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PROCEDURES FOR ASSESSING RISKS c

IN SURVEYS OF WASTE MANAGEMENT FACILITIES

DECEMBER 22, 1980

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CONTENTS..

1. Introduction a. General .. b. Purpose of Surveys

2. Municipal Waste Disposal. a. General b. Procedures c. Sanitary Landfills, General d. Procedures f o r Sanitary Landfills Site Survey e. Municipal Waste Incinerators, General f . Procedures for Municipal Waste Incinerator

Site Survey 3. Hazardous Waste Disposal

a. General b. Procedures c. Secure Landfills, General

Page

1 1 2 3 3 3 4 5 6

7 8 8 10 10

d. Procedure f o r Secure Landfill Site Survey 12 e. Hazardous Waste Incinerators, General 14 f . Procedure for Hazardous Waste Incineration

Site Survey 15 g . Subterranean Disposal, General 16 h. Procedures for Deep Well Injection Site Survey 17

4 . Report Content and Format 18 a. Introduction 18 b. Operations 18 c. Pollution Potential - 19 d . - The Survey 19 e. Risk Assessment 20

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1. Introduction

1.

.a. General The Environmental Impairment Liability (EIL) insurance

program, because of its unique coverage of gradual seepage and smoke damage, has been of especial interest to waste dis- posers. Environmental Risk Assessment Service (USA) (hereafter "ERAS") has prepared an outline of evaluation procedures for use by EIL surveyors engaged in site surveys and subsequent risk assessment.

The information and procedures reported here have been based in part on experience gained by ERAS in its previous EIL waste management surveys and in part on discussions with engineers currently evaluating hazardous waste sites either on behalf of governmental regulatory programs or on behalf of in- ternal quality control progr- initiated by corporate managers.

behalf of ERAS only, and is not to be disclosed to others without the express prior written consent of ERAS.

This document is for the use of EIL surveyors, acting on

2.

This outline of procedures is intended to waste disposal operations carried out by disposing . . of wastes generated by others and

to apply equally contractors 'to 'operations

of waste generators disposing of their own wastes.

wastes, hazardous wastes, and .* reporting and risk assess- ment procedures. Municipal waste disposal includes sanitary landfills and municipal waste incineration. Hazardous waste'disposal covers secure landfills, chemical waste incineration, and deep injection wells.

Each section begins with a description of tasks common to all disposal of wastes in that category and then addressess the specialized requirements of each method.

It is divided into three sections covering municipal

b. Purpose of Surveys

The survey report islntended to help the insurers decide when to accept liability and what premium to charge. Its purpose is to assess the likelihood that the company seeking insurance will be sued for injury to persons (not including employees) or property (not belonging to the insured) arising out of the present or past leakage or cumulative emissions. In most cases, the desired insurance would not cover sudden and accidental release, such as explosions or major pipe ruptures.

or small recurrent spills if these have been characteristic of steady-state operations. Where sudden accidents are to be included in the assessment, the surveyor will be so informed.

It would cover cumulative injury from minor sloppage r

The EIL program has adopted a numerical scale to express gradations in its qualitative evaluations of the risks under assessment. In the absence of reliable actuarial data on per- vious lossis from- comparable risks, EIL risk assessment is in- tended to furnish a relative evaluation of the risk under

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investigation as it compares with all other industrial and commercial: activities. 2. * Municipal Waste Disposal .

a. General This-section is intended to cover not only waste disposal

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operations conducted by municipalities but also any operation disposing of wastes that are'similar in character to mixed municipal refuse. Such wastes include non-process trash from industrial facilities, commercial wastes from office buildings, restaurants, and residential wastes. They consist of kitchen garbage, metal cans, glass bottles, paper and cardboard, plastic, household appliances, and clothing. Sewage treat- ment sludge that has been dewatered, and contains levels of heavy metals within regulatory limits, may be disposed of as a municipal waste.

low risk operation. It c~ however, have problems with blowing paper, odor, or rodents, seagulls, or other disease vectors. improper handling or operations at any municipal waste facility, but they are not likely to lead to substantial monetary claims. Disease propagation by vectors traceable to a specific site, though unlikely, could produce sub- stantial claims.

An additional potentially serious exposure for all ,disposers of municipal wastes lies in the possibility that unscrupulous waste generators wishing to dispose of potentially hazardous materials, may misrepresent the natureof such materials or conceal them in cargoes of otherwise innocuous materials. Unrecognized hazardous materials may create serious groundwater contamination or air-borne emission problems before they are detected and have major potential for generating large claims for personal injury, property damage or clean-up costs.

b.. Procedures The first step in the survey should be a preliminary

Disposal of mixed municipal refuse should be a relatively

Odor and fugitive paper problems can arise from

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discuss ion (i>

(ii) . .

(iii)

with corporation management to obtain the following: Description of operations at the site, past and present.

Copies of applicable discharge permits from federal, state, or municipal authorities governing discharges into w,ater or air and disposal of wastes on land if applicable, and of periodic compliance testing results.

Copies of any notices of non-compliance with such permits, imposition of fines, if any, or complaints of injury, if any.

Copies of any accident reports or spill reports describing unintended releases of waste materials from the site.

Names and telephone numbers of the environmental regulatory officials from cognizant agencies with whom the facility's management deals.

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c. Sanitary Landfills, General "Sanitary landfill ,'.I ~ as used here, designates a disposal

facility for mixed municipal refuse where the refuse is com- pacted by vehicles as, or soon after, it is deposited and covered with a layer of compacted soil at least daily to control odors and exclude vectors.

First, Two major problems affect all sanitary landfills. the compressed wastes and cover layers prevent oxygen from reaching the lower strata of the fill. Waste there is decom- posed by anaerobic bacterial activity yielding methane as a by-product. Methane is a colorless, odorless, tasteless gas, CHk which is highly inflammable and explosive. than air and can asphyxiate where it is present in sufficient concentrations to displace oxygen. Methane can collect in basements or natural cavities near landfills.

It is heavier

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isolation to dissbate methane. Large fills or those near buildings may have active gas collection systems from which the collected gas - is either flared off, used as a fuel directly, or incorporated into-a natural gas distribution system.

The second major problem affecting sanitary landfills is the leaching: of rain or surface run-off from adjacent land, through fhe deposited waste and into groundwater carrying odors, disease organisms, Or dissolved concentrations with it. Unlike Secure

Small landfills usually rely on wind and geographic

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sanitary landfills are not constructed to prevent the escape of water fram them. that will limit leaching fram the site,,to limit their pollution potential.

They rely on site selection, and geology

. . d. Procedures for Sanitary Landfill Site Surveys The following items of information should be sought for

each site under survey. Not all .. may 'be available. Items (i) and (ii) should be obtained during the preliminary interview with management. Items (iii) thmugh (vii) should be obtained during the site visit, and item (viia'after the visit.

The geological and hydrological data used in site selection, information on the flow of aquifers and quality of groundwater near the site, and the character of the soils or rock strata underlying and surrounding the site, together with indications of the vulnerability of the site to tlooding at 100 year flood levels. management or management's consultants, soil and water data should be obtained from the appropriate governmerital authorities. In the United States these would be the nearest state or federal geological survey offices; flood water data is available from the U. S . Army Corps of Engineers.

The site design or plans, if any, indicating the intended depth and contours of the cavity, the planned source and procedures for applying soil cover, the anticipated surface and groundwater drainage patterns, proposed leachate and methane collection system, if any, and projected leachate and monitoring procedures.

If not available from

The procedures actually employed for controlling incoming waste cargoes to make sure that they include only municipal wastes or wastes of equivalent composition and not industrial process wastes. At many sites, there are no controls other than warning signs. At others, there will be an employee making at least a cursory visual inspection of incoming cargoes.

The suface to keep surface water drainage into the fill at a- minimum.

The procedures actually employed for methane and leachate collection and monitoring. At many sites, especially small ones, there will be none of these. ERAS has been recommending in most cases that at least up and down gradient groundwater

grading procedures actually employed

mnni tnrinr, r.rnl1 c =nil evntqnrhatoy t n c t i n w nynwyam

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(vi)

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(vii)

(viii)

e.

be initiated during the first year of insurance coverage.

The quality of housekeeping, control of fugitive paper, dust, odors, and vectors at the-site, including frequency and thoroughness of compaction and ' cover emplacement.

The nature of surrounding land use, character of adjacent land, and proximity of private and public drinking water.' wells or surface water supplies.

Verification from cognizant -environmental agencies that the site has been operating within the restrictions imposed by its operating permits-and details on any known violations.

Municipal Waste Incinerators, -General Rapidly evolving federal air emissions standards have had

the effect of closing down older incinerators, even those built as recently as the early 1960's. waste incinerators operating in-the United States today are likely to be of recent design and construction, often incorporat- ing heat exchangers for the recovery of energy from the burning wastes.

Municipal incinerators'have, for the most part, greater success in controlling fugitive paper and odor problems than have sanitary landfills

accepted for incineration proves to have a residue that the plant's stack gas emission controls cannot capture. Sewage sludge incineration, in Marblehead and Beverly, Massachusetts, for example, has resulted in odor complaints that may lead to closing down the incinerators. Washington, D . C . , suffered several years of shut down of a very large, newly completed incinerater during the early 1970's because of complaints that heavy metals, primarily lead, in the escaping flue gases were contributing to high'levels of these metals in the blood of school children living near the site. whether the mineral content was attributable to componants of home appliances passing through the incinerator or to metal residues in municipal sewage sludge being accepted for incinera- tion. However, as indicated above, the increasing severity of

As a result, municipal

Their main problems arise from air emissions when a waste

It was not determined

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in campliance with current standards probably present only a modest threat of environmental impairment.

every . . site surveyed, is the possibility that heavy metals, successfully captured in the incinerator ' s flue gas controls or contained in the bottom ash residue, may leachfrom the site where they have been buried. flyashand bottomashdisposal should be determined for each site.

A lesser problem, but one that should be evaluated for

The suitability of provisions for

f. Procedures for Municipal Wast-e Incinerator Site Survey

The following items of information should be sought for each site. States, regulatory standards covering particulate levels of flue gases allow 0.18 mg per dscm (0.08 gr per dscf) corrected

In a jurisdiction where, as -currently in the United

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to 12% C 0 2 for municipal incinerators, the survey will consist

with regulatory permit requirecents. less stringent emission standards, EIL surveyors will have to determine whether the actual emissions are likely to result in injury to persons or property, or in a requirement for off- site clean-up. sought for each site:

primarily of verifying that performance has been in compliance In a jurisdiction with

The following items of information should be

(i) The design and specifications of the waste receiving station, waste preparation equipment, combustion chamber, grates, ash handling

. equipment, combustion temperature controls and flue gas emission controls.

The procedures actually employed for controlling incoming waste cargoes to make sure that they include only municipal wastes or wastes of equivalent composition and not industrial process wastes. usually in covered trucks, are dumped into an indoor

- underground receiving bin from which the waste is moved to the incinerator charge hopper by a clam-shell bucket directed by a crane operator seated at considerable height above the bin. The operator seeks to make the incinerator charge homogeneous by alternating wet material with dry and distrubuting such high heat content materials as rubber tires across a series of hopper loads. He is likely to be the only incinerator employee with any opportunity to give even the most cursory inspection to incoming cargoes. He is, however,

f

(ii)

At many incinerators arriving cargoes,

a.

(vii)

(viii)

likely to spot and initally reject any drummed material, until at least an inspection of barrel . markings can be carried out.

The flue gas sampling procedure in use and time series of sampling data showing composition and concentrations of gases detected and quantities and chemical composi- tion of particulates released, measured net after the effect of- emission controls.

The quality of housekeeping, control of fugitive paper, dust, odors, and vectors at the site.

The nature of surrounding and down wind land use, character of adjacent land, and proximity of the incinerator to residential areas.

The location and m a n n e r of incinerator residue disposal and composition of fly ash and bottom ash. should review section 2d of These instructions and deter- mine which of items d(i) - d(viii) would be helpful in evaluation of possible leaching of incinerator residue from the land disposal site.

Surveyors

Verification from cognizant environmental agencies that the incinerator and residue disposal site have been operating within the restrictions imposed by theh operating permits.

Determination what disposition in 'the closing of the incinerator.

of wastes will be made event of mechan-ical failure requiring temporary

3 . Hazardous Waste Disposal a. General This section is intended to cover disposal operations dealing

Some industrial process .wastes are no more inherantly hazardous with all environmentally troublesome industrial process wastes.

than zesidential waste paper or garbage and differ only in scale and geographic concentration. The surveyor will have to evaluate each disposal situation on its merits to see what wastes are involved before deciding which elements of Section 2 and which of Section 3 of this outline are appropriate for evaluating.

"Hazardous wastes , I ' for purposes of this outline, include sub- stances that are chemically, physically, or biologically active; that is, inflammable, explosive, acid, caustic, toxic, radioactive, carcinogenic, teratagenic of: mutagenic.

Some are hazardous because of their potential for causing personal injury or property damage from sudden releases in high con- centrations.

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gradual injury over long terms in low concentrations.

applicable to waste disposal contractors who are - in, the business of disposing of wastes generated by others as to waste generators who dispose of their own wastes.

Others are so designated because of their potential for doing

The survey outline that follows is intended to be equally

One aspect of hazardous waste di-sposal deserves preliminary comment. violently or produce new by-products if combined with others. A mandatory first step in hazardous waste management is to make sure of the composition of the waste to be dealt with. regulatory schemes prescribe manifest systems through which the waste generator identifies the compositi-on of each container or cargo in shipping documents destined for the disposer. manifest systems are a welcome component of a waste disposal procedure, they are, themselves, vulnerable to human error or intentional manipulation.

surprises in the behavior of a cargo or container of waste to subject it to laboratory analysis. ing program and its scope will vary greatly depending on the types of materials handled but only where other circumstances make it certain that waste composition is known should cargo- by-cargo or container-by-container testing be foregone. Such circumstances only arise where, for example, a waste generator is disposing of his own wastes and knows that only a single waspe stream,or a very small number of waste streams, is involved

and groundwater contamination in the United States, has been anticipatory storage of drummed wastes by entrepreneurs who are in the process of raising capital for, or constructing, waste disposal or waste reprocessing plants. (Typically solvent recovery plants). Such accumulation begins as a way to generate quick cash flow fram customers eager to get rid of their wastes. It often continues beyond expected limits when financial or technical obstacles to plant completion intervene. The result of a series of severe pollution episodes has been a regulatory climate in which secure land fill disposal sites are expected to

Some of the materia1s"in this category may react

Some

While

The only reliable procedure by which a disposer can avoid is

The rigour of the test-

.One common circumstance that has led to both serious fires

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inter arriving wastes immediately and store no wastes at a l l above ground and chemical waste incinerators to store only in amounts compatable with ensuring continuity of combustion operations.

b. Procedures The first step in the survey should be a preliminary

discussion with corporate management to obtain the following: Description of operations at the site, past and present.

Copies of applicable discharge permits from federal, state, or municipal authorities overning discharges

applicable, and of periodic conlpliance testing results.

into water or air and disposal o !! wastes on land if

Copies of any notices of non-compliance with such permits, imposition of fines, if any, or com- plaints of injury, if any.

Copies of any accident reports or spill reports describing unintended-releases of waste materials from the site.

Names and telephone numbers of the environmental regulatory officials from cognizant agencies with whom the facility 's management deals. Secure Landfills, General

"Secure Landfill" is a term designating a disposal facility for hazardous wastes designed to provide a permenant repository for materials that would present one or another severe hazard if they escaped.

disposing of non-combustible inorganic wastes that cannot be neutralized or detoxified by chemical or physical treatment.

or clay formations are expected to act as barriors to prevent their contents from reaching underlying OL adjacent aquifiers . Usually they are lined with several feet of clay or bentonite of prescribed impermeability, overlying sumps filledwith porous gravel so that any-liquids escaping will be collected and can be pumped out for disposal elsewhere. man-made membrane is incorporated into or placed below the clay liners.

P At present secure landfills are the preferred technology for

Typically, they are located in areas where underlying rock

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Sometimes a layer of

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. At present, not enough is known about the effective lifetime of the materials incorporated into such membranes to permit a reliable forecast of the extent to which they will augment the long-term integrity of clay liners.

Once the liner is in place and properly compacted, the secure landfill is filled with waste, preferably dry material either in bulk or packed in drums. Even where the contents of drums are non-inflammable and dry, it is important to keep the containers intact to protect their contents from contact with rain water until the site is filled, capped, and pumped dry .

clay barriers as the site is filled in order to isolate the contents into small cells so that any liquid escaping from a drum or percolat- ing into the site will be restricted to a single portion of the cavity. The purpose is to reduce the risk of contact among incompatable wastes. Monitoring wells are built inside the cavity, and outside it, to permit the detection and sampling .of leachate.

so as to deflect rain and surface water from its contents and then capped with a layer of clay and, sometimes, man-made membrane.

Proponants of secure landfiils regard them as the safest currently available technology to isolate toxic wastes, particularly non-combustible inorganic sludges with little liquid content. Critics point out that even clays of high impermeability will eventually admit or release liquids assuming a modest head of hydrostatic pressure. They point out that hydrogeology is an inexact science and so emphasize that it is possible to plan for site integrity in terms of decades or centuries, not millennia.

quantities of liquid wastes into a secure landfill greatly increases the liklihood of leachate escaping although it is sometimes allowed where the liquids have been mixed with absorbent materials. reactive, and volatile wastes are also not considered appropriate for secure landfills..

Preferred practice is to build up a honeycomb of internal

When the cavity is filled, &t is covered with soil, graded

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Proponents and critics agree that the introduction of substantial

Ignitable,

- Notwithstanding.precautions, some leachate can be expected to

accumulate in the collection sumps beneath the clay liner from rain falling during construction of the cavity and in the leachate collection system inside the liner from rain falling

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into the site during its operating life before it has been filled and capped. Meteorological records and construction progress reports must be compared with the volume of leachate actually pumped from below and within the liner to determine whether the amourits of leachate collected are attributable to rain falling directly into the cavity. If the vol&e of leachate collected inside the liner is excessive, it indicates either that liquid wastes are being placed in the-site or that ground or surface water is flowing into it or both. the collection sumps below the liner exceeds rainfall into the cavity during the early period of its construction, it indicates at best, unanticipated groundwater levels that will require an active relief pumping system, at worst,-if contaminated, leakage from the site.

If the amount pumped from

d. The following items of information should be sought for

Procedure for Secure Landfill Site Surveys

each site under survey: (i)

(ii)

F

(iii)

The seismic, geological, and hydrological data used in site selection, information on the flow of aquifers and the quality of groundwater near the site, and the character of the soils or rock strata underlying and’ surrounding the site, together with indications of the vulnerability of the site to flooding at 500 year flood levels.

The site design& Ian2 , and specifications showing trwastes to be handled; the intended depth, contours, and liner construction for the cavity; the leachate and gas, if any, collection system; the design for limiting migration of liquids within the site; plans covering monitoring for leachate within, and outside the site; plans for closure and sealing of the site; and plans f o r post-closure maintenance and monitoring as well as qpera-ns s covering the admission,

each cargo or container location withis the site; record keeping procedures for identifying the location of each cargo or container of waste within the site; and contigency Z e s g m L a n s covering fire and _damxe- control and w gl-fic-atio-apub 1 ic-s af e a author i ti es . The procedures actually employed to screen and test incoming.wastes.to make sure they are compatable with secure landfill disposal and with the site’s operating plan.

The procedures actually used to assign cargoes or containers of wastes to specific locations within the site.

testing, anurocedures f o r alloc -_1_1-

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(v) Procedures actually used to limit migration of liquids within the cell.

(vi) The records of leachate collection, sampling, testing, - pumping, and disposal during operation of the site,

. . including volume of liquid removed and concentrations of contadnants . The procedure actually used for drum handling to prevent tumbling or concussion that could rupture drums or release sparks-..

The degree of apparent labor force discipline as reflected in such evidence as wearing of prescribed protective clothing, observance of no-smoking regula- tions, and adherance to prescribed waste screening. and handling procedures.

The degree of labor force training as reflected in training manuals, schedules of training sessions, numbers actually attending, and experience of instructors, all as verified by employees' con- firmation of management records.

The general housekeeping and physical condition of visible portions of the cavity, berms, tanks, dikes, and drum handling areas.

The location and appearance of surface water on or near the site.

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Hazardous waste disposal sites often operate in conjunction with industrial waste water treatment plants, in which aequeous wastes are subjected to physical, chemical, or biological treatment steps to separate out contaminants. are functioning properly, the treated water is re- quired to meet regulatory standards before discharge. In the United States, these standards are established by federal regulations governing "NPDES" permits if the discharge is to be into surface waters and by the local sewage treatment authority if the discharge is to be into a sewer system. Sewage systems in turn, must meet federal effluent standards before discharging into surface waters. Surveyors evaluating hazardous waste disposal systems incorporating industrial waste water treatment plants must determine the condition imposed by the waste water discharge permits and make an evaluation whether these permit conditions are adequate under the circumstances to prevent property damage or personal injury to downstream consumers of water or riparian owners and whether the records of sampling and testing 'effluent establish that the actual discharges conform to t he permit requirements. In addition, surveyors should determine that the residual sludge from the

Vhere such operations

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waste water treatment is subjected to sufficient de- watering procedures before it is placed in the secure landfill to assure that it does not contribute to potential leachate problems. The nature of surrounding land use, character of adjacent land and. proximity of private and public drinking water wells or surface water supplies.

Verification from cognizant environmental agencies that the site has been-operating within the restrictions imposed by its operating permits and detailsonany known violations.

e. Hazardous Waste Incinerators, General Controlled high-temperature incineration under stringent emission

3 (xiii) . .

(xiv)

controls is, at present, the preferred technology for disposal of combustible, organic, hazardous wastes. Incineration facilities are more vulnerable to some forms of potential environmental impairment liability than secure landfills, less vulnerable to others. Incin- erators typically present a major-hazard of sudden and accidental events, explosions and fires, th2t could cause wide dispersal of hazardous materials in storage and of complex by-products of the accidental co-combustion of such materials. Such events can result either from inadvertant combination of incompatable wastes or from fires originating in human error, spontaneous combustion or natural causes.

There are also non-sudden events through which incinerator facilities may cause environmental impairment. tial for leakage into groundwater of liquids being stored prior to incineration. Leakage may be from permanent storage tanks or from drums'or other containers in which wastes have been delivered.

the inkinerator itself. is that of releasing harmful materials in its stack gases either through a single episode of equipment failure or combustion of an unintended waste, or through prolonged failure to recognize or control an escaping contaminant until it has caused personal injury or property damage or requires clean-up.

Proposed new waste regulations in the United States seek to reduce these hazards by limiting the amount of wastes stored on site and by specifying in detail the conditions of incineration. include: rate of feed of waste, fuel, and air; combustion temperatures;

They present a poten-

It can also be from pipes connecting bulk storage facilities to The unique risk from an incinerator, however,

These

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length of retention time wastes must spend at the required temperature, amounts of excess oxygen to be present, composition of flue gases, efficiency of combustion, and allowable particulate emissions.

Incinerators must submit trial burn data and'samples for each new type of waste to be incinerated to allow-opportunity for advance testinp of the hazards of its combustion by-products by regulatory authorities.

The risk of inadvertantly combining incompatable wastes is increasingly being met by a two step waste screening procedure. Arriving bulk cargoes are deposited into small storage tanks, each containing a volume equivalent to one tanktruck. The cargo is held in the storage tank until the completion of laboratory tests on it. Not until the tests are satisfactorily completed is the cargo desig- nated for blending with larger quantities of other compatable wastes for bulk storage until the particular blend of wastes.

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incinerator is prepared to accept that

f. The

site:

Procedure for Hazardous Waste Incineration Site Survey following items of informations should be sought for each

t

The wastes to be handled and the design and specifications of the waste receiving station, preliminary storage facilities, testing laboratory, blending and bulk storage facilities, pumps and pipelines, incinerator, includinp waste, fuel, and air controls combustion chamber, temperature controls, retention time contzols , flue gas emission controls, and monitoring crquipment and bottom and fly ash disposal system; contigency plans covering fire and damage control and notification of public safety authorities.

Meterological data showing direction and average ~

velocity of prevailing wind. year flood levels for the site.

Flood level data showing 500

The operating manuals governing the receiving of incoming wastes, their storage, testing, blending, and incineration, including flue gas sampling and testing, and a description of supervhory controls intended to ensure adherance to these procedures.

The procedures actually followed in the operations described in the foregoing sub-section.

The flue gas sampling procedures in actual use and time series of sampling data showing composition and con- centrations of gases detecked and quantities and chemical composition of particulates released measured net after effect of emission controls.

lb. . I

* (vi)

(vii)

The quality of housekeepin , effectiveness of control of fugitive ash k d . odors, an5 quality of maintenance at the site.

The degree of apparent labor force discipline as reflected in such evidence as wearing of prescribed protective clothing, observance of no-smoking regulations, and adherance to pre- scribed waste screening and handling procedures, average .l.ength of employment of laborers.

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(viii) The degree of labor force training as reflected in training manuals, schedule of training sessions, numbers actually attend- ing, and experience of instructors all as verified by employees' confirmation of management records.

The location and manner of incinerator residue disposal (if any) Some incinerators will burn only. high volatility materials that will burn leaving no ash; Determine chemical composition of fly ash, if any.

(ix) others may produce fly ash.

(x) The nature of surrounding and down wind land use, character of adjacent land and proximity of fncinerator to residential areas.

(xi) Verification from cognizant environmental agencies that the incinerator and residue disposal site have been operating within the restrictions imposed by their operating permits.

g. Subterranean Disposal, Geheral'ly

"Subterranean disposal ," in this outline is used to cover deep injection wells, salt dome depositories and depositories mined out of hard rock. Of these three forms of disposal technologies only deep injection wells have been widely used in the disposal of hazardous wastes. Underground cavern storage, however, has been extensively researched for its potential in the disposal of high level nuclear wastes, particularly those wastes generated during nuclear weapons production and during the reprocessing of spent nuclear fuel elements from nuclear fuel plants.

All three technologies have in common the virtue that they isolate the wastes disposed of from further intentional or inadvertent human actions, and protect it from being disturbed by such natural forces as floods or high winds. However, they also share the characteristic that each has a potential for contaminating groundwater aquifers on a scale that may be large compared to surface disposal methods, and under circumstances where remedial action may be impossible. All three are also vulnerable to se-ismic disturbance which, by altering rock structure and changing groundwater flows, may expose wastes previously disposed of to extensive contact with groundwater.

The only subterranean disposal method currently subject to

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regulations in the United States is deep well injection. Under the Safe Drinking Water Act Amendments of 1977, Title 42 U . S . Code Section 300 (h.), EPA was given the authority to issue regulations governing the design and operation of deep injection wells. These regulations, however; as of October, 1980,'.have not yet been isked. The most important EIL hazards to be associated with deep well injection of wastes are those relating to accidental combining of inconpatable wastes while they are in surface storage, and the possibility that either because of an unperceived leak in the casing, or because of un- anticipated hydrogeological conditions -- affecting the res ervoir into which the wastes are being injected, the injected wastes will escape into an aquifier that is,or could be, a source of,drinking or irrigation water. The first class of hazards are, however, likely to be much lower for deep well injection operations than for incinerators. only a single waste stream or at most a small number of similar and compatable wastes. receiving and blending assume, however, a heterogeneous mix of incom- ing wastes to make this outline as comprehensive as possible.

Deep well injection s i t e s are often used to dispose of

Referenceein the following section to

h. Procedures for Deep Well 'Injection Site Survey The following items of information should be sought for each

site: (i>

(iii)

(iv)

The wastes to be handled and the design and specifica- tions of the waste receiving station, preliminary storage facilities, testing laboratory, blending and bulk storage facilities, pumps and pipelines, and injection well casing and construction, contigency response plans covering fire and damage control and notification of public safety authorities.

The geological and hydrological data upon which the design and construction of the injection well were based, including, specifically, information on the locations and water quality of any aquifiers intersected by the deep injection well, the identity and extent of the stratum into which the wastes are being injected, the quality of any water within this stratum, and proximity of the stratum to potential sources .of drinking water or irrigation water and the rate and direction of movement of groundwater in areas that could be contaminated by any escaping wastes.

The operating manuals governing-the receiving of incoming wastes, their storage, testing, blending, and injection.

The actual procedures employed in receiving incoming wastes, their storage, testing, blending and injection, and in - - - - - -

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(iii)

(iv) . .

(vii)

The operating manuals governing the receiving of incoming wastes, their storage, testing, blending, and injection.

The actual procedures employed in receiving incoming wastes, their storage, testing, blending, and injection, and in determining the integrity of the injection well casing.

The procedures, if any, f o r determining whether injected wastes are reaching and remaining in the intended reservoir.

The nature of surrounding land and water use especially the use of land positioned along the path of flow of any aquifier vulnerable to con- tamination if injected wastes were to escape from their intended reservoir.

Verification from cognizant environmental agencies that the injection well and waste receiving station have been operating within the restrictions imposed by applicable operating permits.

4 . Report Content and Format

to report preparation and risk assessment. rigidly and may be omitted to make way for more significant informa- tion depending on the nature of the operation being surveyed. surveyor's report, however, should be in narrative form, not a series of unconnected answers to the questions presented.

The topics and questions sp t forth below are intended as a guide They need not be followed

The

a. Introduction Describe the organization and its business. Give sales volume and number of employees, number of sites covered by the insurance, volume of waste disposal of, or any similar information that

f l would provide an indication of the general scale of the operation. Attach and annual report and SEC Form 10-K if one can be obtained.

b. Operations (i) Describe the location, surroundings, and operation at the

site surveyed. if a longer description is easier to prepare than a short one, don't worry about excessive length. Provide your evaluation of the site's proximity to neighbors or geographical features that have the effect of raising or lowering its potential for causing bodily injury, property damage or requiring clean-up. local residents on environmental matters amicable? Have there been claims or complaints?

property and relationship to possible damage targets. Prepare a brief, non-technical process description for each major waste disposal process. site? What treatment or disposal processes are used?

A short paragraph may be sufficient but

(ii)

Are relations with

Obtain site plans and . local area maps, where posssible, showing limits of insured'::

(iii) What wastes enter the

1 9 .

(Copies of material flow diagram should be obtained when ava i l ab le .) What waste streams r e s u l t from treatment processes?

( iv> Give your eva lua t ion of management's apparent goa ls with r e spec t t o p o l l u t i o n problems ,- i ts i n s t i t u t i o n a l

. . structure f o r environmental supervisoin, and of i t s e f fec t iveness i n avoiding .or containing such problems.

'What i s the na tu re and extent of t he plant manager's experience and t h a t of any o t h e r technica l s ta f f? is the employee turnover ra te o r average l eng th of em- ployment, f o r supervisors? For laborers? Evaluate general housekeeping and apparent a t t e n t i o n given t o upkeep and prevent ive maintenance of equipment. Note measures being taken t o a n t i c i p a t e poss ib le problems.

What

C. Pol lu t ion P o t e n t i a l Describe any emission o r waste-release problem that you may have i d e n t i f i e d i n the course-.of your survey o r d i scuss ions . Even where no s p e c i a l problems are i d e n t i f i e d , c h a r a c t e r i z e what you believe t o be t h e s i g n i f i c a n t r i s k s from the ope ra t ion

' under survey f o r : a i r , w a t e r , s o l i d wastes.

d . The (i>

( i i >

( i i i )

( v i i )

(v i i i )

Survey Describe the p l a n t v i s i t . When w a s i t done? With whom did you meet? What ind iv idua ls guided you? What did you see? Describe the s ta te of compliance with regula tory re- quirements.

Have waste discharge permits been obtained from regulatory, agencies? (Copies of l a tes t vers ions should be obtained.

Are r epor t s f i l e d wi th regula tory agencies on w a s t e discharges? (Copies o f la tes t r epor t s should be obtained,

Are q u a n t i t a t i v e o r q u a l i t i t i v e analyses made of waste discharges? Using what procedures? With what results?

Is t h e p l a n t opera t ing under s p e c i a l variances from discharge requirements? Time compliance schedules? Special agreements with regula tory agencies? of such agreements should be obtained.)

(Copies

A r e any l e g a l o r regula tory agency ac t ions , pe r t a in ing t o environmental damages o r damages r e s u l t i n g from waste discharges, now pending,or have any such ac t ions been s e t t l e d wi th in the l a s t f i v e t o ten years? Are any p a r t i e s contemplating such ac t ion? Have any com- p l a i n t s of such a na tu re been made t o the company?

Obtain permission t o contact cognizant regula tory agenc- ies . I f permission i s withheld, determine why. Obtain names and telephone numbers of regulatory o f f i c i a l s

. . b

20.

with whom management deals. Call the and obtain their evaluation of the in program.

named individuals ured ' s compliance

- . (ix) For discharges to local sewage systems; are there any .discharge permit stipulations as to the quantities and .compositions of effluents?. (Copies of agreements with local sewage systems should be obtained.) conditions being met? -

Are these

.. e. Risk Assessment

Provide in a few paragraphs your summary conclusions of the risk presented. For each site visited, give a numerical ranking on a scale of 1 to 10. high risk, while a rating of 3 or below would imply a very low

A rating of 8 or above will imply a very

: risk.

If you have any recommendations, compliance with which you believe should be made a condition of insurance, specify them here.

You may also, at your option, list here any other recom- mendations you may have foe reducing the risk of environmental impairment from the operations- surveyed.

f