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U.S. Environmental Protection Agency
Region 5 Library (PL-12J)
77 West Jackson Blvd., 12th Floor
Chicago, IL 60604-3590


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everybody's problem;
hazardous waste
  Every year, billions of tons of solid wastes are
discarded in the United States. These wastes range in
nature from common household trash to complex
materials in industrial wastes, sewage sludge, agricul-
tural residues, mining refuse, and pathological wastes
from institutions such as hospitals and laboratories.
  The U.S. Environmental Protection Agency (EPA)
estimates that in 1980 at least 57 million metric tons of
the nation's total wasteload can be classified as hazard-
ous. Unfortunately, many dangerous materials that
society has "thrown away" over recent decades have
endured in the environment—making household
words of 'Love Canal' and 'Valley of the Drums.' These
two incidents are not unique. EPA has on file hundreds
of documented cases of damage to life and the
environment resulting from the indiscriminate or im-
proper management of hazardous wastes. The vast
majority of cases involve pollution of ground water—
the source of drinking water for about half of the U.S.
population—from improperly sited or operated land-
fills and surface impoundments (pits, ponds, and la-
goons). In addition to polluting ground water, the
improper handling or disposal of hazardous waste can
cause several other kinds of environmental damage, as
illustrated by these case histories (often involving more
than one form of damage) from EPA records.

Hazardous wast© can pollute ground waters

•  The water supplies of Toone and Teague, Tennessee,
   were contaminated in 1978 with organic compounds
What appears to be a
pleasant rural landscape
actually hides ground
water contaminated by
a nearby Industrial
9andfilL The ground
water was the source of
water for the towns of
Toone and Teague,
Tennessee.

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   A young man was
   asphyxiated as he
discharged hazardous
 waste from his truck
  into this open pit in
     Bberviile Parish,
          Louisiana.
  when water leached from a nearby landfill. When
  the landfill closed, about 6 years earlier, the site held
  some 350,000 drums, many of them leaking pesticide
  wastes. Because the towns no longer have access to
  uncontaminated ground water- they must pump
  water in from other locations.
® Ground water in a 30-square-mile area near Denver
  was contaminated from disposal of pesticide waste in
  unlined disposal  ponds. The waste, from manufactur-
  ing activities of the U.S. Army and a chemical
  company, dates back to the 1943-to-1957 period.
  Decontamination, if possible, could take several years
  and cost as much as $80 million.

Hazardous waste can contaminate rivers, lakes,
and ©ther surface waters

• At least 1,500 drums containing waste, primarily from
  metal-finishing operations, were buried near Byron,
  Illinois, for an unknown number of years until about
  1972. Surface waters (and soil and ground water as
  well) were contaminated with cyanides, heavy met-
  als, phenols, and  miscellaneous other materials.
  Wildlife, stream life, and local vegetation were
  destroyed. The disposal site suffered long-range
  damage from the toxic pollutants that drained into
  the soil.
• About 17,000 drums littered a 7-acre site in Kentucky
  —which became known as 'Valley of the Drums' —
  about 25 miles south of Louisville. Some 6,000 drums
  were full, many of them oozing their toxic contents
  onto the ground. Sn addition, an undetermined
  quantity of hazardous waste was buried in drums
  and subsurface pits. In 1979, EPA analyses of soil and
  surface water in the drainage area identified about
  200 organic chemicals and 30 metals.

Hazardous waste  can pollute the air;

• In 1972, waste containing hexachlorobenzene (HCB),
  one of the family of toxic organic compounds that
  contains chlorine, was disposed of in a landfill  near
  Darrow and Geismar, Louisiana. The HCB vaporized
  and subsequently accumulated in cattle over a 100-
  square-mile area. The cattle had to be destroyed,
  representing a direct economic loss of over $380,000.
  Elevated, although subtoxic, levels of HCB in blood
  plasma were found in some area residents.
                             When industrial wastes ignite, they not only present the
                            immedaate dangers of heat and smoke but can also spread!
                                                harmful particles over wide areas.I

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®
  A truck driver was killed in 1978 as He discharged
  waste from his truck into one of four open pits at a
  disposal site in Iberville Parish, Louisiana. He was
  asphyxiated by hydrogen sulfide produced when
  liquid wastes mixed in the open pit. The area was
  surrounded by water and had a history of flooding.

           waste can burn or @Mpl®d@;

• A fire broke out in 1978 at a disposal site in Chester,
  Pennsylvania, where 30,000 to 50,000 drums of
  industrial waste had been received over a 3-year
  period. The smoke forced closing of the Commodore
  Barry Bridge and 45 firemen required medical
  treatment, mostly as a result of lung and skin
  irritation from chemical fumes. A number of homes
  are located within three blocks of the site; drummed
  waste was kept only 20 feet from a natural gas
  storage tank and liquefied natural gas tanks were
  about 100 yards away. Waste was emptied directly on
  the soil of the 3-acre site; some probably drained to
  the tidal section of the adjacent Delaware River.
  Waste may even  have been dumped into the river.
• A bulldozer operator was killed in a 1975 explosion at
  a landfill in Edison Township, New Jersey, as he  was
  burying and compacting drums of unidentified
  chemical waste. Of the 200 truckloads of waste the
  landfill received daily, about 50 were industrial waste.

Hazardous waste can poison via the food chain:
• In 1970, three children in an Albuquerque, New         killed a bulldozer
  Mexico, family became  seriously ill after eating a pig     operator as he buried
  that had been fed corn treated with a mercury          of unSfSed     §
                                                      hazardous wastes.

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Boarded-up houses offer
  mute testimony of the
 environmental disaster
at Love Canal in Niagara
       Falls, New York.
                        compound. Local health officials found several bags
                        of similarly treated corn in the community dump.
                     •  Over a 4-month period in 1976, an Indiana family
                        consumed milk contaminated with twice the
                        maximum concentration of polychlorinated biphenyls
                        (PCBs) considered safe by the Food and Drug
                        Administration. The milk came from the family's cow,
                        which had been grazing in a pasture fertilized with
                        the City of Bloomington's sewage sludge. The sludge
                        contained high levels of PCBs from a local
                        manufacturing plant. A Federal law passed in 1976
                        banned production of PCBs after January 1,1979.

                     Hazardous waste can poison by direct contact:

                     «  The health of some residents of Love Canal, near
                        Niagara Falls, was seriously damaged by chemical
                        waste buried a quarter of a century ago. As drums
                        holding the waste corroded, their contents
                        percolated through the soil into yards and
                        basements, forcing evacuation of over 200 families in
                        1978 and 1979. About 80 chemicals, a number of
                        them suspected carcinogens, were identified.
                     *  In 1979, cattle on a Kansas farm were contaminated
                       with PCBs after waste oil was used in animal
                       backrubbers. The waste oil (from electrical transform-
                       ers) had been purchased from a salvage yard in
                         After being contaminated with PCBs, many cattle on a farm in
                      Kansas had to be destroyed and buried in this EPA-approved site.

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Hazardous waste was illegally disposed of into this buried tank by a "midnight dumper/
who was observed entering the property by an eyewitness. Notified of the dumping,
the Michigan Department of Natural Resources had to dig up the property to locate the
tank, which was leaking and contaminating the soil and ground water.
                       1972, before the effects of RGBs were widely known.
                       Products from 54 head of cattle had been shipped to
                       a number of States and had to be traced and
                       disposed of properly; another 112 head had to be
                       destroyed. The farm and  a feedlot where the cattle
                       had been shipped were also contaminated.

                       These examples provide dramatic evidence of damage
                     to life and the environment from mismanagement of
                     hazardous waste. It was in large part to prevent such
                     tragedies that, in 1976, Congress enacted Subtitle C of
                     the Resource Conservation and Recovery Act (RCRA),
                     Public Law 94-580. This law imposes strict controls over
                     the management of hazardous waste throughout its
                     entire life cycle. The costs for proper environmental
                     controls will be higher than amounts spent in the past
                     to manage these wastes* But the astronomical costs of
                     cleaning up damage caused by poor disposal practices
                     should be eliminated. An ounce of prevention, in this
                     instance,  is a sound investment.
                       An EPA study made in 1979 indicated that cleaning
                     up abandoned hazardous waste sites and those operat-
                     ing  under environmentally  unsound conditions could
                     cost as much as $44 billion,  only part of which is likely
                     to be paid for by the owners of the sites. The remainder
                     would have to come from other sources.  But in many
                     cases it is impossible to assign dollar values to the
                     long-term harm to health and the environment that has
                     resulted from improper management of  hazardous
                     waste.

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Tlie national Program Ife Control
Hazardous Waste

  In a report to Congress in 1973, EPA recommended
passage of a Federal law to regulate the handling of
hazardous waste. EPA reported that although existing
Federal legislation was adequate to protect the air,
surface waters, and oceans from improper disposal of
hazardous waste, there were no national controls over
its disposal on land. Moreover, the air and water
pollution laws requiring industry to adopt environmen-
tally acceptable treatment and disposal practices had
increased the amounts of hazardous waste being
dumped on the land, a relatively unregulated outlet for
disposal. Thus, a law was needed to close the circle of
Federal environmental protection by providing, for the
first time, control over disposal of hazardous waste on
land.
  Congress responded by including hazardous waste
provisions in RCRA—the law that established a national
program to protect human health and the environment
from improper handling of solid waste and to encour-
age conservation of natural resources. Directed by RCRA
to take the lead in developing strict controls, EPA began
a three-pronged effort to attack the nation's hazardous
waste problem.
  The first phase, the regulatory program under RCRA,
is intended to help States prevent any Love Canals in
the future. Central to this program is a national
"cradle-to-grave" control system to track all significant
If If is managed ©n-sit@
                               Disposal
                               Treatment
Monhazardoiss
Waste
 A

                                                  9

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 quantities of hazardous waste from wherever it is
 generated to its final disposal. The regulatory program
 includes:
 • identification of hazardous waste
 • standards for generators and transporters of
   hazardous waste
 • performance, design, and operating requirements for
   facilities that treat, store, or dispose of hazardous
   waste
 • a system for issuing permits to such facilities
 • guidelines describing conditions under which State
   governments can be authorized to carry out their
   own hazardous waste management programs

   Along with its authority under RCRA, EPA is using
 regulatory authorities under several other Acts it
 administers. These include the Clean Water Act, the
 Safe Drinking Water Act, the Toxic Substances Control
 Act, and the Refuse Act. Under certain provisions of
 these Acts, EPA has been able to:
 • fund the development of programs for management
   and enforcement of hazardous waste activities by
   State and local governments
 • fund cleanup of disposal sites
 • approve landfills and incinerators for PCB disposal
   and treatment
 • provide technical assistance to State and local officials
   to help them analyze and remedy existing or
   potential problems caused  by improper hazardous
   waste management

  The second phase of the national hazardous waste
 management effort consists of EPA investigations to
 identify dangerous abandoned or uncontrolled dump
 sites, which the Agency estimated in 1979 to number as
 many as 2,000. Under RCRA, EPA can force the owner to
 clean  up a hazardous waste disposal site if it causes an
 "imminent and substantial" danger to human health
 and the environment. EPA has stepped up its efforts
 under this provision to discover, investigate, and clean
 up abandoned disposal areas.
  Unfortunately, the owners of dangerous sites often
 cannot be found. Even when they are found, they may
 not have the finances necessary for cleanup, or they
 may deny any legal liability for damages attributed to
the site. Thus innocent victims must resort to long and
 costly legal proceedings under State laws, and
 government agencies are faced with cleanup expenses.
  The third phase of the attack on hazardous waste is a
10

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1979 legislative proposal, termed the "superfund,"
developed by EPA and others to rectify the limitations
of the imminent hazard provision. The main purpose is
to provide funds that will permit Federal and State
governments to move quickly and effectively to deal
with the consequences of uncontrolled and abandoned
disposal sites, as well as spills of oil and hazardous
substances.

The Public

  Of special  importance in RCRA is a provision stating
that "public  participation in the development, revision,
implementation, and enforcement of any regulation,
guideline, information, or program under this Act shall
be provided  for, encouraged, and assisted" by EPA and
the States. This booklet is an example  of the kind of
information  EPA makes available to the public It is
intended to  help build an understanding of the
hazardous waste problem and thus promote effective
public participation in  the development of Federal and
State programs for bringing the problem under control.
Abandoned or
uncontrolled sites
where wastes have
been dumped
indiscriminately have
been termed "ticking
time bombs." The search
for abandoned sites wiBS
be a continuing process.
                                                 11

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                      a                              is * * *
                        RCRA defines a hazardous waste as a solid waste that
                      may cause or significantly contribute to serious illness or
                      death, or that poses a substantial threat to human
                      health or the environment when improperly managed.
                      Hazardous wastes are among the leavings of a highly
                      technological society and come from many segments of
                      that society—industry, hospitals, research laboratories,
                      and al!  levels of government Industry is by far the
                      largest  source, generating these wastes to manufacture
                      cars, fuel, paper, plastics, clothing, rubber, paint, pes-
                      ticides,  medicines, and a host of other products that
                      Americans need or expect in their day-to-day lives.
                        Working from the RCRA definition, EPA has compiled
                      and proposed a list of hazardous wastes. Listing is the
                      most common method for defining hazardous waste in
                      European countries and in some State Saws. EPA has
                      also proposed that a hazardous waste be identified by
                      testing  it to determine if it possesses any one of four
                      characteristics. If it does, it will be subject to regulation
                      under RCRA. Three of the characteristics selected by EPA
                      produce acute effects likely to cause almost immediate
                      damage; the fourth creates chronic effects most likely
                      to appear over a longer time period. The four charac-
                      teristics are:

                      ®  Ignitafollity, which identifies wastes that pose a fire
                        hazard during routine management. Fires not only
                        present immediate dangers of heat and smoke but
                        also can spread harmful particles over wide areas.
                      ®  C©rr©shfSty, which identifies wastes requiring special
                        containers because of their ability to corrode stand-
                        ard materials, or requiring segregation from other
  Materials that corrode
  and escape from their
containers pose a threat
     to health and the
         environment
                     12

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                               ifjlll^
  wastes because of their ability to dissolve toxic
  contaminants.
  Reactivity (or explosiveness), which identifies wastes
  that, during routine management, tend to react
  spontaneously, to react vigorously with air or water,
  to be unstable to shock or heat, to generate toxic
  gases, or to explode.
  Tonkity, which identifies wastes that, when impro-
  perly managed, may release toxicants in sufficient
  quantities to pose a substantial hazard to human
  health or the environment.
  Several of the methods used to test for the charac-
teristics are identical to those used by the U.S. Depart-
ment of Transportation in its program to control trans-
port of hazardous materials.
  EPA may add to or delete from the list of hazardous
wastes or characteristics identifying a hazardous waste.
Any changes will be published in the Federal Register,
and the public will be given an opportunity to com-
ment on proposed changes.
                                                 13

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Some Facts About Hazardous  Waste

Understanding problems related to managing hazardous waste requires much detailed information,
including the kinds and quantities of waste generated, where they are generated, how they are
managed, and costs of managing them properly. Accurate information of such a broad scope is
difficult to obtain. Inaccuracies result from inconsistencies in data sources, overgeneralizations, and
variations in actual wastes generated within industrial groups; however, the figures presented here


The chemicals and allied products industry generates 60 percent
of industrial hazardous waste:
                                            All others

                                            Stone, clay, and glass products
                                            Fabricated metal products
                                            Paper and allied products

                                            Primary metals

                                            Machinery (except electrical)

                                            Chemicals and allied products
                                            % of Total Hazardous Waste
                                            in the United States
                                                   Source: EPA, Draft Environmental
                                                   Impact Statement, 1979.
Geographically, hazardous waste tends to be concentrated in certain
regions. About 60 percent is generated in  10 States: New Jersey, Illinois,
Ohio, California, Pennsylvania, Texas, New York, Michigan, Tennessee,
and Indiana.
          3-8%
             1 0-5-2%

     2-3% f^3 below 0.5%

% of Total Hazardous Waste


             14
                               Source: EPA, Draft Environmental Impact Statement, 1979.

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were the best available when this booklet was published. As new and improved data are collected,
EPAs figures will be revised and made available to the public; meanwhile, these data provide a
realistic basis for understanding the hazardous waste problem in the United States.
    Generation of hazardous waste by U. S. manufacturing industries in 1980 is estimated at 57
million metric tons (wet)—over half of this is from the chemical industry, a broad industrial category
that produces such common materials as plastics, synthetic fibers, synthetic rubber, fertilizers,
medicines, detergents, soaps, cosmetics, paints, pigments, adhesives, pesticides, and explosives, as
well as numerous other organic and inorganic chemicals used by various industries.


Most hazardous waste  is disposed of by environmentally unsound
methods:

             % of Total Hazardous Waste in the United States
                                                                10%s&und
                                          Source: EPA Industry Studies, 1975-1978.
 Environmentally sound technologies are available for treatment and
 disposal of hazardous waste.  Costs vary widely, according to type and
 volume of waste handled, and are substantially in excess of unsound
 practices:
Incineration  Physical,
(land-based)
               Land-     Chemical
             spreading   fixation
                                   Technology
                                                           treatment
                               Source: EPA, Draft Economic Impact Analysis, 1979.
                                                            15

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• separate hazardous from nonhazardous waste at the
  source and concentrate it, which reduces handling,
  transportation, and disposal costs
• incinerate the waste, or subject it to treatment that
  makes it nonhazardous
• dispose of the waste in a secure landfill (one that is
  located, designed, operated, and monitored —even
  after it is closed — in a manner that protects life and
  the environment)

  Transferring a hazardous waste to another industry is
an option that is receiving increasing attention. Operat-
ing on the principle that one company's waste may be
another's raw material, this option can take two forms:
the materials exchange, which is equipped to handle,
treat, and physically exchange wastes and the informa-
tion exchange, which acts only as a clearinghouse,
leaving generator and potential purchasers to negotiate
directly.
  The first information exchange started in The Nether-
lands in 1972. Since then, the idea has spread quickly in
Europe and is beginning to spread in the United States.
At least 20 information exchanges and 3 materials
exchanges are now in operation  in the United States.
The first information exchange in the United States was
established in 1975 by the St. Louis Regional Commerce
and Growth Association. Typically, information ex-
 ... ©r it can be carried out carelessly without adequate
 environmental safeguards.
                                                  17

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     In EPA studies, this
   industrial incinerator
was successful in almost
 totally destroying DDT;
 it has also been able to
destroy transformer oils
      containing RGBs.
                       changes are run by chambers of commerce or other
                       nonprofit groups. In contrast materials exchanges are
                       usually operated by profit-oriented private concerns.
                         Probably only a small percentage of hazardous waste
                       is suitable for exchange. Purer, less-contaminated wastes
                       stand the best chance of being exchanged. Also, waste
                       is more likely to be exchanged where the purchaser is in
                       the same or a nearby locality, which minimizes transpor-
                       tation costs. The waste exchange, though not a
                       panacea, makes a valuable contribution by reducing the
                       amounts of material to be managed by less desirable
                       options.
                         Related to the exchange option is the recovery of
                       energy or materials. With shortages of raw materials
                       and tighter restrictions on disposal of wastes, recovery
                       will become a more viable alternative. Many wastes
                       contain valuable basic ingredients. And the extraction
                       of materials from concentrated wastes requires less
                       energy—and generates less water and air pollution —
                       than the mining and processing of virgin materials.
                       Consequently, when energy or materials are recovered
                       from hazardous waste, natural resources are conserved
                       and the environment is protected.
                         Incineration is a proven method of destroying organic
                       waste without posing a threat to the environment.  EPA
                       has conducted a number of research and field-scale
                       projects on incineration methods for chemical wastes.
                      Two successful projects carried out in 1979 involved
                      several types of commercial incinerators and 20 differ-
                      ent chemical wastes, including 9 pesticides. These
                      wastes were almost totally detoxified or destroyed. The
                      successful use of cement kilns to destroy chlorine- or
                      bromine-containing organic waste—which is very toxic
                      because it resists degradation and  accumulates in living
                      tissues—is one of the more important results of EPA's
                      demonstration project. The chlorine or bromine in the
                      waste reduces the alkalinity of the residue left after
                      combustion, simplifying disposal. The heat value  of the
                     18

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waste also replaces some of the fuel needed to
manufacture cement.
  Another promising approach to disposing of chSorine-
or bromine-containing organic waste is to burn it at sea
aboard special incinerator ships. This technique,
pioneered in Europe, has been used on several
occasions by the United States, including the disposal of
the Air Force's surplus stock of Herbicide Orange, the
defoliant used in Vietnam. The incineration was aboard
a Dutch vessel, the Vulcanus. The possibility of building
American incinerator vessels is being considered.
  Three kinds of processes can be used to render a
hazardous waste less hazardous or nonhazardous:

• physical processes, such as carbon or resin
  adsorption, distillation, centrifuging, flocculation,
  sedimentation, reverse osmosis, and uStrafiltration
• chemical processes, such as fixation into solids that
  are more readily disposed of,  neutralization, ion
  exchange to remove heavy metals, oxidation, and
  precipitation
• biological processes, such as activated sludge
  treatment to destroy organic  compounds,
  composting of organic-rich wastes, trickling filters to
  promote decomposition, and  controlled application
  on land (wlandfarmingw) to degrade organic
  compounds

  These various options can reduce the amounts of
hazardous waste that must be disposed of directly on
Sand, a crucial concern because the Sand available for
disposal is decreasing, while waste tonnages are
increasing. The hazardous waste management industry,
major waste-generating industries, and EPA are
devoting increased attention to  development of  new,
improved, and less expensive treatment technologies.
But even with new technology, some hazardous waste
will always be destined for land  disposal.
A Dutch vessel, the
Vukanus, can incinerate
hazardous organic
wastes at sea. This
disposal method is
controlled in the United
States under the Marine
Protection, Research,
and Sanctuaries Act.
                                                 19

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                              =
  Sound technologies may be available to manage
hazardous wastes, but EPA studies of 17 industries
between 1975 and 1978 indicate that they are not being
used for 90 percent of the waste generated. The
predominate practice is disposal in unlined impound-
ments (pits, ponds, and  lagoons) and landfills. Up to 80
percent of hazardous waste is disposed of on the
generator's property.
  The least expensive environmentally sound method of
disposal is a secure landfill; however, only a limited
number of secure landfills are in operation in the
United States. Many commercial incinerators pollute the
air when they burn hazardous waste. Dumping at sea,
an inexpensive alternative for companies holding the
required EPA permits, will be sharply reduced in 1981
when all provisions of the 1972  Marine Protection,
Research, and Sanctuaries Act are in effect. The
cheapest alternative of all is the "midnight dumper/'
With only a truck and a total  disregard for public safety,
midnight dumpers can take hazardous waste off gen-
erators' hands for relatively modest fees and then
dispose of it in any one of a number of ways—flushing
it into sewers and ditches, dumping it in lakes and
rivers, dropping it off ships at sea, burying it in
farmland, concealing it  in municipal waste for disposal
in sanitary landfills, and storing or dumping it on open
lots or fields.
  The common practice of open storage has led to
some of the most damaging incidents caused by mis-
management of hazardous waste—the Valley of the
Drums' and a site in Lowell, Massachusetts, being
flagrant examples. The Lowell site dates back to 1970,
when a private corporation was set up to salvage and
reprocess waste from area industries. In 1977, the
company declared bankruptcy, leaving some 20,000
barrels, many rusted and leaking, containing 1 million
gallons of toxic waste. Some of the barrels were only a
few hundred feet from  a stream that flows into the
Concord River, a tributary to the Merrimack. Several
communities get their drinking  water from the Mer-
rimack. Another 250,000 to 300,000 gallons were Seft in
leaking storage tanks. This 5.2-acre site was located only
a few hundred yards from some residences in the Town
of Lowell. With the company  bankrupt, the State of
Massachusetts had to appropriate $1.5 million to clean
up the site.
Drums were stored In
the open at this site in
Lowell, Massachusetts.
The company that
operated the sate went
bankrupt, leaving the
State of Massachusetts
with the formidable
task of clean up.
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                      RCRA:
                      moving toward a
                      safer environment
Under RCRA regulations,
       companies that
  generate wastes may
 test them to determine
  if they are hazardous.
  Harm to human health and the environment caused
by past mismanagement of hazardous waste led to
incorporation in RCRA of a "eradle-to-grave" control
system. This system calls for regulation of hazardous
waste from the time it is first generated through
transport to final treatment or disposal. The concept
uses a pathways approach, so-called because the
movement of hazardous waste destined for storage,
treatment, or disposal is constantly monitored and
controlled/This approach is basically different from that
used to regulate air and water pollution, where specific
standards are tailored for each industrial category. The
pathways approach was chosen because hazardous
waste is mobile and can be disposed of at locations far
from where it was generated. Sn contrast, sources of
industrial air and water pollution are fixed and rela-
tively easy to identify.
  The Congress intended that the individual States
develop their own hazardous waste control systems,
subject to EPA approval. To receive approval, the State
program must be equivalent  to the national regulatory
program developed by EPA. EPA handles the program
only in States that choose not to implement their own
programs or that fail to get approval.
  EPA has developed and proposed a set of six regu-
lations to control all stages of the hazardous waste
management cycle, whether the waste is managed
"on-site" (at the point of generation) or transported to
an "off-site" waste management facility. Promulgation
of all of the hazardous waste regulations in final form
was scheduled for 1980, to take effect 6 months later.
Proposed regulations are always subject to change;
therefore, the following discussion focuses on basic
requirements under the Act.

Generators

  Those who generate potentially hazardous waste in
their operations are required to determine if the waste
is hazardous under the RCRA definition. Thus, the
definition of hazardous waste is the cornerstone of the
national regulatory program. Once a waste is identified
as hazardous, RCRA requires that all significant quan-
tities be tracked throughout their life cycle by means of
                      24

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       Transporters of
hazardous waste play a
        key role in the
     "cradle-to-grave"
     control system of
    tracking hazardous
       waste from the
      generator to the
            disposer.
a transport manifest and by stringent recordkeeping
and reporting requirements. In order to identify a
waste as hazardous, the generator refers to a list of
wastes or tests the waste against the characteristics in
the final regulations. Or, the generator may simply
declare the waste is hazardous. Generators disposing of
their waste on-site must be issued a  permit but would
not need a manifest because no transportation is
involved.
  Generators are the key link in the transport control
system. Under the proposed RCRA regulation, they
must:

• originate a transport manifest, describing the
  amount, composition, origin, routing, and destina-
  tion of each shipment
• use approved containers and label them properly
• select a responsible company to transport the waste
• specify the facility to which the waste is to be
  delivered and assure that it has a valid permit
• confirm that a waste reaches the intended facility
• keep records of information in the manifest and
  report it to an authorized State or to EPA
• notify authorities of international shipments
Transporters

  Transporters must deliver hazardous waste shipments
to the facility designated by the generator, keep appro-
priate records, and report any spills enroute. Hazardous
                       26

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waste transporters do not need permits in the Federal
system, but some States require transporters to register.
  Many of the major problems in the past have been
caused by irresponsible actions of some transporters.
After being paid to take hazardous waste to disposal
facilities, they have instead merely dumped the waste
indiscriminately, without regard for the effects of their
actions. For example, the sewage treatment plant in
Louisville, Kentucky, had to be shut down for several
months in 1977 after a local transporter dumped several
tons of pesticide waste into the sewer system. During
the clean-up, which cost Federal, State, and local
agencies $3 million, raw sewage had to be discharged
directly into the Ohio River. The manifest system is
designed to prevent such practices because generators
can quickly notify authorities if the designated facility
does not receive a  shipment.
  Some portions of the RCRA regulation  on transpor-
ters overlap with provisions of the Hazardous Materials
Transportation Act (HMTA) administered  by the U.S.
Department of Transportation (DOT). Regulations issued
under HMTA have  been amended to make them more
compatible with  the RCRA regulation, thus avoiding
duplication of administrative and enforcement ac-
tivities. Overlapping provisions of the two Acts, covering
labeling, packaging, and placarding of hazardous waste
by generators, are  being administered  similarly. EPA and
DOT jointly enforce regulations when they share au-
thority. EPA regulations take effect if DOT Sacks
authority.
Standards and Permits for Facilities

  Owners and operators of facilities that treat, store, or
dispose of hazardous waste must comply with minimum
standards for assuring that the facilities operate safely.
These standards cover containing, testing, and destroy-
ing wastes so that they cannot contaminate ground
water, surface water, or the atmosphere. There are also
standards for safety and emergency measures to be
used if hazardous waste is accidently discharged, for
training of personnel in emergency situations, and for
keeping records and filing reports. Owners and opera-
tors of facilities are also required to demonstrate
financial responsibility for their operations.
  The owner of a hazardous waste facility must apply
for a permit within a specified time. Under the RCRA
regulation, the applicant must provide information on
the site and the amounts and types of hazardous waste
to be handled. To receive a permit, an applicant must
meet the standards set for the specific type of facility.
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The permit describes the terms, conditions^ and
schedules of compliance, as well as monitoring, -fec-
ordkeeping,ind reporting requirements.
  Many procedures of the permit program under RCRA
are simitar to permit requirements under other EPA-
administered laws. The Agency has consolidated these
programs Into one set of regulations. £P$s objective Is
to move in the direction of processing an applicant's
hazardous waste permit simultaneously with any other
required permits. EPM consolidated permit program
includes:

® the hazardous waste management program under
  RCRA
• the underground Injection control program under
  the Safe Drinking Water Act
® the national pollutant discharge elimination system
  under the Clean Water Act
• the dredge or fill program under the Clean Water Act
• the program for prevention of significant deteriora-
  tion of air quality under the Clean Air Act
State Hazardous

  States must be authorized by EPA to conduct their
own hazardous waste management programs, in order
to receive authorization, the State program must be
equivalent to the national program. Among other
things, the State must have legislation and regulations
that are no less stringent than the Federal standards,
and the State must show that It has the resources to
administer and enforce the program. If a State's pro-
gram does not fully comply with EPA requirements, EPA
may grant the State interim authorization for 2 years,
during which time the program should be further
developed to meet aft authorization requirements.
    State and focal governments have important responsibilities In
   handling environmental emergencies, Denver's fire cfepartotent
   includes a hazardous materials response team and stages mod
       drills (bottom photo) to improve its emergency operations.
28

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key problem areas
  As EPA continues to develop the national program
for hazardous waste management, key issues are
surfacing. One is the very scope of the program. Some
700,000 generators, transporters, treaters, storers, and
disposers of hazardous waste must notify EPA of their
activities and, thus, be brought into the program.
Contacting these individuals and  informing them of the
new RCRA requirements called for development of
complex administrative procedures within the Agency's
headquarters and regional offices^
  Another issue involves the interstate movement of
hazardous waste. Some States believe that the U.S.
Constitution allows them to ban the disposal of waste
originating in other States. This approach runs counter
to the concept of large regional hazardous waste
facilities which, by drawing wastes from several States,
could operate at lower costs than smaller facilities. State
importation  bans could also discourage private invest-
ment in new facilities, thus  leading to a shortage of
acceptable facilities to accommodate all the hazardous
waste being regulated under RCRA. The issue of
importing waste is politically and emotionally charged
and may take years to fully resolve. However, in 1978
the U.S. Supreme Court ruled that certain types of State
wasteJmport bans are a restraint on interstate com-
merce and, therefore, unconstitutional.
  Citizen opposition to the siting of facilities in their
communities is another problem. In fact, a facility in
Illinois, with  valid State permits, was closed down by
court order in September 1978 as a result of local
opposition. The  citizens' role in the new regulatory
program is of ultimate importance, not only from the
environmental viewpoint but for the continued prosper-
ity of their communities. Without support by citizens to
site new waste treatment, storage, and disposal fa-
cilities, conveniently located for industry, some indus-
tries generating hazardous  waste may choose to locate
elsewhere. Lack of citizen involvement and support for
effective hazardous waste management can thus have
an adverse economic impact upon communities.
  The requirement of financial responsibility for owners
and operators of hazardous waste facilities is still
another concern. In the past, some owners took in large
quantities of hazardous waste for treatment, storage,
or disposal, but then declared bankruptcy or simply
abandoned the  site without adequately disposing of
the waste. State and local governments were then
faced with cleaning up the  site at taxpayers' expense.
RCRA's financial  requirements could force some small

30

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operators out of business, thus adding to the problem
of insufficient capacity. However, RCRA provides that
existing facilities may obtain interim status before a
permit is issued. This period can be viewed as a safety
valve while the program is starting up.
informing
               the
  Successful development and implementation of the
national hazardous waste regulatory program depend
upon public support, which, in turn, depends upon
public understanding of the many complex technical,
political, social, and economic issues involved. RCRA
provides several mechanisms that afford the public an
opportunity to assume an active role in the program
and seek to increase public understanding of hazardous
waste issues.

Public Hearings and

  RCRA directs that public hearings and meetings be
held by agencies—Federal and State — during the
development, revision, implementation, and
enforcement of activities required under the Act. This is
to assure that the public has an opportunity to
understand and comment on significant issues and that
the agency gives full consideration to those comments
in making final decisions. The regulations developed by
EPA reflect a careful analysis and integration of the
comments received in the public participation stages. As
Public hearings and
meetings are among
several mechanisms that
afford citizens
opportunities to take an
active part in RCRA
programs. Other
mechanisms include
citizen suits, public
notification
requirements, and
public education and
training programs.

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  Information materials
 heSp citizens to gain an
 understanding of solid
 waste issues. With this
  knowledge, they can
participate effectively in
   decisions that, in the
past, were made largely
   by technical experts.
the Federal regulations are revised and further
developed, and the State hazardous waste programs
are developed and implemented, citizens will have the
same opportunities to participate.

Citizen Suits

  RCRA provides to citizens the right to file suit in
Federal court when other means have failed. Two kinds
of legal actions are possible:

® citizens suits may be brought against any person
  (including Federal, State, and local governments) who
  allegedly violates "any permit, standard, regulation,
  condition, requirement, or order which has become
  effective" under RCRA.
® citizens may request that the Federal courts review
  the decisions of the EPA Administrator on final
  regulations.

Public Information

  The public must be informed if it is to participate
constructively in the decisionmaking process. To assure
citizens an opportunity to become well informed, RCRA
requires EPA to develop and disseminate information
on solid waste management Sn carrying out this
directive, EPA's Office of Solid Waste  produces a variety
of technical reports and other information and makes
them available to the public free of charge. All
materials produced  by the Office since 1966 are listed in
Available Information Materials on Solid Waste
Management This catalog is thoroughly indexed by
subject and updated periodically.
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  Another RCRA provision calls for EPA to develop and
implement citizen training programs. Since 1972, EPA
has made grants to civic, scientific, environmental, and
consumer groups and labor unions for informational
activities on solid waste problems. In 1979, EPA
launched a long-term public information program.
Funded by EPA grants, the program Waste Alert I was
undertaken by the American Public Health Association
(as coordinator), the Environmental Action Foundation,
the League of Women Voters Education Fund, the
National Wildlife Federation, the Technical Information
Project, and the Izaak Walton League of America. With
their national memberships and supporters, plus the
knowledge acquired in earlier EPA public education
programs, the coalition is well qualified to reach a
national audience.
Waste Alert 1 has four goals:

• to stimulate public support for effective management
  of solid and hazardous waste
• to help the public understand the issues and
  problems related to siting solid waste facilities
• to encourage citizen participation in resource
  conservation and recovery programs that can
  decrease reliance on disposal
• to promote cooperation among public health and
  environmental groups, State and regional waste
  agencies, industry, elected  officials, and citizens'
  groups.
EPA launched Waste
Alert!, a major citizen
participation program,
in 1979, with a
conference in New
Orleans. Under this
long-range program, a
series of conferences is
being held across the
country to involve
citizens in solid waste
issues.
  To achieve these goals, Wast© Alert! began by
holding conferences in all the EPA regions across the
country. The objectives of this first phase of the
program are:

• to identify and train citizen leaders concerning
  legislation affecting waste management
• to assure that the public has the opportunity to
  understand official programs and proposed actions
  and that the government fully considers the public's
  concerns
• to keep the public informed about significant issues
  and proposed changes in projects or programs
• to assist in planning for State conferences and
  encourage information programs at the local level

  The second phase of Waste Alert I consists of
workshops at the State and local community levels.
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     To be part of the solution to the; hazardous
     waste problem —

     • recognize that we are all part of the problem —
       hazardous waste inevitably results from the
       production of the many material goods that help
       Americans to enjoy a high standard of living
     ® reduce the amount of materials we  waste—this will
       not only reduce the quantities of hazardous waste
       generated,  but will also conserve natural resources,
       reduce solid waste disposal problems, and save us
       money
     • understand the many complexities of the hazardous
       waste problem — EPA, public interest groups, and
       State and local governments are sources of
       information
     • participate
       —join Waste Alert! by writing to  EPA, by working
         with a local group already concerned with solid
         and hazardous waste issues, or by getting an
         existing organization to expand its program to
         address such issues
       — take advantage of the many opportunities RCRA
         provides for the public to participate
     ® recognize that there are no easy solutions
This abandoned disposal site in Deerfseld, Ohio, discharged chemical waste
to a stream which flows into the nearby Berlin Reservoir. From 10,000 to
15,000 drums, some of which contained waste from the manufacture of

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  everybody's problem
    Because of the many times in the past when
  hazardous waste was mismanaged out of carelessness,
  indifference, or ignorance, most communities resist new
  sites—and sometimes continuing operation of an
  existing site. Hazardous waste facilities share a common
  characteristic with many other "undesirable" neighbors
  — prisons, highways, airports, and sewage treatment
  plants, for example. No one denies the need for them,
  but no one wants them nearby.
    The resistance to new sites exists for a variety of
  reasons, including Sack of knowledge about hazardous
  waste and hazardous waste facilities (what they are and
  what they do); distrust of government decisions;
  increase in noise, truck traffic, and odor; aesthetics;
  potential effect on land value; uncertainty of how a
  community that allows a disposal facility will benefit;
  and the belief that the facilities may do substantial
  harm to human health and the environment. These
  fears may not be based upon the community's own
  experiences, but rather upon published accounts of past
  incidents in other locations.
    New sites for treatment, processing, and disposal
  must be found as the national hazardous waste
  management program goes into effect. Some existing
  disposal sites must be closed if they are unable to meet
pesticides and plastics, were dumped here. The State has appropriated
over $4 million to clean up the site. An important objective of RCRA is t©
prevent such uncontrolled practices.

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          Citizens and
  governments working
together hold the key to
        the solution of
      hazardous waste
            problems.
the new standards. At the same time, the tonnages
requiring disposal will increase because industrial
production is increasing. Moreover, wastes formerly
handled by environmentally unsound and often illegal
methods will have to be disposed of by sound methods
in legally permitted disposal sites.
  The national regulatory controls will very likely
encourage conservation practices. Waste management
costs generally rise as safer methods are required, which
should be an incentive to reduce generation of wastes.
Similarly, higher disposal costs will make resource
recovery processes comparatively more economical. But
in the foreseeable future, there will be some wastes
that must be disposed of on land. RCRA regulations are
intended to ensure that new landfill sites are located in
areas that are geologically suitable and designed and
operated to  protect public health and the environment.
  Pogo, the famous comic-strip character, once
observed: "We have met the enemy and they are us." In
terms of the nation's hazardous waste problems, Pogo
might have said: "We have found the sources of
hazardous waste, and they are us." The American way
of life as we  know it today depends upon an
abundance of manufactured material goods, and their
manufacture generates  hazardous waste as a
by-product. If we are to continue to enjoy our present
lifestyle, we must begin  as a nation to accept
responsibility for working toward  a solution of the
hazardous waste problem.
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U.S. Environmental Protection Agency
Region 5 Library (PH2J)
77 West Jackson Blvd., 12th Floor
Chicago, IL 60604-3590

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