatives w«re examined. literature and data, and EPA guidance. (Ret 21) and EPA's "Guidelines for This approach was taken as it would The determination«f whether wastes Performing Regulatory Impact provide mfa

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TA*LE 2.—Omecuv AFFECTED INDUSTWES— sludge is being tested, EPA expects that constraints on such a modeling-effort. Continued only sludge containing vesy high levels Thus, the economic impacts model, used of the organic toxicants proposed for quantitatively, projects economic 8C addition (which would most likely be impacts only in the identifiable directly Mutty eed> No. introduced through industrial input), affected markets. would be defined as hazardous. Very As described in the full RIA. directly Africuftnl FonnMionand few sewage sludges are expected to be affected markets have been identified at of p*M hazardous wastes. the four-digit SIC level. Since different Hence, most of the impact of the products are included within a four-digit proposed rate on the municipal sector SIC code, products unaffected by the ttii will be the requirement to evaluate proposed regulation may unavoidably M ate. sludges against the Toxidty be induded In this analysis. wdotar Characteristic levels. This, as explained The directly affected markets are earlier in the preamble, does not linked together by means of the PEM necessarily mean that all sewage model Data requirements include an sludges will be tested using the TCLP. original equilibrium, supply functions, Rather, as with the current EPTC. die demand functions, and the initial. vast majority of sewage sludge ianpacts caused by the proposed generators will perform mat hazard regulatory alternatives. Several ' fend an S (lOx determination using their knowledge of assumptions make this data collection the sludge they generate. EPA believes effort more manageable. Within this . Most of the plant* that produce and use that most of the munidpal facilities economic impacts modal all supply the proposed chemical* appear in die receive such small amounts of industrial functions are treated as being perfectly organic chemical industrial. Any facility input, that (hey will be able to support • elastic. This assumption limits the that i» projected to generate a watte determination of non-hazardousness interaction between directly affected which could produce a TCLP extract without having to test sludges using the markets. A demand shift in an output containing any contaminant at TCLP. market does not change input price and concentration! greater than the To assess more fully the regulation's does not change production costs of a regulatory level (Le., the solubility of the impact on the munidpal sector, the directly affected product What this contaminant exceeds the level), is Agency will be collecting additional simplification implies cannot be assumed to be a hazardous waste. data during the period between proposal assessed because of limited data. In the (Those wastes currently regulated by and promulgation. To help the Agency in long run, however, all supply functions RCRA are not included in the analysis.) its impact estimates, EPA is requesting tend to become more elastic (or flatten), Hie number of affected facilities may that data on munidpal sewage sludges making the importance of this include plants that produce or.use more generated with the EP, the TCLP, or total assumption less « only recurrent or annual costs. Changes Regulation of the waste is assumed to hazardous waste, current disposal .: in waste disposal methods in response prevent these estimated health affects practices are identified by examining . to a regulation are represented by an and corrective costs completely; The the technical literature, by analogy to . upward shift in the supply function. The estimated benefits attributable to the similar wastes for which disposal higher production costs that result regulation are the health effects and practice is known, or by assumption. create a new equilibrium and a corrective costs avoided by its Some baseline disposal alternatives consumer surplus toss. The new implementation. may understate the actual treatment and equilibrium will have tower production Four steps are used to determine disposal applied to that waste, because- at a higher cost than the initial benefits: (1) Estimate quantity and no effort has been made to determine equilibrium. A real resource cost is the concentration of chemical in landfill. (2) which wastes may be affected by State value of the additional costs incurred to estimate concentration of chemical in and local regulations that are more produce the new lower level of output A leachate (U., TCLP extract), (3) estimate stringent than Federal regulations. This dead-weight loss is the loss in surplus chemical concentration at drinking may also occur because firms value consumers placed on those units water well and (4) estimate health voluntarily may be applying more that will no longer be produced. effects and corrective costs attributable thorough treatment and disposal than Extension of the above analysis to a to that ground water contamination. required by regulation. The result of this nultimarket situation is straightforward. The unregulated wastes are assumed potential understatement of baseline Since impacts in input and output to be disposed in a landfill each year for treatment and disposal alternatives is markets need not be considered, total 20 years (the average lifetime of a mat the estimated increase in disposal welfare costs are developed by landfill). The amount of the chemical costs to comply with the characteristic assuming welfare costs in the directly contaminant that leaches through the approach will be greater than the actual affected markets. landfill, and the leaching duration, is increase. Consumer surplus costs represent determined using a leachate For currently landfilled wastes not annual costs. Within this analysis all concentratioh model From the bottom of listed as hazardous but subject to the baseline data are presented for the year the landfill the contaminant is regulation, disposal practice after 1982. Consumer surplus losses will transported through the aquifer to the regulation will become more stringent continue to be incurred, however, for an community well. The concentration of and costs will increase. Disposal costs unknown number of years. To develop the contaminant at the well varies over are assumed to remain the same for "cost estimates for future years, costs are time and is tracked over 100 yean with wastes currently incinerated or first estimated for 1982 and then a ground water transport model The deepwell injected. Solvent wastes and a assumed to be constant for all health and corrective costs attributable few other wastes are assumed to be subsequent years. This simplifying to the contaminated well are then . incinerated. • assumption is necessary since time estimated by a health and corrective Using model plant information, '' constraints preclude the projection of costs model estimates of the incremental disposal market trends. 000327 «-a?-at Published by THE BUREAU OF NATIONAl. AFFAIRS, INC.. Washington, D.C. 20037 CURRENT DEVELOPMENTS 323

Implementation cost*, consisting of U not very precise, so the'rockier ft difficult becaase these benefits arid ' * transaction costs and employment cautioned to interpret the results costs typically accrue to different losses, represent losses in welfare that •; presented carefully. The benefits and individuals. HarbergerXRef. 11) has will be incurred only once. Transaction . costs for each regulatory alternative «n argued that: costs represent the value of resources • summarized in the following table when evaluating the Mt benefit* or costs of a that would be expended to determine if (Table 3). given action (project program, or policy), the • waste stream is to be regualated. -, TABUE 3.—BENEFIT-COST ASSESSMENT costs and benefits accruing to each member These costs are based on an estimated ' of the relevant group (e.g» a nation) should cost of sampling and analyzing each normally be added without regard to the waste stream by affected facilities. individuals to whom they accrue. .Employment losses occur since goods and services are forgone when This principle dates to Kaldor (Ref. 16) individuals are employed. Losses are and Hicks (Ref. 12), who argued that a based on the projected change in ax? S.1M change should be instituted if a potential production and employment-to-output an gain exists so that those who bear the ratios for each directly affected market coat could be compensated fully for their These losses an not valued in dollar «JST loss by the beneficiaries, and the terms because projecting the length of beneficiaries would still be better off time for which an employee is man before. Following the Kaidor-Hicks vws principle, this RIA evaluates benefits unemployed is difficult Similarly, the tsf value to place on time, individual fob and costs to society al large without •kills, age, education, and personal regard to their incidence. dislike of being unemployed an not 11 e.r Table 3 summarizes the benefits and valued hi dollar terms. IS u costs of the regulatory alternatives. The difference between the monetized 8. Results ' . 1*,IOS 1*10 benefits (i^u avoided corrective coats) a. Aggregate benefit*. Continued use and monetized costs (La., nal resource of current practices for managing wastes and dead-weight consumer surplus producing TCLP extracts containing the costs) is compared using theanaualized selected chemicals in excess to method. This difference is positive for• regulatory levels is expected to result in all regulatory alternatives. Thus, each the deterioration of environmental alternative would provide an quality. This deterioration may elevate improvement in economic welfare. risks to human health and reduce the An evaluation of the regulatory quality of environmental resources, such alternatives will allow a comparison of as drinking water. The major route by These estimates of the health effects the different regulatory levels for the which environmental quality is expected and corrective costs attributable to a proposed contaminants. Moving from to be affected is through the teaching of waste art developed for a typical Alternative 2 to 1, respectively leads to . contaminated wastes into ground water. community. The estimates of the virtually no changes m health benefits, Over 50 percent of the U.S. population aggregate benefits of the proposed' but does increase the net monetised . uses ground water for drinking water. regulation an obtained by ••«""<«B benefits by 181 million per year. This • Further, contaminated ground water can that health effects and corrective costs suggests that Alternative 2 is preferable enter surface water, reducing its quality. would be avoided by aD the to Alternative 1. Moving from The capacity of both ground water and communities affected by the proposed Alternative 3 to 1 leads to substantial surface water to assimilate toxic regulation. Since the aggregation reduction in health benefits, and yields 1 chemicals is limited. : process used assumes mat ea'ch waste decrease in net monetized benefits of If people drink contaminated ground affects a tingle typical community, it is H4 million per year. water, a wide range of health effects somewhat arbitrary. Again, the raader is As explained earlier, this RIA may occur, from simple gastrointestinal cautioned to interpret results with can. compares the benefits-'and costs of problems to cancer and birth defects. 6. Aggregate costs. Benefits of the several regulatory alternatives that wen The focus is on the possible excess regulatory alternatives would be determined by mulitplying estimated cancer cases if the selected chemicals accompanied by costs. As described chronic Uoddry reference levels for the an not regulated. It is assumed that previously, total costs of the regulatory •elected compounds, by assumed contaminated water would continue to alternatives includes nal resource costs, dilution/attenuation factors of 10,100 be used as a drinking water source until dead-weight consumer surplus losses. and 1,000. This was necessary, as the the concentration reached taste or odor dead-weight producer surplus losses toxidty reference levels and the model- thnsholds of the avenge person. When (capital value tosses), employee generated dihition/attenuation facton that threshold is attained, it is assumed dislocation costs, and transaction costs. mat wen proposed today could not be they would switch to alternative water Two of these welfare costs have not generated in time for this analysis. sources. been projected in this analysis. Hence, while this analysis provides When a landfill is recognized a* a Employee dislocations have been estimates of the range of regulatory source of ground water contamination, it quantified, but their social costs have impacts due to. the proposed rule, it does is also assumed that the municipality not been evaluated Capital value losses not dinctly provide an estimate of the would take action to prevent further incurred by owners of affected capital impact of the proposed rule. The final leaching of the chemicals. Estimates also have not been evaluated. RIA which will accompany the were developed for a repnsentative c. Benefit-cost comparison. Most promulgation of this rule will analyze Icommunity and aggregated to obtain public policy alternatives have benefits the benefits and costs based on the final national totals. This aggreation process and costs. Policy evaluation can be regulation.

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A Regulatory flexibility Act threshold value which includes a toxicity reference levels which are being na{ority of the total population obscures proposed for use in expanding the Under the Regulatory flexibility Act S any differential impacts oh smaller . Toxicity Characteristic. U.S.C. 601-612 whenever an Agency is firms. The Agency considers a threshold required to iuue for publication in the value of fewer man SO employees to be 2. Non-Carcinogenic Constituents Federal Register any proposed or final a more sensitive index of impacts on Establishing regulatory levels for rale, it must prepare and make available small businesses. individual contaminants requires the fur comment a Regulatory. Flexibility '' For the other two measures, the entire initial input of a health reference level. Analysis which describes the impact of cost for tile industry is compared to the Determination of the appropriate level is the rule on small entities (Le« small aggregate data for small firms as a wont dependent upon the nature of the toxic business, small organizations, and small case. This will provide an extreme effect of tha constituent specifically government Jurisdictions), unless the estimate of the number of industries that whether or not the constituent is a Agency's Administrator certifies that the have small firms mat might experience a carcinogen. Substances which do not rule will not have significant economic ctnt impact A "significant portion cause cancer exert toxicity through impact on • substantial number of small ofcapital available to small entities- mechanisms which exhibit physiological entities. depends on tha average annual portion thresholds. Thus a reserve capacity, The Agency has examined die of new capital expenditures spent on assumed to exist within an organism, proposed rule » potential impact on pollution abatement in the last 10 years. Bust be depleted or overwhelmed small businesses, and has concluded If capital costs as a percentage of new before toxic effects an evident Simply that mis regulation will not have a capital expenditures are more than 10 put for each non-carcinogen there is significant impact on a substantial percentage points larger than the some low level of exposure which has number of small entities. Again, for the average percentage mat has been spent no effect on humans. Protection against reasons stated in the above section, this in the last 10 years, than tha capital a chronic toxic effect for a non- analysis does not directly provide an costs are determined to be significant carcinogen is achieved by keeping estimate of the impact of me proposed Under mis analysis, no SIC* an •xposun levels at or below the rule on small businesses. impacted significantly by any of the More than 20 percent of tha small three measures described. Accordingly, I For non-carcinogenic constituents, die firms in an industry is considered a certify that this proposed regulation will Agency is proposing to use Reference substantial number of affected firms. not have a significant economic impact Doses (RfDs) as the starting point for This analysis uses a worst-case on a substantial number of small' establishing chronic toxicity regulatory approach and assumes mat all affected entities. This regulation therefor* does levels. An RfD is an estimate of a facilities belong to small firms. Three not require a Regulatory Flexibility lifetime daily exposure of a substance to standard measurer suggested by EPA Analysis. the general numan population, which guidance are used in determining a C Paperwork Reduction Act appears to be without an appreciable significant impact on small firms within The proposed rule contains risk of deleterious effects. Conceptually, an industry. These are (1) when Information collection requirements the RfD is closely ntated to the term annualized compliance cost as a subject to OMB review under the Acceptable Daily Intake. ADIs wen first percentage of total costs of production is Paperwork Reduction Act of I960, 44 used by the Food and Drug greater than 5 percent, (2) when capital U.S.C. 3501 et seq. Specifically, under 40 Administration (PDA) hi 19S4 as specific costs of compliance represent a CFR 262.40, generators an required to guidelines and recommendations on the significant portion of capita] available to keep records on how the hazard use of "safe" levels of chemicals, such small entities, and (3) when annualized determination was made for the wastes as food additives or food contaminants, compliance cost as a percentage of sales they generate. EPA believes that these for human consumption (Ret 18). Since for small firms is more than 10 information collection requirements an their initial use by the PDA, ADIs have percentage points higher than insignificant and has not prepared been used by other public health annualized compliance costs as a documentation pursuant to the agencies in establishing "safe" levels for percentage of sales for large firms. For Paperwork Reduction Act If necessary. toxic chemicals. The Food and the purposes of this analysis, the costs such documentation will be prepared far Agricultural Organization. World Health associated with the first regulatory the promulgated rale. Organization, and EPA have used ADIs alternative are used in assessing the In the process of establishing allowable significance of impacts on the small VDL Additional Information pesticide residues in foodstuffs (i.e., firms within affected industries. A Chronic Toxicity Reference Level* tolerances). The National Academy of In determining the ratios needed for Science and EPA have estimated ADIs the third measure, annual compliance 1. Introduction for purposes of establishing safe levels costs for each industry are apportioned When the EP Toxicity Characteristic of contaminants In drinking water (Ret into two groups. One group is used with (EPTC) was promulgated in May of I960, 30). the receipts for targe firms and the other the only standards which existed for The experimental method for is used with receipts for small firms. The establishing toxicity levels, and which estimating the RfD is to measure the proportion going to each group is equal addressed chronic exposure, wen the highest test dose of a substance which to the percentage of small and large National Interim Primary Drinking causes no statistically or biologically firms above and below the size standard Water Standards (NIPDWS). These •significant effect in an appropriately of 50 employees. EPA has elected not to addressed 8 metals, 4 insecticides and 2 conducted animal bioassay test. This adopt the Small Business herbicides, and hence. EP toxicity experimental no-observed-adverse- Administration's definition of small thresholds were limited to these 14 '. effect-level (NOAEL) is an estimate of business, which is fewer than 500 contaminants. Today, however, chronic . the animal population's physiological employees for most SICs. because it toxicity levels have been established for • threshold. The RfD is derived by would include the majority of plants in a number of additional toxicants. This dividing the NOAEL by a suitable the regulated community. Using a Section provides details on the chronic scaling or uncertainty factor.

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NOAELs are usually obtained through, 3. Carcinogenic Constituents Group B indicates probable human a chronic study or a 90-day subchronic The use of the RfD is appropriate only carcinogens. The evidence of human study. Other available toxieological •for non-carcinogenic toxic endpoints. la cardnogenidty from epidemlotogical data, such as metabolism and .'•th•e absence of chemical specific studies for substances within this group pharmacokinetics, are used to validate information on mechanism of action or ranges from almost sufficient to the judgmental choice of a particular ' • kinetics. EPA science policy suggests inadequate. This group is subdivided dose level as the NOAEL. Confidence in that no threshold dose exists for Into two categories (Bi and Bt) on the the NOAEL, and therefore tn the RfD. is carcinogens. No matter how small the basis of the strength of the human dependent on the quality of the dote, some risk remains. evidence. Where there is limited experiment the number and type of The dose-response assessment for epidemiologic evidence of animals tested at each level the number carcinogens usually entails an cardnogenidty, the carcinogen is and range of dote levels, the duration of extrapolation from an experimental high categorized as Bi. Where there is no the ttudy (i*, chronic vs tubchnmic}, dose range and observed carcinogenic evidence or Inadequate evidence from and the nature of the biological endpoint effects.in an animal bioassay, to* a dote human studies, the carcinogen is measured (i.e., die severity of the range where there are no observed categorized as B». Group C comprises observed effects). The longer the experimental data, by meant of a pre- human carcinogens. This group duration of the study, the smaller is the selected dose-response model The slope ndudes agents with limited evidence of uncertainty factor applied to the of the dose-response curve it . animal cardnogenidty. It includes a NOAEL. Selection of the appropriate determined by this model EPA's wide variety of animal evidence. Group uncertainty factor involves adentific Carcinogen Assessment Gronp-hai D indndet ageatt which cannot be ' judgment and the application of general estimated the carcinogenic potency (La* classified because no data or guidelines (Ref. 30). The derivation of the slope of risk versus exposure) for msuffldent data are available. Group E RfDs used for establishing regulatory* humans exposed to low dose levels of tocludea chemicals for which then an levels has been evaluated and verified carcinogens. These potency valnet adequate negative animal bioassays. by an Agency workgroup (Ref. 30. SI, indicate the upper 95 percent confidence This category indicates no evidence of and 32). limit estimate of excess cancer risk for cardnogenidty in humans. Table A-l presents the proposed non- individuals experiencing e given The Agency regards agents classified eardnogens and their RfDs. The RfDs in exposure over a 70 year lifetime, to m Group A or B as suitable for this table en calculated by assuming practice^* given dose multiplied by the quantitative risk assessment The mat a 70 Kg person ingests the slope of the curve gives an upper limit method for qnantitation of Group C compound in 2 liters of drinking water estimate of the number estimated to substances U) best judged on a case-by- parday. . : . develop cancer. The slope can be used case basis, since some Groop C agents r to calculate the upper limit of the dose do not have a data bate of sufficient . T*auA-l.i NON OHONOOOH which gives rise to a given risk level quality and quantity to perform a (e.gn one response in e hundred quantitative cardnogenidty risk thousand). By specifying the level of risk ' " • 'IQaHiMI* • . MO (no matter bow smau) one can estimate the lifetime dose corresponding to it Since carcinogens differ in the weight 4- of evidence supporting the hazard The upper limit of the dose of a assessment. EPA believes* that •1 cardnogen corresponding to • specific establishmenSKt of a single across-the- >t risk level is called the Risk Specific •* board risk level is not appropriate. The s Dose (RSD). To arrive at e starting . health limit for a cardnogen, e risk level Agency proposes to set a reference risk * or range of concern must be specified level as a point of departure, along with m&umtm ______; ______fttt a risk range keyed to the weight of *y«4*»* ——— ' ————— ' ——— r— EPA proposes to specify a risk level of 4 concern on a weight-of-evidence basis, evidence approach. The dose for known ftOTt and probable human carcinogenic •M as described below. return—————— •....______M tn November 1984, EPA proposed agents (Classes A and B) would thus be L4>THMn*fMnt _____ ~ -• '_:. 4 Guidelines for Carcinogen Risk ' determined at the l

. Some agents appear to cause cancer National Interim Primary Drinking TABUE A-3.—PROPOSED MCL's FOR VOLATILE by only one route of exposure or entry. Water Standards, established for eight . ORGANIC COMPOUNDS Conclusions about route specifidty can elemental contaminants and six only be addressed in circumstances • pesticides, as toxidty thresholds. ISa* where, adequate data exists on Today's rale retains these thresholds for cardnogenicity for more than one route aoos the elemental toxicants but proposes CMwni aoos of exposure. Where cardnogenidty compound specific dilution/attenuation 0.78 findings are available Jrom only one factor based thresholds for the organic route of exposure, the~~«ubstanee ia 0.007 fudged to represent a cancer hazard by aoos EPA has also been working to aooi afl routes, unless it oan be scientifically establish Drinking Water Standards for demonstrated that the material cannot additional organic compounds. Final ^•StMS* WWW i t»oW targeMB*QW»t »»»wsitews WbVy *•"•the• alternative routes of interest Where the standards for drinking water, the 5. Apportionment of Health Limits data from one or more routes are Maximum Contaminant Levels (MCLs), • The reference dose for humans is the Bmited, the Agency will evaluate each . ere enforceable and are based upon maximum daily dose of a substance that caseca its merits, placing particular. ., health, treatment technologies, costs, should not be exceeded to assure no emphasis on the sdeutific evidence... end other feasibility factors such as the adverse health effects over a lifetime of exposure. If exposure occurs by multiple the data base demonstrating that cancer MCLs ate set following an analysis routes, some tolerance level can be is produced by one route of exposure based on health considerations as . established for each route so that the but not by another is substantial and guided by the Safe Drinking Water Act '•urn of exposures by the individual convincing. An example of a substance* This intermediate analysis results hi routes does not exceed the reference whose carcinogenic response ia proposed Recommended Maximum dose. characterised as route-specific is Contaminant Levels (PMCLs). which are The concept of apportionment of a chromium and some of its salts. These . non-enforceable health baaed limits. - chemical by medium and by route of substances cause cancer by inhalation Induded in the analysts of the health exposure is not new. The National but not by other conventional routes of considerations for determining PMCLs Research Council's Safe Drinking Water entry. The Agency will regulate such are not only the quality and weight-of- Committee, calculated a suggested no- substances as carcinogens only by the evidence of the supporting toxicological adverse-response-level (SNARL) for relevant route-end as non-carcinogens studies, but also examination of chronic exposure to a non-carcinogen in by all other routes. absorption rates of specific toxicants, drinking water, while incorporating an Table A-2 presents those proposed , the possibility of nutritionally essential "arbitrary assumption" that 20 percent Toxidty Characteristic contaminants levels for some elements, the existence of the intake of the chemical was from mat an carcinogens, the dass of the of route-specific toxidty, the drinking water (Ret 20). EPA. in setting carcinogen, and the Risk Specific Dose. demonstration of other environmental PMCLs for chemicals in drinking water, exposures, and finally, the has followed the suggestion of the NRC, TABLE A-2.-CAHcmoocMC CONTAMMAMTS apportionment of the permissible limit of and selected a fraction of the RfD, AND RSO (MO/U) > usually 20 percent for synthetic organic constituent into media spedfic amounts. chemicals if no empirical data suggest La general final MCLs for non- some other fraction is r.ore appropriate carcinogens are based on 20% of the (50 FR 46680, Nov. 13.1985). EPA is relevant RfDs, to account for exposure proposing to apportion non-carcinogenic from other sources (e.g« food and air). contaminants according to the scheme SI-3 Final MCLs for carcinogens are based outlined on the following pages. SE-4 on risk levels that range from 10 ** to In evaluating carcinogens, the 1E-J National Research Council's Safe Since the above factors have been Drinking Water Committee estimated evaluated for each of the other cancer risks assuming that tap water contaminants in today's.rule, PMCL exposure was both 1 and 20 percent of JE-1 es-« standards derived under the Sefe the total daily intake (Ref. 20). The 7t-1 Drinking Water Act can be used as Agency is however, not proposing to toxidty thresholds. On November 13, epportlon the RSD for carcinogens. For 1985 EPA proposed MCLs for eight such substances, the RSD is estimated synthetic volatile organic chemicals (50 by a procedure which introduces TE-S FR 46880). EPA is also proposing to use unavoidable uncertainties. The these contaminants and their proposed procedure used is deliberately SE-t Ti MCLs, which appear in Table A-3, as conservative, so that a difference in *.«*• toxidty thresholds for the Toxidty dose of a factor of two is still well Characteristic. After public review and within the margin of uncertainty of the tu..nn»»f«i tor evaluation EPA will promulgate final estimated RSD. IWM^M* * ~ ' standards. Should the final MCLs differ Moreover, for carcinogens, the from the proposed MCLs. EPA will base determination of risk is the daily dose . averaged over a-lifetime. Small 4. Use of Existing Agency Health regulatory levels for the Toxicity variations around the daily dose have Standards Characteristic on these revised final little effect on the lifetime risk, providing Under the existing EP Toxicity standards. Characteristic, EPA uses the existing

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that -die even) * is not affected. For this .: route of concern. In the absence of appropriate under the CERCLA statute reason, a two-Held reduction in the BSD 'adequate exposure data, apportionment since cost-effectiveness is an integral is relatively insignificant. For non- Js. established at 20 percent for synthetic part of the decision-making process (Ref. carcinogens. «is possible that not organic chemicals. For inorganic *)• applying a SO percent reduction (the '. chemicals, an adequate data base Many of the chemicals EPA regulates indinct affect of which is to permit an' . generally exists. The actual contribution are ubiquitous in the environment and approximate doubling of tbe.RID], may from other sources can be factored into may be associated with exposures from causa the level to be exceeded on aome the PMCL. Where actual data is sparse, other media (e.g., water, food, air). or eves many days of exposure. however, a 10 percent contribution is Although available scientific and Exceeding the level for non-earcinotpns estimated for inorganics in drinking technical information as well as past nay therefore have significant health water, since sources other than drinking decisions wfUbe considered in reaching consequence! for some individuals. water are more likely carriers for decisions on the apportionment of RfDs. Thus, then is Justification for treating inorganics. sufficient information is not generally aon-carcinogeni differently torn Apportionment has also been used in available on exposure to reliably carcinogens with respect to the risk •valuation procedure developed quantify the proportion of the RfD that apportionment for EPA's Office of Emergency and should be allotted for each chemical. In the process to developing drinking Remedial Response to evaluate and When adequate exposure data does not water standards, EPA considers the manage the risks for specific remedial . exist the Agency is proposing to limit contribution from other sources of ',. action sites under the CERCLA population exposure to a 50% fraction of exposure, such as air and food When (Superfund) law. to thia procedure, .the RfD to reflect consideration of sufficient data are available, the PMCL concentrations are generally potential and actual exposure from other is determined by subtracting the known apportioned equally in environmental media, contribution of the constituent in food media (e«* air and water), as an initial EPA proposes to apportion reference and air from the RfD. Such data is often basis for calculating a rate of release. If • doses according to the scheme shown in not available. In these cases, the amount there an significant cost and feasibility Figure A-1.. permitted in drinking water to calculated differences in controlling, exposures via by an estimation of the percentage of the different pathways, unequal exposure attributable to the exposure apportionment is selected. This option is

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Basically, this scheme indicates that •n organic (tipid) component Each TABUL A-7.—SUMMARY OF CHRONIC Toxcrnr if the .Agency has adequate data to distribution constant (H« and k*r) is REFERENCE LEVELS 'assess exposure from various routes, subdivided into two'equal parts then such data will be used to apportion. according to its range of values, as If on the other hand, adequate data shown in Table A-4. Each contaminant. •Mr* does not exist EPA will use SO percent to be apportioned is classified as having of the RfD and subtract from this 50% a high or low value according to the tiie fraction of the RfD allotted to water, general size of its distribution constants, using the remainder for air. as shown in Table A-6. A relationship EPA proposes to estimate between H, and k«, and the distribution aos. ows«_ aos between air and water has been devised \a.— ows .0 environmental partitioning to atr and aoos. 0.005 water according to a simplified scheme • using a matrix* as shown in Table A-6. using Henry's Law Constant (He) and TABU A-4.—RANGES AND CLASSIFICA- 001 _ ows. 0.01 the octanol-water partition coefficient 4_ 1.0 (!(••) for individual contaminants. TON OF HENRY'S LAW CONSTANTS (Kg) ma. aoos and Octanot-Water Partition Coeffi- Henry's Law constant estimates the CMS 28-3 ratio of a substance between the vapor cients 0.1 . and dissolved (aqueous) state. The k«^ SE-3 HJgft m Air >W«. O.OS estimates the distribution of a 0.7 Lew to wafer >900~ Hghkt 0.7 compound between water and octanoL

TABU A-S.-WENRV'S LAW CONSTANTS' AND OCTANOL-WATER PARTITION COEFFICIENTS FOR 0.7S NON-CARCINOGENIC CONTAMMANTS 0.006 0.00? Minqft 1E-3 •on tai OWS. 2E-3 1E-4~ *SD IE-4 2E-4 CMOBOMMl 1.461+02 3.4SE-03 7.4lE+Oa s.osE-06 1 .411 +02 0.003. 1 lfflE+03 10 is aos_ ows. 0.06 1 SJOE+OO 0.004 X.S1E-OS UQE+00 0.004 ows. 140E-OS 7.64C+01 O.OOS- ows. 0.003 0.1 ows. 0.1 4A2E-06 1.1BE+OS 0.06 s.oa-06 1.4SE+00 as 1JK-07 0.004 tSSC-OI S.14C+M 0.02— TokiM. s.nc-03 MiE+03 1 O26 4 \* 2,43-Trid 2A4C-06 7.341+03 OATS- MO 0.03 0.01. 0.08— ows. aos TABLE A-«.—tXsTRtBtmow MATRIX BETWEEN 1.1.1* 0.7 will distribute to air and 40 percent to THeM WATER AND AIR USING K«, and k« Air» water. 1.1.1* 2E-8 EPA believes that the approach 7E-J outlined above is reasonable in light of 0.4— at the difficulty in obtaining exposure data 10 __ for many compounds within the 0.006 aoos •oao. 1.1,1' OJ- 02 soao. statutory time limit The Agency solicits Ti comments on this general approach. The 1 OMinninid by eampvino KlMt or eompuM k. Mid k. Agency is also considering a simpler 1.1* 10 CWQM VI TMM A4. scheme which examines relative PMCL. O.OOS To construct the matrix, EPA assumed concentrations between water and air (0 that a compound with equal ranges of using Henry's Law constant only. TMHorapMnd. kp« and H« (i-e., high-high or low-low), Table A-7 presents all 52 compounds MO- 2E-2 will distribute between air and water included for toxicity, their respective 0.01- ows- 0.01 into equal parts. For compounds that health based toxicity thresholds, and the aoot FMCL. 0.001 exhibit a high range for H« and a low results of any apportionment1 The SvNctionat tmewn Pnmary 0"Ats Water range for lw EPA assumes that the Tables in section VIU(C) contain further . „X'Propoead Mtonwn Contanininl Laval distribution would be in a ratio of 80 to information used In establishing the *RO»ltafcrenotOaae. 20, air to water. As an example, given proposed regulatory thresholds. that 50 percent of the total RfD is A Ground Water Transport Equation available for apportionment into water and air, and if Table A-5 indicates a 1. Introduction high He and a high k^ the fractionation . Under the framework presented in of the total RfD is 25 percent of the total 1 A* explained in other Mctioiu of thit preamblt.' th'rs proposal, EPA will establish RfD Into each medium. If the It compound! art nbo proposed for inclusion In Ibt regulatory levels for individual chemical contaminant exhibits a low H, and a Toxicity Characteristic bated on their tolvtnl ; .constituents contained in hazardous high KOT then 10 percent of the total RfD properties wastes. These levels are expressed as 000333 PublisrMd by THE BUREAU OF NATIONAL AFFAIRS. INC., Washington, O.C. 20037 CURRENT DEVELOPMENTS 329 maximum acceptable concentrations for . flow conditions. The mechanisms plume. Although further dispersion Individual constituents in extracts of ' • considered include advection, would still be greater than sero. Its wastes. The extract concentration is hydrodynamic dispersion In the effect is Insignificant.) Aquifers have assumed to be the same as the teachate ' longitudinal, lateral, and vertical finite area! extent, however, and may be concentration entering th* ground water dimensions, adsorption, and chemical confined by impermeable layers. If an since the scenario assumes the bottom degradation. Mechanisms not aquifer Is confined by an impermeable of die landfill lies directly over the considered in the model include layer in the longitudinal or lateral fields, saturated cone. EPA has developed a biodegradation, effects of sinks and this assumption will underestimate • quantitative ground water modeling sources, and dilution of constituents downgradient concentrations. procedure to evaluate potential impacts within drinking water wells. The assumption of homogeneous and on ground water and to establish isotropic aquifer properties is rarely regulatory levels for individual • 2> Modal Assumptions encountered in the field but Ac constituents. The proposed regulatory The analytical solution described availability of data and the generic level-setting procedure involves • back- below is based on a number of key nature of this analysis requires the use calculation from a point of potential assumptions pertaining to the features of of a homogeneous and isotropic exposure toe point of release from • ground water flow and the properties of approximation. Also, this assumption is hypothetical sanitary landfill , ' the porous medium. These assumptions •sually employed if the solution of the Specifically, die model assesses die ' include the following! . . problem Is obtained by analytical long-term chemical flux or leaching of a. Saturated soil conditions (no . techniques. . . ' . toxicants to the ground water, from a attenuation of chem teals in the A uniform flew velodty. the fourth waste disposed in a Subtitle D sanitary •maturated sane). ' . • assumption, presumes that the water ' landfill The beginning point of die back- b, Flow regions of Infinite extent fat volume entering from the source is not calculation is a measurement point at a die longitudinal direction, semi-infinite large enough to affect the natural ground specified distance directly extent in the lateral direction. water gradient This assumption is oowngradiant from die disposal unit c. AD aquifer properties are appropriate for simplified analytical .This procedure incorporates the homogeneous, isotropic and of constant solutions, m situations where the ground toxidty, mobility, die persistence' of " thickness. ' • water flow system contains sinks or constituents, and also die long-term - & Groundwater flew is uniform and sources (e.g., pumping or injection uncertainties associated with land continuous in direction and vetodry. disposal e. First-order decay is limited to wells), drastic changes in the velodty ' The toxidty of constituents is hydrolysis and the byproducts of distribution will occur. Under this considered by specifying a regulatory hydrolysis an assumed to be non- situation that steady-state down • . . level at the point of measurement (U, haxardoos. - ' gradient contaminant concentrations drinking water well) and back- I Sorption behaves linearly. may be underestimated. calculating to the maximum acceptable f. Infinite source supplies a constant Hydrolysis of first-order kinetics, the leachate concentration d»t will not mass flux rate. fifth assumption, is the only mechanism exceed die specified standard. The k Ground water recharge is for transformation considered in the mobility of constituents Is considered accounted for. . * ' • proposed model While other dirough application of die TCLP, and for L The ground water is initially free of transformation mechanisms, such as . organics, through incorporation of . biodegradation and oxidation are also sorption as a delay mechanism. The . }. The receptor well is directly In tine important, the Agency's present. inclusion of sorption in die ground water with the source and the ground water. understanding of these mechanisms transport model is important only for - flow. does not yet permit a kinetic . organic constituents which degrade. The effect of the first assumption is to representation of these processes within . The persistence of constituents is * presume that a waste Is placed directly die system modeled. The effects, Incorporated into die ground water at the top of the saturated son*. Since ' relative importance, and interactions of model for organics by considering EPA {us found that a significant number these processes in the ground water hydrolysis. Metals do not degrade.'so no of hazardous waste landfills an located environment an not well understood degradation is assumed. Spedation of within a few feet of an aquifer, and and an under investigation. metab in ground water is an important' since Subtitle D facilities are generally In general all transformations an factor in the extent to which metals sited in similar environments, this dependent upon both the chemical migrate. The Agency is studying die use assumption Is believed to be reasonable. constituent and die prevailing of die M1NTEQ spedation model in This wont-case assumption predicts environmental properties. For order to permit calculating element that no attenuation occurs during the hydrolysis, ground water pH and specific dilution/attentuation factors. migration of constituents In leachates to temperature must be known. The The Agency has not been able to the underlying aquifer. Agency's analysis to date has identified complete these studies yet and The seconaassumption of infinite and more than 20.000 measurements for pH dierefore will continue to employ a semi-infinite flow regions in the and temperature from which distribution standard attenuation factor of 100. Once longitudinal and lateral direction, functions can be assigned for purposes development of die fate and transport respectively, is appropriate for an of evaluating variation and uncertainty. equation approach for die elemental simplified analytical ground water flow Similar data describing microbial species is completed, element specific models. (The term semi-infinite refers to populations, metabotizabie carbon factors will be proposed. the Tact that once a leachate reaches an sources, etc* are not generally available. . The proposed ground water model aquifer, although theoretically it can The Agency believes that given this accounts for most of the major physical disperse in the lateral direction to an limited understanding of the factors - • and chemical processes known to infinite degree, for ail practical purposes Influencing biodegradation and influence movement and transformation then is a point at which further oxidation in the ground water •- of chemicals in simple, homogenous and • dispersion has little effect on the • environment prudence dictates diet isotropic porous media under steady concentration of contaminants within a these processes not be induded in the e-27-M 000334 ENVIRONMENT REPORTER model By including only hydrolysis in minlmhtiag the Isls? identification: of teduded in the Toxicity Characteristic the model die Agency is being • non-hazardous waste as hazardous. docket conservative. Note, however, that EPA is considering The seventh assumption of an infinite the use of both the 80th and the 90th C Tablet ofPropoted Contaminants source represents a worst case. To percentile for this regulation. For non- and Data Uted to Develop Regulatory tBtmf tn^tmH itiT^f*' is protective degrading compounds, the 80th and 90th Level* of homaa haalth and tba environment in percentile* produce dilution/attenuation all possible situations (which do not C-«.—Toxicmr CHARACTER factors of 22 and 10, respectively. . COMTAMMAKTS AMD UVSLS address the total amount of waste The regulatory levels being proposed . disposed), the Agency believes it ia today are based on the 85th cumulative prudent to adopt this conservative lory to** frequency percentile. As indicated • • i/n assumption. previously, this does not necessarily The assumption of dilution of the EPA ia unconcerned about OStl 107.19-1 S.O coBtaaalnant plume by ground water 7440-3S-2 S.O recharge accounts for a process knows wastes which may exceed levels baaed 0008- wo on some higher percentile (e.g* 90 oeis-at 71-43-2 &07 to occur ia the environment Ground . percent). Specific wastes which the 11-44-4 OJ06 water recharge leads to further dilutioa Agency fhifft not to be hazardous using 7440-0-* 1.0 of the'contaminant plume as it moves oofi-a 14.4 the regulatory levels based on the 85th 0.07 downgradient from the facility. EPA percentile, but which could exceed 0.03 that it ia difficult to develop 1.4 se estimates of ground water thresholds based on aoaw higher . 0.07 percentilat and which an determined to S.O recharge for incorporation into a generic pose a hazard to ground water, maybe 10.0 mode. Data is available, however. from 10.0 which rough estimates can be specifically listed by the Agency as iao hazardous wastes under if 261.31 or •4-75-7 V* ' S6-SO-1 4.3 The .assumption of placement of a 10.B 0.40 weQ Ia Ifaa exact position to receiva the 4. Further Information 0.1 concentration of a 1I1-U-2 0.13 represents an absolute worst case. The The Agency has proposed to uee the 72-2D-0 0.003 Agency believes this assumption is . same basic ground water transport 0.001 equation and health effects thresholds . 11S.74.1 0.13 appropriate for use m the model sine* it •74S-4 0.72 ia possible that some* drinking water for use In the Land Disposal Restrictions S7-71-1 4.3 Rule (51 FR 1603), proposed on f anuary .1 8 wells are directly in line with Subtitle D VI &fl land disposal units. 14. 1988. Differences in the equations OOtJ ao» have been introduced for the proposed 743S-V7-6 Tad*re*ta \3. environmental parameters known' to concerning this equation is provided in 9OT affect such* concentrations. For the the preamble section to the proposed M OJO purposes of this regulation, EPA is Land Disposal Restrictions Rule. The 0.14 proposing to use the 85th cumulative reader is referred to that preamble, and TS41-* percentile. EPA believes that using the the reference noted therein, for further •K 85th percentile will provide a reasonable information on the equation and the • balance between the need to identify the data used in running it The computer majority of truly hazardous waste as printouts obtained as a result of running hazardous, while at the same time the equation on the compounds will be

TABLE C-2.—METHODS AND OUAMTTTATION Uurrs TOR TOXM iCONTAMWAMrS

a-27-aa PubUshtd by THE BUREAU OF NATIONAL AFFAIRS. INC., Washington, O.C. 80037 000335 CURRENT DEVELOPMENTS 331

TABU C-2.—METHODS AND QUAHTITATION UMITS ro* To rrcwrnc COMTAI D»<«e»on Ou«nM_.on Wet' WV^V_____L_____f^t IV*l^r*.H______M-WK I t.^ I CO"""*-** . •__ T • »*F' CNoreM-nn* ———————————— ; —— : ——— i ————————————— V MOO/M40 —————— i ————————————————— 0.01 ox CMWotorm ______; _____ *'.. • ______V vao/tno —————. ———————————— 0.01 0.05 •010. 71tO, Tltl —————————————————————— 0.02 0.10 • f>MOl ...... Mio/oim, ,.._. ——————————————— . 0.10 0-K) MO_»_._ ———————————————————————————— __ —————— 3S10/_770, ,,„, ,.,i.,., • 0.10 0.80 *-___ ...... ' J610/I270 ,_. 0.10 0-tt _.*«,.....,„..„..,...... _...... ,.„...,.,....„„. ,.. ,„.,....„_.,._. — , „.__...., •150 ..,..._. OJOOS 0.025 IXMeMMMnnn* — : ————————————————————————————— J610/K70 ,,.,.. ——————— . ————— . ——————— Mto 0.125 M-OfcNoroMroMt ______, ______... ______MlO/ttTO , ,,,, ,„ ... 007$ 0.125 14_f^-t^M»^__l^_iM V 1030/U40 ——————————— , ——————————— , —— OA1 0.05 t.l4keMarawn«-mt ______V M30/KMO ———————————————————————— 001 0.06 y --* ' • i •------Mio/tm ,.,.„.._,. ——— . ————————— OAK 0125 EMM —————————; ——————————————————————————————————— trt«_... —————————————— OXC01 0.0006 \**M**» (»">»_ >>••••-> —————————— ...... • .'. —————————— tow ————————_ , —————————— oxnoi 0.0005 WlO/HTV ,,-..,.,.,,,,. O02S 0.125 —< ^--- — -i -n | ntotm 0-0» 0.125 M10WT70 ,.,., .,...._,._ ———— . —— . —————— . — exes 0.126 Muttnoi —————————————————————— ; ————————————————— 1 —— V tO_0/«MO —————————————————————————— 1X1 . M iMtt ——————————————————————— , ——————————————————— OJW 040 lM_nt ——————————————————————— , ——————————————— •0*0 ———————— - • ———— _ ——— ___ ———— 04XW1 0.0005 Wmury ————————————— _ ———— . —— ; — - ——— ______• *-«?, "»« „- ,„ ,.„ - f ------,r - f y--i 0-02 OMO ————————— : ————————— . OMOS 0-XI2S MMhyWnteMBhd. ______• ______. v •JOSS 0.126 V MM*240 ————————————————— ; —————— 0.01 0.06 35fCy§}7n OJKH 0.126 PMKMB-ptwnai ———————————————————— _ ———————— moiyo 0.01 OJ06 •-•-i - llr- -, ,- .-, ;,- - _.. _ u._^^_ M10/027T i 0.015 0.125 •y-M...... - , 9-»/_9m 1J> 6.0 Btfvnm ————————————————————————————— : —————— MUl -MA TM« ' 0.01 0.05 tii«>r •010.T7W, 77«1. —— . , ..._,.. ... —————————— O01 0.05 1.i.14-T«MeMOQMMn* ______" ______V 0~1 0—6 T «,'_t,?- f«'K"^"tf-»rt ,,,.,„-.,.„.„..„,-,-- - - ..._...... _._ _ • V WlC't?-*1 OA1 0-6 T».r*|. ••-)!. i V fMn/u-<% aoi 0-6 2.3,4.«-T«McNor_ph«nal ———————————————————— , ______3S10/«_70 ...... ,,. , _,„_, ... , ,,..,„-„ 0.10 050 »*»«- ••-,., -.._---,..„„-.,,.,„„•„ V yftp)t%34Q OA1 0.05 TO*-**-*.. ______•NO —————————— _ ————————— . ———————— O.OOS 0025 1.1.1 -ThcWOrOf-Hn* ' - -• ______„ ______V WKKW-f i i • • 0-1 0-5 1,U-Tt_»_3ro-tt_n«______I ______V •MbS-3-a ..._,. 0-1 . «AS •TntfMroi-Vm ______; ______i— L. ______- V WT7TT i^_f*fl 0.01 0.05 • 2.-.5-Tl_Mauph»». ———————————————————————————, ______f«n/«rm 0_6 O_9 2.«.«-Ttfci*.op>»nei —————: ——————————————————— M10/U70 ———————————————————————— ox* o_ts ••»- tr» 4___») . .. • -<«n 04106 .04)25 Ifay-M--*. V MlO-iJ*" 0*1 0.05 1 Tht -v MCMM tit eempow-t to bt »o___t *_t rawM •» «• of •* Z« •Ten MrVwM tar MuMn. SOW W-M n»|^-.7Ch_--!< .Modi Wt- OtMCkon fcn*. to TOP ««»»cl Dtncttai'i *--_ OT OuinMMon »n-» *• MMMd to ft- 6 *m» t» TABU C-3.—CmcwHC Toxcrrr Rl i leva* «» Tc

*jpOflon*A^BMH^MM^MOd f^fHM^i^fa^Hrt *"5S2T fc-w«r fcw-HiHB/"!' • -vymnm-T ,,.,,. „ , , _____ .... .,.,. 0-9Q2(PtSD) ______..___._ — oxnt «->MC ...... : _. OOKOWft «x« bnum...... i_-MMJT>) O.T8 1 j-Oeti-K-oww . ______0-OMMKX) ______0.005 l.l-OcMeroMhyton* ______...... -_• ______; ______aacwtcu ——————————— 0407 2.«4>Mn*-jn...... 0_01 tx_wi. —— 1______0.0002IOWS) ————————————————— 041002 Hiriirniri ;n(tr>itn_«i) ______O.OOOKMSOI. . „.„ . ., „. — .._,..._.._..„ 0.0001 K«__a-ya-«-_*n.. ______BBBft^M-^ 0.0002 HnacMaraboudMfw ______OXKXRSO) ——————————————————— O.OS MeueMetoMhn* _.,..._,.... „...... O.KKSO) ——————— — —————— ^ ———— 0.3 IMMM_...... _._.. «B(IHpJ ... _ ...... 0.74 iase-» « U Lc-d . aostews). O.OS IJ-a-n-.------... ,, , , , „ .... .,„ , - ...... O.OC-MOWS) .0.004 Itarewv ...... __...... 0.002(OWS) 0.002 M**K»r<*-> ----- , • „. , , - 010(P-^) „..._, • 0.1 ItoftMlM- eMat-k. O.KRSO) ,...-..,...... „..._. 0.0 Mr-V -»y kMont... «mo). „.„„,„ , ,. ,...-,. — . OJ 2«l--» 26 03 MNTQtWn_WfM..... — ,. M _,, i ,',,, i,,,,,- •- ,,, 0.02IMDI, —— ... 1JO 240M » 0.004

e-27-B6 Envin 000336 332 ENVIRONMENT REPORTER

TAKE C-3.—Ctnorte Tenocrry Urns FO* Tatar* OwwcttaMvncQonfH#HMm Corftnuea

AMMMM./ •PPOrMMd WMMfl t*_tW w M^MHi IN 4 WHV • tpSSfn* ttN« ««.' D1 100 4.OE-* _s 07» ffHMt ————————— ; ______. 1.40 1.0 •MK0NBI ——————————— : —— i ———— OJO 2 0.03 001 •tar ————————————————————— - - ______0.0$ • 1.M.f-TtncNiMN2ir» —— , ————————— , —— :______0.7 0.02 0007 4X3* 4J9I4 w o.t • T-M«» ———. ————— : ______——————————— :______._. ....,_.._. Ut *J9C-> 10 1.O 0004 1.1.1-TitaMBMhM.r ——__ _ ——————. ______out ±W*Hoi*»m» ______s————— 1 ______,______0.80 0AM Mt &•«-> 10 0.02 tt.01 MOIf-CU ______.———— mi „ mi O.001'

TAIU G-A—OnunoM/ArnMUAHOH FACTOR 'PO* To

O/A KO* «•*

Henna->0» •a >w*k_ 14j» 1010

OM/Hf- 1.-) 14.4 CMgrtt M.4 -4VM/ M.4 CMg 14.4 10C.O mrtf 14.4 tit MMTF 14.4 MNVT 14.4 NHVF. 14.* 14.4 unt NL« WKI ... 14.4 TSO 14.4 MM 144 tr«*M *••*•» 144 14.4 Mt 1/Yr_ >I/W_ 14.4 -I* 0.74 >1/Yr_ >i/vr_ >i/»_ 14.4 tmt 100.0 144 »"»- two <«/•* • 14.4 1JO 144 OJ NtW.. 14.4 1JD MM MM, MBI 144 MO >*^^»_ 14.4 1^0 NHVP——— NHVr. 144 wm wra.. 144 100.0 •Mr.. 100.0 1.M,I-r«*_KMg t.t1 IS/HT ...... „.., tm-nit*,,. 144 *4t •.IffSMft.. mf9 , urn .. .. 14.4 4.JS NH_... 144 To__M a~* MMTT 144 ToMpMn* «uo NH———— 144 rso Lie-MHT... two MO t^o Nira.. «MO——. HtFO. 144 9.W NH—— It'VHI..... 14.4 9.M 144 9.49 NUCQ..— NIK.. 14.4 Vn|**?..g*"l GMM.ti 1.90 If-l/Hr.. 144 _._ • Aetf Un» and n*jtt* n-anDrM '•» • NLF8 -• ' OfyOwVAB-Knabon Factt a-w«d (ra r EMMIMM «•_•. •MHvr - «M H»*o*.i«0- FvnebenM PubU-liod by THE BUREAU OF NATOMAL AFFAIRS, WO., WWhkMjMl, D.C. 20087 00033? CURRENT DEVELOPMENTS 333

TABU C-&—REGULATORY ICMEUKW To CHARACTCmSTtC COMXAMMAMCS

D. Development aad Evaluation of the Energy* i Oak XSdae KatSonal Labors Vxy poteotiat r^r<^**^*>f leachfiu procadoret. TCLP .{CmNL), has eondurted a teseaadi In Phase & additional waste* wen _. program designed to develop MB learhfd and the rfnf*^^ procedures 1. brtfedwction . taoproyed Icartttni lest (he TCLP. Tie ••Antd into the draft TCLP. Dada« this TkiM Section provide* detailed TOP develojtaaeat pjograsa was split op phase «f testing, p»bMc assistance and information an how the TCLP waa into three phases. Phases I and tt and review of the draft wee aotiefted. developed aad «vak»*«»A son part of Phase fll have been conyleled TheoMrali approadi enpiayad ta detailed intonutioe «eaantki^ the TCLP Phase I flonaisied of aa initial data Phaael va«aa foUowK is available in a Background DocameBt gathering effort to which a amber of a. Laiy tcale fteid !j ihuefd with a Jaachata ' nHefl wHn donestic and fctninnetcial (Ref . 33}. derived from fBiuUdfatteftite. The wastes were also extracted with a icfaee and «»e€ te generate a vuoddpal 2. Experimenta! Design variety of laboratory leaching media waste leadiate tMWL). EPA, Hiroujb an Iniarageacy and contact procedure*. Ifase f was b.The MWL wa» used to leadi four agreeaieot % ia die ULS. Deewineat of desigaad ao narrow the uniwaraa of industrial aoUd wastes in large columns.

e-27-ae Envtn ntRcpom 000338 334 ENVIRONMENT REPORTER

c. The leachate concentration oT a describes die results obtained during die deserves attention, primarily because it number of organic and inorganic species first phase of testing (Ref. 6)> Briefly, had profound effect on the way the tint were present in each waste were lysimeter leachate target concentrations TCLP development data was analyzed measured over time. wen established based on both is a review conducted by the Agency's d A total of 34 laboratory leaching practical considerations and die need to Sdence Advisory Board (Ref. 29). .tests were run on the four wastes to npnsent a mid-to-long term leaching At the end of Phase L the assess their accuracy in modeling the Interval or exposure period This was Environmental Engineering Committee ttsults of the lysimeter/column important as die. purpose of die leaching of the Sdence Advisory Board (SAB) experiments. These tests included both test is primarily to evaluate die was asked by EPA to nview and column and batch procedures using font migratory potential of chronically, toxic provide recommendations concerning Jtrefrfog media (La, sodium acetate • organic compounds (Ref. 17). (Use of ' the development program and the buffer, carbonic add, water, and actual chronic toxidty values an discussed in •elected methods. Overall the SAB municipal waste leachate), and four more detail elsewhere in this preamble.) found that the experimental approach media to waste ratios (Le., L5,5,10, and The various laboratory procedures taken reasonably represented an actual 20 to 1). In addition, the EP and • tested wen tiien compared aa to tiieir landfill The SAB did however, question sequential batch leaching procedure ability to reproduce die lysimeter die statistical methodology used to ware also investigated. leachate target concentrations. The evaluate the Phase I data and a. Target Concentrations fTCs), ware absolute value of die percentage recommended that the date be re- established for each constituent based difference for each target concentration/ evaluated using additional statistical osi the lysimeter/column leaching teaching test concentration-pair was analyses. Their primary concerns were corves, by calculating die amount of determined averaged for each leaching the need to provide more resolution in constituent leached over a specific procedure, and dien each procedun was die date through the use of more learning interval (i.e., an amount of ranked from die lowest to highest powerful statistical tests, the need to leachate equal to twenty times the difference and evaluated for indicate the directipn of .the statistical weight of the original industrial solid significance using Duncan's multiple . differences (La* wen individual waste—twenty to one liquid to solid range test These analyses identified laboratory tests generally mon or less ratio). moat of die laboratory procedures as aggressive than lysimeter targets) and i Laboratory leaching test results being equally predictive of lysimeter the need to examine the data for itpared to the TCs, and die two leachate target concentrations, possible compound or dass-related laboratory tests that best replicated particularly when die organics wen lysimeter results were selected for contented trends. further evaluation in Phase tt. No single procedun will be able to S. Results of Phase n - Phase n of the program involved accurately predict leachate ive evaluation and verification of mirations for all compounds in all The SAB comments resulted in the Phaset waste matrices. EPA therefore picked application of a number of additional a. Seven wastes wen leached in the procedures which seemed to moat statistical tests to both the Phase I and essentially die same experimental closely model lysimeter leachate target Phase n data, and the Phases I and II arrangement as used in Phase L concentrations using the absolute value combined data (Ref. 7 and 25). Before ' b. Each waste was subjected to die of the percentage difference; Factors describing the results of these statistical two "best" leaching procedures selected other than avenge percentage analyses, it is important to bear in mind from Phase L as well as die EP. difference, such as ease and expense of that no single leaching procedun will be c. The single procedun which best opention, applicability to both organics able to accurately pndict'leachate satisfied die objectives presented in die and inorganics, and applicability to concentrations for all compounds in all body of this preamble was selected as biological testing, wen also taken into waste matrices. The idea was to select die draft TCLP. : account These factors wen identified in die procedun which most consistently d die dnft TCLP was then circulated the body of the preamble aa objectives modeled die field lysimeters. Another to interested members of industry, for the TCLP. ~ consideration was die need to minimize academia. environmental groups, and On the bails of all these die occurrence of false negative nsults odter with interest and experience considerations, two procedures, similar (Un the situation when the leaching conducting such tests, for comment in concept and operation to the currant test falsely identifies die waste as non- Phase in of die program involved EP, wen selected for further work in • hazardous in tills case die leaching test subjecting die dnft TCLP to an Phase IL Both of these procedures use a would be less aggressive than field evaluation of ruggedneas and precision. 20:1 liquid to solid ratio (t.e« an amount nsults). While it is important to also This work has been partially completed of extraction-fluid equal to twenty times minimize die occurrence of false and die design and nsults to date an the weigth of the solid phase of the positives, EPA believes that minimizing summarized further in this Section. waste) and involve a batch-type false negatives is mon important since Another part of Phase III which is extraction. One procedun uses a 0.1 N die consequences of false negative currently ongoing is a multi-laboratory pH 5 sodium acetate buffer solution as nsults an mon environmentally collaborative evaluation of die draft the extraction medium, and the other serious. In addition, other factors, such TCLP. (The TCLP has evolved to its uses carbon dioxide (COs) saturated as ease and expense of opention, present form in nsponse to both Agency delonized distilled water (Uu. carbonic 'applicability to both organics and activities as well as to comments •dd). inorganics, nproducibility, and received on the circulated drafts.) The • applicability to biological testing (the following sections present the 4. Peer Reviews original objectives in developing the experimental program and the nsults. A number of peer reviews wen •TCLP), wen also considered in selecting conducted at various stages of the TCLP* die most appropriate leaching medium. 3. Results of Phase I development program. The general tone . Table D-l summarizes the results of The ORNL Phase I report explains in of these reviews was always strongly •••• four of the more important statistical detail the experimental approach and positive. One such nview which analyses applied to the data comparing e-27-ae Published by THE BUREAU OF NATIONAL AFFAIRS. INC.. Washington, O.C. 20037 C00339 CURRENT DEVELOPMENTS 335

Iysimeter to laboratory oasuU*. This •hWart nt fetter iadicatea •valuation was table presents comparison* between •fgaifeaaee «1 Ihe 5 percent level sn analysis. three extraction aedia {c*, acetate ~A~*antt.b«iag closest to the lytiweter The aaelyan ef Btecieie*. 3S. C-40-W. O«SO«. MO>NM Phase m of the TCLP development program involves an evaluation of The first test the absolute percent This is most probably a function of the ruggedness and precision as well as a difference, give a crude indication of wastes being extracted in a device multi-laboratory collaborative study. accuracy of each of the methods. which does not prevent loas of volatiles Since the design of these studies, and Looking at Table D-l. the most apparent (i.e^ tosses of volatile organics to the hence the results are a function of how conclusion is that there is~essentially no headspace in the extraction vessel), and EPA addressed some of the operational significant differences among the also a function of the fact that the field aspects of the EP, a discussion of Phase leaching media as to their ability to leachates were analyzed unfiltered 01 follows the next section which duplicate field results. This is especially whereas the laboratory extracts were presents and discusses some of these true for organic compounds. A better analyzed filtered. Higher concentrations procedural problems. means of indicating significant of some organic compounds, especially differences in accuracy is believed to be polyaromatic bydocarbona, were A. Operational Aspects the multivariate analysis, the results of which are also presented. This test observed in the unfiltered extracts. As indicated previously, in moving indicates that the acetate buffer For inorganics, the actual percent from the EP to the TCLP protocol, the extraction is significantly more accurate differences test did produce some Agency hoped to improve the test than the other media. In carrying out the negative values, indicating that some of procedure and eliminate some steps in multivariate analysis, the results for the leaching media tested were more the EP procedure which have caused organics and inorganics were not aggressive towards inorganics than the difficulty for analysts. These indude the examined spearately. Iysimeter field model In Phase L this need for continual pH adjustment, which The actual percent difference, while was true for all three leaching media. In is time consuming and serves as a also giving an estimate of accuracy, can Phase IL however, this was only true for source of impredsion, and the difficulty be used to estimate the aggressiveness 'the acetate buffer and EP leaching in performing the initial and final liquid/ of the leaching media relative to the media. Hence, in Phase H, the carbonic solid separations, which currently field results. A negative vahie indicates add leaching media was generally less involves 0.45 jun pressure filtration. In that the extraction is more aggressive aggressive towards inorganics than the addition, the need to. adequately prevent than the iysimeter field model. Looking Iysimeter field model (Refs. 7 and 25). volatilization of organic compounds at Table D-l. once again there are few Although the Phase I data indicated during extraction was critical. These significant differences among the that the-carbonic add leaching medium three aspects of the test procedure are teaching media as to their ability to most closely approximated the Iysimeter discussed below. As an aid. Table D-2 extract organic compounds. All the results {Ref. 6). when the Phase D data presents a comparison between the EP values for the organics comparisons are were taken'into account, the sodium and the TCLP," in terms of procedural positive values, indicating that the acetate buffer leaching medium seemed aspects. Figures D-l and D-2 present laboratory tests are generally less to be the most appropriate (Refs. 7 and the flow diagrams for each procedure, aggressive than the Iysimeter model. 25). Given the most weight in this respectively.

t-zr-ae Environment Reports* 000340 336 ENVIRONMENT REPORTER

TABLE D-i—COMPARISON OF THE EXTRAC- TABLE 0-8.—COMPARISON OF THE EXTRAC- TABLE O-2.—COMPARISON OF THE EXTRAC- TION PROCEDURE (EP) AND THE Towcmr TWN PROCEDURE (EP) AND. THE Toxicmr TON PROCEDURE (EP) AND THE Toxtcmr CHARACTERISTIC LEACHMQ- PROCEDURE CHARACTERtmc LEACHINQ PROCEDURE CHARACTERISTIC LEACHING PROCEDURE (TCLP)» .(TCLPJ'-ConttmMd (TCXP) «-Continoa

TCU» TCU> TOP

04 N 0.1 pH tl wMe M ManeMMe UMaiS»uekm Mhaura. tthan. •eU tekMan tar' ' M^% . 9*1. i PMMdmar *m0wf^^^^•^w Pmcwknfol i at (H 4.» .»*«»iW. tMnkpv . On* Btx*

CantMti CBUWM/MU • SO (Mi *"" __, _ _^ •ndMtanM (MPDWS) •»•. ttw fcu»"ein

Fiqux* >2: extraction Proetdur* Flowchart 000341 e-27-ae Pubikstttd by THE BUREAU OF NATIONAI. AFFAIRS. INC., Washington. D.C. 20037 CURRENT DEVELOPMENTS 337

FIGURE D-2: TCLP flowchart

MET WASTE SAMPLE • MET WASTE SAMPLE CONTAINS < 0.5 % REPRESENTATIVE WASTE CONTAINS > 0.5 % NUN-FILTERABLE SAMPLE NON-FILTERABLE SOLIDS SOLIDS I I -CRY HASTE SAMPLE LIQUID/SOLID SOLID SEPARATION 0.6-0.€ urn LIQUID/SOLID GLASS FIBER SEPARATION -FILTERS 0.6-0.8 urn DISCARD GLASS FIBER SOLID SOLID I FILTERS LIQUID STORE AT 4«C

REDUCE PARTICLE SIZE IF >9.5 on OH SURFACE AREA <3.1 on2

I TCLP EXTRACTION1 CF SOLID. § O^EADSPACT^CrRACrOR REQUIRED FOR VOLVTILES

I LIQUID/SOLID SEPARATION DISCARD 0.6-4.8 urn GLASS SOLID FIBER FILTERS

1 ' LIQUID

TCLP EXTRACT I I TCLP EXTRACT ANALYTICAL ---TCLP EXTRACT --- METHOCB

1 The extraction fluid employed is a function of the alkalinity of the solid phase of the waste. t MUJNOCOOC i

Environment Rtpotttf 00342 ENVIRONMENT REPORTER

TheEP procedure involves continual developed in response to bans instituted pH adjustment or titration. The on the disposal of liquids in landfills. procedure calls for periodic pH IB applying this method to the TCLP, 'adjustments if necessary, at IS minute however, 9 number of problems were intervals for up to 6 hours or more. This encountered (Ref. 3). The most serious of la very tedious, time consuming and these was the fact that particulates, ' expensive, and is also probably the which are solids, are capable of passing single moat important element in the EP through the paint filter in bulk. Using protocol contributing to variability. Method 9095 in the TCLP, would lead to Using pit-defined leaching media these solids being considered as a eliminates the problem of pH adjustment liquid, and thus, not subject to since such media does not require pH extraction. This could lead to an adjustment during extraction. artificially high (or low) apparent The initial liquid/solid separation ' extract concentration: In addition, the problems are due to the tendency for •mount of liquid the method yields some materials, such as certain types of varies with how the waste is poured or oihjr wastes, to dog the 0.45 urn filter, placed in the filter. These two problems and prevent filtration even if negated the UM of Method 9095 In the considerable pressure (75 psi) is applied. TOJP. This problem is serious, since materials To overcome the problems which do not pass the 0.45 um filter are encountered with the paint filter treated as solids even if they physically method. EPA has returned to die use of appear tp be a liquid. These (liquid) pressure filtration to separate the liquid waates are then carried through EP from the solid phase of a waste. In extraction as a solid. reevaluating this technique, however, This is particularly serious for oily several changes have been made which wastes, since oils have been known to win decrease the time it takes to . frequently migrate to ground waters. It accomplish separation. Improve the is important for the luquid/solid • precision of the method, and provide a * separation to treat, as liquids, those more adequate differentiation between materials which' can behave as liquids in those materials which behave as liquids .the environment It is important to In the environment, and those which recognize, however, that some materials, behave as solids. These changes include such as many paint wastes and some •witching from a 0.45 um filter medium oily wastes, white they have some liquid of varying composition, to specifying a properties, they will generally behave as Q£-0.8 um glass fiber filter, as weir as . solids in the environment (Le* will not limiting the time spent filtering. The use migrate in total). of glass fiber will reduce the possibility In addition, since different analysts, of adsorption of analytes to the filter may expend varying degrees of effort in media. Also, these filters have a much accomplishing the liquid/solid higher throughput and show much less separation with these waste types, this tendency to clog, and for these reasons. problem also contributes to variability. •How the use of a pressure of SO psi As indicated below. EPA believes that rather than 78 psi to accomplish the liquid/solid separation technique separation. Initial experiments Indicate that has been developed for the TCLP substantial operational advantages and protocol reduces the variability that was time savings with the use of glass fiber associated with the EFs liquid/solid filters (Ref. 4). separation technique, and that it also The third problem deals with the need provides a more adequate to prevent loss of volatile organic differentiation between those materials compounds during the conduct of the that behave as liquids in the procedure. This includes losses during environment, and those materials which initial and final liquid/solid separation, behave as solids. extraction, and sample handling. With Initially, it was felt that this problem the assistance of laboratory equipment could be addressed through use of the manufacturers, EPA has addressed this much simplier liquid/solid separation problem through development of a Zero- technique used in RCRA Test Method Headspace Extractor (ZHE). After 9095 (Paint Filter Free Liquid Test) (Ref. experimentation with several prototype 27). This method involves gravity devices, the device described filtration through a 80 mesh paint filter. schematically in Figure D-3 has been This test method was promulgated on successfully applied during evaluation April 30,1985 (50 FR18370). It is of the TCLP procedure. Equipment of intended to be a qualitative this type is now available from two , ; Determination of whether a waste suppliers (See TCLP in the proposed contains any free liquids, and was Appendix D to Part 261).

•-27-w PuMislWd by THE BUREAU OF NATIONAL AFFAIRS. INC., Washington. O.C. 20037 CO 0343 CURRENT DEVELOPMENTS 339

Liquid Inlet/Outlet valve example, in transferring samples from : container to filtration apparatus to extractor, etc. the procedure cails for . i i : determining the weight of any residual Top flange sample material left behind and "~r 11 te r~—--—--•—.-3 subtracting this from the total sample size, this will insure that the amount of extracting medium added to the extractor is truly a function of the solid material within the extractor, and will help to improve overall precision.

7. Results of Phase HI f Phase HI of the TCLP development program involved an evaluation of mggedoesB and precision as well as a •ody muUUaboratory collaborative study. The. experimental design and a summary of the results of the precision evaluations are presented below. While the ruggedness evaluation for the metals • Vaste/Cxtiactton Fluid ana semivoIatUe* have been completed the work on the volatile* portion of the method is in progress. The results of the ruggedness evaluation for the volatiles wulbe noticed for comment upon completion. • . , : EPA's collaborative study is currently c on-going- in addition, the Electric Power Research Institute (EPRI) has conducted a limited collaborative evaluation of the draft TCLP protocol primarily as it appies to inorganic constituents. The report on this study is being drafted The. Fteeauristnq Gas Inlet/Outlet Valve results of both of these studies will be noticed for comment when completed. a Ave&ibn evaluation. As discussed earlier, the TCLP protocol requires the use of a Zero-Headtpace Extractor figure D-3> leio-Heaiaeaee Extt action Veaael. (ZrlE) when dealing with volatiles, and the use of common EP extraction equipmanmt (i-e.. bottles] when dealing^- with non-volatile components. In response. EPA has conducted a . The ZHE is capable of conducting the rated was necessary. Balancing the need precision evaluation of the TCLP initial liquid/solid separation, agitation. to also accommodate as iarge • sample protocol using both devices. These • as well at final extract filtration, with evaluations were conducted fay two •. size as possible, EPA determined that • laboratories, each laboratory conducting only minima! lofts of volatiles. Although device with one-half liter (800 ml) a number of replicate extractions on two considerably more expensive than the internal volume would be more wastes. These wastes were an API bottles used in the curre.ni EP, these • . •appropriate. Due to the 800 ml internal separator sludge/electroplating waste. devices are only required when capacity, the ZHE can coaly admixture containing nonvolatile investigating the teachability of volatile accommodate, a maximum sample sixe organics and a variety of inorganics, and components. Less expensive vessels an of 25 grama fora 100 percent solids an ammonia still lime sludge containing used for assessing the mobility of non- sample. For a waste of less than 100 • variety of polycycUc aromatic volatile components. In addition, since percent solids, the maximum sample hydrocarbons, and several inorganic the 2! IE is capable of also conducting size the 23 IE can accommodate is tied to compounds. These wastes wart also die liquid/solid separation, no the percent solids of the waste. The . •piked with several volatile compounds. additional filtration apparatus is device can only accommodate the The results of the precision evaluation required. minimal 100 gram sample size specified for non-volatile components indicate $» Due to the need to have the-ZHE for bottle extractions for wastes that are TCLP to be of acceptable precision (Ref. compatible with common laboratory 25 percent solids or less. 23). For the most part, the percent equipment, such as off-gassing ovens, In addition to the major improvements coefficient of variation between and laboratory sinks, and also the need "discussed above, EPA has instituted a replicate extractions for individual to produce a device that is easily number of minor improvements in the constituents was less than 30 percent. handled by laboratory personnel, a TCLP protocol. These improvements are This includes the variability contributed device smaller than the 2 liter internal primarily designed to increase the by sampling variability and analytical volume device EPA originally had in overall precision of the method. For variability. Although sampling

*-2T-ae BrMrenmam Hapcm CD0344 340 ENVIRONMENT REPORTER variability' was minimized to'the extent the use of aiMight syringee* TEDLAR* w&tiM' the' proposal draft of the TCLP. potsibte, M Ik reasonable to expect a bags due to expected losses of volatile* which we believe should help to clear •ample variability contribution to the from the VOA vials during collection of tip some of the problems encountered total variability of between 2 and S the extract VOA vials were used to during the first evaluation. This study percent Analytical variability was in collect the extract daring the precision wttTbe similar to the previous one in many cases'comparable to, and in some evaluation of the volatiles. most other aspects, except that a third cases exceeded, the total variability. AUoijn following the protocols, . waste will be evaluated (one expected This observation'is significant as the Inadvertent errors were apparently to not react with the spiked voiatiies), analytical method* used to analyze the made which seem to have affected and two levels of volatile spike will be TCLP extracts are well accepted and to method precision. For example, whereas used (La* .one of relatively high widespread vtUr • the October 1965 version of the protocol concentration and one of relatively low Precision lor the non-votatiles was placed a ""«H'"n of 25 grams on the concentration). The result* of mis observed to be best far those amount of solid material the ZHB could •valuation will be noticed for comment contaainaata present at relatively high accommodate, considerably more solid upon its completion. levels, as la (be. MM! case in any material was extracted during the analysis for ewthod precision. For those precision analysis of one of the wastes 6. Ruggednen evaluation. A caset where the contaminant was tatted (Un the API separator sludge/ roggednes* evaluation Is designed to present at relatively tow concentrations, electroplating waste admixture). This determine how sensitive a test method precision was pair, the percent provided for a variable liquid to aoHd to with respect to'modest departures . coefficient of variation generally falling ratio rather than the specified 20 to 1 from the protocol which can be expected below 50 and 60 percent ratio. . . during routine app&eatfons of the The results of the precision * To complicate matters further, daajo. ,. tocoLThe purpoee of this evaluation •valuations for the volatile component* extenuating circumstances, two • • Ka identify procedural variables which (Ret 9J are not as clearly interpreted. individual laboratories conducted the must be carefuOy controlled, and then to There are several reasons for" mis. These worit rather than the intended single ' emphasize in the protocol the limits of evaluations were initiated as the aero- laboratory. It ia apparent that higher acceptable deviation with respect to headspace extractor became available. concentrations wen obtained on the . these variables. If a procedure is Recall that the present design for the same waste from the different .'"ragged" it wiQ be unaffected by minor ZliE was the result of experimentation . labomtories. • • departures from the specified method with several prototype devices. Hence, As indicated above, these factors values. If results are affected by experience with the ZHE. especially by make the precision data difficult to ~ variation of conditions, the protocol laboratory technicians who were . interpret Whereas the percent mutt be written to specify those responsible for conducting the work was coefficient of variations oa the parameters which must not be varied limited. •till lime sludge were mostly leas than . beyond a determined amount' In addition, the precision work on the 60 or 70 percent, which ia fair given the • As with the precision evaluation, volatile! was conducted using two draft nature of volatile*, the numbers ruggedness was evaluated for bom the TOP protocols. The first public draft generated from the admixture of API ZHE and common EP extractor bottles. protocol was released for comment tn separator sludge and electroplating Different tots of the same wastes used April of 1985. At this time EPA was still waste indicated more variability. As for the precision evaluations were used experimenting with several prototype indicated in the draft report (Ret 9L for the ruggedness evaluation. These devices, and although the April TCLP some of this can be attributed to severe evaluations were performed by one draft addressed volatile components, it laboratory contamination problems, and laboratory. Whereas the ruggedness was largely to obtain technical the oily character of the waste, which evaluation for the common EP extractor comments and suggestions and was not seemed to have dominated the bottles has been completed (Ret 4aJ, the based oh an actual working ZHE device. extraction. ZHE evaluation 1s still in progress. It was this protocol under which the Due to the inconclusive oaten of the Table D-3 presents the parameters TCLP precision evaluation of the resell*. EPA is in the process of . , which were evaluated for ruggednesa volaliles was begun. conducting another precision evaluation using both types of extraction The second public draft of the TCLP of the volatile components. This study equipment protocol was released for comment in October of 1985. Although this draft was TMU D-&—AWWMCTER* tNVCSnOAUD DUMNO TCLP RUQGEDNEM EVALUATION based on the current design for the ZHE. further experience with the device has Comnwn led EPA to re-write the TCLP volatiles TCUM procedure in the form that it currently (DUquM/SeMMto- tS»*1. tttoti. appears (see TCLP in the proposed (8 w~_ ISIOiO. Appendix U to Part 261). In addition, it is PI* ZHE.. z«». possible that further clarification* in the •own—— procedure may be advisable. HI M*dum ft e>»so_. The remainder of the precision evaluation for the volatiles was t» UKfcm f * conducted using the October. 1985 draft « AliguMt TCLP. Several significant changes have TOP). been made in the current (proposed) mtrtl (Sw fan. Soro»*eic« ftnt version due to experience gained with .• the device. For example, wherens the <« AC«J October 1985 version allowed the use of VOA vials for the collection of the TCLP ZHf dun* ( » 10.. 010 »._- extract, the proposed method requires •on (pal

«-27-«8 Publirtwd by THE BUREAU OF NATIONAL AFFAIRS. INC., Washington. O.C. 20037 000345 CURRENT DEVELOPMENTS 341

TABLE D-3.—PARAMETERS INVESTIGATED DUWNO TCLP RUQQEONESS EVALUATION—Continued . (3) Energy Resource* Company (ERCO). EP-H1 Preliminary Study. U.S. EPA Contract tCLP M-01-6487. September. 1984. • (4) Energy Resource* Company (ERCO). Filtration of Various Waste* U*ing Variou* 111) ZHE «*Mt ( •RUMP hegerejring*—— Filter Media. U.S. EPA Contract 68-01-7075. April. 1965. (4a) Energy Resource* Company (ERCO). There were several parameters which during agitation is being investigated to Evaluation of Bottle TCLP Draft Protocol. EPA intended to investigate (to* determine whether the build-up of Draft Final Report U.S. EPA Contract 68-01- extraction temperature and agitation pressure within the ZHE during agitation 9075. February 21.1966. rate), which could not be accommodated (which is expected to occur for some (5) Environ Corporation. Superfund Riik due to lack of appropriate laboratory wastes, particularly carbonate Evaluation Model—Draft prepared under US. containing waste), needs to be EPA Contract November 17.1963. equipment necessary to vary these (6) Franda, CW. et al Mobility of Toxic parameters. In addition, while EPA had controlled more carefully. The build-up Compound* From Hazardous Wastes. originally intended to evaluate the of this pressure could cause the ZHE National Technical Information Service effect* of different glass fiber filters (See piston to move, thereby causing the (NTIS) PB 85-117-034. Springfield. Virginia. Table D-3. Item 9), glass fiber filters presence of headspace. The ruggedness Auguat 1964. other than the type specified in the evaluation would indicate if this (7) Francis, CW, and M. Maskarinec. Field TCLP protocol were unable to withstand variable should be controlled more and Laboratory Studie* in Support of a the pressures stipulated in the TCLP. carefully, perhaps by putting more Hazardous Waste Extraction Text Oak Ridge Hence, the EFs use of polycarbonate pressure (e.g., 2O psi} behind the piston National Laboratory Report No. 6247. filters were investigated instead. EPA during agitation. : February, 1966. has already determined that extract As indicated above, the results of the (8) Francis, CW. and M. Ma*karinec. concentrations may differ slightly volatiles ruggedness evaluation will be Leaching of Metal* From Alkaline Waste* by between the two filter types (Ref. 4 and noticed for comment upon completion. Municipal Watte Laachate. Oak Ridge 7). The remainder of the Table D-3. c. Collaborative study. As indicated National Laboratory. Draft Report. January. parameters are largely self-explanatory. •artier, both EPA and Electric Power 1966. Research Institute (EPRI) have planned (9) Francis, CW. and M. Mukarinec. The ruggedness evaluation for the Predcion Analytic for the Zero-Head common (EP) extraction equipment collaborative evaluations of the TCLP Extractor. Draft Report Oak Ridge National demonstrated that for the most part, the protocol EPA's evaluation, in whic h; the Laboratory. lanuary. 1966. TCLP if fairly rugged (Ref. 4a). This is American Society of Testing and (10) Hannack, P. Letter from P. HaoMck, especially true for the semi-volatile Materials, a number of business Canada Ministry of the Environment Alberta organics. which, with few exceptions, associations and individual companies, Research Center, to T.A. Kimraeu. U.S. EPA, were unaffected by the parameters . the Department of Energy, and Method* and Studies Branch Ret TCLP. investigated. For metals, the results Environment Canada's Environmental October 28,1965. suggest that at least two parameters are Research Center are participating, is (11) Harberger. A. C Three Basic critical. As expected, the acidity of the currently ongoing. This study involves Postulate* of Applied Welfare Economics: An extracting fluid directly influences the 26 laboratories, five different wastes, Interpretive Eatay. Journal of Economic both types of extraction equipment «nd Literature. 9(3):785-797.1971. extraction of metals. The TCLP protocol (12) Hicks, |. The Foundations of WeL'are emphasizes accuracy in the preparation organic and inorganic compounds, Economics. The Economic Journal. 49496- of the extraction fluids, by specifying including volatiles. 712. December, 1939. the exact recipes for the preparation of EPRI's study, which is very similar to (13) International Agency for Research on these fluids, and indicating that the pH •n evaluation EPRI conducted on the EP Cancer (1ARQ. IARC Monographs on the of these fluids should be accurate to (Ref. 2), was limited to the Evaluation of the Cardaogenic Risk of within ± 0.05 pH units. determination of inorganic compounds Chemical* to Humans, Supplement 4. Lyon, Bottle type (i.e.. borosilicate vs flint and deals with common extraction France. 198Z glass) is the second parameter which equipment only. This study deals with (14) JRB AModates, Survey of Industrial apparently affects the concentration of . •even types of utility wastes and Waste Landfill*. VS. EPA Contract 64MB- metals in the extract and may also involves three laboratories. In addition S113. June, 1965. effect (to a lesser degree), the extraction to total precision. EPRI is investigating (15) lust Ri. DA. Heath, and A. Schmitz. of semi-volatiles. It appears that using the contribution of both variability in Applied Welfare Economics sod Public flint glass can result in significantly sampling, and variability introduced Policy. Prentice-Hall. Englewood Cliff*. N«w through analytical methods, as was Jersey. 1982. higher extract concentrations. While (16) Kaldor N. Welfare Proposition* of acid washing the flint glass bottles, or done during the investigation of the EP Economics and Interpersonal Comparisons of an expanded use of blanks, may help to pro-local. Utility. The Economic Journal 49:549-552. solve the problem, specifying Both studies will be noticed for 1939. borosilicate over flint glass would solve comment when completed. (17) KimmelL T.A. and D. Friedman. Model the problem entirely. Due to the IXRefaraBOM AuumptioR* and Rationale Behind The substantially higher cost of the (1) American Society for Testing and Development'of EP-DL Presented at the borosilicate glass (from 3 to 5 times Materials (ASTM). Committee D-34 Draft American Society for Testing and Material* higher), EPA is reguesting comment on Method. Method For 24-Hour Batch-Type (ASTM) Fourth Sympotium for Hazardous this option. Distribution Ratio For Contaminant Sorptton and Indiutria! Solid Wa*te Teiting. IB Press. The volatile* evaluation for the TCLP on Soil* and Sediments. ASTM D34.02- Washington D.C 1964. 022RO. Philadelphia, Pennsylvania. 1965. (18) Lehman. A.J. and O J. Fitzhugh One is currently ongoing. As noted above, (2) Electric Power Research Institute Hundredfold Margin of Safety. Awoeiation of the Table D-3 parameters were (EPRI). Proposed RCRA Extraction Procedure: Food and Drug Officer*, U.S. Quarterly. investigated to determine if they need to Reprodudbility and Sensitivity. Bulletin. Volume 18.1954. be controlled more carefully. As an Environmental A**e*sment Department. Palo (10) McKown et al. Development of example, pressurization of the ZHE Alto. California. November t, 1979. Methodology for the Evaluation of Solid

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Wests*. Velum L BPACoatmet 08-08-2982. Dated: May 31.1988. TASKS 1^—Tomorrv CMARACTCTISTIC Cow- La* M. Thomas. TAMINANT8 AND REGULATORY LEVELS—Co* (BO) National Research Council (NRCJ. Admuiittntor. tlnuad Drinking Water and Health. VoL 4. Sat* Drinking Water Committee. National For the reasons set out in the AroAimy fees*. Washington. D.C. 1982. preamble, tt is proposed to amend Title (mo/1) (21) Office 'of Management and Budget 40 of the Code of Federal Regulations as (0MB). Intarim Regulatory Impact Analysis follows: 0.72 CasJance. Waahlngton XXC. June. 1981. 4.3 SO £2) Research Triangle Institute {RTT). PART »t-4D€NTinCATK>N AND M Regulatory Impact Analysis for Expansion of UST1NG OF HAZARDOUS WASTE •00 Itadctty Characteristic Under RCRA. US. 7430-97-6 •2 1. The authoritMrity dtation far Part 281 OOH 71-49.3 1.4 BPA Contract 88-01-7075. October. 1985. 0.0 (83) S-Cubed. Precision Evaluation of the continues to read •8 follow*: T.2 TOP Protocol For Non-Volatile Components. 00*1- •13 Authority: Sacs. 1008, 2002(a). 300L and S7-00-S U Draft Report US. EPA Contract 8*43-1958. 30tt of the Solid Waste Disposal Act as ' 14.4 ameodad by the Re rce Conser ti 1W40-1 M (M) Speflenberg, SJ». Orgaaic Extraction Recovery Act of 1978. as amended (42 U&C. 77at-40-2 1.O 0011 KMr- 7440-22-4 tfl Pracedura. VS. EPA Contract 88-«l-«49. 8905.8912(a}.8B21. and 8822). O04»-1.1.t»T« 10.0 1.3 129) Technology Applications Inc. (TAI). 2.1261454 is revised to read a* C047- T« 1S7-10-* •1 Statistical Analysis of TOP Development followst U •TohMM- 40040-3 14.4 Data. US. EPA Contract 88-01-8938. May 28. 0014-To S091-3S-2 0.07 -1.1.1-TlM* 7f-«S-0 99 (a) A solid waste exhibits the 005t-1.t>Trt*to 70-00-5 1.2 (28) US. EPA. Background Document DOS8-T Regulatory Impact Analysis. Washington. •dunfTCLP) P.C. December, 1983. waste contains less than OS percent (29) US. EPA Science Advisory Board filterable solids, the waste itselt after to cop* (SAB). Report on the Review of HP-ID. filtering using the methodology outlined 1.1 IteTCLFto designed to deterniae the in Appendix 11. is considered to be th* ^mobility of both aganic and inorganic Washington, D.C. May. 1984. contaminants present in llqaid. solid, and (90) US. EPA.. Background 1 extract for th* purpose of this section. mulHphestc wastes. Issues Relating to the Development and Use (b) A solid wast* that exhibits the U Ifatotalanaiyaloofthewaste of Reference Doses to Support 40 CFR Part characteristic of toxidtjr, but is not demonstrates mat Individual contaminants . Land DtaMMl Restrictions. Washington. listed es a hazardous waste in Subpart are not present in the waste, or that they are DL& November. 1985. D. has the EPA Hazardous Waste present but at such low concentrations that (31) US. ERA. Acceptable Daily Intake Number specified in Table 1 which the appropriate regulatory thresholds oadd Workgroup Paper; Assessing Risks corresponds to the toxic contaminant not possibly be exceeded, the TCLK.need not Associated With Systemic Toxicants. uusing it to be hazardous. be not. Washington. D.C. 1985. XO Summary ofmtthod (See Figure 1 J. OK) US. EPA. Verified Reference Doaea TABU 1.—Toxcrrv ChAMcrERttnc 2.1 Fbr wastes containing lass than OS% (ROTa) of the US. EPA. Washington. D.C. CONTAMMANTS AND RCOULATOMV L8VBU8 solids, the waste, after filtration through a (33) US EPA. Background Document For 0.8-0.8 |un glass fiber filter, is defined as the Toxteity Characteristic Leaching Procedure. TCLP extract *»*/«) U For wastes containing greater than Washington, 041 February. 1966. 04% solids, the Kqaid phase, if any. is OOtS-AtHto to7-ta»t Ust of Subjects in « CFR Parts 2*1,271, 8-0 separated from the eolkt phase and stored for ooos- 100 later analysis. The particle size of the solid e*7 phase is reduced (if necessary), weighed, and Administrative practice and one. •OS extracted with en amount of extraction fluid procedure. Air pollution control, uw* 7S-1S4 equal to 20 times the weight of the solid Chemicals, Confidential botinms 9S-JM •AT phase. The extraction fluid employed is a ona cmm tr-r*< •as information. Hazardous materials. 0024-CN tce-eo-T i.« function of the alkalinity of the solid phase of Hazardous materials transportation. •07 the waste. A special extractor vessel is used OOQ7.-C* tna-et-o 10 when testing for volatiles (See Table 1). Hazardous substances. Hazardous owe- .r ie.o waste, Indian lands, Intergovernmental 00271 tOiO Following extraction, the liquid extract is relations. Natural resources. Nuclear too separated from the solid phase by 0.8-04 too materials. Penalties, Pesticides and •4.78-T 1.4 glass fiber Alter filtration. -1 o 2£ If compatible (e.g. precipitate or pests. Radioactive materials. Recycling, -7 «0« Reporting and recordkeeping 107-OS-J 0.40 ' • multiple phases win not form on 0032—1.1 -CcN«oi»w 0.1 combination), the initial liquid phase of the requirements. Superfund, Water «.ts ya*te Is added to the liquid extract and these pollution control. Water supply. Waste 0.00* 34-MKMeNor •001 liquids are analyzed together. If incompatible. treatment and disposal. 1IS-74-1 • 13 the liquids are analyzed separately and the

8-27-88 Published by THE BUREAU OF NATIONAL AFFAIRS, INC., Washington, O.C. 20037 000347 CURRENT DEVELOPMENTS 343

sssult* ere mathematically combined to yield leech or absorb waste components. Class. made up accurately, and these ftuidt thouid volume weighted average concentration. . • polvtetMfluoroethyUne (PTFE). or type 31* be monitored frequently for impurities. • 34 Interference*, * skinless steel equipment may be used when fcT Analytic*! standards sheH be 3.1 Potential interferences that may be evaluaWng the mobility of both organic and prepared according to the appropriate C encountered during analytit are discussed la Inorganic components. Device* mad*, of high •nahyttcal method. the individual analytical method*. density polyethylene (HOPE), polypropylene, &0 Santpte Collection, pntervotion. and 44 Apparotut and mottriolt: . ', or polyvinyl chloride may be used when 4.1 Agitation Apparatus: An acceptable * evaluating the mobility of metal*. handling. agitation apparatus it one which to capable 4.4 Fillers: Filters shall be made of ft.1 AH sample* shall be collecled uting a of rotating the extraction vessel in an end- • boreetBcate glaas fiber, contain no binder sampling plan that addrestet the over-end fashion (See Figure 2) at 30±2 rpm •ttisrielt, *nd nave an effective pore tize of consideration ditcutted in "Test Method* for Salable devices known to EPA are identified 04-04 nm. or equivalent Filters known to Evaluating Solid Wastes" (SW-*46). in Tablet BPA to ntel the** specifications ere • U Preservatives ahatl aot be added to 44 .Extraction vetsec Identified m Table «. Pre-filters most not be aamplee. 44.1 Zero-Headspece Extraction Vessel osed When evaluating the mobility of metato. •J Samptet can be refrigerated untet* tt (ZHE). When the waste to « being tested for fitters shall be add washed prior to vte by ratultt m irreversible physical changes to the mobility of any volatile contaminants (See «i««JnfJ^14Nn^c_acidfoDowedby Table 1). an extraction vessel which allowt three coneecutive rinses with detonixed e.4 When the waste to to be evaluated for tor liquid/solid separation within the device. dtotilled water (minimum of 800 sal par rinse). volatile contaminant*, care must be token to and which effectively precludes beadspace Class fiber filters are fragile and abovld bo insure Oat these are not lost Sample* shall to depicted* Figure 3). to seed. This type of handled with oats. be taken end ttored In a manner which vessel allows for initial Uquid/sobd . 44 pH Meters: Any of in* oommonly prevents the loss of volatile contaminant*. If separation, extraction, and final extract •vaOabiepH meter* are acceptable. • potaibte. any necessary particle site filtration without having to open the vessel 44 ZHE extract eoBectiw device* (See Section 4JLl) .Tbeee vessels snail have reduction should be conducted as the sample an internal volumer of m to 000 ad and be TEDlAR*bagsorgtes*,statolsssetaetcf to being taken (See Step U). Refer to SW-e48 equipped to accommodate a SO mat Uter. fTFE gss tight syringe* are used to ooQect the far additional sampling and storage Suitable ZHE devices known to EPA are initial IfoukTphaaa and the final extract of the requirementt when volatile* are identified to Table 3. These devicet contain waste when using the ZHB device. viton Curings which should be replaced '•J TCU extrwRa should be prepared for devices: Any device capable of transferring •nalyslt and analysed at toon at possible frequently; . the extraction Ovid into (neZKE without 442 When the watte to being evaluated fallowing extraction. If they need to be changing the nature of the extraction fluid to stored, even for a short period of .time. far other than volatile contaminant*, an acceptable (t^, a constant displacement attraction vessel which does not preduds- Storage shall be at 4*C and samples for' beadtpece (*4~ 2-liter bottle) to used. • • pump, a gat tight syrtefs. praasurt nitration volatile* analysis shall not be allowed to Suitable extraction vessels include bottle* •nit (See Section 444). or another ZHE come into contact with the atmosphere (U, axade fraa various materiel*, depending on • device). •o headtpace). ' ' the contaminants to be analysed and the '44 laboratory balance; Any teboratory 74 Procedure when votatfla or* not nature of the watte (See Section 444V Tbete Wane* accurate to within ±041 gram* may imnMd. bottle* are avaiiabte from a number of . be used (*H weight measurements are to be '.' Although a minimum sample stee of 100 t laboratory supplier*. When this type of . within ±0.1 gram*). gram* is required, a larger sample size may extraction vessel it used, the filtration device It Waier.ASTMTy|»IdetoBited. be .necessary* depending on the percent • discussed to Section 444 to used lor initial carbon treated, decarbooisod, filtered water •olid* of die waste sample. Enough watte ^quid-solid separation and final extract (or equivalent water that it treated to remove •ample should be collected such that at least filtration.. volatile components) thai! be need whan 75 grams of the solid phase of the waste (aa 44 FtttMtion device*: evaluating watte* for volatile contammaatt. determined using glass fiber filter nitration), .44.1 Zero-Headspace Extractor Vessel OtberwitfcASTM Type Idetoniied dttttlled ia extracted. Thia will insure that mare is {See Figure'3k When the waste Is being water (or equivalent) ia need. Tbete water* adequate extract for the required analyses evaluated for volatile*, the sero-baadepeee abovld be monitored periodically lor (04* semhrolatilea. mete!*, pesticide* and extraction vessel is used for filtration. The tapuribea. • • berblckfetlC device sbsll be capable of supporting and 11 1X>N Hydrochloric add (Ha) made The determination of which extraction fluid keeping in place the glass fiber filter, end be from ACS Reagent grade. •. to use (See Step 7.12) may also be conducted •Me to withstand the pressure needed to U J*N Nitric acid (HNCW made from at the start of thlt procedure. This accomplish separation (50 psi). ACS Reagent grade. determination shall be on the solid phase of Mote. When it to tutpected that the glass M WNSodhnn hydroxide (NaOf) made the waste (as obtained using glass fiber filter fiber filter hat been ruptured, an fa-tine glass filtration). '• • • fiber filter may be used to filter the extract 48 Cladal acetic add (HOAc) made I 74 If the watte win obviously yield no 444 Filler Holder. When the waste to ACS Reagent grade, free liquid when subjected to pretture being evaluated for other than volatile ggg Bxtrectiott Quid: filtration, weigh out a representative compound!, a filler holder capable of • •AS Extraction fluid fffcTkli Ovid M subsaaple of the watte (100 gram minimum) •Bpporting a glass fiber filter and able to •adebyaddingS.7mlgtacla)HOActolOO and proceed to Step Ml. withstand the pressure needed to scoempltoh ml of the appropriate water (See Section i.1). 74 tf the sample UBquid or nwltlpbatic. separation it used. Suitable filter holders adding e44 ml of UO N NaOH, and diluting to Jkpid/soljii separation J* required. Thto range from simple vacuum units to relatively a volume of 1 Bter. Whan correcfly prepared Involves the filtration device discussed in complex systems capable of exerting the pH of thi* fluid will be 449 * 0JS. Section 4A2, and to outlined in Steps 7J to pressure «p to 50 psi and more. The type of «A2 Extraction fluid *2:Thlt fluid to 74. •' filter holder uted depends on the properties made by diluting W ml glacial HOAc with 74 Fre-welgh the filter and the container of the material to be filtered (See Section ASTM Type X water (See Section fci) to e which wilt receive the filtrate.. 443). These devices shall have a minimum volume of t liter. When correctly prepared, 7.4 Assemble filter holder end filter totem*! volume of 300 ml end be equipped to fee pH of thit fluid win be »» ± 045. following the manufacturer's instructions. accommodate a minimum filter else Of 47 mm. Notev—Tbete extraction fluids thall be Place the filter on the support screen and Filter holder* known to EPA to be tulttWe for made up fresh dairy. The pH ahould be secure. Add wash the filter rf evaluating the use are shown in Teble 4. checked prior to use to teture that they are mobility of melaU (See Section 44).- 444 Material* of Construction: 74 Weigh out a representative tubsample Extraction vessels and filtration devicet shaB •TEDLARk a registered trademark of of the waste (lOOjpam minimum) and record be made of inert material* which will not DuPont weight.

C-ZT-W environment rtaportor 000348 344 ENVIRONMENT REPORTER

**'~AlWituiries to stand »o permit the '* Weight of dry 'waste and filters minus land the filter used to separate the. initial liquid •oKd pbxfcrio setde. Wastes (hat settle weight of Filtert divided ty Initial weight from the solid phase. slowly may be<*ntrifuged prior to filtration. "• of waste (Step"?1.' bY7.77muftiilfied by ' NoteWIf any of the solid phase remains .7J7 Trmofer. the waste-sample to *e filter - . adhered to the walls of the filter holder; or; hold*. 7itO,4 If the'WlW comprises less' than 04% die container used to transfer thewste. jtx Nble^waswmattrial has obviously of die Waste, ttwsolld is discarded and the* weight shall be determined subtracted from adhered to tiw container wed to transfer the liquid phase Is' defined as the TCLP extract the weight of die solid pn,a*e of the waste, as sample to tBrflUretton apparatus, determine Proceed to Step 7.14. < determined above, and th'ls weight fs used in ttw weight of this residue and subtract it from 7.104 . If. the'soild Is greater than or eo.ua! calculating ttw amount of extraction fluid to tha sample weight dttermined in Step 74, to to 04% of ihe-*wM(e,'retnrn to Step 7.1. end add into the extractor bottle. defamfe* At weight of the waste sample ' begin the procedure with a new sample of Slowly add an amount of dw appropriate which wil.be filtered waste. Do not extract the solid that has been extraction fluid (See Step 7.12). into the Gradually epply vacuum or senile pressure of •Wed. •• '- " extractor bottle equal to 20 times the weight 1-10 ptkBttQi air er pressurizihg gas move* Note. This stepJs only used to determine of the solid phase diet has been placed into through the filler. If this point is not reached whether, the sottd must be extracted or Ha extractor bottle, dose extractor bottle under 10 pit. and if no additional liquid KM' whether it may be discarded anextracted If tightly, secure in rotary extractor device and pasted through the filter in any 2 minute to not need in calculating the amount of rotate at 30 ± 2 rpm for 18 hours. The • interval slowly inoease the pressure in 10- extraction fluid to use In extracting the temperature shall be maintained at 22 ±3 *C pal increments to a maximum of SO psi After waste, nor to the dried aelid d»pfved from Ais during the extraction period each incremental increase of 10 pai if the step subjected to extraction. A new sample. ' Note.—As agitation continues, pressure preisuriring |ii has not moved through the will have to be prepared for extraction. May build up within the extractor bottle (due filter, and if no additional liquid has passed 7.lt If OM sample has more than 04% to the evolution of gaases such as carbon. through the filter in any 2 minute interval, wilds. It is aow evaluated for particle else. If dioxide). To relieve these pressures, the proceed to the next 10 psi increment When the solid matenal has a surface arm per gram extractor bottk may be periodically opened the pressurizlpg gas begins to move through of material equal to or greater than 3.1cm*. or end vented into a hood the fillet; or when liquid flow has ceased at • {•capable of passing through a.B4 mm (037$ 7.14 Following the 18 hour extraction, the Sd pai (La, doe* not result In any additional inch} standard sieve,' proceed to Step 7.12. If material ia the extractor vessel is separated- filtrate within any 2 minute period), filtration the surface are* la smaller or the particle size Into it» component liquid and solid phases by {estopped. •'. " '"' . Is larger than that described above, the solid filtering through a new glass fiber filter as * NotWlnstanlaneous application of high material is prepared for extraction by outlined ia Step 7J. This new filter shall be pressure can degrade die glass fiber filter, acid washed (See Section 4.4) if evaluating and may came premature plugging, material to a surface ana or particle size as the mobility of metals, 74 The material in the filter holder is described above. When surface area or 7.15 The TCLP extract ia aow prepared as defined as the solid phase of the waste, and ' particle size has been appropriately altered,.' fellows: ' the filtrate Is defined as the liquid phase, . proceed to Step 7.12. •' . . ' • ' 7.15,1 If the waste contained no initial Nota. Some wastes, such as oily wastes 7.12, This step describes the determination liquid phase the filtered liquid material and some paint wastes, will obviously of die appropriate extracting fluid to use (See obtained from Step 7.14 is defined as the contain some material which appears to be a Sections 54 and 7 4). . TCLP. extract Proceed to Step 7.18. liquid—but even after applying vacuum or 7.12.1 Weigh out a small sub-sample of 7.1&2 If compatible (e.g, will not form pressure filtration, as outlined in Step 7.7. this the solid phase of the waste, reduce the solid precipitate or multiple phases), the filtered material may not filter. If this is the case, the (if necessary) to a particle size of liquid resulting from Step 7.14 is combined material within me filtration device ia approximately 1 martn diameter or less, 'and ' with die initial liquid phase of the waste as defined as a solid, and is carried through the** transfer a 54 gram portion to a 800 ml beaker obtained la Step 74. This combined liquid is extraction as a solid. or erienmeyer flask. defined as die TCLP extract Proceed to Step 7.U2 Add 964 ml distilled detonized 7.16. 73 Determine the weight of the liquid water (ASTM Type 2). cover with watchglass. 7.154 If the Initial liquid phase of the phase by subtracting the weight of the filtrate and stir vigorously for S minutes using a • waste, as obtained from Step 7JJ, is not or . container (See Step 74) from the total weight magnetic stirrar. Measure and record the pH. may not be compatible with the filtered liquid of the filtrate-filled container. The liquid If the pH is < 54. extraction fluid «1 is used. resulting from Step 7.14. these liquids are not phase may now be either analyzed (See Step Proceed to Step 7.18. combined These, liquids era collectively 7.15) or stored at 4*C until time of analysis. 7.124 If the pH from Step 7.124 it >5JX defined as the TCLP extract en analyzed The weight of the solid phase of the waste, add 34 ml 1.0 N HCl. slurry for 30 seconds. separately, and die results are combined sample ia determined by subtracting the . .. cover with a watchglass. heat to SO*C. and mathematically. Proceed to Step 7.18. weight of the liquid phase from the weight of hold for to minutes. 7.18 The TCLP extract will be prepared the total waste sample, as determined in Step 7.114 Let the solution cod to room end analyzed according to the appropriate 74or7J.r temperature and record pH. If pH is <54, use SW-846 analytical methods identified in solid phases. extraction fluid an. If the pH is >S4. Appendix HI of 40 CFR 281. TCLP extracts to Note—ff the weight of the solid phase of extraction fluid «2 is need. be analyzed for metals shall be acid digested. the waste is less than 75 grams, review Step • 7.13 Calculate the weight of the remaining •If die individual phases era to be analyzed 7.0. solid material by subtracting the weight of separately, determine the volume of the 7.10 The sample will be handled the sub-sample taken for Step 7.12. from the Individual phases (to 0.1 ml), conduct the differently from this point depending on original amount of solid material as obtained appropriate analyses, and combine the whether it contains more or less than 04% from Step 7.1 or 7J . Transfer remaining solid results mathematically by using a simple solids. If the sample obviously has greater material into the extractor vessel including weighted average: then 0.5* solids go to Step 7.11. If it appears that the solid may comprise less than 04% of the total waste, the percent solids will be determined as follows: 7.10.1 Remove the solid phase and filter, (V.) (C,) + (V.)(C.) from tiie filtration apparatus. Final contaminant concentration. 7.10-2 Dry the filter and solid phase at V, 4-V, 100±20*C until two successive weighings- yield the, same value. Record final weight. 7.104 Calculate the percent solids as follow*

8-27-88 Published by THE BUREAU OF NATIONAL AFFAIRS, INC., Washington. O.C. 20037 000349 CURRENT DEVELOPMENTS 345

extract, and i* analyzed directly. If the waste valve and open valve. Begin applying gentle Vi -The volume of the fir»l phew It) • ocW (hate C -The concentration of the contaminant of • repeat Step Muting* new 100 (ram into the filtrate collection container. If no concern in the first phase |mg/l) minimum sample, determine the percent. additional liquid ha* passed through the filler Vi-Tbe volume of the woood phase (l) "• • 'solid*, and proceed to Step8.4.2. in any 2 minute intervel. slowly increase the €4 -The concentration of the toniaminsnt of M£' |f the sample to <25W solids, weigh pressure in 10 psi increment* to a aiaximum concern in the second phase (mg/l) i/. put • new 100 gram minimum representative of 90 psi. After each incremental increase of 747 Tne contaminant concentrations to sample, and proceed .to Step 8,5. If the sample 10 psi. if no additional liquid has passed the TOP extract we compared to the to > 25% aoiid*. the maximum amount of through the filter in any ^ minute interval, thresholds identified in the appropriate •ample the ZHE can accommodate is proceed to the next 10 psi increment When regulation*. Refer to Section 9 for quality determined by dividing 25 gram* by the liquid flow ha* ceased such thai continued percent'solids obtained from Step M. Weigh pressure filtration at SO psi doe* not result in Msurmnce requirements. out anew representative sample of the JLO Pmxdun when votoUlet an determined size. any additional filtrate within any Z minute iavohtd U After a representative sample of the period. DItration to stopped. Close, the liquid The ZHE device ha* approximately a 300 ««te(«aiB»Jeaiie determined from Step M) inlet/outlet valve, discontinue pressure 10 the •I tetemel capacity. Although e minimum has been weighed out and recorded, the piston, and disconnect the filtrate collection sample tin of 100 areas waa required IB the •ample la now evaluated for particle cite (See container. Section 7 procedure, the ZHE can only Step 84}. If the solid material within the Net*" tealantaneous application of high accommodate • maximum 100 pexeeat solids waste ofavioMly ha* a surface area per gram pressure can degrade the glass fiber filter and sample of 25 grams, doe to the need to add en of material aqn*l to or free tar than 3.1 em1, may cense premature plugging. amount of extraction fluid equal to 20 times e* to capable of peestag through a Maun M The SMterial in the ZHE to defined as the weight of the solid phase. Step M 0L37»inch] standard sieve, proceed die eottd phase of the waste, and the flhrata provides the meeu of which to determine the •sanecUatsly toSt*? 8^ tf the surface area to to defined as the liquid phase. approximate sample stee for the ZHE device. •mailer orthe particle size I* toner dun that Although the fouowing procedure allows described above, the solid BHterial which Notsv-Some wastes, such as oily waste* for particle size reduction during the conduct doe* not meet the above criteria to aeparated and some paint wastes, wffl obviously of the procedure, this could matt ia the toee from to liquid phase by sieving (or contain some material which appear* to be a of voletile compounds. If possible, any aqulvaicnl means), and the solid to prepared liquid—but even after applying pressure necessary particle sixe reduction (See Step far extraction by crushing, cutting, or grinding filtration, this material will not Alter. If this to •3) should be conducted on the sample M H to a surface aree or particlelatsa as described the case, the material within the filtration to being taken. Particle else reduction should device to denned as a solid, and to carried enry be conducted duris«t!M procedure if Note'—Wastes and appropriate equipment through die TCLP extraction a* s solid. there it no other choice. . • • should be it&iferated, if possible, to 4'C If the original waste contained less than OS* • to carrying otf the fcJtowraealep*, do not prior to particle *Ue reduction. Grinding and solids. (See Step 8.4} this filtrate to defined es •How the waste to be exposed to the Killing machinery which genaralea heat shall 'the TCLP extract, and to aneryxed directly— atmoephere for any more tteoe de*n le'. not be used for particle »ix* reduction. If proceed to Step 8.13. ab*ohitery necessary. • - - . reduction of the solid phase of the waste to 8.10 Determine the weight of the Bouid 8J I*e»wet|h the (evacuated) container necessary, expostzre of the waste to the phase by subtracting the weight of the filtrate wnk&wiUraceiv* the 01tra1a

8-27-86 Envtn nt Reporter 000350 tNVIHONMENT REPORTER

Reposition the Zl IE in the vertical position syringe:) holding the initial liquid phase of the TABLE 1.—VOLATILE CONTAMINANTS >— with the liquid inlet/outlet valve on top. Put waste, unless doing so would create multiple • . Continued 5-tO ptl behind the piston (if necessary), and phases, or unless there is not enough volume •lowly open the liquid inlet/outlet valve to left within the filtrate collection container. A Confound CASNO Meed out any beadspace (into a hood) that separate filtrate collection container must be may have been introduced due to the used in these cases. Filter through the glass t,14_2.T«*»cNoi_*l TwaoMwoMiMMnt.. 127-18-4 addition of extraction fluid This bleeding fiber filter, using the ZHE device as discussed T( 10S-S8-3 shall be done quickly and shall be stopped at in Step 9-8. All extract shall be filtered and 1.1.1-Tn 71-SS-S the first appearance of liquid from the valve. collected if the extract is multi-phasic or if 1.1.2 T* 79-00-5 Re-pressurize the ZHE with 5-10 psi and the waste contained an initial liquid phase. TneWore 7S-01-4 check all ZHE fittings to insure that they an Trtcf rs-es-i Note—If the glass fiber filter is not intact t.1j-THeNOfO-1JU4 78-13-1 dosed. • . Vinyl eh_»ld»:_ 7541-4 •.114 Place the ZHE in the rotary following agitation, the filtration device K»i»n»———„ 1330-20-7 extractor apparatus (if it is not already there), discussed in the NOTE In Section 4J.1 may be used to filter the material within the ZHE. ' -Mud.* compound- Utv#*il in bo» to Una tt-pm-t and rotate the ZHE at 30 + 2 rpm for 18 . •te-am HUM ana s<* To«_*» CftneHnMc. hours. The temperature shall be maintained •.13 If the waste contained no initial at 22 ± + 3*C during agitation. liquid phase, the filtered liquid material TAWJE 2.—SUITABLE ROTARY AGITATO* B.12 Following the 18 hour extraction, obtained from Step 8.12 is defined as the APPARATUS* check the pressure behind the ZHE piston by TCLP extract If the waste contained an quickly opening and closing the gas inlet/ initial liquid phase, the filtered liquid outlet valve, and noting the escape of gas. If material obtained from Step 8.12, and the • the pressure has not been maintained (i.e« no initial liquid phase (Step 84) are collectively g*s release observed), the device is leaking. defined as the TCLP extract (KBIMS-MM Replace ZHE O-rings or other fittings, as 8.14 The TCLP extract will be prepared accessary, and redo the extraction with a and analyzed according to the appropriate 10 »»»»-! new sample of waste. If the pressure within SW-848«nalytical methods, as identified in __c*-»_ft. PUT 44S-4116. the device has been maintained, the material Appendix HI of 40 CFR 281. If the individual ft-Muic*. PUMB in the extractor vessel is once again phases are to be analyzed separately, RUo. ISM) 752- separated into its component liquid and solid determine the volume of the individual phase*. If the waste contained an initial • : phases (to 0,1 ml), conduct the appropriate liquid, phase, the liquid may be filtered analyses and combine the results directly into the name filtrate collection • mathematically by using a simple volume •Mr-end fMRpn « X ± 2 rpm it tccapuo* container (La. TEDLAR* bag. gat-tight weighted average: •Mriewgh t* d-wc« * juttM*. * * net MMstL It AMy VBO IWQMaTV (VttOM&nQ 10 fV.MC,)+fV.)(Cj Final contaminant concentration » TABLE 3.—SUITABLE ZESO-HEAOSPACE v,+v. . VESSELS MedKNo.

3740-ZH8 where. constituent measured in the extract is within P031 541 MSB V, m The volume of the first phase (1) 20S' of the appropriate regulatory threshold. If Ci » The concentration of the contaminant of more than 1 extraction is being rim on S01KS1CS concern in the first phase (mg/1) samples of the same waste, the method of (SOOi 22S-33S4. Vt « The volume of the second phase (1) standard additjon need only be applied once Ct - The concentration of the contaminant of and the percent recoveries applied to the • concern in the second phase (mg/l) remainder of the extractions. TABLE 4.—SUTTABLC FILTER HOLDERS ' 9.5 TCLP extracts shall be analyzed 8.15 The contaminant concentrations in So* Ac TCLP extract are compared to the within the following periods after generation: thresholds identified in the appropriate Volatiles— 14 days. Semi-volatile*— 40 days. regulations. Refer to Section 9 for quality Mercury— 28 days, and other Metals— 180 M-cHper* Cerp- «2M>0 days. 410*00 47 assurance requirements. -S2-771I. 9.0 Quality Assurance-requirements. Dud-rv C-MomH. 30J400 142 9.1 Ail data, including quality assurance TABLE 1.— (41S) 829-6010 Corp.. YT30142MW 142 data, should be maintained and available for XX10M700 47 reference or inspection. 9.2 A minimum of one blank for every 10 > Any (Me* C-P.M o( «^»Mng «w tquid kom Iht «eW extraction* that have been conducted in an phMt «l M VMM it twUHi. piowdng tw * « enxneMy extraction vessel shall be employed as a eoniption witi «it M«M and «w eonMkMMt » b» wi*. I^M.. **#K dmedmew (no(nott MMM a-ov-a-ov-ll mamay MM u*au*ad wrwwrwn check to determine if any memory effects cKy inCBjinc conunnumi tn al eenetm. from the extraction equipment is occurring. One blank shall also be employed for every WS-90-7 TABLE 5.— SUITABLE FILTER MEDIA •7-6S-3 new batch of leaching fluid that is made up. 107-OS-2 —' 9.3 All quality control measures dcsct ibcd in the appropriate analytical method* shall be followed. CWion. MM JtrMy "Off 07 9.4 The method of standard addition shall (2011 773-SSOO. be employed for each waste type if: 1) Recovery of the compound from spiked splits /• Nan** per* M«, of the TCLP extract is not between 50 and • * 1SOS, or 2) If the concentration of the 1.1.1.2-Tc.KMeroMhlM.

8-27-48 Published by THE BUREAU OF NATIONAL, AFFAIRS, INC.. Washington. O.C. 20037 000351 CUMMtrxi

FIGURE It TCLP Flowchart

WET rtASTE S/WPLE *.. ' MET WASTE SAMPLE CONTAINS < 0.5 % REPRESENTATIVE MASTE OONTAIfe > 0.5 I MUN-flilERABLE SWPLE fDN-FILTERABLE SOLIC6 SOLIDS I ER* HASTE SMPLE LIQUID/SOLID SOLID SEPARATION 0.6-4.8 urn UOUIO/SOLID GLASS FIBER SEPARATION FILTERS 0.6-0.8 urn DISCARD GLASS FIBER SOLID SOLID FILTERS •MW • STQJ(EAT • 4«•C

REDUCE PARTICLE SIZE IP >9.5 on • OR SURFACE AREA <3.1 cm2 t ICLP EXTRACTION! OP SOLID REQUIRED FOR WIATUBS I LIQUID/SOLID

SEPARATION ••••••. DISCAFD 0.6-0.8 un GLASS SOLID FIBER FILTERS

LN3UID

ICLP EXTRACT

I ICLP EXTRACT ANALVTICAL -- . ICLP EXTRACT „ a. ICTHOCS

1 The extraction fluid employed is a function of the alkalinity of the solid phase of the waste.

000352 10 CO i o C5 o

1C »

NUIA 1 2

Apot I

n f 4 OC)

do* I01CH I I CURRENT DEVELOPMENTS 349

4. Amend Table 1 of Appendix m of T*«u 1-Amw* MCTMOO* PC* OMAWC 2. Amend 1271.1 Paragraph U) by Part 281 to add the following compound* Dmaou OOMTAINEO IM CW B«6 Conin adding the following entry to Table 1 in and methods in alphabttka! order • *•* chronological order by date of publication: r Appendix m Chemical Analysis Test ftrt.1 Methods • *•••* O)"* IPOftOMAMC TASUE 1.—fltoutA-noMS IMPUMSNTMG THE CHUMCMJ GQNTMKO w 8W-«46 HAZARDOUS AND Souo WATTC AUCNO-

PART902-DESIONATION, . REPORTABLE QUANTmES, AND SSVMKa.is.aa». NQTinCATION am/sm MVU* ana. 1 The euAority citation for Part 302 continue* to read as follows: * Aghnriiy• Sec. WofttieCempPthenMve 'Ell¥ltOBflUKDtu RCfpOBM* OMBIpCttMuOIX stDO PART 271" 'REQUIREMENTS FOR UabiHty Act of 19N. 42 US.C 9SO& Sees. 311 ***• ** 2&J5& AUTHORIZATION OP STATE aad Ml(a) of OM Ptderal Water Pollution Jlwan Control Act. 33US.C. 1321 and 1361. lit Ml HA*. HAZARDOUS WASTE PROM anowra 2. Section 302.4 is amended by ».1S.M( WM.IMO. 1. The authority dtation for Part 271 nvislng the entry for "Characteristic of continues to reac as follows: SP Toxidty- in Table 302.4 and the Authority: Sees. 1008* 2002(a), and footnotes are republished as foUow. •008 of the Solid Waste Disposal Act cs c amended by the Resource Conservstion __.__ and Recovery Act of 1876. as amended •went (42 U&C. 8805,8812(a), and 8828).

TA«JE3024.~UCTOFl«i tSt •mes i no

1A4 09U a 4 DBM x « ORM •c 1AM OMt X • M 00*1 D ~ O CMoiBM». toetaMt 4.T4MMMMM, t*t.S.*.T*» t4M DOS* «*4 eon 0 SWW2Z10) 4 CtOT •x e OBJT OMi a UU OBS» • 10M4S.4) 100(464) o D e M 001* x H0.4S4) x X 1-184S4) .* 1««04»4) _ DO»T X 1«(04HI 4 OOM 0 4 OBM X

EfMAn 350 ENVIRONMENT REPORTER

TAMC 3024.—lor ee HAZARDOUS SUWTANCCS AND REKJRTABU QoAHrmts—Contfnued.

Unda t M eon x M10.4S4) V 4 0000 X 1(0.4*4) MMN t M 0014 X U0.4S4) 1* tA ooao c «00(4S4) •f. tsmnnt __ >r A" — 004t~ —C- 4 -0044 X «ta 4': 0010- X 1(0.454) M.U.TWI IB0.4S4) M.1J •-•18B1--1*4 'Cow 5x t.tj ••S* -O947 X 4.O040 A 10(4 S4) 1*4 004* C . .M-OOtS N 71IW *4 COM C WOO(4S4| B4 OKI • X M».4«4) .1*4. oou . e M 0001 A 1*4 OOH A H0(4i.4)

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|« Doc. aa.13083 Htad «-u-a* a

Journal

CONGRESS EPA June II said its Science Advisory Board's Environ- mental Health <^-»»"«**-« Metals Subcommittee will bold June 17. W«. an open meeting to discuss the revised draft health assess- (WILDERNESS) to adjust the boundaries of the National ment document for beryllium and other agenda items, The WOdenea Preservation System in Texas. S SMS (Bentsen) meeting is Mt for July lft-U, 1 pm, Andenon Room, toAgricuttore. Medical Education Wtog, School of Medicine, University of Rochester, N.Y. (Jl PR HISS). To attend the meeting, MOUM BBs and Resolutions tn*odue«d contact by July 11, Brands Johnson at SAB; (MS) SIS-S952. JaatlT.lMO. Copies of the draft (EPA-MO/M4-W6B) can be obtained (HIGHWAYS) to limit outdoor advertising adjacent to from ORD Publications Offlce, Canter for Environmental interstate and federal-aid primary highways. HR W4J Research Information, EPA Onndnatf. Ohio 45J6J; (515) (i^4int