SW-22P
WASTE MANAGEMENT
TECHNOLOGY
and
RESOURCE & ENERGY
RECOVERY

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PROCEEDINGS
OF THE FIFTH NATIONAL CONGRESS

WASTE MANAGEMENT
TECHNOLOGY
and
RESOURCE fi ENERGY
RECOVERY
Cosponsored by the National Solid Wastes Management Association
and the U.S. Environmental Protection Agency
Dallas, December 7-9, 1976
     230
        ago, Illinois  L-J
     U.S. ENVIRONMENTAL PROTECTION AGENCY
                  1977

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    U,3.
An environmental  protection publication  (SW-22p)  in  the  solid waste management series.


   For sale by the Superintendent of Documents, U. S.  Government  Printing Office
                            Washington,  D.C.   20402

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FOREWORD



     The U.S. Environmental Protection Agency and the National Solid Wastes



Management Association's Institute of Waste Technology and Waste Equipment



Manufacturers'  Institute co-sponsored the Fifth National Congress on Waste



Management Technology and Resource and Energy Recovery in Dallas, Texas, on



December 7-9, 1976.



     These technical and planning-oriented Congresses have served to advance



the awareness of developing technologies and practices and to facilitate



their utilization.  This Fifth Congress gave particular attention to the



three major areas of solid waste management:  hazardous and chemical wastes,



land disposal and resource recovery.  Careful assessment of operating ex-



perience in these areas was featured on the program.



     The meeting included participants from State and local, as well as the



Federal government, waste management and resource recovery firms, universities,



research and development companies and the financial community.  The wide



range of viewpoints included in this volume proved a valuable store of current



information and opinion on vital areas of interest in the solid waste manage-



ment field.



     We acknowledge the leadership of NSWMA's Institute of Waste Technology



and Waste Equipment Manufacturers' Institute in organizing these discussions.



Special acknowledgement is due to Peter Vardy, Vice President, Environmental



Management-Technical Services, Waste Management, Inc. who served as Chairman



of the NSWMA Institute of Waste Technology and Glenn Park, Vice President-



Director of Engineering, Peabody Solid Wastes Management, and Chairman of the



NSWMA Waste Equipment Manufacturers' Institute.  Recognition is also deserved
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   .ollowing organizations which lent their support to this conference:

American Public Works Association

American Society of Mechanical  Engineers

Association of State and Territorial Solid Waste Management Officials

National Association of Counties

National Association of Regional Councils

National League of Cities/11.S.  Conference of Mayors
                                    Sheldon Meyers
                                    Deputy Assistant Administrator for
                                    Solid Waste Management
                                    Eugene J. Wingerter
                                    Executive Director
                                    National Solid Wastes Management Association
                            iv

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TABLE OF CONTENTS
                         OPENING GENERAL REMARKS                            PAGE
STATEMENT OF MEETING PURPOSE
    Wayne D. Trewhitt	
TO WHAT EXTENT IS FEDERAL DIRECTION AND REGULATION NEEDED?
    Sheldon Meyers	
FORECAST OF FUTURE TRENDS FOR LAND DISPOSAL AND RECOVERY OF WASTES
    James R. Greco	
                  RESOURCE RECOVERY AND WASTE PROCESSING
MARKETING THE OUTPUTS - ENERGY, FUELS, MATERIALS
    Harvey W. Gershman	
PROCUREMENT - WHAT ARE THE ESSENTIAL CONSIDERATIONS?
    Robert A. Lowe	
THE FINANCE-ABILITY AND THE FINANCING OPTIONS FOR RESOURCE RECOVERY
    Robert H. Aldrich	
    Charles A. Ballard	
RECOVERING ENERGY ON-SITE - THE EMERGING ROLE OF MODULAR INCINERATOR-HEAT
RECOVERY SYSTEMS
    Ross E.  Hofmann	

EXPLOSION PROTECTION IN REFUSE SHREDDING
    Dr. Robert G. Zalosh	

WHAT ABOUT THE USE OF SUPPLEMENTAL FUELS?
    Stephen A. Lingle	

PITFALLS IN PLANNING - THE ENERGY PURCHASER'S STANDPOINT
    Alden H. Howard	

SOURCE REDUCTION AND SEPARATION - IMPACT ON RECOVERY FACILITIES
    Dr. John Skinner	

REGIONALIZATION - ITS ROLE IN RESOURCE RECOVERY
    Stephen G. Lewis	

SOUTH CHARLESTON, WEST VIRGINIA - IN-DEPTH CASE STUDY
    Joseph Riyero	

SAUGUS OPERATIONAL EXPERIENCE
    John Kehoe, Jr	

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                                                                            PAGE

                             FEATURED ADDRESS
INDUSTRY'S COMMITMENT TO TECHNOLOGY AND SERVICES
    Peter Vardy	
                   LANDFILL AND CHEMICAL WASTE DISPOSAL
CHEMICAL WASTE LANDFILL DEMONSTRATION:  THE MINNESOTA EXPERIENCE
    Robert A. Silvagni	
GROUNDWATER PROTECTION SYSTEMS
    John R. Reinhardt	
HAZARDOUS WASTE REGULATORY POLICY ALTERNATIVES
    John P.  Lehman	
    Rosalie Grasso	
    Dr. Harvey F. Collins	
WHAT IS THE ROLE OF 208 REGIONAL PLANNING ORGANIZATIONS IN SOLID WASTE
MANAGEMENT
    Robert A. Colonna	
    Maryann Dean	
LINERS - VIABLE OPTIONS AND THEIR APPLICATIONS
    Dr. Henry E. Haxo	
THE IMPORTANCE OF SOIL ATTENUATION FOR LEACHATE CONTROL
    Dr. Wallace Fuller	
THE APPLICATION OF SLUDGE TO LAND
    Dr. Eliot Epstein	
    Dr. James F. Parr	
THE DILEMMA OF LIABILITY AND PERPETUAL CARE ISSUES
    Michael J. Shannon	
    John G. Pacey	
THE ECONOMICS OF LANDFILLING AND PROCESSING - TODAY AND TOMORROW
    John Thompson	
GROUNDWATER PROTECTION ISSUES
    Eugene A. Glysson	
                                      vi

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                                                                            PAGE
                         EFFECTIVE STATE PROGRAMS
THE IMPORTANCE OF AN EFFECTIVE STATE SOLID WASTE MANAGEMENT PROGRAM
    William G. Bentley	
                    GOVERNMENT RESOURCE RECOVERY PLANS
RHODE ISLAND SOLID WASTE MANAGEMENT CORPORATION
    Lou David	
MIDDLESEX COUNTY, NEW JERSEY
    Theodore O'Neil and Garrett Smith.

CITY OF RICHMOND, VIRGINIA
    Michael Fiore, P.E	
                                APPENDICES
NSWMA INSTITUTE OF WASTE TECHNOLOGY	

NSWMA WASTE EQUIPMENT MANUFACTURERS' INSTITUTE.
                                      vii

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OPENING GENERAL REMARKS
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                  "Opening General  Session Remarks"
                                 by
                          Wayne D.  Trewhitt
                     Vice President - Secretary
                    Easley and Brassy Corporation
                                 and
                              Chairman
                 NSWMA Institute of Waste Technology
Certainly this Fifth National  Congress on Waste Management Technology and
Resource and Energy Recovery promises to be as revealing and challenging
as the previous four.   And again we are pleased to acknowledge the co-sponsors
of these conferences -- the U.S. Environmental Protection Agency's Office of
Solid Waste (formerly Office of Solid Waste Management Programs) and the
National Solid Wastes Management Association's Waste Equipment Manufacturers'
Institute and Institute of Waste Technology.   Additionally, thank you's go to
the following associations who have lent their support to this important conference:
              American Public Works Association Institute of Solid Waste
              American Society of Mechanical  Engineers
              Association of State and Territorial Solid Waste Management Officials
              National Association of Counties
              National Association of Regional Councils
              National League of Cities/U.S.  Conference of Mayors
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With the support of fine organizations such as these, this Conference truly



reflects the broadest possible perspective on the key issues in a candid and



forthright manner - to that end this Congress is directed.








As you are likely aware, the focus of this year's Congress is upon resource



recovery, waste processing, landfill ing and hazardous waste disposal.  Two con-



current forums are planned -- mini-conferences if you will -- each including



four sessions - 2 of which are technically-oriented, 2 which are management-



oriented.  Fewer speakers this year are identified, so as to allow more in-depth



presentations, thorough critique and amplification by expert panelists, and ample



opportunity for audience participation.  For those of you who were in attendance



at the Fourth National Congress, you may recall  that the audience dialogue often



provided the most stimulating, controversial, and provocative discussions.  We



encourage that response at the sessions this year.







At the Business Luncheon planned for this afternoon from 1:00 to 2:30 p.m. in



the Conquistador Room 1 and 2, Peter Vardy, Vice President of Environmental



Management, Waste Management, Inc. and Chairman  of NSWMA's Institute of Waste



Technology will deliver an address in behalf of  the Institute and what we have



witnessed over the past 2 years.







Most notably at this Congress and following it,  we should all strive for



cooperative understanding and reasonable implementation of the newly enacted



"Resource Conservation and Recovery Act of 1976".   This Act is likely to be
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often referenced and much discussed throuqhout the next two days.  To fully



convey the purpose and likely impact of the Act we are pleased to have Mr.



Phil Cummings, Staff Counsel, Senate Public Works Commitee, and Mr. Sheldon



Meyers, Deputy Assistant Administrator, U.S. EPA with us.   Mr. Cummings who



played an instrumental role in assuring passage of the Act will be featured



as our Luncheon Speaker on Thursday.  Mr.  Meyers, who this past summer assumed



the duties of the Deputy Assistant Administrator's position.  He will speak on



the topic "To What Extent Is Federal Direction and Regulation Necessary?".
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THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976— EVERYBODY'S BUSINESS

                            Sheldon Meyers*

     Good Morning.  I am pleased to be here and to have this opportunity

to participate in the opening session of the Fifth National Congress on

Waste Management Technology and Resource and Energy Recovery.  My

assigned task this morning—which was, of course, formulated many weeks

ago—is to answer the question:  "To what extent is Federal direction or

regulation needed?" On the 21st of October, when the Resource Conservation

and Recovery Act of 1976 was signed into law, the answer to this question

was provided to all of us.  I heard the answer loud and clear and applaud

it with vigor.

     The Resource Conservation and Recovery Act of 1976 is without doubt

one of those kinds of laws which political scientists cite as evidence

that the system works.  That is to say, it is among those laws which are

truly reflective of the will of active public opinion on a given topic at

a given historical moment.  Built on  the foundation of the Solid Waste

Disposal Act of 1965 and the Resource Recovery Act of 1970 the Resource

Conservation and Recovery Act of 1976 is the evolutionary product of

several years of deliberations and hearings held by a number of committees

of both houses of the Congress.  Whether you fully agree with it or not,

Whether or not you think that it emphasizes one  facet of solid waste
      *Deputy Assistant Administrator, Office of Solid Waste, 'J.S.
Environmental Protection Agency.   Presented at the Fifth National
Congress on Waste Management Technology and Resource and Energy  Recovery,
December 8, 1976, Dallas, Texas.

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management too much and another too little, you cannot deny that the




Congress did its work well.  The Act addresses the complete spectrum of




problems and opportunities which are so intrinsically a part of the




solid waste management issue. It reflects a full awareness of those




areas where we have a high level of technical understanding and knowledge




as well as those areas of technical uncertainty and relates both to the




social and economic ramifications of improved practice.




     The Act reflects the fact that all levels of government, industry




and a variety of environmental and other public interest groups had full




opportunity to be heard.  It is no wonder then that both houses of




Congress passed it by overwhelming votes.




     RCRA integrates the primary thrusts of the two earlier solid waste




acts.  It acknowledges the interrelation of the resource-use and public




health issues associated with land disposal.  It mandates a series of




actions, requiring effort on the part of all  levels of government,




industry and the public—over time—to insure that progress in protecting




health and the environment will not be inhibited by a  failure to move




forward in the areas of resource conservation and recovery.




     Make no mistake about it.  The Congress  had a difficult  job on its




hands.  A long hard  look at  the status of  solid waste management reveals




that this issue touches the  very frontiers  of our society's movement




toward environmental responsibility.  How  we  deal with solid waste




influences, and is,  in turn, influenced by,  far-reaching  social and




economic issues.  These range  from  the attitudes of the individual




citizen and consumer,  through  how we  extract, manufacture and market





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products, to such complex issues as dep-etion allowances ana international




trade policies.  It is no wonder tnat it took a while and that the Act




does not provide immediate, ready-made solutions to all the varied




problems and perplexities we have been debating for so many years.




Instead, the Act calls for new patterns of interaction among all levels




of government, the assumption of key responsibilities by industry on




several fronts, and for meaningful public understanding and participation




in all the major activities mandated by the Act.




     In my opinion, this is as it should be.  Particularly if we examine




the Resource Conservation and Recovery Act of 1976 in light of the




recently passed Toxic Substances Act and the Safe Drinking Water Act  it




becomes apparent that the Congress is reflecting a new dimension in




public understanding of what is required to  improve the environment.




Tn^s iew understanding goes far beyond the relatively simplistic attitudes




so popular a decade ago, when many seemed to think that placing stoppers




on air polluting stacks and water polluting outfall pipes was all that




was needed to  save us from burgeoning environmental problems we had




neglected during cwo centuries of technological and economic achievement.




     Those of  us in this room are bound to see this new law, most of  the




time, from a perspective that narrowly reflects each person's particular




area of  expertise and interest.  This is inevitable.  Nevertheless,  it




is essential that we all draw back from time to time and attempt  to  see




it whole, with all of its many provisions in focus,  from the small end




of the  telescope.  That, of course,  is what  I  am doing  this morning.




     Viewed from such a perspective,  I think we can  speculate with some




degree  of certainty on the law's essential meaning.  It means that our





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country is now ready to face the fact that the land is a natural medium




which needs to be protected just as air and water do and that resource




conservation and recovery are a key element in the process of achieving




environmental quality.




     The sink of last resort is going to disappear as an inexpensive




option for hiding our mistakes and in its place environmentally sound




procedures for dealing with wastes will emerge.  I believe that all the




provisions of the Act are supportive of this goal within which, by no




means our only, but certainly our most urgent, necessity is to move




rapidly toward controlling the most obviously undesirable portions of




the waste stream.  Hence, the special, urgent and necessary emphasis 011




all aspects of hazardous wastes management.




     Subtitle C of the new law brings management of hazardous wastes




under Federal-State regulatory control.  Hazardous waste is defined in




the Act as any waste  that "because of its quantity, concentration, or




physical, chemical, or infectious characteristics" may seriously threaten




public health or the  environment.  EPA is required to identify  these




wastes, set standards for their management from cradle to grave and




issue guidelines for  State programs over the next year and a half.  The




standards go into effect 6 months after their promulgation.  States are




to  establish hazardous waste control  programs that will meet Federal




requirements and issue permits for treatment, storage, and disposal of




such wastes.  In those States which choose not to do so, Federal




regulations will apply.  Civil and criminal penalities are established




for noncompliance.  To assist States  in developing and implementing a




hazardous waste program, $25 million  in grants is authorized to be

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appropriated for each of fiscal years '78 and '79.  Please note that we

do not yet have appropriations under the new law, and therefore do not

yet know what sums will actually be available for implementation of the

hazardous waste or other provisions of RCRA which require funding.

     The new law will increase financial and technical assistance to

State, regional, and local agencies for the development of comprehensive

programs of environmentally sound disposal, resource recovery, and

resource conservation.  "Resource conservation" is defined in the Act as

"reduction of the amounts of solid waste that are generated, reduction

of overall resource consumption, and utilization of recovered resources."

EPA will issue guidelines for State solid waste plans.  To facilitate

regional planning, EPA guidelines will also be issued for identifying

regional areas with common solid waste problems.  The amount of Federal

funds authorized for grants to States for developing and implementing

State and regional plans is $30 million for fiscal '78 and $40 million

for fiscal '79.  In addition, $15 million is authorized for each of those

years for grants to regional and local agencies as well as States to

implement specific programs that fall within approved State plans.

     For a State to be eligible for these grants, its solid waste plan

must mee* minimum criteria.  Among them is inclusion of a requirement

that all solid waste be utilized for resource recovery, disposed of in a

sanitary landfill, or disposed of in some other environmentally sound

manner.  The plan must also provide for the closing or upgrading of all

existing open dumps.
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     Criteria for identifying open dumps and for identifying sanitary

landfills will be published by EPA no later than October 1977,  and the

Agency will conduct a national inventory of all open dumps within the ]2

months that follow.  The Act mandates that all open dumps throughout the

country must be closed or upgraded by 1983 and forbids the creation of

new dumps.  Special grant assistance to help meet these new requirements

for land disposal facilities will be available for rural communities.

Twenty-five million dollars for FY 78 and 79 is authorized for assistance

to rural areas.

     Grants to a limited number of "special communities" are also

authorized.  These are to be communities of less than 25,000 population,

most of whose solid waste comes from outside their boundaries, causing

serious environmental problems.

     Recognizing that States and many local governments will face very

difficult problems in meeting the goals and requirements of this legislation,

the Act provides for technical assistance teams, called "Resource Recovery

and Conservation Panels," which will be available to State and local

governments on request.  The teams will be prepared to assist in upgrading

collection and disposal as well as in developing resource recovery and

resource conservation systems.  We expect to field these teams from our

Regional Offices,  where they can gain familiarity with conditions  in

specific geographic areas.

     Wide general  authority  is conferred by the law for studies, research

and development, demonstrations, training, and information  activities.

The authorization  for these  functions total $45 million for fiscal  "78.

The. objective is to strengthen and increase the technological base,

available  expertise, and public understanding  that must underlie State

and  local programs in order  for them to succeed.
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Demonstrations in resource recovery and improved solid waste disposal




facilities are authorized.  Studies are required in many specific areas,




including sludge management, source separation, agricultural and mining




wastes, actions to reduce waste generation, collection methods, incentives




for recycling, the imposition of disposal charges on products, and the




problems of acquiring land for solid waste management facilities.




     In the task of building up the technology for solid waste management,




we in the Office of Solid Waste will continue to share responsibility




with EPA's Office of Research and Development.  In the energy recovery




projects, EPA and the Energy Research and Development Administration are




required to work out cooperative arrangements.' The commercialization of




proven resource recovery technology is assigned by the Act to the Department




of Commerce.




     A large-scale study of resource conservation will be undertaken




by an interagency committee headed by the EPA Administrator.  The study




will cover the effects of current public policies on resource use and




the consequences for the environment and society, and the potential




effects of proposed measures, particularly the imposition of disposal




charges on products.




     In the provisions for information activities, special emphasis is




placed on rapid dissemination of information, on public education programs,




and a central reference library of solid waste management data and other




materials.  Efforts are required not only to inform the public but also




to promote their participation in the development of Federal and State




regulations, guidelines, and programs.






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     The authorization for EPA for general administration of the programs

under this Act is $35 million for fiscal '77—more than double last year's

appropriation—$38 million for fiscal '78, and $42 million for fiscal "79.

At least 20 percent of this is to be used for the Resource Conservation

and Recovery Panels I described earlier and at least. 30 percent for

carrying out the hazardous waste program.

     There, in a rather large nutshell, are the major provisions of the

law.  It is obvious from the nature and number of specified activities
                                                             i
and the increased authorizations for funding that national perceptions

of solid waste management issues have undergone major changes.

     Perhaps of greatest significance is the heightened concern about

threats to health and environment from hazardous wastes and from inadequately

controlled land disposal.  This concern has developed from damage incidents,

from investigations of recent years, and from the realization that

pollution controls to protect air, waterways, and oceans are resulting

in rapidly mounting loads of residues destined for the land, a heretofore

largely unprotected medium. The provisions  in the Act for Federal regulation

of hazardous wastes and the prohibition of  open dumping are the strongest

in the Act, and are unprecedented in Federal legislation in the field

of solid waste management.  The Act clearly provides for State administration

and enforcement, with Federal power serving as a necessary backstop

where States fail to act.  The provisions for assistance to the States

for developing programs that meet basic  standards make that quite clear.

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     For the first time, sludges are specifically included in the




definition of solid waste in the legislation.  Sewage sludge disposal is




already a perplexing, expensive problem for many cities, and by 1985,




the quantity of sewage sludge generated is expected to double as a




result of improved wastewater treatment.  Sludge is prominent among




those wastes which we believe can be put to work to convert a problem




into an environmental asset.  Its value as a soil conditioner for non-




food-chain use is widely known.  Since some sludges contain heavy metals




and other contaminants, the use of sludge for food crops requires




careful analyses including testing of both the sludge and the soil prior




to application.  Identifying safe, economic, and acceptable means of




sludge disposal and utilization is a matter of high priority for EPA.




     Sludge management represents only one of many instances in the




field of waste management where, partly in response to environmental




problems of disposal, attention has increasingly turned to means of




utilizing waste as a resource.




     Federal assistance for planning and building resource recovery




facilities is available under the Act for State, regional and local




solid waste programs, and as demonstration grants.  No large financing




mechanisms or loan guarantee provisions were included in the Act, but in




view of the current level of technology and the unpredictability of




markets for recovered products, the emphasis on regional and statewide




planning and on demonstrations and evaluations at the Federal level is




appropriate.  Source separation methods for materials recovery are also




cited for support and study, and though lacking the glamour of the




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large-scale technological systems which depend in large measure on




energy recovery for their economic viability, source separation approaches




may one day be regarded as the most effective means of recovering




materials from the waste stream.




     It is noteworthy that waste reduction is clearly recognized in the




Act as part of the continuum of processes that make up sound solid waste




management.  One of the specified objectives of Federal assistance to




State and local programs is to encourage resource conservation, and it




is a required subject of studies and information dissemination




activities.  Further development of methods and policies in resource




conservation are badly needed. Much of the interest in this area has in




the past been concentrated on packaging but there aie many other issues,




relating to measures of greater and lesser economic scope, that also




must be grappled with.  The studies mandated in the Act of public




policies related to resource use, including the concept of placing




disposal charges on products and thereby creating economic incentives  to




avoid waste, should contribute  substantially to a better understanding




of the directions  in which this country should move to promote optimum




resource use.




     The new law thus addresses issues in solid waste management that




have relatively recently come to the fore in the public consciousness.




And, as I have already  implied, it also carries forward the continuing




emphasis on the State program as a major key to successfully  unlocking




the opportunities  inherent in waste problems.  The provisions of the




new Act for planning and program grants, technical assistance,  research




and demonstrations, and information collection and dissemination should  all





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serve to enlarge the capabilities of both States and local governments
to fulfill their increased responsibilities.
     In the Office of Solid Waste in EPA, we are involved in the complexities
of getting the new Act under way.  The nature of RCRA demands the involvement
in our plans and deliberations of other components of EPA.  These include,
in addition to air, water, pesticides and toxic substances components,
the Office of Planning and Management, the Offices of General Counsel
and Enforcement, the Office of Regional and Intergovernmental Operations
and several components under the supervision of the Assistant Administrator
for Research and Development.  The last mentioned is especially important.
Major unmet needs in this field depend on a variety of research efforts
cited in Subtitle H of the Act.
     But of course this is not EPA's Act, it is the public's, and as all
of us have had ample opportunity to learn in recent years, the far-
ranging issues influenced by solid waste management cannot be properly
characterized, let alone resolved, if the only active participants  in
the process are those of us who regularly read the technical literature
and have the professional opportunity to attend meetings such as this.
The framers of the Act understood this very well and made it clear that
solid waste is everybody's business.  Hence they called for rapid information
dissemination, public education and public participation programs.  The
Congress understood that even those represented in the audience today,
who have varied positions and interests and sometimes conflicting views,
are nevertheless an in-group, and that all in-groups tend to reinforce
their own biases,
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     I assure you that I intend to take the public information and




public participation requirements of this legislation very seriously




indeed.  Our Regional offices will play a major role in this activity,




to ensure full State and local governmental involvement and benefit.




Next week, on December 16, we are holding our first informal Public




Participation Meeting in Washington, to give representatives of major




governmental, industrial, environmental and other organizations the




opportunity to give us their preliminary views, attitudes, and suggestions




on the planning and implementation of the RCRA.





     As I implied earlier, the Act takes note of what we know, but just




as certainly of what we don't know. Moreover, since scientific knowledge




by its very nature is always incomplete, public awareness, understanding,




and participation  are absolutely essential.  Without it, we would have




little chance of defining and regulating hazardous wastes, and even less




of upgrading land disposal overall, phasing out the use of open dumps,




and bringing into existence a new magnitude of activity in the areas of




resource recovery and conservation.




     Our field is one in which, until quite recently, few of the practitioners




really thought of themselves as being governed by the same environmental




and public health considerations which have long applied to other environmental




problems, such as air pollution.  The new Act makes it clear that this




is an illusion which we must now cast off.  Since this is so, I shall




close my remarks today with two quotations from Dr. Leroy E. Burney who




was Surgeon General of the U.S. Public Health Service way back in 1958,




when the first National Conference on Air Pollution was held, three




years after the first Federal Air Pollution Act was passed.





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Dr. Burney said, and I quote:


     "In law, the suspect is innocent until his guilt has been

     proved beyond reasonable  doubt.  In the protection of

     human health, such absolute proof often comes late.  To

     wait for it is to invite disaster, or at least to suffer

     unnecessarily through long periods of time.

     "Many years ago, before anyone had seen a germ, or positively

     identified a single causative agent of epidemic diseases, far-

     sighted leaders observed the association between epidemics and

     filth.  Wherever they had sufficient foresight to act on this

     circumstantial evidence, they made striking progress.  Cleaning

     up the city filth resulted in better health.  Years later,

     they found out why.

     "I suggest that our present position with respect

     to contemporary problems, especially those relating to

     the urban environment, may be parallel to that of

     Pasteur's predecessors."

Later on, in that same address, Dr. Burney made another statement which

also seems particularly pertinent to our situation in solid waste management

today.  He said, and I quote:

     "The problems that come as byproducts of our almost

     unbelievable material progress demand everybody's skills

     and knowledge.  More than that, they demand genuine

     cooperation. We can no longer ask, Who's going to be

     in charge? or Who's going to get the credit? We must

     ask How can we most effectively work together?"

     Thank  you.
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 FORECAST OF FUTURE TRENDS FOR LAND DISPOSAL

           AND RECOVERY OF WASTES
               James R. Greco
             Technical  Director
National Solid Wastes Management Association
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     Nearly three years ago a market study of the solid waste management field

was conducted by a nationally known market analysis firm.  The opening paragraph

of the summary section concluded that:

          "The solid waste management program in the United States
           will continue to expand during the decade as Federal and
           state governments continue to enforce legislation and laws
           that have been and will be enacted to improve solid waste
           management practices and to recover either useful materials
           or energy from the ever-increasing amounts of solid wastes
           generated".

Certainly, the intent of the Resource Conservation and Recovery Act of 1976

is to improve solid waste management practices and to encourage expanded re-

covery of useful materials or energy - in addition to the conservation of

valuable material and energy resources and the protection of the environment.

The Protection of the Environment is perhaps the central and most significant

aspect of the new law.  It is key to the dual mandate for the prohibition of open

dumping and regulating the storage, transportation, treatment, and disposal of

hazardous wastes. Certainly, the business environment for land disposal and hazardous

waste management will thrive with the promulgation of these provisions - and

resultingly, resource recovery programs, likewise.  Whether this scenario will un-

fold, however, is legitimately questionable!  One reason being as to whether the

law's mandate will be implemented with sufficient funding authorizations and ap-

propriations.  Another reason may be the legal morass that can result because of

the possibility of citizen suits challenging the effectiveness of the regulations.

Nevertheless, let me postulate an example of trends for land disposal and recovery.


By the end of this decade, hazardous wastes will come under a control system.  Few

hazardous wastes will be indiscriminantly put into or onto the land.  Consequently,

the "pollution potential" of land disposal sites will be lessened, perhaps

dramatically!  I believe the prohibition of open dumping will be implemented

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gradually and slowly.  Although by law open dumping should be non-existent by

1983, it may not be economically practicable to meet this deadline much sooner

than the early 1980's.  Naturally, with the ban on open dumping, more communities

will begin to implement resource recovery programs as feasibility and economic

viability become attainable.  How do I feel about "resource recovery'"?  I

believe we as an industry have entered a period of "responsible optimism" where

solid waste management/resource recovery systems are more realistically considered.

Perhaps the most revealing fact which has surfaced during the past year is that

resource recovery technology can be part of the solid waste management system

and is also viewed firstly as a disposal option and secondly, but importantly,

a recovery opportunity.  As far as the focus for recovery technology - more emphasis

will be placed on materials recovery study, research, and development that was  not

anticipated last year.  Materials recovery not only for recycling glass and metals

but also on the production of new process materials and feedstocks for manufacturing

processes.


Ironically, the success of the new law and the shape of the future may not be

ultimately determined by the Federal government, State governments, local govern-

ments, or the private sector - but by the general public.  The general public has

not seemed to perceive solid waste management.  We have failed as an industry

to convey to the citizenry our identity as an "environmentally needed" industry.

We must also act to do so urgently but responsibly - lest we, as an industry

find ourselves in a situation where:

     (l) the public focuses on solid waste management problems and A pollution
        potential perspective rather than pollution abatement:

     (2.)the public delays the commencement of environmentally acceptable
        facilities and sites via the permit process;

     ( ') the public is unwilling to pay the costs of improved solid waste
        management practices, environmental protection, resource conservation,
        and resource recovery:
                                 -20-

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     (4) law suits are filed to challenge the regulations and accelerate
        the closing of dumps; and

     (5) with perhaps a Catch-22 situation arising .

Certainly, we, as responsible governmental officials and private enterprise,

must work intensely to build the environmental protection character of our

industry in the public's mind.  Public law 94-580 can be a step in the right

direction and should be.


In the October, 1974 issue of Scouting Magazine, there appeared an article

entitled "There's Gold in Your Garbage".  I surmised that the magazine's reader-

ship were youths who must have been amazed when they read about the "gold" in

their garbage.  Then I fantasized.  Suppose there really was gold in the garbage?

Would not the scouts pick it out and extract the monetary value for themselves

if they recognized the gold in the garbage?  But suppose the scouts did not see

this treasure but the refuse collector did.  The collector would likely "source

separate" to pull the gold before it was mixed in with the trash, provided that

the householder (scout) would cooperate.  But suppose the collector like the

householder failed to perceive that the garbage did contain gold, and the local

government suspected some profit from the community's discards (which may be laden

literally with gold)?  To find that gold and realize its value, perhaps a central

plant would be built, mechanized and tuned to pull upon demand the gold from the

otherwise valueless stream.  But then again, suppose neither the householder, nor

the collector, nor the local government thought there was gold in their garbage -

or perhaps it was just too difficult to find?  Well the gold might then be buried,

hidden in the rubbish, with hopes that some day it will be mined to fruition.  But

if that hope diminishes, the scout - with whom this short story began- might deduce

                                 -21-

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that it makes no sense to search for gold where none may never exist, and he




may conclude that in the end it makes no sense to handle vast amounts of wastes




when the volumes might somehow be reduced.







The solid waste management industry certainly is experiencing much debate and




discussion as to the alternative and perhaps compatible methods for solid waste




management, resource recovery and resource conservation.  However, whatever the




alternative implemented, one must recognize that solid wastes management es-




sentially is a service of need and necessity for the general public.  Hence,




the central purpose remains to remove the wastes from where they are generated




to an ultimate disposal site in a manner consistent with the protection of the




general health and welfare of the public in a cost-effective way.  Where feasible,




recovery of energy and material resources will serve to complement this purpose




for the betterment of the populace!
                                 -22-

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RESOURCE RECOVERY AND WASTE PROCESSING
                 -23-

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MARKETING THE OUTPUTS - ENERGY, FUELS, MATERIALS
                      By
         Harvey W. Gershman, Director
          Resource Recovery Division
          Urban Services Group, Inc.
        Presented at the Fifth National
         Congress on Waste Management
          Technology and Resource and
        Energy Recovery, Dallas,  Texas
               December 8, 1976
                -24-

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               MARKETING THE OUTPUTS - ENERGY, FUELS MATERIALS




    If resource recovery processing is to replace other traditional methods




of solid waste disposal, users for the outputs must be identified and secured.




The success with which users are developed from the start of project design




will be the key to their eventual involvement and the overall economic viability




of any forthcoming project.  Discussed here are important considerations for




the planning process from the start, to the point where actual facility pro-




curement begins.




    There are three stages in developing the market:  the identification stage;




the commitment stage; and, the contractual stage.






Identification Stage




    During the first stage, the "Markets Study" is performed.  It identifies




what users are available for the various energy and material products that




are possible to be produced by resource recovery technologies.




    The first step is to get a handle on what is in your waste stream, since




it constitutes the set of raw materials from which the energy and materials




products will be produced.  This need not be done through any large-scale sampling




program, since the effort required and the statistical validity of such work




with respect to the level of accuracy needed at this stage, will most likely




not lead to productive results.  Also, there is an increasing data base, both




on a national level and as examples from specific jurisdictions, on




composition of the waste stream.  A literature search, looking at such sources




as data from the U.S. Department of the Interior's Bureau of Mines facility and




from the U.S. EPA's Office of Solid Waste, will provide the basis for applying




existing information to your individual circumstances.  With this accomplished,




you can then feel the rough level of potential products you have, and don't have.
                                     -25-

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     Based on this level of knowledge of the waste stream,  the approach with
the markets during the identification and commitment stages should be to use
your rough estimates of tonnage output for the products in  development of
commitments to accept:  either a product tonnage range with minimum and
maximum levels set; or, at least a certain tonnage, with a  floor tonnage set
upon your best estimate of the minimum amount of available  raw wastes that
could be turned into a product.  Refinements can be made to pin down more
precise tonnage levels later on.
     The markets investigation should not preclude, a priori,  the production
of any available energy or material  product.  To do this may unnecessarily
limit the scope of investigations and the eventual viability of the implemented
project.  Remember—the markets are  your disposal  mechanism which also play
a key role in the economic success of the project.   As such, the recovery project
should be viewed as abridge  effectively relating the input wastes (the raw
product) to the end-users in a viable, long-term manner.
     The first contact with possible users is made  during  this stage, a'ld
the dialogue that is developed is important for any future  involvement.
Often, and especially for certain energy users, development of an apprecia-
tion for solid-waste-derived products will be a first.   Because of this, a
markets education may have to be performed as other background data are
gathered.
     For energy product users, the data gathered should include:   descrip-
tion of energy production facilities, future energy requirements, types
and amounts of fuels consumed, availability of on-site  space,  energy demand
curves, value of alternative fuel/energy sources,  economics of present energy
production, adaptability of integrating the use of either solid fuels, pyrolysis
rjasi-s, pyrolysis oils, steam and electricity, and overall interest in using
                               -26-

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new energy sources.  Energy users identified include:  electrical or steam
generating utilities, large industrial facilities, university and hospital
complexes, downtown existing steam/cooling loops, new commercial/industrial
steam-chilled water loops, and so forth.
     Also, remember that your goal in development of markets is to structure
a markets situation that can handle all of your projected output of a given
product.  This need not be done by one single user.  For the energy product,
which represents the largest single product in terms of percentage product
output, it is extremely helpful to secure a single, highly reliable user.  The con-
cept   of multiple users, however, is worth investigation. We find this con-
cept   being used, for instance, in the planned steam-generating facility
for Akron, Ohio.  With the increased attention being payed to such technologies
as the small, modular heat recovery system, jurisdictions may be able to
implement such projects as refuse-derived -fuel  production (RDF) and use by a
number of small to medium sized users.  Particularly for areas with significant,
potential commercial and industrial  users with the ability to use relatively
small amounts of a facility's RDF output, c;uch a project may even be more
desirable than going with one large,but insecure, user.   In this way, the impact
of eventually losing one user will be lowered.
     Once this information is gathered, an evaluation will be required to
determine when one or several  installations can provide  the required consumption
levels for the different energy outputs.   Once the more  preferrable users are
identified,  future activities  should be closely coordinated to ensure a continuing
and active market role in future project  planning.   Establishing a relationship
with the likely energy users will  make future project coordination and develop-
ment much easier.
                              -27-

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      This market role should not be underestimated.  Various project develop-



 ment  processes have discovered, in fact,  that all potential markets are not



 passive ones.  In Lynn, Massachusetts, the General Electric facility is



 a  good example of this.  Here, the future energy user took an active role in



 the development and implementation of the RESCO project.  The help of such



 active future users can be very valuable, with proper consideration given to



 the specific type and level of involvement they will play.



      For materials products, contact is made with likely users for the various



 products in the waste stream.  These users are often more familiar with the use



 of the recovered product in their industry then energy users.  For example,



 certain industries (e.g., paper, steel, aluminum, glass) have established



 specifications for secondary products they are interested in purchasing End



 have  experience with using similar products in their manufacturing process.  For



 these reasons, it will be less difficult to assess material  product users



                                    Trie uLi.



 be on a first-come, first-served basis to those who actually deliver a product,



 as "commitments" are often made to several projects.



     The result of the general  identification will  be a "Markets Data Base"



which states who could be looked toward,  for which products, at what tonnages,



and for what probably value.   With this in hand, it will be possible to decide



what generic type of resource recovery processing should be employed to meet



the specifications  set forth  as a result of the survey.



     Overall, some estimate whould be made of the potential  value of



waste-derived products.   Generally speaking,  the value of the recovered product



is tied to some economic indicator.   It may be a quoted value in Iron Age



Magazine for No.  2 Bundles in New York or in the Federal Power Commission's



Monthly Fuel Cost and Quantity bulletin  for the cost of a million BTU's in



                                -28-

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 Illinois.   There  are  almost  as many  variations  to  such  a  formula  as  there are



 agreements.   Additionally, the price set may  be simply  fixed.  The value of



 these  products  per  ton of input waste  can only  be  determined by factoring in



 the  process  recovery  efficiency, fuel/energy  product  quality and  amount, local



 pricing  considerations (energy and materials),  and  transportation costs to bring



 the  product  to  the  user.





 Commitment  Stage



     With the markets in.mind, a closer look  at  the processing technologies



 available to meet market specification should be made next.  This evaluation



 will look at technological risk, system capital  and operating cost, alternative



 facility sites, overall system logistics and  cost, financial and management



 alternatives, required legislation/authority  farming, budget requests, etc.



 As this other information is developed, a further refinement of market develop-



 ment should ts^'e pV?ce prior to decisi"op on project "*no/no-c;o".



     The development of more detailed documents such as "Memoranda of Under-



 standing", "Letters of Intent to Bid for the Purchase of Recovered Products",



 or actual "Invitation of Bid for P>ecovered Products" should be undertaken.



 Such instruments should clearly state terms and conditions that each  party



will place on the other during actual sale of the product over a period of



 time.



     In negotiating prices for energy products*, the guiding principle should



be to establish a fair and equitable price for both the producer and  the user.



This price should provide an  incentive to produce the fuel as well as use  it.



Hence,  the price should lie somewhere between the net cost of production and  the



net value of the fuel  to the  user.
      Solid,  liquid  and  gaseous fuels, eloc-tricity.




                               -29-

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     Determination of these values is the next problem.   Tor example, for a
refuse-derived fuel  (RDF) product to be used in 'existing boiler installations,
the net cost of production would include:  (1) the annual capital investment
cost;  (2) annual  operating and maintenance costs; and,  (3) the marginal
savings/cost of not  having to landfill  or incinerate that product which
was delivered to the user.  Questions remain as to how precise each of these
factors may be calculated.  The life span of these systems are extremely
difficult to estimate with a fine degree of accuracy.  There is also a problem
of apportionment in  applying the operating and maintenance costs of the various
items when there is  more than one output.
     For the user  of an energy product  such as RDF,  the  net value of the fuel
would be the dollar  value of the heat content adjusted to account for addi-
tional costs.   The expenses would include:  the capital  cost of auxiliary
equipment for storing,  handling and firing the fuel; operating and mainlenance
costs; and, changes  in boiler effiency.   All  these are netted against tie value
of the displaced fuel.
     Again, such values cannot be expressed with a great deal of certainty.
If the user is an  electric utility, there may be "economic dispatch penalty
costs" associated  with the operation of'the boiler designated for RDF use
if it is more economical  to operate other types of units.   Costs may increase
when newer and more  efficient units enter into the utility system after the
utility has installed equipment and contractually obligated itself to accept
RDF.  The utility  must consider this possibility since it is obligated and
regulated to supply  power to the public at the cheapest  possible price.   This
effect is most pronounced in the case where additional generation capacity flows
                               -30-

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from newly added nuclear power plants.  Incremental costs of generation in

these plants are much lower than for those fired by fossil fuels.  The success

to negotiating an agreement that is attractive to both parties will occur if

each party does not try to optimize his benefit at the expense of the other.

     For an energy product such as steam, the considerations and experiences

are different.  Historically, incinerators with steam generating capacities

have not had "out of plant" users.   While this trend is definitely being

reversed by energy recovery facilities across the nation, problems remain

to be considered prior to implementing steam energy recovery systems.  One

of the problems of. selling steam to commercial users (based on municipal  solid

waste as feedstock) is the necessity to vary generation to meet load condi-

tions.   In order to do this, a boiler by-pass flue or steam-condensing equip-

ment must be provided.  Conversely, when the demand for steam exceeds the supply,

auxiliary fuel-firing systems must be incljded in order to provide an unin-

terrupted supply.

     Unlike fuels  derived from solid waste,  steam produced from solid waste

is indistinguishable from that produced from other energy sources.  To be

saleable, this steam must meet the specific  needs of the users.  When designing

a solid waste disposal/steam recovery system and pricing the resultant energy

product, several  factors thus need to be considered.   These include:

   • proxijnity_ to  customers - A steam generating facility must have
     a  nearby market because steam cannot be transported economi-
     cally more than a few miles.   In congested areas,  expensive
     pipeline installation may further restrict this  distance.

   • value -  The  cost at which the steam is  delivered must be com-
     petitive with the cost of the customer's alternative enorgy
     sources.

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   • quantity - Price is effected by the ability of the steam plant
     to supply amounts of steam which are compatible with the cus-
     tomer's needs.  If supply is guaranteed to the customer and peak
     loadings cannot be met entirely by burning refuse alone, then
     stand-by fossil fuel-fired boilers will be needed and the price
     correspondingly increased.

   • operating schedule - The steam producing facility must set up
     an operating basis that conforms to the operating schedule of
     the steam customer.  This effects the price of the steam as
     well as the existence of the market itself.

   > steam quality - The temperature and pressure at which the steam
     is produced must be a function of the limits acceptable to the
     customer's steam contract.  Variations from this norm could
     seriously effect the price of the steam.

   » reliability - If service is to be non-interruptable, contin-
     gency plans should be made when the solid waste unit is out
     of service.

   • timing - This aspect can seriously affect the steam plant and
     the expected revenues.   Unanticipated delays in construction
     of the facility could force the steam customer to secure
     another source.

Steam can be marketed in two ways:  as a guaranteed supply ("unin-

teri'uptable service"), or db a limited supply tnat requires a Back-up

system ("interruptable service").   The pricing structure will vary in

accordance  with  the  type  of  service  offered.

     In the first case, the municipality provides a complete and re-

liable supply of steam, and assumes the responsibility of producing

steam from other sources if there should be an interruption in the

production of steam from solid waste.  If the municipality is supplying

steam that the customer does not have the capability of producing,

then the municipality must guarantee the reliability of supply.   While

the municipality's costs go up, so also does the value of the steam it

is selling.  This steam has a value equivalent to what the customer

would have to spend to produce it himself.   In the second case,  the

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 customer  buys all the steam the municipality produces from solid waste, and
 thereby assumes  the burden of producing additional steam in the event that
 this supply is interrupted or not adequate to meet his demand.  In this case,
 the value of the steam is necessarily lower, in that it is limited to the value
 of the fuel saved by the customer.  At the same time, the municipality assumes
 less risk and responsibility.
     The  price of steam delivered to the industrial user is therefore a
 matter of "marginal cost" vs. "true replacement cost".  Fuel shortages and
 dislocations as well as rapidly rising prices for fossil fuels should accen-
 tuate a trend toward the marketability of a reliable steam supply.
     For  materials products, the "commitment" document should include terms
 and conditions with respect to floor prices and exchange price formulas, length
 of commitment, quantity, quality, delivery schedule, and termination provisions.
     The  longer the period over which material would be pruchased, the better.
 Five-year periods are often specified, especially in "Letters of Intent." This is
 adequate, although a ten-year period would be preferrable, since it would be
 more representative of a project's amortization and operational lifespan.
     In general, the decisions on implementing energy and/or materials recovery
 will  follow a few overall guidelines.  Not every facility will  choose to
 implement both energy and materials recovery, regardless of the technological
 development situation.   Both, however, are tied to the availability of
markets -- without them, the production of the given energy or materials
will  be meaningless.  Somewhere during the "identification" and "commitment"
 stages, an initial decision must be made on which products to produce.  The
 decision on energy production will  be most directly tied to the existing or
near-future disposal crisis, since the energy raw materials represent the largest
percentage of the waste stream,  and also the preponderence of the  biodegradable
                              -33-

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material.  Also crucial here are the economic questions of production costs
versus energy revenues and disposal credits.  With the materials products,
however, the economic questions take priority, since any disposal crisis
will not be significantly improved by materials recovery.

Contractual Stage
     During the "contractual" stage, the "commitment" agreements, which served
to solidify the project for purposes of budgetary planning, council approval,,
etc., need to be made into hard and fast agreements clearly stating all the
terms and conditions that will be promulgated into actual purchase orders or
purchase agreements.  Having such contracts will  provide the basis for making
the project financable, especially if some sort of bonding mechanism, es-
pecially revenue bonding, is to be employed for the intended project.  The
"contractual" stage is the stage at which signatures are placed on the 'bottom
lino'.   Other key matters must be also made to happen prior* to this finalizaticp,
and confirmation of the marketplace.  These include the successful implementa-
tion of a "Request for Proposals", in the case of a facility to be privately
operated, to the preparation of budget requests and general bond authorizations
in the case of a publicly owned/financed facility.  In order to get to this
stage,  other factors including site, management,  risks, technology, waste
control, etc. will also have to be decided.
     From the supplier's point of view,  the primary concern of a solid waste
processing facility is its ability to dispose of the waste.  The
establishment of long-term contracts assures the  operator of a steady outlet
for the recovered products without the need for stockpiling large amounts.
Further, long-term contracts avoid dependence on  spot markets which are sensitive
to local supply and demand factors which can fluctuate widely.  The possibility
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 of  higher  revenues  from  spot markets whould  be  sacrificed   in  order  to  obtain
 a guaranteed outlet for  the recovered  product.  As  a  result, additional  over-
 head costs for storage can be avoided.  The  long-term market,  with a specified
 floor price, also can provide a basis  for  the insured revenues necessary  to estab-
 lish  the  financial  foundation for a resource recovery  facility.
     For the purchaser of the recovered materials,  the  long-term  contract
 guarantees a steady supply of raw materials  at  a reasonable price.   This  also
 ensures continuous  processing.  Thus,  the  buyer can justify a  required capital
 investment in additional handling equipment  and the other items necessary to
 introduce  the recovered  products into  the  manufacturing process.
     •Finalization of signed user contracts will only  take place if the user is
 convinced that the  intended project will produce products according  to their
 required specifications.  If there is  uncertainty in  the ability  of  a process
 to produce the required  output specification, one of  two things will occur.
The first is that the user will end any negotiations.  Secondly,  they may still
 sign for the product, well knowing that start-up period will prove whether or
 not the facility can meet specifications.
     In making contacts  with potential buyers,  the assumption  should be made
that purchase orders for the sale of recovered  products will go out  for bid.
This approach, however,  often prevents the potential user from offering his
best price, since he knows that any signed "Letter of Intent" will become  public
information and may serve as a minimum target for other bidders.  Thus, users
can be expected to withhold their best price or pricing structure from tie
 "Letter of Intent",  knowinq  that at the time  of  bidding they probably  will  have
to bid higher in order to purchase the material.  The "Letter of Intent",  However,
does assure that they will at least bid, and that the price will not be lower
than the one stated.
                               -35-

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     If a formal bid for the sale of a recovered material is to be made with
both a floor price and an exchange price mechanism, one of these prices need:;
to be fixed in advance so that tfie final bids will be comparable.  Thus, when
bids are let, the floor price will be specified by the recovery facility and
bids will only be based on the need for an exchange price to be established.
The current letters provide a basis for designating this floor price.
     Those "Letters of  Intent" which provide a floor price can be grouped togetner
to calculate a guaranteed minimum revenue, assuming the worst possible market
conditions.  The results can then be employed to analyze the economic feasi-
bility of the facility.  It is worth noting, however, that the floor pri.ce
incorporates any unforeseen risk the bidder may incur and is generally much
lower than any reasonable market price.   Such a pegging of the floor price is
to be expected when considering:   (1) that the operating period may not begin
until two to three years hence, and; (2) that it is questionable whether long-term
variations in the prices of secondary materials can be predicted.   It i:> impor-
tant, therefore, that every effort be made to obtain realistic floor prices
to provide support for the viability of the facility.

Suriima ry
     The considerations necessary for successful market development are numerous
and will have their own peculiarities for each situation.   As with any essential
element of a resource recovery project,  they should be well  thought out from
the start.  Much of this work is  in the  developmental stage, and many people
across the nation are putting significant effort into it.   With the passage
of time, these efforts will  lead  to a much clearer understanding of how to
create the bridge that resource recovery represents.
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                  EPA Technical  Assistance Advisor's
                     Presentation to CHy Council
                  on the Initial Steps of Procuring a
                       Resource Recovery System

                       NSWMA Conference, Dallas
                           December 8, 1976

                         Robert  A.  Lowe
               Chief Technical Assistance  Branch
                   Resource Recovery Division
                      Office of  Solid Haste
              U.S. Environmental Protection Agency

(Scenario.)

     EPA has been invited to meet with the City Council to answer some
questions about their plans to implement a resource recovery system. In
preliminary conversations, City officials indicated that they have read
some of the literature on resource recovery; they have attended several
national and regional meetings over the past few years; and they have
discussed their situation with a consulting engineer, an investment
banker, and several system vendors.  They have not yet begun a formal
study that is expected to lead toward recycling their solid waste;
however, they want to do so now.

     Having heard that EPA has given information and advice to other
coiwiunities, City has asked us to discuss their plans and to answer
quesrions about how they should approach the problem, what should they
do first, and what important points should be considered.

_EPA's Rolf

     Let me begin by explaining the role of EPA's technical  assistance
program.  Our role is to help provide policy direction to States and
communities.  We are not a substitute for consultants.  Consultants have
greater expertise than we have.   But consultants usually do not serve
their client's needs unless asked the right questions.  Many times
governments do not have enough experience with resource recovery to ask
the right questions.  Therefore, EPA's role is to assist local governments
in identifying the important questions, and to identify the range of
issues and alternative decisions, and the possible consequences of those
decisions.

     Contrary to common understanding, our knowledge does not come from
n Supreme Being; it comes from observing arid analyzing the experiences
of other cities.
     Tne City is about the size of Mew Orleans, St. Louis, or Mempliis.
Considering City and County together, the metro area compares in size
vw Orleans, Tampa-St. Petersburg, and Portland, Oregon areas.
T!i--; City generates about 1,000 to 1400 tons per day (depending
OA nor capita waste generation, rates, on whether conmercinl  sources are
included, and on how many days per week the waste is collected). The
County yjnerates an additional 750 to 1030 tons p?r day.

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     In view of the short remaining life of the City's  landfill
and in view of new State and Federal  legislation,  it  is  clear that
City has a problem; and thay cannot afford to  waste time,

     Solving City's problem i; constrained by  the  debt  situation,  the
new Stats law on leachate collection,  the air  pollution  situation,  and
the sludge disposal problem.  These are serious, but  they  can be overcome
or accommodated.

     There are several  important things in the city's favor.
City's size and population density means an adequate  quantity of solid waste
is there; and public collection means  that this waste can  be directed to source
separation and central  processing systems.  There  are also potentially
qood markets for waste  paper and waste derived energy.

liiiat to look at

     There are so many  aspects of implementing a resource  recovery
system--!t seems that everything must  be done  first and  all  at once—
lhat it is easy to become confused.  To simplify matters,  many cities
have started with a technology approach, identifying  markets  and
ev.iluacing technologies.

     Unfortunately, we've seen many cities start this way  and
v".>nd lots of money and lots of time and get no where.   They  find  that
Kuy'vc gone down blind alleys because they did not consider  some
very important issues.

     We want you to avoid these blind  alleys.   Ke  recomnend  that you
do not take the technology approach.   We rocormend that  you
fjisider resource recovery as a full-scale business enterprise and
I •'••'.> a business approach  instead.

     Of all the issues  that must be addressed, four stand  out as being
of primary importance:


     o Markets

     o Haste supply

     o Financing

     o Sites
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Markets.  I'm sure you are all aware of the importance of securing
markets.  With me today to discuss these market issues are
Harvey Gershman, a management consultant, and Alden Howard, a
prospective industrial customer for steam.  I defer to them.

Haste Supply.  A supply of waste is essential -- waste is the raw
material without which revenues cannot be earned.  Obtaining a
supply of waste should not be taken for granted,  fortunately,
because City collects its v/aste in its own trucks, it has control
over its 1000-1400 tons per day and can direct that waste to the
system of its choice.  But don't make the mistake of assuming that
you can build a 2,000 ton per day plant and get the County's waste.
More will be said about bringing several jurisdictions into a single
system by Steve Lewis, a management consultant with experience in
regional systems.

Financing.     The third issue, financing, is so important that
it must"be factored into any city's thinking from the very beginning,
especially in your city where, because the City has reached its debt
ceiling, general obligation financing cannot be used.  The city will
probably have to use project financing or some other financing
mechanism secured by a source of revenues, such as a special tax
assessment, that is earmarked to pay for the project and kept separate
from general revenues.  Regardless of the mechanssrn, the project
must be structured in such a way that prospective bondholders will
have confidence that their investment is safe.  In other-words, the
project must be financeable.  Different financing mechanisms have
different requirements that can dictate how a project must be structured.

To make sure the project is financeaole, the possible financing
mechansims and their requirements mint be considered frorn t'ne
beginning of the City's study.  We will go into more detail on
financeability and financing mechansims with two investment
bankers, Bob Aldrich and Charlie Ballard,

Sites.     Which site is selected depends upon a lot of factors,
including proximity and access to waste generators and to customers,
which will be identified as your study progresses.  But as every
elected official knows, siting a solid waste facility is very
difficult; and it is never too early to begin acquiring a site.

There are three other major issues:

     • Type of system

     • Procurement approach

     t  Legal issues
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Type of System  The type of systems that are appropriate will
be~dictated by the market;?.  We have observed that there is a
tendency to limit consideration to central processing facilities
and to overlook source separation systems.  The enthusiasm for
large plants may have something to do with the fact that many
companies can make money if a plant is built.  Cut the City
can make money—or at least reduce costs—by source separating
if you can get long term contracts with floor prices.  Therefore,
we encourage you to consider source separation as  an option. There are
many good reasons for this, which will be discussed by John Skinner,
Director of the City Planning Agency.

Procurement Approach.  There ar.e three basic procurement approaches:

     •  The A&E approach, where the city hires a professional
        engineering firm to design a system, develop specifications,
        and perhaps to monitor construction; then  the city purchases
        the equipment, materials and labor.   The City owns and
        operates the system and is responsible for its performance.

     e  The turnkey approach, where the city buys  the system or
        the principal components as a package and  does not take
        title until the system has passed a  performance test.
        Then the city owns and operates the  facility.

     •  The full service approach, where the city  buys a service
        from a system vendor who designs, contructs and operates
        the facility.

     These are described in detail in EPA's  Resource Recovery  Plant
Inpleirentation Guide. In my dealings with otFer~cities, I have noticed
that their" thinking about procurement is made more difficult because
of misconceptions about two issues:

     •  Control and responsibility

     •  Risk and reward

No company will accept responsibility for something unless it  has
control over it.  For example, no company will guarantee the performance
of a system unless it had control over both  the design and construction
of the facility.  In an A&E situation, no one but  the city has overall
responsibility; and as the Nashville experience shows, it is nearly
impossible to assign the blame if something  goes wrong.
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     In a turnkey arrangement, the contractor will  accept responsibility
until the performance test is over.   As an example, with all  ths problois
in Baltimore, there was essentially no question that Monsanto was responsible
1'or everything (within the limit--$4 million-- of their contrvctu.tl
obligation).   But once the performance test is over nnd a second party
begins to operate the facility, it would be nearly  impossible to hold
the contractor responsible if something went wrong  because it v/ould
be difficult to prove that the problem was caused by the contractor  and
not by the operator.

     In a full service arrangement,  the "contractor  will assume
responsibility for the performance of the system under normal conditions.
But the contractor has no control  over some events  such as sabotage,
earthquakes, and strikes by suppliers (known as force majeure),  and
therefore will not pay for losses  due to these events.

     I mention this control/responsibility relationship so that
you may be wary of companies—including designers,  equipment
manufacturers, and system vendors—that promise--ei ther  explicitly
or implicitly—that their design will work or their machinary wjjl_
work.  Unless they control the entire system, they  cannot guarantee
that it will  work and will not back up their promises with money.

     Regarding risks and rewards,  every city wants  to minimize costs
and maximize benefits.  So do private companies (system vendors,
product customers, etc.).  But every project involves making  an
investment without knowing for sure how the future  will turn  out.
Companies make such investments every day.  So do cities.  Making
an investment under conditions of  uncercainty involves taking a  risk.
This risk can be bigger or smaller depending on the size of the
investment, the strength of the markets, the amount of experience
with the technology, the experience  of the'designers, and other  factor;,.

     Companies will take risks if  the potential reward (profit)  is
large enough.  The greater the risk, the greater the potential reward
that is required to make the investment.  Cities frequently make decisions
on the same principles, although they generally undertake ''ess risky
projects because they are not created to make a profit nor can they
suffer the consequences of severe  losses.

     If costs could be estimated accurately—if the future could be
predicted, it would be a lot easier  to choose between the A«E and full
"uryice approaches.  But actual costs (that won't be known until the
facility is built and operated) could vary widely,  depending  upon
v.hether certain conditions are favorable or unfavorable.
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     Under the best conditions,  the actual  costs  of  a  project will
be low—perhaps lower than the city's  original  ostiirtat.es.   If the
city buys a system under the Afii" approach wh?n  conditions  are favorable,
the city is the direct beneficiary through  lower  costs.   If the  city
buys a system under the full  service approach when conditions are
favorable, the city will be paying the company  a  profit.   And the
cost to the city rrny he more under full  service than under ASE,
depending on how efficient the company is.

     On the other hand, if conditions  are bad,  actual  project costs
will be higher than originally estimated—perhaps much higher.   Under
the A&E approach, the city would pay dearly; under a fu11  service
arrangement, the City would pay the amount  originally  agreed upon  tnd
would be protected from large losses,  which the company  would have to
absorb (unless they default).

     Looking back on the projects that have been  built,  a  few have
been built within their budget.   But most projects end up  costing
more—sometimes much more--than was budgeted.   In view of  the risk
factors mentioned earlier, actual costs  in  future projects are
more likely to be over budget than under.

     Which approach is cheaper?  Which one  is best?  EPA has no
preferred procurement approach for all  cases; however, in  our judgment,
when an investment is risky,  we think  it is prudent  for  cities to  redur.-;
their risk by securing guarantees from industry;  and the rost moaning'-
guarantees are secured in a full-service contract.   This approach  is
frequently criticized as being too costly,  but  we think  that a full
service arrangement can be less costly in irwny  cases.   In  the long run,
the only system that is too rosily is  Mr* <;y;!-pm  that  didn't uor''

     One final word on procurement. Thj ,iumbar of qualified resource
recovery companies is limited.   They can bid on only a few projects
at a time.  Consequently, they must be very selective  about which
jobs they bid on.  What this weans for cities is  that  they cannot
expect the good companies to come beating down  their doors.  Cities
must make an effort to attract bidders,  to  demonstrate that they offer
a viable business opportunity.

     This, companies have told us, means that cities should do their
homework before they come to the bargaining table.   Tor  example, they
should select a procurement approach b?Tor? ,1 request  for  proposals is
issued.  They should also resolvs some Important  legal questions,  such as:

          Is negotiated procurement allowed?
          Can the community enljr into a put-or pay  contract?
          Can the community lease nr sell land  to indusiry?
          Can the community enter into a long-term contract?
          Can the community enter into revenue-sharing?
          Must the community comply wich split-bidding laws?
          What are States salvage laws?
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     Don't let yourself yet into the position—that some cities
have found themselves—of issuing a request for proposals \iithout
having answered these questions.

I low to Proceed

     Before the other consultants talk more about these issues,
I'd like to make a few observations about how citi?s
cjo about planning and implementing a project.  If you look at  the
projects that have succeeded, you'll see that they hav3 several
traits in common:

          o  Project Manager—Each success had one person who
             kept the project moving, follovwd up on all  details,
             and did a lot of work.  Committees don't do work;
             individuals do.   But not department heads:
             they're too busy with other things.

          o  Executive Support—Each success had department heads,
             council members  and chief executives who './ere
             committed to the project and used their power
             to get the project approved and moving.

          •  Coordination—Each success received gudiance and
             public support from an advisory task force of some
             kind.  In addition, each success was tha result
             of cooperation between many city, state, industry,
             and citizen groups and departments.

          e  Realistic schedule—Every project that we know of
             has taken at least 3 to 5 years to get from the first
             planning steps to plant operation.  Although every
             elected official would like to have an operating
             plant to impress the voters before the next election,
             it is not realistic to expect that a project can  be
             completed in a short time.

          o  Team of consultants--Each success hired not just
             engineers, but financial, legal, and management
             consultants as well.  Some cities did not hire
             legal and financial consultants in the early stages
             of their planning when they could have done the most
             good.  But they  did hire them eventually.

          •  Minimize conflict of interests—A conflict of interest
             may exist whenever any consultant, advisory task  force
             member, or anyone else involved in the decision-Making
             process stands to profit from particular options  that
             could be recommended.  Such conflicts can be minimi/ed
             by disqualifying these individuals or ("inns from  follow-on
             business.  Mot all conflicts ran be eliminated; in such
             cases, public recognition of the conflict can hslp
             protect the public interest.
                             -43-

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                                  -8-
          e   Planning  expenditures—Each success spent a lot of
             money,  for  feasibility studies,  for market research,
             for evaluation of proposals, and  for negotiations of
             contracts.   Some tried to skimp  in the early phases
             and ended up paying more for lawyers and other consultants
             later.   It  does not make sense to quibble about $50,ODD
             wehn $50  million is at stake.

     One way or another,  projects can be built without hiring the
proper consultants;  but  they always seem to take longer.  And these
delays are costly.   At present rates of inflation, a $50 million project
will  cost about 510,000  more for each day the  project is delayed, just
because of inflation.

     We are  encouraged by the prospects for a successful implementation
  in  the City,  and we  look forward to working with you.
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               Finance - Ability of Resource Recovery  Facilities



                       Robert H. Aldrich,  Vice  President



                        White, Meld & Co.  Incorporated
          There are two measures of the success of a financing:  the first, that




the necessary capital is raised; and second, that the cost of capital is reason-




able in comparison to the money market and considering the risks associated with




a particular financing.  The ultimate measure of success, of course, is that the




project itself meets its objectives and the investors are fully and properly




compensated.




          Financing of solid waste resource recovery facilities is rapidly develop-




ing into a specialized field, due primarily to unique features of




the business and the need of the investment banker to have an in-depth knowledge




of the industry.  It is unique because, by its very nature, resource recovery




requires the combined resources of both the public and private sectors.




          A community looks to resource recovery to provide a reliable and eco-




nomic means of disposing of solid waste in an environmentally sound manner.  The




main resource the public provides is a continuous supply of solid waste, and a




mechanism by which to pay for the service of disposal.   The private sector, on




the other hand,  looks to resource recovery as a natural extension of its engineer-




ing and manufacturing technology, and a means of generating profit by providing a




basic service to a community and marketing or utilizing the resources contained




in the waste stream.





                                      -45-

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          Federal and state laws and regulations controlling the financing of




resource recovery facilities have recognized the need and desire for joint




public/private participation in resource recovery and have provided for the in-




vestment community financing mechanisms which are unusual and quite attractive.




The main features of the financing mechanisms are that the facility can be pri-




vately owned and operated and that the owner of the facility can take tax advan-




tages of ownership including investment tax credit, accelerated depreciation, and




deductions for interest expenses — and yet the facility can be financed using tax-




exempt municipal bonds, where the interest income on the bonds is exempt from




state and Federal taxes.  This combination of benefits —  tax ownership avail-




able only to the private sector, and the low interest costs of tax-exempt munici-




pal bonds normally restricted to public debt, provides to resource recovery pro-




jects the opportunity to obtain a comparatively favorable net cost of capital.




          However, whereas the financing mechanisms and alternatives appear




attractive, and they are, the finance -ability  of  resource  recovery projects is




still dependent upon the underlying strength of the project, and the security




features structured into the financing package.  Risks must be identified,




and the financing structured so as to minimize these risks and to assign respon-




sibilities to the appropriate parties, generally through contractual relationships.






What the Investment Community Looks to in a Resource Recovery Financing




          This presentation assumes that the facility is to be financed as a




project financing using revenue bonds, equity, etc., and not secured by a general




obligation of a community, state, or private corporation.
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          Resource recovery facilities must compete for funds in the marketplace.




In general, resource recovery facilities are competing in a specific market —




the long term municipal bond market, against state and local general obligation




or revenue bond issues for school construction, housing, hospitals, sewage plants,




etc.  In 1976, the total bonds sold into this market will be approximately $30-




billion.  While the cumulative to-date dollar value of solid waste bonds has been



low (less than $200K), the size of the individual solid waste bond issues nave




been comparatively large and growing, and the annual requirements are expected




to rise over $1 billion per year.




          In resource recovery projects, we look to the following in analyzing




the finance-ability:




          • The need of the community, as measured in terms of available solid




            waste and its alternative method and economics of disposal.




          • The ability and the proposed mechanism by which the community will




            pay for the disposal service — the "tipping fee".




          • The state of the technology to be utilized — including the  history




            of operation; the strength of the contractors; and the form  and




            substance of the guarantee of the contractors to convert solid waste




            into saleable resources in a reliable and economic manner over the




            term of the financing.
                                          -47-

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          •  The availability of reliable long term markejts  for  the recovered




            resources  and the nature  of the purchase contracts.




          •  An economic analysis of the project,  by a  reliable  inde-




            pendent engineering firm, to determine that the facility will be




            able to operate at the projected  costs and generate the required




            revenues.




          • And finally, the security features built into the financing itself




            including:  reserve funds, payment schedules, guarantees,  and cover-




            age ratios.




          The investment community is positive in their reaction toward resource




recovery projects, recognizing the basic need of  such  facilities to communities




as well as recognizing the quality of the private sector companies participating




in this industry.  From time to time, in our  natural competitive fervor,  we  tend




to criticize our competitors' systems and services, seeking to  gain some  compe-




titive advantage for ourselves.  Let me state here and now, that this  form of




competitive activity is counter-productive to the development of our  industry and




can only do more harm than good since the investment community  is not  in  the




position to judge the relative merits of rumors,  and will,  unless this trend is




checked, be to the detriment of all resource  recovery  projects.  This  could  have




costly consequences to our industry.




Roles of the Community




          The decision by a community on whether  or not to undertake a resource




recovery project  is generally based upon an evaluation of comparative  economics  —




comparing the cost of landfill with the alternative of implementing a  resource




recovery program.







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          The finance-ability of the facility is greatly strengthened if the com-




munity has limited access to alternative disposal sites.  Where land-fills are




running out of capacity, and/or where state laws or policies are restricting the




use or increasing the cost of land-fill, resource recovery projects look most




attractive.




          The ability of the community to control the flow of solid waste to the




facility and to pay for the service is critical to the financing package.  At




times the ability to pay for such service is questionable in certain financially




troubled urban areas.  However, it is our opinion that because of the critical




nature of reliable solid waste disposal in such areas combined with strong con-




trol over the flow of solid waste, the project financing can be equal or superior




to general obligation bonds of those urban areas.




The Roles of_the Contractor & Operator




          The private sector participant should obligate itself to construct the




facility to meet predefined performance specifications at a price which allows




for inflation and a reasonable contingency.  Further, the contractor, or an opera-




tor if not the same, should enter into firm contracts over the full term of the




financing to provide the essential services of reliably disposing of the solid




waste and providing specification grade by-products for sale.




          The finance-ability of the project is directly related to the financial




strength and commitment of the private sector participants.   Of most importance,




is that the technology to be used be one that has been demonstrated to the point




where the investors and community are satisfied that the facility will perform
                                     -49-

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its function reliably and economically over the term of the  bonds.   The  technical




competence of the private sector participants is a further measure  of the quality




of the project.




Importance of the Market for Recovered Resources




          In order to provide adequate revenues to the project,  firm long term




take or pay contracts must be negotiated for substantially all of the resources




recovered in the operation of the facility. Since energy is  a major source of revenue




it is most important that the energy purchasers not only commit  to  purchase the



output of the facility, but that the investor be satisfied that  the pur-




chasers are financially sound and that the intended market will  exist for the




term of the bonds.




          The contracts negotiated should provide for escalation of prices, gener-




ally tied to alternative energy costs to the user.




The Use of an Economic Analysis




          An economic analysis of the project over the terrr  of the  bonds must




be included in the basic financing package.  Included in analysis should be a




complete breakdown of the projected cash flow of the project analyzing the anti-




cipated revenues and costs (a profit and loss statement) as  well as projected




balance sheets on the project itself.  The report should include a sensitivity



analysis measuring the impact of various levels of operating, maintenance and



replacement costs, projected revenues, and financing assumptions.




          In addition, the economic analysis should provide  to the  investor the



coverage ratios (a measure of the availability of funds to repay principal and
                                      -50-

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Interest) expected under various operating conditions.  This coverage ratio should



be sufficient to satisfy the investor that he will be properly compensated.




Additional Security Features




          The additional security features built into a resource recovery financ-




ing should include:



          l)  A reasonable (one year) reserve fund to pay principal and interest




              on the debt.




          2)  A reasonable reserve fund for maintenance of the facility,  as well



              planned replacement of certain key components of the facility.




          3)  An equity contribution to the project by the private sector,  not




              only assures the investor of the level of commitment by the operator,



              but reduces the level of annual debt service.




          k)  A "gross tipping fee" concept may be used.   Under this concept the




              community obligates itself to pay a gross tipping fee adequate to




              provide the payment of debt service and operation and maintenance




              costs.  Through predetermined sharing formulas revenue derived from




              the sales of energy and recovered materials is then rebated to the




              community providing the "net tipping fee".   A contract between the



              community and the operator can provide for  a guaranteed rebate  to




              the community from the operator if revenues are not sufficient.



          5)  A land-fill must be available to dispose of the residual waste



              from the facility as well as to provide a stand-by for periods  in




              which the facility is inoperable.
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          While the above comments deal in general with project financing using a




combination of revenue bonds and equity, it is,  of course,  possible  to  provide




additional security to the financing in the form of guarantees by the community,




the state, the Federal government or the private sector participants.   These




guarantees can take several forms including:   general obligations,  special tax




revenue bonds, moral obligations, price supports,  or some limited guarantees.




An example of the limited guarantee is the case  in Saugus,  Massachusetts where




the private participants guaranteed to provide additional capital to the facility




up to the total tax benefits they derived as owners of the  facility.




          The various contractual and security elements discussed throughout this




paper are representative of the requirements for a successful resource  recovery




project financing.  However, due to various constraints and obstacles,  the ideal




is seldom achieved.  Certain security deficiencies or risks can be accepted by  the




investor at a cost to the project, but there are limits to  the extent that de-




ficiencies may exist and a financing be accomplished.




          This paper, due to time constraints, did not attempt to deal with the




legal questions involving the issuance of debt or forms of  procurement.  Nor did




it deal with the critical problems associated with keeping  the debt off the balance




sheet of the private participant (a key element in a financing program), or with




the constraints imposed by law or policy on the community of having the debt in-




cluded in its debt limit, thus impairing its future borrowing capacity.
                                    -52-

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          In conclusion, financing of resource recovery facilities  can be  suc-




cessfully accomplished through project financing without the  use  of general  obli-




gation or special tax bonds.   The key factor is structuring a financing which




properly assigns risks and rewards, and which is secured not  only by strong  con-




tracts between financially and technically reliable entities, but also by  strong



commitments on the part of the communities and the private sector participants.
                                    -53-

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Project Interrelationships
        -54-

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                Financing Options for Resource Recovery
                         Charles A. Ballard
                           Vice President
                       Dillon. Read and Co., Inc.
Thank you.  Any discussion concerning financing options for solid waste
disposal/resource recovery systems iriust be viewed objectively.  We are,
after all, discussing a new industry - one, in fact, so now that the
historical lack of meaningful investment, by definition, precludes
widely accepted financi;il precedents.  Nevertheless, some patterns arc
beginning to emerge, albeit far more slowly than might be considered
in the Nation's best interest.

The financing of solid waste disposal/resource recovery systems should
not be viewed as unique.  Financial alternatives must address operating
objectives, and often these objectives cannot be set in concrete, but
rather are subjective and result from preconceived bias, past experience,
or local circumstance.

I felt it might be helpful to review the approaches that four other cities
are employing to finance solid waste disposal facilities.  Each of these
cities has embraced one of a series of options, specificallv:

             the issuance of General Obligation Bonds;
             the issuance of Special Revenue Bonds;
             the issuance of Industrial Development Revenue Bonds;
             financing from the private sector; or
             combinations of the above.

Reviewing each option briefly, General Obligation Bonds commit the full
faith and credit of a municipality to the repayment of the principal of,
and interest on, borrowed funds.

Special Revenue Bonds may take numerous forms, but essentially, a stream
of municipal revenues is pledged to secure the repayment of bonds issued.
These revenues may be from a special taxation district, an unrelated
revenue district, the financed project, or from some other source.

Industrial Development Revenue Bonds may be employed to the extent that
the financed project meets certain requisite conditions of the Internal
Revenue Code.

These first three options generally involve tax exempt financing, i.e.,
the interest payable to bondholders is exempt from Federal income tax
under the appropriate provisions of Section 103 (c) of the Internal
Revenue Code.


                                 -56*

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Private Sector Financing involves, either directly or indirectly,  a pledge
of the credit of a participating corporation.

Additionally, each of the preceding  four options may bo combined  to
obtain necessary funding.

Perhaps the case-by-case review of four actual  examples may bring  into
better focus the application of the f Lancing options described.
(Insert Slide 2).

As may be expected, each of the subject cities  - and I have been,  or ain
currently, involved with each, - have varying populations,  characteristics
and objectives.

City A has a service area population of approximately 250,000.   The stated
characteristics of City A regarding its solid waste disposal/resource
recovery facility include the following:

       1) the City desired no ownership of the  subject facility;
       2) the City desired no direct management responsibility for the
          operation of the facility;
       3) the City had no credit support that it could offer to the facll:ty's
          financing; rind,
       *)) the City desired no participation in  facility profits.

Simply, City A's Facility objectives included the dependable and environ-
mentally sound disposal of solid wastes, and partial recovery of these solid
wastes.

City B has a service area population of approximately 850,000.   It desired
no direct facility ownership or management responsibility for a twenty year
period.  It had no credit support to offer, but it did desire a meaningful
profit participation.  As with City A, City B desired dependable and environ-
mentally sound disposal of solid wastes but it  had as an additional objective,
total resource recovery.

City C has a service area population of approximately 550,000 people.  City C
desired immediate ownership of the facility, a limited management  respon-
sibility, was able to afford limited credit support and was interested in a
profit participation.  Its Facility objectives  were otherwise similar to those
of City B.

City D has a service area population of approximately 1,300,000, it desired
ovmership of the facility upon its completion,  limited nanagenent respon-
sibility, and through State Bonding, had strong credit support available.
Its profit participation desires and other Facility objectives were similar
to Cities B and C.


                                -56-

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City A'L solution was not an overly complex one, but often simplicity
rules the day in meeting objectives.  City A entered into a disposal
contract with a private sector operator for the disposal of its solid
wastes.  The contract provided for hauling services as well as for
disposal cervices.  Through the powers chanted to the City under its State
laws, the City VMS authorized to issue Industrial Development Revenue
Bonds for the acquisition or construction of facilities which inure to
the benefit of the City, the State, or its citizens.  The City could issue
such bonds, limiting bondholders' resource to those revenues, pledged to
secure the bonds.

To generate such revenues the City entered into a twenty-year lease with
the operator for the use of the facility, and issued its limited recourse
bonds in an amount sufficient to construct the facility.  These bonds
were secured by the pledge and assignment of the lease payments receivable
from the project operator.  The proceeds of the bond issue were placed in
trust and construction contractors were paid as delivery progressed.  The
operator gave its guarantee of lease payments to Bondholders and, further
entered into contracts with certain Dy-product purchasers for the purchase
of recovered items.  The financing has been completed; the project has
been completed; and the City and the operator have each achieved its stated
objectives.  Through the City's auspices the operator was able to receive
lower cost tax exempt financing, but was required to pledge its direct
credit to secure such financing.  In this example, the credit of a private
sector corporation was combined with a city's authority to issue tax exempt
industrial development bonds to finance the solid waste disposal facility.

City B had a more complex problem.  The cost of a full resource recovery
operation servicing the needs of 850,000 people was substantially in excess
of that experienced by City A.  Few corporations are capable of, or, if
capable, desire to employ their credit in such manner.  Nevertheless, the
funding problem was solved by the structure shown.             Tracing
first the contract flow, City B encered into a twenty-year contract with
a private sector operator to provide for the disposal of certain minimum
amounts of solid waste on a monthly basis.  If the City did not deliver
such minimum, it would nevertheless be required to pay for the disposal of
the minimum.  Although the price per ton for disposal was established,
it was to be adjusted to reflect escalation as determined by certain
independent price indices.  The operator then entered into a twenty-year
agreement with a principal energy purchaser under which the energy
purchaser agreed to purchase any and all energy delivered at a price based
upon its alternative fuel costs; such price however, could not fall below
a stated minimum.  Simultaneously, the operator entered into long-term
purchase contracts with other by-product purchasers.  Each of these latter
contracts contained minimum "take or pay provisions", providing that by-
products would be purchased at prices based upon market conditions, but in
no event would such prices be below stated minimums.

                                 -57-

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As with City A, City E ted authority under its State laws to issue,
through an industrial development authority, industrial development revenue
bonds.  The operator entered into an agreement with the industrial
development authority to lease the completed facility for twenty years at
annual payments sufficient to amortize the debt issued.  The operator
secured its obligation to make lease payments with a pledge of the- disposal
contract with the City, a pledge of the energy purchase contract, and a
pledge of the contracts with other by-product purchasers.  To complete
this "circle of obligations" the operator's parent company extended a
performance guaranty to both the City and the Bondholders which assured
that the project would be completed in a timely fashion and would operate
in accord with performance specifications.

City B's financing has been completed, and the facility is currently under
construction.  The issuance of industrial development bonds combined with
the City's contractual obligation and several forms of private sector
credit made the financing feasible.

City C, as you remember, desired immediate ownership of the facility and
had limited credit support available, but its other objectives and
characteristics were similar to those of City B.  As with City B, the capita]
cost of City C's plant is to be signifleant.  In general, these objectives
and characteristics dictated an even more cotiplex solution to the financing
proolem.

Let's again look at the contract flow.             While the service area
population of City C was 550,000, nearly half of that population resided
in the Comity surrounding the City's corporate limits.  The facility, when
completed, would inure to the benefit not only of the City residents,
but also to those of the County.  Accordingly, negotiations were held with
the County, and the County ultimately agreed that it wouid Lend direct
support to the to-be constructed plant.  A Cooperative Agreement was executed
by the City and the County, each agreeing thereunder to make available
its general funds in the cumulative amount of approximately 30 percent of
the facility's installed cost.  A bond trustee, acting on behalf of the
Bondholders, was made a beneficiary of this agreement.

City C then entered into numerous 25-year agreements with energy purchasers
providing for the long-term purchase of energy at prices to be adjusted to
reflect the plant's actual operating and capital costs.  No profit margins
were included.  The City further entered into contracts with independent
construction companies for the construction of the subject facility.

Because City C desired only limited responsibility for the facility's
operation, a contract was entered into with a member of the private sector
for the supervision of the project's construction and initial operating phases
                                -58-

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The trustee was, by assignment, made a beneficiary of all of these agreements,
based on this security afforded by these contracts, other ordinances and
legal action taken by the City and the County, the trustee should be in a
position to issue revenue bonds for the remaining facility cost.   Revenue
bondholders would have first claim on all project revenues, such claim being
prior to repayment of the general funds advanced by the City and County.

Tills financing is currently under negotiation.  Under such a structure,
General Obligation Bonds, Industrial Developnent Revenue Bonds, and private
sector financing, through the assignment of "take or pay" energy contracts,
are being combined to accomplish the project's funding.

City D's objectives were similar to those of City C except in one particular
regard.  Strong credit support is available, through State auspices, once
the project is constructed and in operation.

Accordingly, City D has two stages to its financing plan, one occurring
during the construction stage, the second during the operating stage.

            First - the construction phase - and again, let's follow the
contract flow.  Because the County government has direct responsibility for
the disposal of solid wastes, that political sub division is to he employed
in preference to the City.  The County will enter into an agreement with
the State to provide for the facility's pciTnnent funding on completion.
The County further will enter into agreements with a private sector ir-jmber
for the construction and operation of the subject facility.  Tne construction
phase includes a "turn-key" price.  The major energy purchaser will agree to
purchase the facility's energy by-products for a twenty year period.  Because
the private sector operator will be involved during the operating period,
it also will be party to this agreement.

Based upon this agreement with the County and the energy user, the contractor
may enter into the construction contracts for the Facility's construction.

To finance the construction phase several additional agreements were required.
The funding agreement between the County and the State provides that the
State will make its funds available prior to the commencement of construction,
which funds will be held in escrow by trustee B until completion of
construction.  Such agreement addresses the concerns of a changing State
legislature, administration, etc.  Trustee R, having funds on deposit with it,
may then enter into a funding agreement with Trustee A, providing that upor
"completion" such funds would DC transferee! to trustee A.  Trustee A, armed
with trustee B's agreement, a construction loan agreement with the operator,
and an agreement with the operator's parent coupon/ guaranteeing timely
completion, may issue notes, secured by such agreements, to short-term
lenders to fund construction requirements.
                                 -59-

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                   When construction is completed and operations commence,
the structure changes slightly.  Instead of a construction performance
guarantee the contractor's parent company will have a continuing operating
performance guarantee, assuring both the County and the energy purchaser
that the facility will perform in accordance with design specifications.
The State funds, heretofore being held by trustee D, will be transferred to
trustee A who will then repay construction lenders, and other contract
funds advanced by the contractor on behalf of the County.   Energy payments
from the energy purchaser and operating payments from the County will be
sufficient to pay operating and maintenance expenses of the contract, and
hopefully, allow seme cash flow to accrue to the County's benefit.

Under this structure, General Obligation Bonds and Private Sector capital
will be jointly employed to fund the project's completion and capitfl
costs.  There, of course, are other options including leveraged leasing,
and other combinations, which may, in your particular instance, address
particular objectives and area characteristics.  Each must be examined
carefully with competent financial and legal counsel to assure the best
possible financial result.  Thank you.
                                  -60-

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                   CONTROLLED-AIR  INCINERATION —

                                KEY TO
              PRACTICAL PRODUCTION OF ENERGY FRO*! WASTES

                                  by

                            ROSS E. HOFMANN
                  President, Ross Hofmann, Associates
                         Coral Gables, Florida
     For the past seven years, RoAi Hofmann, AM>'M'?O *i. >• Leon inti-

mately involved with the development of the small \*j. t- energy pro-

duction systems using controlled-air incinerat11.., believing that

they offer a major economic and technical solution to our fossil

fuel shortfall.

     It is estimated that at least 425,000 tens of residential and

commercial solid waste is generated daily by American communities.

A considerable additional amount of combustible solid waste is gen-

erated by thousands of factories and institutions within these same

urban areas.  The municipal segment alone apparently contains a

daily potential energy content of over four trillion, 250 billion Btu.

     This much energy is too valuable a resource to be buried in

landfills or destroyed by a simple combustion process.  In one year,

the municipal and privately generated solid wastes in these communi -

ties can produce energy equivalent to over 1.5 trillion cubic fef
                             -61-

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of natural gas — more than the shortfall estimated to exist.  Al-
ternatively, it can produce the energy equivalent of over 10 billion
gallons of oil currently firing thousands of boilers throughout the:
nation.  It is capable of producing over 900 billion pounds of high
pressure steam annually, either for electrical production, or for
direct process and heating use in thousands of factories and critical
institutions, such as hospitals.
     There is nothing new about "resource recovery" from solid waste.
A few demonstration projects, both federally and privately financed,
have been going on for five years. < Some projects have attempted to
remove and sell the metals, glass, and paper products from the waste
stream, with varying success due to the vagaries of the scrap markets.
Others have looked at the potential for extracting the energy in
waste, ranging frou complicated and expensive chemical processes,
such as pyrolysis, to direct energy production through incineration.
Three direct energy processes have emerged for the production of
steam from some sort of boiler.  Milled combustibles, or refuse de-
rived fuel  (RDF), in _he solid waste stream have been used to augment
coal in utility company boilers for the production of electricity;
or have been used to fjra boilers as the sole fuel source.  Other
energy production plants have attempted to use "water-wall" incin-
erators, lining tha o?:imary chamber of a conventional, large-scale,
municipal incinerator with boiler tubes for the direct product-ion ct
steam and/or turbine-produced electricity.  The third approach .' as
 •oncentrated or small, "controlled-air" incinerators, with matching
separate boilers, installed in identical modules to produce stenm
 r..r immediate process or he.ating use.  This thirr1 approach mav prove
                            -62-

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;he most dramatic o   ~ I" ,  ..   rre succrs^es to date, oot.;    • -u •  'I '




and economically, ;:r>rtir,u<- .




     Most o-i i."ii nq d^mmi"? t rnt ions of resource recovo/y pr<-vTS< . ^




 ooii to coni-rr." -.-itr-  on  a  mnns  production approach.  This h.ip c.irri i>,i




over into rv,ose  that utilize  solid waste for energy production.   It



is usual-/ O'-.visioned that waste from large ciuif;s and their sur-



roundinq subarbs will be  transported to a central processing plant,




with a capacity  of up to  1,000 tons dailv 01 nK.re, to take advantage




of the economies of  scale.



     This ignores some  simple  economics when ceal^rg with solid waste




-nanaqement.  The most expensive aspect is the w~ st cf tL insportation.



Tie greater the  mass production, the wider tha Ere?  nat mu^t be



•. f'Cfid to obtain the waste  and haul it to a jeatrj. point, and the




,ii3:5e.r the overall cost.  This has been dramatxca I! / pointed out  in



• t ilysis of sanitary landfill  total costs whicr, ha-^e ri ?Qn consider-




ably as available Rites have  involved longer an-i longer hauls from



original pick  up arp.is    For example, a half hocu or»r way trip is



estimated to cost ?2,.-, i er  ton hauled, while a twc, hour trip is es-



timated to cost  $7.30 per ton  hauled, to which musi. be added transfer



station costs  of from $1.20  to $1.50 per ton.  T<  date, the design



and construction costs of the  mass production piants have been so



high, compared to product net  revenue, that a reasonable payout period



appears difficult to attain.   Further, there is almost a direct cor-



relation between the locations that generate waste, the quantities



they generate, and a direct demand for process or heating steam on



a short haul basis.   The  economics appear to lead to modular,  str.i



tegically located, small  installations.  A large proportion of •



                             -63-

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pot ntial users need energy to survive, but in relatively small




qua, titles that match closely the amounts available from local wastes.




                            BASIC CRITERIA




     For any energy production system to be practical,  it must meet



several basic criteria.  It must be environmentally acceptable in



present day America.  With incineration, this means air emissions



must pass stringent codes.  It should be economically feasible.  If




inflation is to be halted, total ownership costs of design, construc-




tion, and operation must be kept to a minimum.  It must be safe to



operate, both in the mind of the public and in reality.  Technically,



it must be sound, and capable of technological up-gradanq at reason-



able cost as engineering advances t.ikc place.  It obviously .should




deliver far more energy than it consumes (hopefully, in ratios of at




least 20 to 1 or better).  The energy should be saleable, immediately,




in a competitive market.  This latter point is particularly applicable




to waste heat, as it is difficult to store and is normally unr-il nn




generated.



     Large municipal incinerators, when converted to steam production



units, have experienced problems in meeting these criteria.  Emission



rates have been high unless expensive and rather sophisticated air



pollution control devices are installed.  Conventional incinerators



have produced a rather contaminated gas which coats and corrodes boil-




er tubes.  Costs of operation and total ownership have been high enough



to affect the feasibility of the process.



     The "small" incinerators available today are mass produced in




a factory and shipped, either completely assembled or in large sections,




to the site, resulting  in  low capital  cost.   To achieve  a
                              -64-

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given capacity, they are normally  installed  in  identical modules,



capable of any amount of desired expansion as needed.  They  utilize




pntiroly difforont engineering principles from  the  large conventional




incinerators.  As a result, they have  solved the emission problems




and the economic problems that have plagued  incineration for so many



years.  After automatic air treatment  within the- unit, they  produce



.1 fl.iMvoly nnrontaminntod q.in from Hir> burninq w.iMlo.  This high




temperature gas is passed through  a specially designed packaged boil-




er, or air mixer, as the fuel from which the energy  is extracted.








                   END USF.S OF THE F.NF.nr.Y PRODUCKD




     In an effort to achieve maximum pfficiency,  tho energy of the



waste heat gases has been used in  a variety  of  ways.  In general,




these are directly related to the  needs of the  institution,  industry,




or municipality considering tho purchnsr-.  Thn  most  common method



is to produce steam or hot wator dirc-rt ly in a  closo-coupled boiler




for process, comfort, or sanitary  use.  In institutional and dwelling




or office complexes, as well as factories, the  heating of air for



comfort conditioning is being investigated,  utilizing multi-tube



heat exchangers mounted in the exhaust system with or without blowers.



Direct conversion of the heat exchanger can  also be made for heating



water for process or sanitary use.  This system can be sophisticated



by the use of a thermal fluid heat exchanger for more efficient re-



covery of the available heat and in situations  where high temperature



process heating media is useful.   Another heat  recovery system is to



mix ambient air with the exhaust gases for process drying, curing



operations, or conveying air to maintain materials at elevated temp






                             -65-

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eratures.  Many plants and towns are now investigating the use of



low pressure steam turbines both for mechanical drives and for gen-



eration of electricity.



     With the steam production systems, the efficiency of the boilers



is in the range of 60% to 75%, depending on the design.  Emissions



in the stack gases, under normal operating conditions, have been



proven to be as low as 0.03 grains of particulate matter per cubic



foot of dry flue gas corrected to 12% CO2-  Net savings of fossil



fuel consumption are as high as 95% over a direct-fired boiler of



equivalent efficiency.  Steam sales revenue? are recapturing all



total ownership costs in many installations and tiermitting an oper-



ating profit in waste disposal.







                 CONSTRAINTS OF SOLID WASTE AS A FUEL



     Obviously, solid waste is not as efficient a fuel as any of the



fossil fuels.  It has a lower Btu output per pound in its average



"as received" condition; greater weights must be burned to produce



the energy equivalent of oil, coal, or gas.  The heat output of



solid wastes "as received" averages from 3,000 to 9,000 Btu/lb.  The



majority is one-half to one-third that of coal.  A pound of #2 oil



releases four times the enrgy of the equivalent weight of solid waste.



Waste has not the compactness of fossil fuel, and far greater volumes



must be burned to reach equivalent energy output.  Oil measures 31



to 35 cubic feet per ton; coal measures 45 to 50 cubic feet per ton;



solid waste usually ranges in density, in its "as received" condition,



from 130 to 400 cubic feet per ton.  However, it also contains, by



weight, up to 30% moisture and up to 30% non-combustibles, neither



of which contribute to the release of energy.  The combustible port-to.



                            -66-

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has densities as low as 650 cubic feet per ton.



     Hence, the fuel required in the average 70% efficient direct-



fired boiler to produce 1,000 Ibs. of steam would be approximately



1,440 cubic feet of natural gas or 10 gallons of #2 dieael oil, com-



pared to from 250 to 500 Ibs. of waste in a waste heat boiler.  De-



signers of waste heat recovery systems accept these ratios.  The



materials handling equipment and the engineering of combustion sys-



tems provide for the lower densities and larger volumes of fuel



(solid waste) that must be charged to produce satisfactory energy



recovery.







                       POLITICAL CONSIDERATIONS



     Solid Wdsbu as a jjolcnlial fuel is becoming increasingly val-



uable.  This has led to political discussions on federal, state, and



local levels, concerning the ownership of waste and what should be



done with it.  This Uittlo is sh.ipinq up between regional control,



with maun proclucLlim, muIt i million dollar, solid waste resource re-



covery systems, and the small controlled air systems that are being



promoted on a satellite basis for large cities, or for use in the



smaller towns, or in-house for factories and institutions.  With



solid waste at last being regarded as a practical fuel for the pro-



duction of usable energy on a profitable basis, we feel that this



battle will intensify during the coming years.



     In 1975, Public Service Commissions entered the picture because



controlled-air incinerators normally required allocations of fossil



fuel to at least start the combustion process'.  Some states, such as



Arkansas, have already handed down landmark decisions concerning the



allocation of natural gas to the plants that are producing ene-'cy




                             -67-

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from solid waste.  In summary, they have stated that such plants




produce up to 90% more energy than they consume in fossil fuels,




and, therefore, should be granted a high priority in the allocation




of fossil fuels such as natural gas.  The implications of such a



decision are considerable for any town planning to install a munic-




ipal plant for the burning of its waste and the selling of the entsrgy



to nearby factories.








                          ECONOMIC REALITIES



     During the past 18 months our firm has performed feasibility




studies on controlled-air incineration — waste heat recovery sys-



tems in a large number of communities ranging in population from



25,000 to 250,000.  A primary goal of these evaluations was to de-




termine whether there was an adequate match between the generation




of energy from solid waste and the energy requirements of commercial




buyers.  In all studies the concentration has been on the "bottom



line" of a profit and loss statement and on comparisons between the



"regional" and the "local" approach.



     Most engineers and accountants have known that the cost per



ton of design capacity of the small energy production systems is




considerably under the per ton cost of the large mass production re-



source recovery systems.  The small systems range in installed cost



from $12,000 to $14,000 per ton design capacity, as against c-ipitaj



costs per ton that are four to five times larger for the mass pro-




duction systems.



     A surprising result of the audits of the small systems was the




'. I*-  "loratinq cost we found.  Americans have always bocn led to
                             -68-

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believe that with mass production, operating costs fall off drastic-




ally.  Promoters of the large systems have inferred that their labor




costs per processed ton would be extremely low.  Intensive auditing




of the figures by our firm and the other engineering concerns has




revealed that this is not the case.  Recent audits have revealed



that total operating costs of small municipal plants (with outputs



as low as 100 tons per day) have been less than $6.25 per ton.  None



of the mass production plants have apparently been able to approach




this low a figure.



     These are gross operating costs from which must be deducted



the income from the sale of energy.  When the income figure is ap-




plied, all of the existing small plants appear to be generating a



profit for their municipalities.




     Table 1A shows the capital costs for plant and equipment of a




typical 120 ton per day municipal plant, with a cost per ton of de-



sign capacity of 512,417.  This figure is average for plants in this




size range in 1976.



     Table IB shows the annual operating costs.  Without interest




and depreciation they amount to $7.76 per ton.  When commercial in-



terest at 9% is added and the plant and equipment are completely de-



preciated over a relatively short time period, the total ownership



costs increase to $14.74 per ton.



     In this particular plant tipping fees are charged on a basis




equivalent to what the municipality figured were the real costs of




operating (and charging for) its sanitary landfill.  The steam sales



fontiact that was negotiated with a local industrial plant is tied



>..itc> the yuing price of fossil fuel and the steam is sold at a price





                            -69-

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approximately 15% lower than the industry can produce it in its own
boilers.  Table 1C shows the "bottom line" that is currently being
realized by the municipality on the operation of the plant under
commercial accounting methods with rapid depreciation and full com-
mercial interest being charged against the venture.  Over the life
of the plant total profit on the $1*5 million investment would be
$4,566,000.  If fossil fuel prices rise steam revenues and hence
profit will rise accordingly.
     In addition to the approximately 100 municipal plants that are
installed, under design or being seriously considered at present,
several hundred institutions such as hospitals and universities, and
an even larger number of factories have either installed or committed
to these same heat recovery systems for in-house use, to virtually
eliminate hauling fees, and to reduce fossil fuel costs by producing
energy from their own wastes.
     Installed capital costs of these installations usually range
from $100,000 to $170,000.  The return on investment is proving ex-
tremely attractive.  Table 2 shows the operational savings being ex-
perienced by typical hospitals — an average pay back of from 27 t.o
38 months.  Factories are finding even more rapid pay backs, in some
cases as low as 19 months.  When one realizes that a medium sized
factory generates 20 tons or more daily of high Btu waste, this is
not surprising.
     Futurists predict that, within 30 years, all resources will be-
come more limited for western civilization, that there will be less
and less waste generated, and the fuel for waste energy production
will gradually disappear.  In the meantime, each of us still produces
                            -70-

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almost five pounds of such waste daily.   It  can  be  put  to practical



use immediately.




     Equally important, compared to  all  other  processes being offer-




ed as an alternate to fossil  fuels where higher  temperature energy



is desired, the solid waste direct 'energy production  systems appear




to offer the greatest net oncrcjy return  or qain  against the energy



required to operate these- processes.  This is  based on  the studies



made to date on solid waste as a resource, as  well  as current designs



of other alternate energy processes.



     The importance of the waste energy  recovery process is that it




workn — .\i\il il workii now.   II in not ,i  I hcory th.it requires 10  moro



yours of development.  II is;  not a cure-all, but it can make a tre-



mendous impact on the present energy shortfall.
                            -71-

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                               TABLE 1A
                          CAPITAL INVESTMENT

             MUNICIPAL SOLID WASTE ENERGY PRODL'C^ION  PLANT
                   (120 tons per day design ca:>a<*it,'
Vn (ineerxng. Construction Management, Legal ,. PSa .
     Permits and Emission Testing	,	,,  f>   128,800
? a.\? Acquisition, Site Preparation, Sewer SjSti",  "ojrs,
     Landscaping, Fencing and Signs	       C>4,300
B-iilding Construction	     <1 9 ,000
Incineration - Steam Boiler System, with Suppc ;t
     Equipment, Instrumentation and Steam
     Delivery Lines, -Installed and Tested	   ...      9iC.4CO
Truck Scale	      , 	,.       l.,500
                          TOTAL CAPITAL COST            51,490,000

Cost per Ton of Design Capacity: $12,417


                           MOBILE EQUIPMENT

Front Loading Tractors	  $    22,000
Pick-up Truck	       3,900
Furniture and Supply Storage Facility	       3 ,800
Residue and Waste Containers	       7,000
                               TOTAL                    $   36,700
                              -72-

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                               TABLE IB
                        ANNUAL OPERATING COSTS
                        120  TON PER DAY PLANT
                        (34,320 tons per year)
Labor, Plant and Office 	  *  -04 . = 70
Frinoe Benefits	    i> 7-7''
Operating Supplies:
     Auxiliary Fuel  (#2 Oil)	    3*-. • ' ''
     Boiler Treatment	     q / •'"
     Utilities - Water, Electricity, Phone	    ID ,«•( >
     Plant, Vehicle and Office Supplies	     •> 800
     Vehicle Fuel	     1,400
Insurance	    15,700
Maintenance Fund	    40 , 300
Residue Disposal (Net Cost)	    28,600
                         TOTAL OPERATING COSTS        $ 266,370

Cost Per Ton of Waste: $7.76



Interest on Investment @ 9%	 $ 134,900
Depreciation on Buildings and Plant
     (Straight Line 15 Years)	    99,333
Depreciation on Vehicles (5 Years)	     5,180
                              TOTAL COSTS             $  505,783
Cost Per Ton of Waste: $14.74
                             -73-

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                               TABLE 1C
                           INCOME STATEMENT
                         120 TON PER DAY PLANT
SALES REVENUE
         Tippj n
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         - TABLE  2  -







ANNUAL OPERATING  COST SAVINGS




    IN GENERAL  HOSPITALS
Census
Size
300
400
500
600
700
Fuel
Savings
(Oil)
$22,648
30,198
37,201
43,986
50,549
Compacting
& Hauling
Savings
$13,450
16,800
20,600
25,900
30,600
Total
Savings
$36,098
46,998
57,801
69,886
81,249
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               EXPLOSION PROTECTION IN REFUSE SHREDDING
                                  By
                           Robert G. Zalosh
                  Factory Mutual Research Corporation
                         Factory Mutual System
                         Norwood, Mass.  02062

                                 ABSTRACT

     There have been over 100 reported refuse shredder explosions in the last
few years.  It is virtually impossible to eliminate all shredder explosions
because of the wide assortment of potentially explosible materials, i.e.,
flammable vapors, gas, and dusts and chemical explosives, that can be present
in municipal refuse.  The responsible material was not identified in the
majority of shredder explosions, but flammable vapors have been identified
in many others.  Commercial explosives, notably dynamite, which have occasion-
ally been involved, are the most difficult to protect against.  Explosion vent-
ing, explosion suppression systems, and continuous waterspray in the shredder
appear to be effective damage control measures for deflagration type explosions
caused by most flammable gases and vapors.  Although venting has been the measure
most often employed, the majority of shredder vent designs have not utilized
current explosion venting design technology.
                                    -76-

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INTRODUCTION
     The use of shredders to process solid waste has increased remarkably during
                                                               (1 2)
the past five years.  According to the recent Waste Age surveys  '   of shred-
ding operations in the United States and Canada, the number of reported refuse
shredding installations has multiplied approximately fivefold from 27 reported
shredding plants in 1971 to 144 in 1976.  Many of these installations shred
prior to landfilling, since the Environmental Protection Agency considers that
landfilling of shredded refuse can be an environmentally acceptable disposal
method that reduces the need for daily soil cover and increases site life.
Several other installations shred in order to obtain a relatively homogeneous
waste stream more amenable to automated material handling and other processes
associated with resource recovery, incineration, or the preparation of refuse-
derived fuels.
     This increased shredding activity has been accompanied by increased anxiety
about an inherent hazard in municipal refuse shredding.  The heterogeneous
municipal solid waste mixture entering the shredder occasionally includes poten-
tially explosible materials such as flammable vapors, combustible dusts, and
commercial or military explosives.  These materials can be ignited by impact
sparks or hot spots occurring during the hammering or grinding operations within
the shredders.  The resulting explosion may cause injuries or equipment damage
unless appropriate explosion protection measures are implemented.
     Factory Mutual Research Corporation (FMRC) recently conducted a refuse
shredder explosion hazard assessment for the Energy Research and Development
Administration.  The hazard assessment included a survey of explosions that
have already occurred at refuse shredding plants, and an analysis of alternative
explosion protection techniques available to shredder manufacturers and/or
operators.  The results of that study are summarized in this paper.  The complete
      (4)
report    can be obtained from the National Technical Information Service.
     The FMRC survey of shredder explosions was primarily concerned with the
conventional hammemills and grinders commonly employed in municipal solid
waste (MSW) plants.  Rogers and Hitte^ ' and Robinson  ' have recently pre-
sented comprehensive descriptions of hammermills and grinders, as well as other,
less common, refuse shredders.  The shredder explosions documented in the FMRC

                                  -77-

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survey were those that either caused damage or required the activation of a pro-
tection system (e.g., explosion vents) to avoid damage.  Thus, we excluded minor
"pops" due to aerosol cans and other materials that are more a nuisance than
bona fide explosions.  The only exceptions to this definition were a few cases
in which explosions were included that did not cause any physical damage, but
whose blast caused severe vibration of the building and shakeup of the plant
operators.
     A total of 95 explosions in mixed MSW shredders were reported during the
course of the FMRC survey.  (Since the survey was completed, this author has
learned of several other shredder explosions, putting the current total at well
above 100.)  The distribution of reported explosions among the three major types
of shredders is listed in Table I.  It is apparent that grinders, horizontal
shaft hammermills, and vertical shaft hammermills have each experienced a sig-
nificant number of explosions that is consistent with the relative populations
of shredder types in operation.
     Although shredder explosions are numerous, the damage and injury potential
from any single explosion is limited by the structural integrity of the shredder.
Only three of the reported explosions have resulted in any personal injuries and
those three involved plant personnel in the immediate vicinity of the shredder.
Damage within the plant is usually associated with peripheral equipment such as
ducts or conveyors, which are not as explosion resistant as the sturdy shredders.
Figures 1 and 2 show the damage incurred by a conveyor following one of the more
severe shredder explosions.  Only five (5.3 percent) of the reported explosions
have resulted in more than $25,000 property damage or caused the shredder to be
inoperable for more than a week.
     The reported intervals between shredder explosions were also documented In
the FMRC survey in terms of both time and solid waste throughout.  The average
reported throughout between explosions was 85,000 tons.  However, the newer
MSW plants that had shredded less than 50,000 tons (and, therefore, had better
recall of explosions occurring) reported an average interval of 20,000 tons
processed between explosions.  It is clear from these numbers that operators
of large MSW shredding installations can expect to encounter several explosions
during the lifetima of the plant.  The types and quantities of materials that
are responsible for these explosions are discussed in the following section.

                                 -78-

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                       FACTORY MUTUAL RESEARCH  CORPORATION
                                   TABLE I

           DOCUMENTED EXPLOSIONS  IN DIFFERENT TYPES OF SHREDDERS
Shredder
Type
Vertical
Grinder
Horizontal
Hammermill
Vertical
Hammermtll
Total
Number of
Locations
8
24
15
47
Number of
Shredders
11
38
17
66
Number of
Explosions
24
47
24
95
                                  TABLE II

          MATERIALS RESPONSIBLE  FOR REPORTED SHREDDER EXPLOSIONS
                                      Commercial or
                      Flammable       Military
                      Vapors  & Gases  Explosives
Undetermined  Total
Number of Explosions
                           30
                                           11
                                                           54
                                                                     95
                                   -79-

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              FACTORY  MUTUAL  RESEARCH CORPORATION
FIGURE  1  DAMAGED CONVEYOR FOLLOWING SHREDDER EXPLOSION
FIGURE   2   CLOSE-UP  OF DAMAGED CONVEYOR
                       -80-

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 POTENTIALLY  EXPLOSIBLE MSW MATERIALS
      Common  sense dictates that  explosives  such as  dynamite,  TNT and gunpowder,
 should not be  shredded because of  the obvious  explosion hazard.   However,  even
 if these materials can be completely  removed from the  shredded waste stream,
 there are a  variety of flammable liquids, gases,  and dusts  which will invariably
 be present in  refuse shredders.
      Table II  is a compilation of  the different types  of materials responsible
 for the shredder explosions reported  during the FMRC survey.   Only 11.6  percent
 of the reported  explosions were  attributed  to  identifiable  commercial or mili-
 tary explosives.  The large majority  of  explosions  were either attributed  to
 flammable vapors/gases or were of  undetermined origin.   Since many common  flam-
 mable vapors may not be recognized by shredder operators as explosible materials,
 many of the  explosions of undetermined origin  may also  have been due to  flammable
 vapors.

 Flammable Vapors and Gases
      Table III contains representative explosibility data for ten common flam-
 mable gases  and  vapors that may  occasionally appear in  MSW  shredders. The
 flash points listed in Table III are  the minimum temperatures at which enough
 vapor is evolved to form a flammable  mixture within the shredder.   Since tem-
 peratures in an  operating shredder are probably higher  than 100CF,  all of
 the vapors in  Table III are capable of forming explosible gas-air mixtures*
 in the shredder.
      The vapor concentration at  the flash point is  the  lower  flammable limit  -
 also listed  in Table III.   The other  end of the flammability  range is the  upper
 flammable limit  - defined as the maximum vapor concentration  capable of  sustain-
 ing flame propagation through gas-air mixture.   Although any  vapor  concentration
 between the  lower and upper flammable limits corresponds to an explosible  mix-
 ture,  the most violent explosions  are usually  associated with nearly stoichio-
 metrlc mixtures.  A stoichlometric mixture  is  defined as one  in  which there is
 just enough  air  and fuel for the combustion reaction to be  completed with  no
*Even if the liquid temperature is below the flash point, flammable liquids
 dispersed in the form of a fine mist or spray can undergo explosions.
                                  -81-

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                       FACTORY  MUTUAL  RESEARCH CORPORATION
                                 TABLE  III
         EXPLOSIVE PROPERTIES OF COMMON FLAMMABLE VAPORS AND GASES
Gas/Vapor
Acetone
Benzene
Ethyl Alcohol
Gasoline
(100 octane)
Isopropyl
Alcohol
Methane
Naphtha
Propane
Toluene
Turpentine
Common
Household
Uses/Products
Paint Solvent
Paint Thinner
Liquor, Cologne
Motor/Lawn-
mower Fuel
Rubbing
Alcohol
Refuse Decompo-
sition Gas
Lighter Fluid
Charcoal Fluid
Fuel Gas
Paint Thinner
Paint Cleaner
Flash
Point*
(°F)
0
12
55
-45
53
Gas
28-85
Gas
40
95
Flammable Limits
(vol %)**
Lower - Upper
2.6 -
1.3 -
3.3 -
1.4 -
2.2 -
5.0 -
0.9 -
2.1 -
1.2 -
0.7 -
13
7.9
19
7.4

15
6.7
9.5
7.1

P ** K **
max G .
(psig) (psi-ft-sec )
83
97
99
-
92
-
94
96
92
-
1410
1625
1770
—
1340
-
1770
1770
1700
-
*   from reference 6
**  from reference 7
*** from Table 3 in reference  8
                                 -82-

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remaining gaseous fuel or oxidant.  The stoichiometric concentrations  of  the
vapors listed in Table III are equal  to approximately twice  the lower  flammable
limit concentrations.
     The other two parameters in Table III, P    and K , refer to explosions  of
approximately stoichiometric gas-air  mixtures in closed vessels.  P    is  the
                                                                   max
maximum pressure developed in the explosion, and K  is defined to be

                            V1/3                                         (1)
where  —I    is the maximum rate of pressure rise and V  is  the vessel volume.
The valuesmS? P    and K  lie in relatively narrow ranges for the  flammable gases
               max      u
and vapors listed in Table III.  Two gases with significantly larger values of
P    and K- are acetylene and hydrogen.  They were not included in Table  III be-
 max      la
cause they are not as likely to appear in municipal refuse.  However, should they
get into a shredder (acetylene was suspected in one reported shredder explosion)
they are capable of producing more violent explosions.
     The maximum pressures and rates of pressure rise indicated in Table  III
refer to deflagration type explosions.  The flame propagates through the  unburned
gas-air mixture at subsonic velocities (of the order of 1-10 ft/sec) in a deflag-
ration, whereas it propagates supersonically in a detonation.  The distinction  is
important since during a detonation the pressure rises virtually Instantaneously
(as soon as the shock wave arrives at a given location) and  there  is no time to
take corrective action before the explosion is consummated.  Most  shredder explo-
sions involving the flammable gases or vapors in Table III are probably defla-
grations because detonations require either explosive ignition sources or a
tubular (or ductlike) geometry.
     Most MSW shredders would be damaged beyond repair when  subjected to  the
peak pressures shown in Table III (83-99 psig).  These pressures refer to a
closed vessel completely filled with an optimum gas-air mixture.   For a typical
shredder volume of 1600 ft  (including inlet hood), a stoichiometric mixture
would require about 1.7 gallons of gasoline to be vaporized  and mixed with the
air in the shredder.  Comparable volumes would be required for the other  volatile
liquids listed In Table III.  Vapor volumes and mixtures of  that size are
                                  -83-

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certainly possible but a more likely scenario is for only a portion of the shred-
der to be occupied by a flammable mixture at ignition.
     Figure 3 can be used to estimate the maximum pressure developed in an explo-
sion involving a local pocket of flammable gas/air mixture of approximately
stoichiometric proportions.  The data and theoretical curve in Figure 3 refer
                                                             (9)
to a propane/air mixture.  According to the theoretical model    of the adiabatic
compression of a oerfect gas, the results in Figure 3 should be applicable to
all gas mixtures having the same value of the ratio (M  T,)/(M.  T ).  The sym-
bols M and T denote mixture molecular weight and temperature, and the subscripts
u and b refer to unburned and burned gas, respectively.  This ratio is also equ.il
to the theoretical ratio of the maximum pressure to initial pressure for a
                                          (9)
deflagration in a completely filled vessel   .  Since the values of P    for the
                                                                     max
fuels, including propane in Table III do not differ by much (P   =91+8 psig),
we expect the curve in Figure 3 to also be approximately valid for all of these
fuels.
     Since the pressures in Table III and in Figure 3 pertain to closed vessels,
they provide conservative estimates of the pressures developed in partially
vented shredders.  A quantitative discussion, of the relief provided by venting
is presented in the discussion of alternate protection measures.  Nevertheless,
it is interesting to use the data in Figure 3 to estimate the amount of flam-
mable gas/vapor required to produce significantly high pressures in a structure
the size of a typical shredder.
     According to Figure 3, flammable mixture volumes equal to 10 percent of
the shredder volume are capable of producing overpressures of about 10 psi in a
completely enclosed hammermill.  Based on damage estimates from some of the
explosion reports, it appears that pressures of 7-10 psi will initiate major
damage to discharge hoods, door latches, and other peripheral equipment.  Thus,
damaging explosions can result from as small a volume as 0.17 gal of gasoline
completely vaporized and mixed in stoichiometric proportion with 10 percent
of the air in a 1600 ft  shredder.  Discarded containers containing at least
that quantity of gasoline, paint thinner, charcoal lighter fluid, etc. must
appear often in MSW shredder input streams.  It is no wonder that a large frac-
tion of the reported shredder explosions were due to such flammable vapors and
gases.
                                  -84-

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                                                                o
                                                                o
I I I  I  I    i	11 I i  i i  i  i   i	i 11 i
                 -  aansssHd NOisoidxa wnwixvw

                                    -85-

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Commercial and Military Explosives
     Carelessly or surreptitiously discarded explosives, such as gunpowder, dyna-
mite, and military ordnance, occasionally appear in MSW shredding plants.  Many
of these explosives can be triggered by impact, friction, sparks, or hot spots
present during shredding.  Shredder explosions caused by these materials are
more difficult to control than flammable vapor explosions because  1) explosives;
contain their own oxidant and need not vaporize and mix with air to form an ex-
plosive mixture, and 2) the resulting explosion is often a detonation rather
than a deflagration.
     Laboratory tests to determine explosive sensitivity have been conducted for
the more common explosive materials.  Interpretation of this test data, indicates
TNT, will also detonate when triggered by the lead azide primer, which is particu-
larly impact sensitive.  The sensitivity of smokeless gunpowder is strongly in-
fluenced by its moisture content.
     Reports of the shredder explosions due to dynamite and military ordnance
indicate that blast waves, characteristic of detonations, occurred.  There has
been one documented shredder explosion caused by smokeless gunpowder, but it waa
not one of the more violent explosions.  This is probably because gunpowder is a
low-order explosive, tending to produce deflagrations.  The explosive yield and
TNT equivalence of various explosives in Table IV can be found, for example, in
Baker's text.(10)

Combustible Dusts and Hybrid Dust/Gas Mixtures
     Although none of the reported shredder explosions were unequivocally attribu-
ted to combustible dusts, there is speculation that some of the explosions of
"undetermined cause" may have actually been caused by a combustible dust cloud.
If some explosions at shredding plants are indeed caused by dust, they are more
likely to originate in dust collecting equipment rather than the shredder itself.
This is because a bona fide dust explosion can only occur if the dust particle
size is small enough to be classified as a powder, i.e., much smaller than 1 mm.
Thus, Palmer, in discussing the explosion hazard of grinding machines (Reference 11,
p. 300), states that "the explosion risk is low for those crushers delivering
product of a few centimeters (1 in.) diameter," which is a typical average
                                  -86-

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particle size for'MSW shredder output.  Palmer warns, however, that precautions
should be taken to prevent the small proportion of powder produced In the crush-
ing process from accumulating In a confined area.
     Palmer's speculation and admonition Is consistent with the results of the
                                                      (12)
FMRC survey of shredder explosions.  In the one report     where there was any
real evidence of a dust explosion, the explosion originated in a small separate
structure through which the shredded refuse was conveyed.  Apparently, dust was
allowed to accumulate in the conveyor house, and a friction spark set off the
explosion which destroyed the concrete structure.  Photographs illustrating the
damage Incurred in this incident are shown in Figures 4 and 5.
     It is very likely that, upon occasion, combustible dust and flammable gas
or vapor will be present simultaneously in a refuse shredder.  These so-called
hybrid mixtures are particularly hazardous because they can be explosive even
when the Individual gas/air and dust/air constituent mixtures are not explosible.
           (14)
For example    , a methane concentration of 1 vol percent in air is below the
lower flammable limit, and PVC dust consisting of particles with a diameter of
100 microns will not explode in any concentration.  However, when the two are
combined, an explosible hybrid mixture results that can develop a maximum pres-
sure of about 8 bars (118 psi) at a PVC concentration of 100 gm/m .
     It is particularly noteworthy that small quantities of methane can con-
tribute to explosible hybrid mixtures.  The refuse decomposition process which
produces methane ia a relatively slow one (landfills require about six months
to generate collectible quantities of methane), probably too slow to produce
enough methane to form a flammable methane/air mixture in a shredder.  However,
it may be possible for small quantities of methane to combine with accumula-
tions of fine combustible dust to form an explosible hybrid mixture in the
shredder.
                                  -87-

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              FACTORY MUTUAL RESEARCH  CORPORATION
FIGURE  4  EXPLOSION AT VOLUME REDUCTION PLANT.  SHREDDER
           BUILDING AT RIGHT.   COMPACTOR BUILDING  AT LEFT.
           (Reference 12)
FIGURE  5  REMAINDER OF  REAR  WALL  OF CONVEYOR BUILDING NEAREST TO
           SHREDDER PLANT               (Reference 12)

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EXPLOSION PROTECTION MEASURES
     Explosion protection consists of preventive measures and damage control
techniques.  Although prevention is preferable to damage control, it is un-
realistic to expect currently available preventive measures to eliminate all,
or even most, shredder explosions.  Manual and automatic shredder input screen-
ing and other preventive measures are discussed in this section, but primary
emphasis is placed on damage control measures.
     In assessing the potential effectiveness of damage control techniques,
It is important to differentiate between detonations and deflagrations.  The
local overpressurization in a detonation occurs instantaneously via shock wave
propagation, but the overpressurization in a deflagration occurs over a time
interval on the order of 0.1 - 1.0 sec in a typical size shredder.  Most of
the protective measures discussed herein should be effective for incipient
deflagrations, but cannot be expected to provide much protection for detona-
tions.  The two exceptions are isolation and blast resistant construction.
Since most shredder explosions are deflagrations, all of the protection meas-
ures are worthy of consideration.

Preventive Measures
     To prevent an explosion, either the ignition source, the explosive material,
or, (for combustion type explosions) the oxidant must be removed.  In hammermills
and grinders, ignition sources include impact sparks, friction sparks and local
hot spots.  These sparks and hot spots are inevitable with the metal hammers
and grinder rings used today.  Some radically different hammer/grinder material
or coating would be required to eliminate all ignition sources, and no such
development seems to be imminent.
     Inerting to reduce the oxygen content does not appear any more promising.
Refuse shredding operations currently are continuous processes involving large
openings to the atmospheric at the inlet and outlet.  Inerting would require
either completely closing the shredder openings or else providing a continuous
source of inert gns.   Neither technique appears to be economically feasible.
                                 -89-

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     The other preventive measure, removal of explosible material, involves
either manual or automatic screening of shredder input materials or continu-
ous purging of explosible material in the shredder.  Manual screening is already
a common practice.  Obviously explosive materials, as well as difficult-to-shred
items, such as rolled-up carpets, cables, and large tree limbs, are removed
from the tipping floor or the shredder input conveyor.  Manual screening is
necessary but cannot be relied upon to remove the entire gamut of potentially
explosible items.  A possible improvement in manual screening efficiency might
be achieved by indoctrinating refuse plant and collection personnel in the
potential explosion hazards of the seemingly innocuous flammable vapors dis-
cussed previously.
     The use of automatic detectors to screen various explosive materials is
possible in principle, but its feasibility is questionable.  Vapor detectors
placed upstream of the shredder would have to be extremely sensitive to detect
the presence of flammable vapors or explosives still contained in their package.
Vapor detectors placed within the shredder would only be useful if they triggered
some active suppression or inerting system, since most shredders require several
minutes to come to a halt.  In either case, the detector would have to be in-
vulnerable to false alarms caused by a variety of non-explosible vapors, and
would also have to resist deterioration in a rugged, dirty environment.  Cur-
rently available commercial detectors do not meet these stringent constraints
(reference 4, pp 51-52).  Thus, automatic screening of potentially explosive
materials is not a realistic alternative in the near future.
     Continuous purging of explosible materials by utilizing large air flow
ventilation rates has also been considered.  To be effective, the air flow rate
must be large enough to dilute or remove the flammable vapor (or dust) before
it mixes with air and encounters an ignition source.  Vapor mixing and spark
ignition sources, i.e., hammer impacts, are both related to shredder shaft ro-
tation, so the characteristic time for these processes is the reciprocal of
shaft RPM, K.  The characteristic time for diluting/removing the vapor in the
shredder is V/Q, where V is the shredder volume (ft ) and Q is the air flow
rate (cfm).  Thus, if the vapor is to be swept out before it forms a flammable
mixture and ignites, the ratio Q/VH should be larger than unity.  However, for

                                  -90-

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the typical values, Q = 10,000 cfm, V = 1,000 ft3, £2 = 1,000 RPM, this ratio
     _2
is 10  , two orders of magnitude too small to rely on continuous purging as a
preventive measure.  We conclude that purging, like the other preventive measures,
may be helpful, but does not provide a foolproof safeguard against explosions.

Explosion Venting
     The basic concept of an explosion venting system is that the maximum pres-
sure developed in a deflagration can be greatly reduced if the burned and un-
burned gases are allowed to escape from the confining structure before the com-
bustion process is completed.  This can be achieved by providing vent doors,
blow-off panels, rupture discs, etc., on the equipment or building containing
the explosion.  To be effective, the vent area, inertia, release pressure,
and proximity to the ignition source must be adequate to allow the gases to es-
cape before damaging overpressures are generated.  Furthermore, any ducting em-
ployed to channel the gases out of the surrounding building must avoid a recom-
pression of the gases on their way out.
     Most refuse snredders currently in use do not have adequate explosion vent-
ing provisions.  Those shredders that are outfitted with explosion vents usually
have undersized vents (according to the guidelines discussed in this section)
that are often located too far from the ignition source, ±. ., the hammers,
to be effective.  This is particularly true when inlet and discharge openings
and reject chutes are relied upon for venting.  These openings are usually too
obstructed with refuse and debris to provide a large enough outflow rate for
the vented combustion gases.
     During the past few years, several different quantitative explosion vent-
ing guidelines have been proposed for gas and dust explosions in process equip-
ment.  These guidelines, which are prescribed in references 8,9 and 13-17
describe how a vent system can be designed for a given combination of fuel/
oxidant mixture, ignition source, and restraining vessel.  Most of these guide-
lines have been developed from tests in spherical, cubical, cylindrical, or
other simple shaped vessels of various sizes ranging from laboratory scale to
60 m .  They have not been verified for equipment as complicated in shape and
contents as a refuse shredder.  In particular, internal equipment and refuse

                                  -91-

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within the shredder are likely to obstruct the flow of vented gases and thus
produce significantly higher pressures than are measured in similar sized
vessels free of obstructions.  Furthermore, there are sometimes large discrepan-
cies between the various venting recommendations.
     Since none of the quantitative explosion venting guidelines have been
verified by tests simulating shredder explosions caused by flammable gases or
vapors, no single guideline can be decreed to be most applicable for shredder
explosions.  The general procedure for using the guidelines for gas explosions
will be reviewed here and a comparison of predicted vent areas for three dif-
ferent shredders will be presented.  The guidelines will be applied for a
worst-case, near stoichiometric propane-air mixture, since propane is repre-
sentative of the flammable gases expected in a refuse shredder (Table III),
and much of the available venting data was obtained with propane.
     An essential parameter in all of the recent guidelines is the quantity
AP   , which is the maximum tolerable overpressure for the equipment (includ-
  m&x
ing ducts, hoods, etc.) containing the deflagration.  The appropriate value of
AP    should be specified by the equipment manufacturers on the basis of test-
ing or structural analysis.  Inquiries to shredder manufacturers, however,
have indicated that they are unaware of what the value of AP   , should be for
                                                          ngf*
their equipment.  Therefore, observations and measurements     of damage in-
curred during several shredder explosions will be used as the basis for esti-
mating AP   .  These observations indicate that appreciable damage to peripheral
equipment occurred at overpressures of about 5-7 psig.  The recommendations
presented here (Table IV) correspond to AP   =4.4, which was a convenient figure
to use in one of the guidelines, and also provides a small measure of conserva-
tism, i.e., safety.
     Another parameter in the venting guidelines is P , the pressure at which
the vent is opened.  P  should be considerably less than AP    because  1) the
maximum pressure in a vented deflagration is often larger than the vent release
pressure, and 2) most industrial buildings containing, or adjacent to, shred-
ders will fail at overpressures well under 5-7 psig.  In the following examples,
P  is set equal to 1.45 psig because this is the lowest value of P  in some of
the venting correlations.

                                  -92-

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     The turbulence level* in the vessel is still another pertinent factor in
the explosion venting guidelines.  In some guidelines   *    the turbulence level
is an on-versus-off factor, i.e., agitated gas versus quiescent gas, while in
other guidelines  '    the turbulence level is specified as some multiple of
the fundamental laminar burning velocity of the gas-air mixture.  In both cases,
the required vent area to achieve a specified peak pressure is larger for a
turbulent gas mixture, such as would be expected in a shredder, than for an
initially quiescent mixture in which laminar flow prevails throughout the vent-
ing process.
     Once the combination of shredder volume, maximum tolerable overpressure,
worst-expected-caoe fuel/air mixture, desired vent release pressure, and turbulence
level have been ascertained, the explosion venting correlations in references 2,9,
and 13-17 can be utilized to determine the required vent area.  This has been
performed for the three representative shredders listed in Table IV.  The recom-
mended vent areas shown in Table IV are slightly larger than the values originally
given in Table XII of reference 4, because the values shown in Table IV were
                         (19-21)
calculated using new data        on turbulence effects that have become available
since the report was written.  The new data indicate  1) that the most appropri-
ate value for the ratio turbulent/laminar burning velocity factor appearing in
the Yao correlation is x-4 and 2) that the turbulent value of K  (defined in
                                                               b
eq (1)) for propane appearing in Bartknecht's nomograms is 5.5 times the
laminar value indicated in Table III.
     Although there have not been any shredder explosion tests with gaseous
fuels to verify the validity of the vent areas recommended in the various guide-
             /T O \
lines, Scholl     has recently conducted some dust explosion tests.  The tests
were conducted in an older version of a HAZEMAG horizontal hammermill and were
primarily sponsored by HAZEMAG Germany.  Most of Scholl's tests were designed
to evaluate various explosion suppression configurations, but he also conducted
some explosion venting tests.
     Figure 6 is a schematic illustration of the dust dispersion arrangement
and instrumentation employed by Scholl.  Four different dusts (coal dust,
*Turbulence level here refers to both the pre-ignition state of the gas and to
 the turbulence developed by the vented gases.
                                  -93-

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                      FACTORY MUTUAl RESEARCH  CORPORATION
                                 TABLE IV
                    COMPARISON OF RECOMMENDED VENT AREA
                 CORRELATIONS APPLIED TO THREE HAMMERMILLS

                                             Recommended Vent Area  (ft  )
                Shredder                NFPA 68*     Yao**     Bartknecht***
     Williams Model 680*494558.1
     (Horiz. Hamuermill + Inlet Hood,
     Volume -150C ft3
     L/D = 3)
     Modified Hazemag**                   57.8        50.8           73.2
     (Horiz. Hammermill,
     Volume -1800 ft3
     L/D = 2)

     Heil Model 42D                       12.3         9.7           11.8
     Vertical Hammermill,
     Volume -150 ft3
     L/D = 2)

*   Based on Table 2, pp 68-36, reference 8
**  from Figure 11 of reference 16, for x=4
*** from Figure 10 of reference 14, adjusted to account for turbulent
    value of K
                                      -94-

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                                                V,  « 14.3 m3
                                                V2- 3.3m3
                                                V3« 0.8m3
                                                V4» 2.6m3
                                                V8- 8.0m*
             Rotor
                                       --> St3


'. ! ! 1st
.
1+2
|V*


rt
                   F  «  Open  Area  (Ffot(ri-5.8m2)
                   Z  =  Ignition
                   St *  Dust  Disperiol Orifice
                   P  *  Presture  Transducers
FIGURE 6   SCHEMATIC DRAWING OF HORIZONTAL HAMMERMILL USED  IN
           SCHOLL'S DUST EXPLOSION TESTS; TOTAL VOLUME = 29 m3.
           (From Reference 18 ,  Figure  5)
                         -95-

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polyester, "Hexa", and "Sirona") were tested with a spark ignition located
near the rotor.  Pressures were measured in the mill and in the inlet and dis-
charge hoods.  The objective of the tests was to find some suppression and/or
venting arrangement that would keep the pressures within tolerable levels and
also prevent flame propagation through the inlet and discharge hoppers.
     In order to obtain an adequate vent area in the vicinity of the ignition
source, i.e., the rotor, Scholl eventually modified the hammennill as shown
in Figure 7.  The results obtained with the modified vented hammennill are
                                                                2           2
shown in Table V.  When the vent area was increased from 10.8 ft  to 64.6 ft  ,
the mill pressure was reduced from 3.7 psig to 0.7 pslg in the test series with
Sirona dust.  A significant reduction in pressure was also obtained with Hexa
dust when the vent area was increased from 21.6 ft  to 64.6 ft .
     The flame duration times indicated in Table V indicate that venting alone
cannot be expected to prevent flame propagation into and through the shredder
inlet and outlet areas.  Therefore, the vented gases should not be discharged
into a space containing personnel or unprotected equipment.  If the shredder
is located inside a building, it is often necessary to provide a vent duct to
channel the vented gases out of the building.
     If a vent duct is employed, the vent must be designed to prevent a re-
compression of the vented gases and a possible escalation of the deflagration
                              (14)
into a detonation.  Bartknecht     recommends that the vent duct for typical
granulators be less than 6 m (19 ft), and, if its length is in the range 3-6 m,
the maximum pressure can be increased substantially over the equivalent un-
                                       /Q \
ducted situation.  The NFPA guidelines     suggest that, if any appreciable duct
length is required, the cross-sectional area of the duct should be at least
twice that of the vent device.  Furthermore, the duct should not have any
bends including the junction with the shredder.
     Several refuse shredder installations already employ vented ducts and/or
blow off panels on the walls of the shredder building.  Figure 8 shows such
an installation in which one vent duct attached to the shredder led to two
heavy hinged doors on the roof of the building.  Unfortunately, the doors were
too heavy to open fast enough, and were blown off their hinges as a result of
the explosion.  The ducting and roof vent have since been replaced with a diverg-
ing duct and a lighter roof vent.
                                  -96-

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                                        Vent Area
                                          1-6 m2

                                        Inlet Hood  Lengthened

                                        One Impact  Plate  Removed
FIGURE 7   MODIFIED HAMMERMILL USED IN SCROLL'S EXPLOSION VENTING;
           TOTAL VOLUME = 51 m3.  (From Reference 18 ,  Figure  34)
                           -97-

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             FACTORY  MUTUAL  RESEARCH CORPORATION
                        TABLE  V
     SCHOLL'S DUST EXPLOSION VENTING TEST RESULTS
                  (from Reference  18)
Dust Type     Vent Area       Pffiax      Flame Duration
                 (ft2)        (psig)           (sec)
 SlronaIO          57?              174
    "            21.6          2.6              3.2
                 64.6          0.7              0.7
  Hexa           21.6          2.8              8.6
    "            64.6          1.6              4.7
                        -98-

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             FACTORY  MUTUAL RESEARCH  CORPORATION
FIGURE 8    SHREDDER BUILDING FOLLOWING EXPLOSION
                         -99-

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     Several other damaging explosions in inadequately vented shredders have
demonstrated the need for improved venting guidelines applicable to shredder
operations.  A test program similar to the one conducted by Scholl, but employ-
ing flammable gases, would be extremely useful in generating the data required
for such improved guidelines.

Explosion Suppression System
     The basic premise of an explosion suppression systeir is that the maximum
pressure and flame propagation can be reduced to tolerable levels if a suitable
extinguishing agent is injected quickly enough into an incipient confined gas
or dust deflagration.  An inherent advantage of a successful suppression systeir
over an explosion venting system is that the flame will be extinguished in the
shredder, so that the post explosion fire hazard is eliminated.
     Various types of explosion detection devices (ultraviolet, infrared, thermal,
and pressure) cau be employed to actuate the suppression system, but the one
usually employed in the dirty, obstructed shredder environment is a fast-response
pressure transducer.  The actuation pressure of the detector must be low enough
to allow for early introduction of the extinguishing agent, but high enough to
avoid false alarms due to slight pressure transients under normal operation.
For shredders, the actuation pressure is usually in the range 0.5 - 1.5 psig
depending on the extinguishing agent used.
     The explosion suppression agents most commonly employed in the United States
are the halogenate.d hydrocarbons (Halons).  The Halons are believed to chemically
inhibit the combustion process.  The Halons used for explosion suppression appli-
cations are bromochloromethane (Halon 1011, CB), Halon 1301 (CF Br), and
Halon 2402 (C_F Br ).  Fenwal, Inc., which is the only American manufacturer
of commercial explosion suppression systems, recommends Halon 1011 for use in
hammermills and grinders.  The concentration of CB recommended by Fenwal is
25 liquid cc's per ft  of vessel volume.
     The explosion suppression agents favored in Germany are the chemical
extinguishing powdsrs, amnsnium phosphate and sodium bicarbonate.  Tests con-
                    (1'^ 14)
ducted by Bartknecht   *    indicate that these powders are effective even at

                                 -100-

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relatively high actuation pressures, i.e., when the deflagration process  is
well underway.  Thus, powder suppression systems seem to be less susceptible  to
false alarms than are Halon systems.  Bartknecht provides recommended concen-
trations of extinguishing powder for various combustible gases and dusts  and  for
different actuation pressures in references 13 and 14.  Results of recent
                 (19)
Coast Guard tests     in large obstructed enclosures also indicate that the mini-
mum required ageut concentrations  (mass of agent per unit enclosure volume) for
successful suppression are lower for dry chemical powders (Purple K) than for
Halons.
     No matter which agent is deployed, the effectiveness of an explosion sup-
pression system is limited by both the detection time and the travel time for
dispersing the agent into the unburned-fuel/air mixture.  Thus, fuel/air mixtures
with exceptionally fast burning velocities and rates of pressure rise cannot  be
extinguished early enough to provide proper protection.  For successful suppres-
                                                   (19)
sion of propane/air mixtures, the Coast Guard tests     indicated that Halon
agents must be completely dispersed within 150 millisec after ignition.  Fuels with
faster burning rates (or larger values of K_), e.g., acetylene, would require
                                           G
shorter detection/dispersal times*.
     Although there have been no shredder explosion tests with gaseous fuels,
                                    (18)
Scholl's explosion suppression tests     have recently provided a quantitative
measure of the effectiveness of the German suppression system for dust explo-
sions.  The haitimermill used in Scholl's first series of suppression tests is
the one shown in Figure 6.  The results obtained by Scholl for polyester dust
explosions with and without a suppression system are given in Table VI.  The
suppression system arrangement used in this test series consisted of 14 agent
containers uniformly distributed throughout the hammermill.  It is clear from
Table VI that the suppression system reduced the peak pressures significantly
below the corresponding unsuppressed case.   Furthermore, the flame duration
times in the shredder inlet and outlet were reduced by an order of magnitude
with the suppression system.
*The critical detection/disposal time also depends upon shredder volume, V,
 since the time
 (reference 13).
since the time at which a given overpressure is developed is proportional to V
                                 -101-

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                       FACTORY MUTUAL RESEARCH  CORPORATION
                                 TABLE VI
                 SCROLL'S DUST EXPLOSION SUPPRESSION TESTS
                             (from Reference 18)
Polyester Dust
Concentration
(gm/m )
250
500
250
500

P
max
(psig)
5.9*
8.1*
3.7
5.1
Flame
Duration
(sec)
4.8
>6.1
0.25
0.35
Suppression
System
No
No
Yes**
Yes**
*  Outlet hood was bent and rubber curtain  at  inlet  blew away in these tests.
** The suppression system used in these  tests  consisted of  14 kg bottles of
   dry chemical suppression agent installed throughout  the  mill and activated
   at an overpressure of 1.5 psi.
                                  -102-

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     Scholl also made two significant observations about the disadvantages of
using a suppression system with an actuation pressure of 1.5 psig:  1) he
observed that relatively mild deflagrations, such as were obtained using coal
dust, produced maximum pressures below the actuation pressure.  Therefore,
the agents were never discharged and flames propagated through  the hammermill;
2) the same result occurred when a large vent area was used in  conjunction with
the suppression system to minimize overpressures.  Thus, venting and suppression
are incompatible unlass the vent relief pressure is significantly higher than
the suppression actuation pressure.
     Fenwal suppression systems with Halon 1011 agent actuated  by pressure trans-
ducers triggering at 0.5 psig and at 1.5 psig have been installed during the past
year at several shredding plants.  There have been several successful actuations
and suppressions.  There has also been one incident in which some damage was
incurred, but the material causing that explosion was not determined.

Water Spray
     A continuous water spray is used in several refuse and automobile shredders
primarily to reduce the suspended dust level.  These shredders  have experienced
significantly fewer damaging explosions than shredders operating dry.
     A fine water spray or mist can prevent or mitigate explosions through the
following mechanisms:  1) the water droplets can quench, or at  least decelerate,
the incipient flame; 2) air entrained into the water spray may  dilute the flam-
mable mixture more efficiently than forced ventilation; 3) the  water vapor
represents an inerting agent slowing down the combustion reaction; and 4) some
flammable gas may be removed by adsorption onto the water droplets.
     Our current understanding of these mechanisms is not sufficient to specify
the water flow rates and drop sizes needed for successful suppression/prevention.
One shredder installation that has experienced some success* with a water spray,
utilizes a flow rate of A gal/min for four shredders and ducting with a total
volume of 18,000 cu ft.      Although large water flow rates are desirable for
explosion mitigation, they can cause such deleterious side effects as corrosion,
*The water spray seems to have reduced both the frequency and severity of
 explosions in this plant.
                                 -103-

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increased particle size of shredder output, and high moisture content in shredder
output.  More testing and operating experience is needed before the optimum com-
bination of water flow rate and drop size, i.e., nozzle type and pressure, can be
determined.

Miscellaneous Protection Measures
     One of the simplest and most effective injury prevention techniques is
isolation.  Plant personnel should not be near the shredder while it is opera-
ting.  One of thfi injuries reported in the shredder explosion survey occurred
in a plant where the control room is only about 10 ft from the shredder.  In
plants where the control room is immediately adjacent to the shredder, it is
important to use high-strength glass (> 3 psig fracture pressure) in the control
room window.
     If personnel or valuable equipment must be located near the shredder, the
use of barricades or blast mats should be considered.  The barricades should
be designed to deflect an impinging blast wave and also prevent penetration
by missiles (fragments) caused by the explosion.

CONCLUSIONS
     There have been over 100 reported refuse shredder explosions in which some
damage was incurred or which caused the activation of some explosion protection
measure.  76 percent of the shredding installations surveyed, have experienced
at least one explosion.  Although the responsible material was not identified
in the majority of explosions, flammable gases and vapors are often involved.
Damaging overpressures can be produced from as little as 1/4 gal of gasoline,
paint thinner, etc. in a shredder of typical size.  Commercial and military
explosives such as dynamite and gunpowder have also been responsible for some
explosions.
     Because of the wide assortment of potentially explosible material in mixed
municipal refuse, preventive measures such as manual or automatic screening of
shredder input cannot be expected to eliminate explosions entirely.  Instead,
emphasis should be placed on damage control measures.  Explosion venting,
explosion suppression systems, and water spray all show promise for mitigating
                                  -104-

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 the effects of deflagration-type explosions associated with most flammable vapors.
However, tests and additional operating experience are needed to determine
whether existing design guidelines for these systems are applicable to the
complicated shredder environment.  For detonation-type explosions caused by
most commercial and military explosives, isolation of the shredder and the use
of blast mats or barricade appear to be the only feasible damage/injury con-
trol measures.
                              ACKNOWLEDGMENTS

     The author is grateful to Messrs. D.E. Patterson and A.A. Weintraub of the
Energy Research and Development Administration for initiating and supporting
this work under Contract No. E(49-l)-3737.  Thanks are also due to
S.A. Wiener and J.L. Buckley of Factory Mutual Research Corporation for their
contributions during the course of the study.
                                  -105-

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                                REFERENCES

 1.  Anonymous, "Solid Waste Shredding:  Blueprint for Progress,"
     Waste Age, vol 6, pp 10-15, July 1975.
 2.  Anonymous, "Solid Waste Shredding:  Continued Growth in Waste Processing,"
     Waste Age, vol 7, no. 7, pp 34-40, July 1976.
 3.  Rogers, H.W. and Hitte, S.J., "Solid Waste Shredding and Shredder Selection,"
     Environmental Protection Agency Report EPA/530/SW-140, March 1975.
 4.  Zalosh, R.G,, Wiener, S.A., and Buckley, J.L., "Assessment of Explosion
     Hazards in Refuse Shredders," Energy Research & Development Administration
     report ERDA-76-71, 1976 (available from National Technical Information
     Service, Springfield, Virginia 22161).
 5.  Robinson, W.D., "Shredding Systems for Mixed Municipal and Industrial Solid
     Wastes," 1976 National Waste Processing Conference Proceedings,
     Paper M4-C, ASME 1976.
 6.  NFPA No. 325M, "Properties of Flammable Liquids," 1969, available from
     National Fire Protection Association, Boston, Mass.  02210.
 7.  Zabetakis, M.G., "Flammability Characteristics of Combustible Gases and
     Vapors," Bureau of Mines Bulletin 627, 1965.
 8.  NFPA No. 68, "Explosion Venting 1974," available from the
     National Fire Protection Association, Boston, Mass.  02210.
 9.  Yao, C., de Ris, J., Bajpai, S.N., and Buckley, J.L., "Evaluation of
     Protection from Explosion Overpressure in AEC Gloveboxes,"
     FMRC Report RC69-T-23, 1969.
10.  Baker, W.E., Explosions in Air, University of Texas Press, 1973.
11.  Palmer, K.N., Dust Explosions and Fires, Chapman and Hall Ltd., 1973.
12.  Burrill, W.G., Lucier, G.H., and Gaudreau, A.P., "Explosion-Fire
     Investigation, Volume Reduction Plant, Milford, Connecticut,"
     Intertech Corp. report originally submitted to
     American Empire Insurance Co., 1974.
13.  Bartknecht, W., "The Course of Gas and Dust Explosions and Their Control,"
     Loss Prevention and Safety Promotion in the Process Industries,
     pp 159-172, C.H. Buschmann, ed., 1974.
                                 -106-

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14.  Bartknecht, W., "Explosion Protection Measures On Fluidized Bed  Spray
     Granulators and Fluidized Bed Driers," lecture presented at
     CIBA-GEIGY Corp., Ardsley, N.Y., October 1975, (translated by H. Burg).
15.  Cubbage, P.A. and Marshall, M.R., "Explosion Relief Protection for
     Industrial Plants of Intermediate Strength," Paper L in Inst. Chem. Engr.
     Symposium Series No. 39, 1974, see also Inst. Chem. Engr. Symposium
     Series No. 33, 1972.
16.  Yao, C., "Explosion Venting of Low-Strength Equipment and Structures,"
     Loss Prevention V_7 AIChE, 1973.
17.  Howard, W.B. and Russell, W.W., "A Procedure for Designing Gas
     Combustion Venting Systems," Paper K in Inst. Chem Engr. Symposium
     Series No. 39, 1974.
18.  Scholl, E.W., "Explosion Tests in a Refuse Shredding Mill,"
     German Federal Institute for Labor Protection and Accident Investigation,
     Dortmund, Research Report No. 124, 1974. (in German)
19.  Richards, R.C. and Sheehan, D., "Explosion Suppression Systems for
     Marine Applications," Offshore Technology Conference, Paper Number 2561, 1976.
20.  Zaloah, R.G., "Explosion Protection Evaluation for the Brent B Offshore
     Platform," Factory Mutual Research Corporation Report RC76-T-72, 1976.
21.  Albrecht, A.R., Dow Chemical Co., personal communication and transmittal
     of recent data obtained by W. Bartknecht, 1976.
22.  Fenwal, Inc., "System Application Guide for Explosion Suppression
     Systems," prepared by Fenwal, Inc., Ashland, Mass., 1973.
23.  Nollet, A., AENCO Inc., personal communication, 1976.
                                  -107-

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                USE OF REFUSE-DERIVED SOLID FUEL

                   IN1 ELECTRIC UTILITY BOILERS

           by Stephen A.  Lingle and J. Robert HoTtov;ay*
                             Summary

     Processing of municipal  solid waste to produce products which can
be used as supplemental  fuels is one of the major alternatives for
simultaneous disposal  of solid waste and recovery of energy.  This
technology involves physical  or chemical processing of municipal  solid
waste to produce solid,  liquid, or gaseous products called refuse-
derived fuels.  Most of  the attention to date has been on refuse-
derived soJJ_d_ fuels, commonly called RDF.  Solid RDF can be produced
by physically processing solid waste through size reduction and
density classified ion.   The RDF can then be sold to users v.'ho have
existing boilers for use as a supplement to fossil  fuels to generate
steam or electricity.

     Since successful  demonstration of this concept by the City of
St. Louis, the Union Electric Company and the U.S.  Environmental
Protection Agency, it has been met by a rush of interest and enthusiam
by cities.  By the end of this year, a total of four commercial facilities
will have been constructed, and at least four more are considered
committed.  Many other cities are involved in feasibility studies.

     Although actual operating experience is very limited, there seems
to be a feeling that questions and problems relating to production of
RDF can be worked out.  However, cities may face a significant problem
in obtaining firm, long-term markets for the RDF with guaranteed minimum
revenues.  Thus, the ability to market RDF appears to be the most critical
issue affecting the future of this recovery approach.
     * Stephen A. Lingle, Chief, Technology & Markets Branch, Resource
Recovery Division, Office of Solid Waste Management Programs, U.S.
Environmental Protection Agency, presented this paper at. the Fifth
National Congress on Waste Management Technology and Resource Recovery
sponsored by the National Solid Haste Kanagiwsnt /Usoi. iat ion-  Dtnlas,
Texas, December 9, 1976.

     * J. Robert Holloway is an Environmental Engineer with the
Technology 5 Markets Branch, Resource Recovery Division, U.S.
Environmental Protection Agency.
                                -103-

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     Four key points can be made regarding markets for RDF as  a
supplemental  fuel:

          1)   Electric utilities dcmn'nate market potential:   In
     examining the  markets for RDF,  one fact which clearly stands
     out is the importance of the electric utility industry.
     Without  use by this industry with its abundance of large,
     coal fired boilers, it is questionable that solid refuse-
     derived  fuel  can be marketed on a broad scale.   Industrial
     boilers  have  significant potential  as a market.   However,
     though large  in number, most industrial boilers are not
     large enough  in size to accomodate the RDF which would  be
     produced from  plants of 500 tons-per-day or greater scale.
     Marketing to multiple users could partially solve this
     problem, but  introduces other problems of its own.   Thus,
     electric utilities deserve a special  examination.

        2) Technical uncertainties  reduce user interest.   In
     a demonstration project, RDF has been burned successfully  in
     a coal-fired  suspension boiler.   However, experience is
     extremely limited and technological  uncertainties remain.
     A principle concern is the possibility of increased air
     emissions.  Also, some aspects  of boiler performance,  such
     as corrosion  and ash handling,  are not yet satisfactorily
     resolved.  Many utilities, though cautious toward these
     technical issues, do net see them as major, insurmountable
     barriers.  However, costs may be experienced in addressing
     them which would have to be considered in determining  a
     price for the  RDF.  Furthermore, many utilities are waiting
     for satisfactory resolution of  these technical  issues
     before signing agreements or contracts to purchase RDF.

        3)  RDF use may not be advantageous to electric utilities.
     Utilities have shown a significant interest in  possible  purchase
     of waste-derived fuels, prompted largely by a desire to  be
     socially responsive.  However,  the electric utilities  have a
     unique set of  institutional constraints which question  the
     rationale of  their involve.vent  in purchasing and burning a
     waste-derived  fuel.  Particularly significant is the fact  that
     profits  of electric utilities are regulated.  Since fuel  savings
     must generally be passed through to customers,  there are  not
     strong profit  incentives for using waste-based  fuels.   In
     addition, the  primary objective of electric utilities  is  to
     provide  reliable service.  New,  unproven fuels  are inconsistent
     with that objective.  In view of these institutional  factors,
     even small technical uncertainties take on added significance.
     In short, why  take any chances?
                               -109-

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        4)  Costs Incurred in usjnn RDF can reduce its value
     significantly.   Some of the major costs involved in "using RDF
     can include (1)  receiving, storage and firing,  (2) modifications
     required (if any) for air emissions control,  ash handling,  or
     additional  boiler maintenance, (3) economic dispatch  penalty,
     i.e., the increase in electric generating cost  which  might
     result from operating boilers equipped to fire  RDF instead  of
     operating more  efficient boilers.

          The magnitude of these costs will vary from case-to-case.
     There is not yet sufficient experience to reasonably  estimate
     some of them.  However, those which can be estimated, such  as
     storage and firing costs, are clearly not minor.  These costs
     could range from $2.00 to $6.00 per ton of RDF  even if the
     RDF processing  plant is located adjacent to the power plant
     and transportation costs are eliminated.  Transportation
     could add $3.00 to $4.00 of additional cost.   By comparison,
     RDF might have  a gross value (based on heat content alone)  on
     the order of $7.00 to $16.00 per ton.  Thus,  when estimating
     costs for RDF supplemental fuel systems, it is  important to
     estimate the net price which can be obtained  for the  RDF by
     taking into account these costs.

     The above points by no means suggest that electric utilities
are not a viable market, or that RDF sold to them would have little
or no value.  It merely points out that electric utilities do not
yet represent an established market for RDF and that until there is
more experience, the extent of their interest in RDF or the net  price
which they will  be able to pay are still uncertain.   In the neantime,
it is appropriate for communities to continue to work with utilities
to determine if satisfactory RDF purchase conditions can be negotiated.


                           Background

What is refuse-derived fuel?

     The term refuse-derived fuel can refer to any usable fuel produced
by mechanically, thermally, chemically, or biologically processing raiv
solid waste.  For example, a gas or oil product resulting from pyrolysis
of solid waste could be a refuse-derived fuel.  A refuse-derived fuel
may be used either as a supplement to fossil fuels in existing steam
generators, or as the sole fuel in a new steam generator designed
specifically for waste burning.  However,  in its common usage, refuse-
derived fuel (RDF) has come to represent a sol id product produced by
mechanically processing municipal solid waste for use as a supplement
to fossil fuels in existing steam boilers.  This latter concept  is the
subject of this paper, and the term  "RDF"  used here refers to solid
RDF.
                                -110-

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     RDF can be produced in three physical forms:  "fluff," "dust,"
and "densified."

     •  Fluff RDF can be produced by either wet or dry processing.
        Using dry processing, waste is shredded, usually to 1 to
        1 1/2 inch particle size, and then separated in an air
        classifier into a light fuel fraction (RDF) and a heavy
        fraction of primarily non-combustibles.  Using wet
        processing, waste is pulped in a device called a hydro-
        pulper, the resulting slurry is passed through a cyclone
        to remove the heavy primarily non-combustible portion, and
        the remaining organics are dried.   Additional screening or
        other product upgrading steps are often used in either
        process.

     •  Dust RDF can be prepared by adding an embrittling chemical
        to shredded waste and pulverizing it into a powdery material.
        Currently, dust RDF has been prepared by only one company,
        which has developed a proprietary process.

     •  Densified RDF is fluff or dust RDF which has been densified
        into pellets or briquettes.

Current Experience

     There is only limited experience in producing any of these RDF
forms or burning them as supplemental fuels.  Fluff RDF preparation
and burning has been demonstrated at an EPA supported project in
St. Louis, Missouri, and implemented commercially at Ames, Iowa.  A
demonstration facility, partially supported by the Maryland Departme-it
of Environmental Service, is operating in Baltimore County, Maryland.

     The St. Louis demonstration facility has operated intermittently
since 1972.  The 45 ton-per-day facility used single stage shredding
and vertical chute air classification to recover about 80 percent of
the waste as 1 1/2 inch fluff RDF.  The RDF was trucked from the City
operated processing plant to Union Electric Company's Meramac Power
Station where it was pnuematically fired into a 125 megawatt pulverized
coal-fired steam generator at heat input rates up to 27 percent.  Thu
experimental facility is no longer operating.

     The Ames, Iowa project has been operating commercially since
November 1975.  The plant effectively handles the 150 tons of waste
generated daily by the City.  The 40 ton-per-hour facility uses two
stage shredding, followed by vertical chute air classification to
recover about 80 percent of the waste as 1 1/2 inch fluff RDF.  The
RDF is pnuematically transported to the adjacent City Powsr Pl.-.n!
where it can be fired into a 33 megawatt pulverized coal fired boiler,
and two small spreader stoker boilers.
                               -Ill-

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     The Baltimore County, Maryland facility has been operating since?
January 1976.   The plant is currently utilized to shred and landfill
solid waste and recover ferrous metals.   Test programs to burn a shredded
and air classified waste are simultaneously being carried out.  Tests
have taken place or are planned to burn  the RDF in a spreader stoker
boiler and cement kiln.  Tests in a suspension-fired boiler may be run
in the future.  The facility has a capacity of 120 tons-per-hour and
currently handles about 700 tons-per-day of solid waste.   It uses two
single stage shredding lines to reduce waste to 1 to 2 inch particle
size.  This is followed by two-stage verticle chute air classification:

     Other cities which have recently completed construction of a
facility to produce fluff RDF are Milwaukee, Wisconsin, Chicago,
Illinois.  In  both cases, the fluff RDF  is to be utilized in suspension
fired electric utility boilers.

     Experience with both dust and densified RDF is significantly
more limited.   A privately-owned dust RDF pilot plant has operated,
and a larger facility in E. Bridgewater, Massachusetts is in shakedown.
A commercial facility is under construction in Bridgeport, Connecticut.
The same proprietary process is involved in all three projects.

     Densified RDF has been produced and burned only on a test
basis to date.  EPA's Office of Research and Development is currently
conducting tests of preparing and burning densified RDF at large
scale in'Washington, D. C.

     Thus, there is an interesting dichotomy of limited experience,
yet a willingness to proceed.  In addition to the cities mentioned
above, at least nine other cities are currently involved in design
of an RDF system.  Numerous other cities have commissioned feasibility
studies.  This activity suggests a widespread belief that RDF can be
successfully produced.  There is a sobering question of markets which
these cities must face, however.  Few if any cities to date have been
able to obtain firm, long-term contracts for RDF with well defined
product revenues.  Some of the possible reasons for this market
uncertainty are discussed in this paper.

                         Markets for RDF

     Electric utilities and industrial plants are two basic potential
markets for RDF.

     Most large electric utilities use primarily "suspension fired"
boilers where the fuels are pnuematically fired into the boiler and
burn in suspension.  Most industrial boilers are relatively small
"spreader stoker" fed units that burn part or all of the fuel on a
moving grate  in the furnace.  Fluff or dust RDF can be used in
suspension boilers.  Fluff and densified RDF can be used in the grate
equipped boilers.
                                -112-

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     Table 1  contains a summary of the capacity of these two markets
nationally.  Though large in numbers, industrial  boilers have only
about one-third the total national capacity of electric utility
boilers.  However, far more significant is the average boiler capacity
in the two sectors.  Average electric utility boiler capacity is
630 million Btu/hr., while average industrial boiler capacity is only
30 million Btu/hr.

     To accommodate waste from large urban areas, large boiler
capacities are necessary.  For example, a city that generated 500
tons-per-day of refuse would require boiler capacity of at least
500 million Btu/hr to consume the RDF produced.*  Most electric
utility boilers are above this size.  However, only about 55 coal
fired industrial boilers are larger than 500 million Btu per hour.
These boilers are concentrated primarily in the east-north central
area of the United States.

     This does not mean that industrial boilers are not an important
potential market.  Many individual industrial plants have multiple
boilers.  This would expand the capacity in any one location.  Also,
several industries  in a given area may have boilers.  This means that
marketing of RDF to multiple users in a given area is a distinct
possibility.  Nevertheless, from a capacity standpoint, electric
utility boilers offer a significantly greater potential than industrial
boilers.

     Another factor is the stability of the user.  Electric utilities
offer a more stable long-term market because they are unlikely to
cease operations.  The same cannot be said for industrial plants.  Even
very large companies can suspend or cease operation of individual plants.

     On the other hand, the gross value of the RDF is likely to be lower
when used in an electric utility boiler vs. an industrial boiler.  This
is because large electric utilities have long-term, high volume fuel
purchase contracts that result in lower fuel costs than for most industries.
Because a user would buy RDF based on its fuel cost savings, gross revenues
could be lower when marketing RDF to electric utilities.

     But, all factors considered, the electric utility boiler market
appears to have nuch more potential than the industrial boiler market.
     This assumes that 350 tons of RDF are produced from the 500 tons
     of waste, that 40 percent of the boiler heat input is provided
     by the RDF, that the boiler averages a 70 percent load factor
     (capacity utilization), and operates 24 hours per day.   Using, RDF
     to provide 40 percent of total  boiler heat input is considered to
     be possible in "stoker" boilers.  For "suspension" boilers, 20
     percent or less is a more likely estimate.
                                -113-

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                               -114-

-------
     Key Factors that influence marketability of RDF, particularly to
the electric utility market are discussed below.  Included are:

     •  Technical Factors

        1) Fuel characteristics of RDF

        2) -Boiler corrosion

        3) Boiler residue

        4) Boiler emissions

     •  Institutional Factors Affecting Electric Utilities

     •  Economic Factors:  Determinants of RDF Value


                Technical Issues in Marketing RDF

     Characteristics as a fuel.  Table 2 shows a comparison of certain
key characteristics of RDF and coal from the St. Louis and Ames,  Iowa
projects previously described.  One would expect the characteristics
of the St. Louis and Ames RDF's to be similar since in both cases
approximately 80 percent of air classifier inputs have been recovered
as light fraction (RDF).  However, the data show some interesting
variations.   One explanation for the differences may be that the
St. Louis data are the average of all measurements made over the  life
of the project.  The Ames data represent a four month average, and thus
reflect seasonal influence.

     In both cases, the data show the heat content of the RDF's to be
about half that of coal, while both ash and moisture are significantly
higher.  Sulfur, on the other hand, is lower in RDF than coal.  The
lower sulfur content has been viewed as a potential benefit from  an air
emissions (SOv) standpoint.  However, the higher concentrations of ash
may create asn handling problems, and the higher concentrations of
moisture decrease the effective heat value of the RDF.

     These RDF characteristics are not representative of what can be
achieved by additional processing of waste to produce RDF.  For example,
additional processing such as screening and drying can reduce both ash
and moisture content.  Processing into a dust RDF will produce a
significantly higher heat content, as well as lower ash and moisture.
There is a trade-off between the cost of the processing employed  in
producing an RDF, and the value of the resulting product.  Requirements
of the user will determine what specifications the RDF must meet.

     Burning experience.  There are three primary areas of interest
regarding boiler performance when burning RDF:  corrosion, bottom ash,
and air emissions.


                                -115-

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-------
     Corrosion.  Currently there are only limited data on boiler tube
corrosion, and all of it is based on short-term burning experience.
However, early indications are encouraging.   Analysis of critical  boiler
components at the Union Electric Company indicated no observable increase
over coal only firing.  However, this was based on intermittent firing of
roughly 50,000 tons of RDF over three years, which in total  constituted
less than 3 percent of total boiler heat input.  Thus, these observations
cannot be considered the last word.  Nevertheless, the willingness of
Union Electric to move ahead with a $70 million project to burn 6000
tons of refuse daily is strong testimony to their belief that corrosion
would not be a significant problem.  Discussions which EPA has held with
other electric utility representatives indicate that corrosion is  not
generally perceived as a prohibitive problem area.  Even still, some
utilities prefer to take a wait-and-see posture until there has been
more operating experience.

     Bottom ash.  The bulk of existing data on bottom ash are from
testing at St. Louis.  At 10 percent RDF heat input, bottom ash
increased 4 to 7 times over that for coal only firing.  This was
due both to the fact that RDF has 5 to 6 times as much ash as coal
on an equivalent heat value basis, and the fact that not all of
the RDF fired into the furnace actually burned.  About 10 percent  of
RDF heat content was lost to bottom ash vs.  less than 1 percent for coal.

     There is some experience with suspension firing of RDF at Ames, Iowa,
although most of Ames' experience to date has been with burning in a
spreader stoker boiler.  Early observations of bottom ash during suspension
boiler firing generally confirm the St. Louis results.  Though specific
data are not available, it can be said that substantial quantities of
RDF did not burn in suspension and added to the bottom ash loading.

     Increased bottom ash implies that alterations in boiler ash handling
may be required.  One notable impact at St.  Louis was that ash pond BOD
and COD increased with RDF firing to the point where additional treatment
would have been required.  This treatment can be easily accomplished from
a technical standpoint, but naturally involves a cost that would ultimately
be charged against the RDF.

     However, bottom ash can be reduced by increasing burn-out of  the
RDF in the boiler.  Modifications in method of firing into the boiler --
that is, raising the elevation of RDF firing nozzles to increase retention
time of RDF particles in the boiler -- could possibly increase burnout.
At Ames, Iowa, a unique method of increasing burnout in the suspension
fired boiler is being tried.  Combustion air is being injected into the
boiler just above the water line in the bottom ash pit to allow the
unburned RDF particles to burn as they float on the surface of the
water.  The effectiveness of this approach has not been fully evaluate1';
due to limited operating experience with the suspension fired boiler.
                                -117-

-------
     Another possible means of increasing burnout and reducing bottom
ash is to recover a higher quality RDF fraction,  that is,  one with a
lower inorganic content and smaller, less dense particles.   This may
be possible by recovering a lower fraction of air classifier inputs
as light fraction, say 60 or 70 percent, rather than 80.   Shredding
to a smaller particle size is also an alternative to increase burnout.
Furthermore, the RDF could be screened or dried.   However,  these
actions would result in either higher net processing costs  or lower
product yield.

     Air emissions.  At St. Louis, data were collected on  a wide range
of emissions when firing both coal only and combinations  of coal and
RDF.  Measured were particulates, SOX, N0x> and trace elements.   A more
complete discussion of these results is available in another EPA report.^

     The data did not confirm any increase or decrease in  either SOX or
NOX emissions when firing RDF with coal vs. coal-only firing.  A
decrease in SOX had been expected because RDF has a lower  sulfur content
than coal.  Apparently at firing rates of 5 to 20 percent,  the impact
on SOX emissions was not great enough to be reflected beyond the scatter
of data.

     Trace elements were measured even though there are no  Federal
standards for any of these elements for coal fired steam generators.
Emissions were found to increase for most of these elements when
firing RDF.  For three of the elements measured (lead, berryllium,
and mercury), EPA has determined acceptable ambient air levels.
Ambient air levels of these elements, estimated from measured stack
emissions at St.  Louis, were well below these levels when  firing
both coal-only and coal and RDF.

     Particulate emissions were viewed as one of the key issues in
RDF firing.  At St. Louis, there was no measured increase in controlled
particulate emissions up to the boiler design load of 125 megawatts
when firing coal and RDF vs. coal only.  However, above boiler design
load, that is, between 125 and 140 megawatts, the actual  maximum boiler
load, controlled emissions did increase substantially when  RDF was
fired with coal.

     Measurements of uncontrolled emissions indicated no significant
change with coal plus RDF firing vs. coal only firing at any boiler
load.  Thus, a decrease in electrostatic precipitator (ESP) efficiency
was the apparent cause of the increases measured in the controlled
stack emissions.  A number of possible changes brought about by burning
RDF which could have caused the efficiency decrease were investigated.
Although no totally satisfactory answer was found, an increase  in gas
flow rate through the ESP was identified as the primary cause' of the
loss in efficiency.  The increased flow rate resulted fron the  hujlif-
moisture content of the RDF compared with coal.

                                -118-

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     The St. Louis emissions results should be useful  in determining
the feasibility of future RDF projects.   However,  caution should be
exercised in drawing generalized conclusions from  these results.

     Emissions in other situations will  depend on  a number of
site-specific factors including boiler and ESP design,  type of RDF,
and type of coal.  It is important that these factors  be examined
prior to decisions to proceed with an RDF project.

     It is possible that particulate emissions, even if they do increase,
can be reduced by changes in RDF firing procedures, ESP operation,  or
other factors.  If such actions are unsuccessful,  mechanical modification
to the ESP would probably be an effective, although potentially costly,
solution.  As is the case with the other technical  factors discussed,
there is a feeling that air emissions, while possibly  requiring corrective
action in some cases, can be properly controlled.   The question is  what
impact will any necessary adjustments ultimately have  on the net value
of the RDF.
             Institutional Issues in Utility Markets

     Electric utilities have been the target of RDF marketing efforts
for a variety of reasons.  They have large capacity for using RDF and
are located in virtually all urban areas where solid waste is generated.
They represent a stable market, since individual utilities can be
expected to be operating for the duration of long-term contracts.

     From the utilities' perspective, purchase of RDF provides an
opportunity to assume a good-neighbor role in the community by providing
a valuable service.  At the same time, a new, though limited, source of
fuel can be obtained.  In some cases, there may be some opportunity for
a profit or lower rates to customers.

     However, there are a number of problems with electric utilities
as RDF markets:

     •  The major objective of electric utilities is to provide
        reliable service .  Any technological uncertainties which
        might be associated with RDF use are inconsistent with that
        goal.

     •  Utilities, like many other instutitions, have limited
        financial capability.  Investments for RDF handling compete
        with investments in new generating capacity.

     •  Utilities are a profit-regulated industry.  This diminishes
        the economic incentive to use a cheaper fuel such as RDF,
        which carries with it increased operating risk.  For example,
        any savings in fuel costs would probably have to be passed
        through to users in lower rates.  This makes it difficult
        to earn a rate of return commensurate with risks in using
        RDF.

                                 -119-

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      •  Utilities, like other industries,  are under increasing  pressure
        to meet environmental regulations.   Any possibility  of
        increased emissions from burning solid waste could make
        utilities very cautious about its  use.

     Recently, the Edison Electric Institute (EEI)  surveyed  its member
utilities to determine their views on use  of RDF as a fuel.   Here are
some of the results:

     •  Forty nine electric utilities were actively studying the
        use of municipal solid waste as a  part of 62 MSW utilization
        studies.

     •  Seventy six percent of these studies C47 of the 62)  involve
        purchasing waste-derived fuels, 15 percent involve purchasing
        steam, and 3 percent involve electricity purchase.

     •  Of the 47 studies involving purchase of fuel, 29 involve
        shredded solid waste; 4 involve incineration of raw  solid
        waste; 3 involve the use of pelletized RDF; 6 involve
        pulverized (dust) RDF; and 5, the use of a pyrolysis fuel.

     Wy would an electric utility want to become involved in such a
project?  The four reasons most commonly cited in the survey were:

     •  to make a profit.  Despite the regulatory constraints,  there
        may be opportunities, though limited, to increase profit by
        such ventures.  (However, most utilities do not think that
        the potential for making a profit is very high.)

     •  to supplement available fuel resources.  However, while
        a new source of fuel would be expected to be a possible
        benefit to electric utilities, solid waste has been  viewed
        by that industry as not available in sufficiently large,
        reliable quantities to be a significant new fuel in  general.
        In specific circumstances, it could mean a great deal,
        however.

     •  to ensure that a resource recovery project is compatible
        with the needs of the utility.  If a utility believes that
        a project is going to be built in any case, they may get
        involved early to ensure that their interests are
        represented.

     •  to assist in solving a significant public problem.
        Utilities tend to place a high value on efforts at civic
        improvement.  Since  they are constantly under fire from
        rate-payers, any actions to improve their community image
        are looked upon favorably by management.
                                -120-

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     Over half of the companies involved in studies indicated the last
reason, public service, to be their primary motivation.  Only 14 percent
would insist that participation result in a profit to them.

     However, the public service motive can go only so far.  The industry
realizes that it has no real responsibility to dispose of solid waste.
Its primary responsibility is to provide reliable and adequate service at
the lowest reasonable cost.  H. J. Young, Senior vice president of EEI,
testifying before the Congressional Symposium on Resource Conservation
and Recovery on April 7, 1976, stated the following:  "In order for
utilities to consider becoming involved in resource recovery projects,
these systems must be developed in such a way that will ensure
reliability of service, be cost competitive with other fuels, minimize
capital investment risks, comply with environmental regulations, and
avoid large increases in operating costs."

     It is questionable that operating experience to date is sufficient
to definitively address these factors.  Thus, there seems to be a
tendency toward a "wait-and-see" attitude by many utilities.  Utilities
which have become involved are requiring contracts which provide an
opportunity for them to discontinue their involvement at minimum cost
if significant problems develop during a test period.  Also, utilities
have shown a reluctance to put up "front-end" capital, and naturally
expect to reduce the price paid for RDF to cover any incremental costs
experienced.  This is by no means a criticism.  It is simply good
business on the part of the utilities.

     The widespread interest shown by utilities at this still early
stage of resource recovery implementation, when many technical questions
remain unanswered, is a strong, favorable indication for the future.
However, at the current time, there are still a number of significant
constraints facing this market.
                            RDF Value

     The price that a user, particularly an electric utility, will pay
for RDF will depend on numerous factors.  A starting point would be
a simple equation such as the following:

                       Prdf = Pcoal - Crdf

     Expressing all factors on a per unit of heat basis, Prdf is price
received for the RDF, Pcoal is the price paid by the utility for coal,
and Crdf is the net incremental costs experienced by the utility as a
result of RDF use.
                                -121-

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     Thus, if $1.00 per million Btu were paid for coal, if RDF had a
heat value of 10 million Btu/ton, and if a utility experienced incremental
costs totaling $5,00 per ton for each ton of RDF used, then:

     Prdf = $1.00 per million Btu - $.50 per million Btu

          = $.50 per million Btu                  ^

     To use this equation accurately requires that the measurement of
heat value of the RDF be at the same moisture content as the  coal  being
used, and that any loss of RDF due to incomplete burnout be taken  into
account.  Otherwise, the usable heat of the RDF relative to coal  would
be overstated.

     Another way of looking at the pricing determination substitutes
the value of the coal saved (SAVcoal) for the price of coal per million
Btu.

                      Prdf = SAVcoal - Crdf

     Using tins equation, if one half ton of coal at $14.00 per ton
were saved for each ton of RDF burned, and ••'f it cost $5.00 incrementally
for each ton of RDF burned then:

                       Prdf = $7.00 - 5.00

                            = $2.00 per ton (or $.20 per million Btu)

These are only examples, and the costs used are not intended  to represent
an actual situation.

     The latter formula assures that the user pays only for the usable
heat produced by the RDF.  By measuring coal actually saved,  it
automatically takes into consideration factors such as burnout of the
RDF, heat lost when vaporizing moisture in the RDF, and other changes
in boiler efficiency, such as increased stack heat loss.  This approach
suffers from the practical problem that it may not be possible for a
utility to accurately measure the quantity of coal saved based on the
amount of electricity generated.  This is because the unit's  steam and
electricity generating efficiency changes:  1) as the boiler  gets older,
2) between maintenance and cleaning cycles, and 3) with changes in
boiler loads.

     In practice, both of the above equations can lead to the same result
in terms of RDF value if sufficient data are available to apply them
accurately.  Both of these equations assume that the RDF is priced
equivalently with coal on a heat value basis (after deducting incremental
costs) rather than being priced at a discount.  If a utility wanted to
discount the RDF price below that paid for equivalent Btu's from other
fuels  (perhaps to provide an economic incentive) then this discount
would  also be deducted in calculating the price of the RDF.

                                -122-

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     The most complicated factor in the above equations is the incremental
cost incurred in using RDF.  Some of the components of this cost are:

     1)  Capital and operating cost of RDF storage and firing
         facilities.

     2)  Increased holler operating or maintenance costs due
         to corrosion, ash handling, air emissions, or other
         factors.

     3)  Economic dispatch penalty, i.e., the increase in
         overall electric generating cost to the electric
         company, which might result from operating boilers
         equipped to fire RDF instead of operating more
         efficient units, such as nuclear or hydro powered.

     4)  Cost of replacement electricity while unit is out of
         service for initial modification to fire RDF.

There are also other, possibily less significant, costs which can
arise in specific situations.

     It is difficult to define in the abstract what value should be
placed on any of the factors in this equation, and they will naturally
vary from case-to-case.  However, it is worth pointing out the order of
magnitude of some of the key components of the cost factor (Crdf) in
comparison to the gross value of the RDF.

     One item is the capital cost of receiving, storage, and handling
facilities for RDF at a power plant.  Definitive examples of these costs
are limited at the present time.  But a consideration of available
information suggests that we might assume $4 to $8 million as a rough
ballpark estimate of the capital investment to handle 1000 tons of RDF
per day at a power plant.  Amortizing $4 million over 15 years at
6 percent translates to $1.10 per ton of RDF.  Amortizing $8 million
at 12 -percent over 10 years amounts to $3.90 per ton of RDF.  (if the
storage and handling facilities were owned and financed by a munici-
pality or authority, 6 percent financing and 15 to 20 year amortization
might be expected.  If the same facilities were owned and financed by
the utility or a private firm, 12 percent and 10 years is more likely.)

     Operating costs (labor, utilities and maintenance) at the power
plant can also be crudely estimated.  Two feasibility studies
(conducted for the Tennessee Valley Authority and the Delmarva Power
and Light Company, Delaware) estimated costs in the range of $0.75 to
$1.20 per ton of RDF.  Another estimate, obtained from private sources,
placed O&M costs at around $2.50 per ton of RDF.  Thus, collectively,
capital and operating costs amount to on the order of $2.00 to $6.00 per
ton of RDF.  If the RDF processing plant is not adjacent to the power
plant where the RDF is to be burned, then truck or rail transport will
be required. One cost estimate for a project now under construction was
S3.00 to S4.00 per ton of RDF for an 8 mile track transport.  Thus, the
cost of handling RDF can oe significant.


                                 -123-

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     Other components of the utility RDF cost factor, such as possible
costs of emissions or residuals control and economic dispatch penalty,
would have to also be subtracted from the gross value.  No reasonable
estimates can be made of these costs at this time.   In specific instances,
they could have values ranging from zero to several  dollars per ton.

     These costs must be subtracted from the gross  RDF value to obtain
a net price.  -As a basis for estimating possible gross RDF values,
Table 3 shows the average contract price paid for coal in various
regions of the United States in June 1976.  Based on these data, it
appears that RDF might have a gross value of roughly $0.65 to $1.25
per million Btu.

     Table 4 combines these ranges of costs and revenues to determine a
possible range of net RDF values.  The result is net values ranging from
a high of over $13.00 per ton to a low of a negative value of nearly
$4.00 per ton.  Not included in this estimate are any costs relating to
pollution control or other additional boiler maintenance costs, or an
economic dispatch penalty.  There could be no costs for these items, or
in some cases significant costs could be experienced.

     There are two purposes in pointing out this range of potential
values.  One is fo illustrate the need for municipalities to thoroughly
analyze their own situation, rather than depending on suppositions or
approximations of RDF value.  The other is to point out the significance
of the difference between net and gross RDF value.   However, the net RDF
value is only one component of an overall economic analysis of a plant
to prepare RDF and sell it as a fuel.  Capital and operating costs of
the RDF processing plant and revenues from recovery of any other products
must be estimated.  Then, this overall system net cost must be compared
with costs of alternative disposal and recovery options.


                          Conclusions

     Obviously, markets are a key factor  in the viability of any
resource recovery technology.  However, they take on added significance
in the case of a refuse-derived solid fuel (RDF).  Some other technologies
produce "final" end products, such as steam or electricity, which are
not significantly different from the same products produced by other
means.  Still others produce intermediate products (fuels), such as oil
or gas, representing chemically refined solid waste.  However, refuse-
derived solid fuel (with one notable exception) is physically processed
solid waste - essentially size reduced and classified by density.  A
key aspect of the technical and economic appeal of this technology is
its simplicity; there is no chemical processing equipment or thermal
conversion equipment employed in producing a solid RDF.  However,
obviously the product is somewhat more crude than final products such
as steam or more refined waste-derived fuels.  Thus, the front-end
processing simplicity may simply translate into a more difficult
marketing task.

                                 -124-

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                            TABLE 4
                    RANGE OF NET RDF VALUES
Revenues
Gross RDF Value
RDF Storage and Handling Costs
Capital Costs
Operating Costs
Transport Costs
Net RDF Value per Ton
Other Costs
Low
$6.501
Low
$3.903
2.50
4.00
(-$3.90)

High
$16. 252
High
$1.104
.75
0
$13.40

  Economic Dispath                                ?            -0-
  Pollution Control                               ?            -0-
  Other                                           ?            -0-
  Based on 10 million Btu/ton; 65<£ per million Btu
^ Based on 13 million Btu/ton; $1.25 per million Btu
^ Based on $8 million amortized over 10 years at 12 percent
* Based on $4 million amortized over 15 years at 6 percent
Source:  U.S. EPA estimates.
                               -126-

-------
     However, there is a tremendous momentum behind this technology.
A host of firms are marketing RDF processing plants, many cities are
considering implementation of such a system, and many electric utilities
are considering involvement as a fuel user.

     The primary message which should come from a consideration of
both the market uncertainties and the great enthusiam behind this
recovery approach should be one of realism.  One should not conclude
that technical or economic problems will prevent implementation of
this technology, nor that all the problems will simply work them-
selves out.  Important marketing questions exist at the present
time and should be understood by those considering such a system.
But the technology is still in an early stage of development.  It
is important that industry and government understand both the problems
and the opportunities and work together to resolve the uncertainties
and build a foundation for future implementations.
                                -127-

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                           References
1.  Holloway, J.R., EPA Resource Recovery Demonstration:   Summary
      of Air Emissions Analysis, Haste Age.  August  1976,  p.  50-52.
                                 -123-

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                 THE ENERGY PURCHASERS' STANDPOINT

                      PITFALLS IN PLANNING

                         AT den H. Howard
                President - Energy Systems Division
                     Wheelabrator-Frye, Inc.


        At the present time, a  1200 TPD  solid waste steam gen-

erating plant is in operation in Saugus,  Massachusetts.   The

steam output from this plant is piped across  the nearby  Saugus

River to a large industrial plant for use in  processing,  testing

and power generation.  The 2 billion pounds  (907,100 t)  annually

to be supplied will reduce the  fuel oil  requirements of  the

industrial plant by about 73,000 gallons (276,335 litres)  of #6

fuel oil daily.

        This paper, while describing the basic features  of the

plant, will deal primarily with the inception of the idea, the

attempts at municipal participation,  funding, securing of permits

and some of the unusual  features of operation due to its integra-

tion with the industrial plant's steam  system.

        The General Electric Company operates its River  Works

Plant in Lynn, Massachusetts, bordering  on the Saugus River.  This

large industrial complex occupies 278 acres and employs  about

13,000 people.  Its energy systems are  complex and its steam plant

capacity is over 1 million pounds per hour (453.5 t/hr)  and its

power generating capacity is 80 MW.  This consists of 60 MW of

steam turbine capacity and 20 MW of gas  turbine capacity which is

part of a combined cycle package of a gas turbine and a heat

recovery steam generator.
                             -129-

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        Steam is used for building heating, processing, and for



power generation, but the largest demands on the steam system




are from testing operations.  The plant manufactures steam tur-




bines and jet engines and large flows of up to 450,000#/hr (204.1




t/hr) are required to meet the conditions of an individual test.




Steam ejectors are used for altitude simulation in jet engine



testing, and some ejectors can pull in access of 250,000#/hr



(113.4 t/hr).




        Steam is generated at 2 pressures:  650 and 200 PSIG




(4481.8 and 1379.0 kPa).   The bulk of the steam is generated at




650 PSIG (4481.8 kPa) and is used directly by some test equip-



ment at that pressure.  The rest goes to extraction turbines




which make up the bulk of the supply to the 200 PSIG (1379.0 kPa)




system.  The steam plant consists of 7 boilers, the largest of



which is 300,000#/hr  (136 t/hr), 650 PSIG  (4481.8 kPa)  dual-




fired, oil or gas unit.




        In the late 60's, plans were being made for the normal



replacement of two units which were reaching the end of their



useful life.  At the  same time, the City of Lynn was coming to



the realization that  they would be facing a solid waste crisis,



within a few years, and as General Electric was the major tax-



payer in the community, they would share in any increased cost



resulting from the solution of the problem.



        It was really at that time the thought of a joint solu-




tion became apparent.  Why not think of solid waste as an asset,




rather than a liability, and examine the possibility of reqover-




                             -130-

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ing the heat content as fuel?  Many years previously, the indus-




trial plant had two small steam generators which were fired by



rubbish, but could a unit be built today large enough to replace




the two oil-fired units soon to be retired?




        City officials were approached to see if they would be



interested in providing some form of collection facility on land



owned by the company across the Saugus River from the plant.  It




was originally contemplated that the rubbish would be shredded,



then conveyed across the river on an enclosed conveyor, and the




residue returned the same way.



        It was immediately apparent that if steam were to be



generated at the plant's system conditions of 650 PSIG (4481.8




kPa), 825°F  (440.5°C), and in quantities between 350,000 to




400.000t/hr  (158.7 - 181.4 t/hr), we were dealing in some un-




knowns.  The concern for corrosion in the superheaters and



the overall effect of chlorides on boiler surfaces was upper-




most.  It was felt a feasibility study was necessary to determine



if the concept was both technically and economically sound.




        Working with the City officials and a major boiler manu-




facturer, funding was received through H.E."W. and the Office of



Solid Waste for the study.  The project examined the communities'



solid waste quantities and makeup, its chemical content and heat-



ing value.  The boiler manufacturer examined preliminary design



concepts and paid particular attention to corrosion considerations.



Concurrently, the study looked at the size of units and the



reliability requirements and how steam from an external source



could best be integrated into the plant's steam system.



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     The study indicated, as you would expect,  that solid waste
could be considered an acceptable low-grade fuel and facilities could
be designed to recover the heat value from it.   The economics looked
particularly attractive, although it should be  pointed out these
studies preceded any real concern for environmental control requirements
which have added significantly to the capital costs of the installation.
The study looked at various combinations of equipment and locations.
You will recall the collection site was across  the river from the
industrial plant, and either the steam or the rubbish and residue
would have to be transported across the water.   The study also evaluat-
ed the economics of the entire installation on  the plant side and, of
course, showed the lowest cost per ton; but, the Company did not have
the available land, nor could they stand the traffic congestion of
40 or 50 rubbish trucks a day in the plant, so  that was not considered
a viable combination.
     I mentioned earlier that one plan was collection and shredding
on the Saugus side of the river and conveying the rubbish over to
a boiler on the Lynn side and returning the residue, utilizing the
same conveyor.  Another was the entire collection, burning and steam
generation, on the Saugus side and transporting the steam across the
river on a pipe trestle  to the Lynn side.  A variation of both of
these was the generation of saturated steam on the Saugus side and
a separately fired superheater across the river at the plant site.
It was felt this might  avoid some of the contemplated problems of
corrosion which might only be present at the higher temperatures.
After careful consideration of all the technical problems, space
requirements, and  capital cost, the  system  chosen has the entire
                             -132-

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rubbish burning steam generating facility on one side of the river




and the steam transported over a pipe trestle at the pressure and




temperature of the Plant's steam system.




     Upon completion of the feasibility study, the actual sizing



and costing of the plant was necessary in order to approach the



proper municipal authorities for approval of a bond issue.  It was




evident that the City of Lynn did not generate enough solid waste



themselves to produce the quantities of steam required.  It had been




estimated that in order to meet the steam demands of 225-250,000#/hr




 (1020-113.4 t/hr) average and peaks of 350,000#/hr (158.7 t/hr),



a minimum size plant of 1000 TPD would be required.



     Lynn's solid waste load was estimated in the vicinity of 350



TPD, so other communities were solicited and the North Shore Solid




Waste Disposal District was formed, with eight communities, under



provisions of the General Laws of Massachusetts.  The district put




together a specification for the proposed plant and solicited proposals



from firms we felt had the technical resources to design, construct




and operate such a facility.



     Throughout this process, which was time-consuming, the industrial



plant was facing a deadline due to the replacement schedule of its




boilers.  Replacement steam was required by the later part of 1975



which meant preliminary design, funding and approvals had to be firmed



up  in 1972.



     Many evening meetings of the North Shore Solid Waste Disposal



District were spent listening to firms present their proposals.



Throughout this process, the industrial plant was cast in a unique



role.  As a corporate citizen of one community, they had a vital




                             -133-

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interest in the proceedings, but had no justification to dictate or




rule on the capabilities of the proposers.  But as the sole steam user,




(and without that steam sale, there would be no justification of such




a project)  they had a vital concern first to have the assurance the




plant would be built, and secondly, that it could succeed.   For the




first time, they were putting their destiny in the hands of others,



and they needed absolute confidence that their steam demands would be



met in a timely and economical fashion.  If the plan faltered, they




had to make plans immediately to install conventional boiler equipment



to meet their 1975 replacement schedule.




     Initial cost projections indicated a capital expenditure of



about 22 million dollars would be required to construct a 1200 TPD



plant, and municipal bonds were felt to be the most attractive way



of providing that capital.  A problem developed in that the solid




waste district was made up of both cities and towns, and the town




meeting form of government was employed by some.  Bond issues had



to be approved by town meeting and by city councils or boards of




aldermen, depending on the particular charter.  It soon became



evident that it would be practically impossible to go into a town



meeting and ask for that town's share of a 22 million dollar bond



issue for a project so radical at that time.  In this age of protest



and self-styled public-interest experts, long delays could be expe'Cted




if the necessary capital had to be raised in this manner.




      While  it was  recognized municipal bonds offered the  most at-




tractive interest  rate,  the possibility  of  industrial bonds  at  a




slightly higher  percentage  looked  attractive.   Their use  required




                             -134-

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some legislative changes so that solid waste facilities would qualify
along with regular industrial construction.  The necessary legislation
was obtained and bonding companies contacted, but here again the spector
of long-drawn out battles at town meetings loomed again.  The bond
merchants explained that in order to sell industrial revenue bonds,
there must be proof of the ability of the venture to succeed and
that took the form of long-term or 20-year rubbish contracts.  An
investor in a 20-year bond must have the assurance the plant could
meet its commitment of its steam sale and, therefore, must be assured
of a continuing supply of low cost fuel; namely, solid waste.  While
the possibility existed that contracts could, in time, be negotiated
and approved by the proper authorities, the commitment date to the
industrial plant did not allow this.
     When it appeared the entire project would falter because of this,
it became evident to some that private capital offered the only hope
to initiate the project.  The cities and towns who made up the solid
waste district were presently, with one exception, dumping in a large
commercial landfill immediately adjacent to the plant's land in
Saugus, where the solid waste facility was to be built.  This landfill
was receiving the rubbish for some 18 communities in the Greater
Boston-North Shore area.  The State and local community had tried to
close this facility on many occasions, but there was no acceptable
alternative, so it was still operating.  The owner approached the
company and suggested he would like to build the plant, realizing
incineration and energy recovery offered a long-range solution
with many benefits over operation of a sanitary landfill operation
in a hostile environment.
                                 -135-

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     They felt he needed a partner, preferably a company that could



bring in the technical resources to assure the plant's success as



this concept had never been done in this country.  He was put in




touch with a major pollution-control manufacturer and engineering




firm, who had an association with a Swiss company that had built




over 50 rubbish-burning steam generation plants in Europe and Japan,




and more recently, one in Montreal, Canada.  A joint ventuer was



formed, called REFUSE ENERGY SYSTEMS COMPANY(RESCO), and the planb




was originally financed by the two partners, and then refinanced with



industrial bonds once construction was underway.




     A great deal of time went into the negotiation of the contract




between the industrial plant and RESCO.  A high degree of redundancy



was required to assure the company their steam demands could be met




at all times, regardless of planned or unplanned boiler outage,



or even a prolonged rubbish strike.  They have contracted for 2 billion



pounds/year  (907,100 t/hr) of 650 PSI 825°F (4481.75 kPa 440.5°C)



steam which is generated-in 2- 750 TPD solid waste furnaces, each




capable of 185,000#/hr  (83.9 t/h4) on rubbish or on oil firing.



The maximum demand will be 350,000#/hr  (158.7 t/hr}, and this rate of



taking is allowed for 1200 hrs/yr.  The average demand from RESCO



will be about 225-250,000#/hr (102.0-113.4 t/hr).  The contract



requires a minimum flow of 65,000#/hr  (29.5 t/hr)  in order to keep



the  3,000 ft  (914.4 meter) line at temperature.



     The cost of  steam purchased bears a direct ratio to the cost




if they were to generate it in their own plant.  A formula was




conceived that uses a maintenance  factor,  depreciation, labor, etc.,




over the contract period of 14 years,  plus factoring  in the cost of



                              -136-

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oil and this equals the cost per 10001 the plant would have incurred




if they were forced to put in conventional fossil fired boilers.




A fixed percentage of that number determines the final cost/1000#




for the contracted steam.  The main variable there is the price of




oil, so over the length of the contract the purchased price will be



affected by any fluctuation in the price of energy.




     One of the more interesting features of the contract is the




total energy exchange between the two plants.  The industrial plant




will supply to RESCO, a portion of their condensate, fuel oil and




all of their electrical needs on a total energy exchange basis.



They have excess turbine generator capacity, and will take RESCO's



steam over and above their contracted requirements and convert to




kilowatts for them.  This will be done on a BTU/KW rate agreed to in




the contract.  Condensate returned from the plant system and not



needed in their own boilers will also be sent to RESCO for a negotiated




rate which will cover heat content and pumping costs.  Because the



plant had large #6 fuel oil storage facilities and were effectively




increasing that by the reduced usage in lieu of steam being generated



from solid waste, it seemed logical to eliminate the capital cost of




providing large fuel oil storage tanks, at the RESCO site.  Oil is




supplied over the pipe trestle from the plant and is pumped to a



20,000 gal.  (75,700 litres) day tank at the RESCO site which provides




easy suction for fuel pumps.



     It is apparent that the plant running at full capacity burning



1200 TPD of rubbish can generate more steam than is required under



the present contract.  The existing commercial landfill site could



accommodate a future industrial complex which could utilize the  steam,




and the industrial plant is continuing studies as to the feasibility



                             -137-

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of increasing steam demands if they were to retire more of their




existing boiler equipment.  The utility company shows interest in




excess power that can be generated and fed to their system.




     The design of the solid waste steam generating facility follows




closely that of many successful European installations, some of



which have been in operation over 20 years.




     Trucks will dump mixed refuse into a storage pit of 6700 tons




capacity, which is 5.6 days of storage at an average disposal rate




of 1200 tons/day  (1091 t/day).  This large storage capacity will




allow the plant capacity to be doubled without the necessity of increas-




ing the pit size.




     Refuse will be transferred to the boilers or fragmenter by one




of two overhead cranes.  One crane will be in continuous use and




the other will be a standby.




     The facility has two refuse boilers, each will consume an average




of 600 tons/day  (546 t/day) of refuse and will produce approximately




180,000 Ib/hr  (68 t/hr) each of 690 PSIG  (4758 kPa) and 875°F  (468°C).



     The refuse boiler units are designed with a three level, inclined




reciprocating grate, water wall furnace and a convection heat transfer




surface containing a three section superheater, generating section and



economizer.  Gases leaving each boiler enter an electrostatic pre-




cipitator and are then conveyed by the ID fan to the concrete stack.




     Backup steaming capacity is provided by fuel oil burners located




in each refuse boiler and two 120,000 Ib/hr  (54.5 t/hr) package boilers




designed to burn  fuel oil.  The backup steaming capacity will not be




used under normal circumstances, but is installed to make sure that




the industrial plant's steam requirements will always be met.



                             -138-

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     Each refuse boiler is equipped with an electrostatic precipitator
for removal of particulate from the flue gases.  Each boiler will
discharge a maximum of 200,000 ACFM (5660 M3/Min) at 430°F  (221°C)
which is equivalent to 107,000 scfd (3028 M ).  Particulate emissions
from the boiler are about 1-2 grains per scfd  (35-70 g/M ) adjusted
to 12% CO.,.   The precipitator is designed for an efficiency of 97.5%
to maintain emissions to the atmosphere within the allowable of .05
grains per scfd (1.77 g/M ).
     Oxides of nitrogen are produced by burning a high nitrogen
content fuel with a high efficiency burner that produces flame
temperatures about 2800°F (1538°C).  Refuse is a low nitrogen and
relatively low heat content fuel.  The composition of refuse, as fed
into the burning zone, and the method of handling the fuel during
combustion precludes the generation of high heat zones and high
flame temperatures associated with the burning of highly  pulverized
coal of highly atomized oil in conventional utility type power boilers
and therefore eliminates the possibility of generating nitrous oxides.
     Refuse is a low sulphur fuel with a sulphur content of less
than .3% and usually less than .1%.  Fuel oil burned in the plant
will be sufficiently low in sulphur content to meet the requirements
of the Massachusetts Bureau of Air Quality Control requirements.
     The refuse storage pit is located in the refuse handling
building which is totally enclosed.  The intake for the forced draft
fans, which provide combustion air to the refuse boilers, is from
this building.  This arrangement provides for a slight negative
pressure in the building and thereby prevents any odors escaping
                             -139-

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to the surrounding area.  The odors are conveyed by the combustion




air to the furnaces where the temperature is sufficiently high to



completely destroy them.




     Hydrocarbons are formed in the furnace, however, the operating



temperature of the furnace is too high and the residence time too




long to allow them to escape without being burned.   The temperature




would have to be below 1000°F (538°C) in order for hydrocarbons




such as methane, parafins, olefins, etc., to escape without going




through the combustion process and producing CO2 and water which are




harmless.




     I commented previously on the difficulties encountered in




securing funding through municipal participation, and that private




financing with a subsequent conversion to industrial revenue bonds




seems a viable approach.  While some larger cities would obviously




generate sufficient solid waste to power a 1200 TPD plant, the com-




bination of trash quantity and a steam customer large enough to




utilize the output of the plant may often be found only in the suburban




communities which, therefore, makes the area or regional approach



the logical choice.  We have come to realize that we can effectively



and economically operate water supply and sanitary sewage systems



on a regional basis, but most small communities appear to be extremely




provincial in their approach to solving their solid waste dilemmas.




This is not hard to understand when we recall our solid waste has been




buried inexpensively in landfills; and because the pickup and transpor-




tation constituted the major cost element,  landfill  sites were generally




found within the towns' borders.  A need exists to educate local




officials that  the solution  to solid waste  disposal  needs to go beycnd





                             -140-

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those borders and economies and an improved system can be achieved



on a regional basis.




     It is in this area that the states, rather than the federal




government  must display some leadership and direction through better



enforcement of existing regulations governing  landfill operations



in order to adequately control open dumping which gives properly



run sanitary landfills a bad name.  The State must also provide




incentives for communities to form regional solid waste alliances.




Appropriate sites can be secured by state governments through eminent




domain takings where no one community could likely have that power for




a regional facility.




     The greatest contribution state governments can make to the



long-range encouragement of energy recovery from our solid waste




would be to streamline and simplify the morass of approvals necessary




to bring such a plant on line.  The ever-increasing regulatory



agencies involved in granting approval for construction and operation



is frightening and must be simplified.  Of course, new concern and



control is necessary due to our expanding population and worldwide



environmental considerations, but more than often State agencies



have conflicting regulations or overlapping approval responsibilities




which must be simplified if we are to avoid discouraging and, in fact,



preventing many worthwhile projects.



     Our present regulatory agencies are structured primarily for the



protection of our health and safety and do not respond easily to new




techniques or dimensions of scientific advancement.  Decisions are



often required during the design  and construction stages of multi-



million dollar projects that state agencies are incapable of responding





                             -141-

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to in a timely fashion.  Because we live in an age of protest,  they




are sensitive to all objectors which is our democratic way of life,




but some means must be found to avoid the unfair delay of projects




benefiting many because of the often ill-considered protests of a




few.  A fair balance must be struck more quickly than is frequently



possible at present.




     If the granting of permits can be simplified without sacrificing




protection for the public, a great deal of needless time and expense




can be avoided.  To illustrate the point, the utility bridge required




to cross the Saugus River to transport the steam to the customer




required approval of eight agencies or Government Legislative bodies.




The approval process starts with the town or city's conservation




commission which must send a favorable recommendation to the town's




board of selectmen, or a city's city council or board of aldermen.




Their formal approval is required before The State Department of Public




Works - Waterway Division - will act on an application for construction.




But in the case of the RESCO Bridge, it is a fixed span over a river




that has drawn bridges both up stream and down; and, therefore,  a




special act of The Legislature of The Commonwealth of Massachusetts



was required before DPW could act.  Upon passage of that special act,



they reviewed the request after examining the Environmental Impact




Statement which is required for the bridge, as well as the entire



project.  Once finally approved by DPW, they sent their recommendation




to  the Corps of Engineers who have final authority.  Because it is




a navigable waterway,  the corps would not take any action until the




Coast Guard had sent in their recommendations and approvals which




they would not do until after a public hearing was held.  This process




and the subsequent  receipt of the necessary permits consumed over  one




                              -142-

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year of time and numerous hours of testimony time by engineers,




lawyers, and officials of the company.  When one realizes the entire




process could have been stymied by one partirae City Park Attendant




who was Chairman of the City Conservation Commission, it is apparent




our precedures for approval must be modernized if we are to benefit



from projects which can improve our environment  and preserve our



precious resources.



     Our present regulations submit a developer to an unreasonable




risk in that the Massachusetts Department of Public Health - Division




of Air Quality - requires the submission of a complete set of drawings




and specifications including detailed operating and maintenance




procedures before they will act on the approval of the necessary




construction permit.  Because of the uniqueness of this project,




the department agreed to allow five-phase submissions for approval




covering the following subdivisions of design: (a) site work and



foundations, (b) substructures,  (c) superstructures,  (d) machinery,



and  (e) operational and maintenance procedures.  While construction




is proceeding on the project, committing many millions of dollars,




final approval of the plant design has not yet been received.  The



state has informed RESCO that no further phased approvals will be




permitted by the department on subsequent projects, thereby requiring



the expenditure to provide complete drawings and specifications before



any approvals are granted.  What reasonably prudent investor will take




that risk in the future?



     There is a need for legislation which will create a centralized



state licensing board with the responsibility to protect the public



health and safety, but which also has the power to expedite certain




regulations or procedures in the overall best,interests of the public.



                            -143-

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     Federal legislation, recently adopted will enable a growing
number of communities to plan comprehensive solid waste management
programs and investigate resource recovery options available to them.
A number of localities have already been involved in planning and
procurement activities.  From our experiences and theirs we know
that the planning process for comprehensive solid waste management
services, particularly those built around resource recovery, is often
a time consuming and frustrating experience.  To facilitate responsible
private industry's participation in providing recovery services a
number of key issues should first be resolved.  It is here that the
Resource Conservation and Recovery Act of 1976 can be of assistance
in assuming that State and regional plans are responsive to eliminating
the many roadblocks hindering development of these facilities.
Those state plans must assure a quantity of waste supply sufficient
for the scale of the proposed facility.  The economics of resource
recovery partially depend upon income obtained for the disposal services
rendered to the community.  There are a number of different approaches
to assuring sufficient waste for the resource recovery plant.  In
Boston, we competed in the open marketplace with landfill and other
disposal operations.  We feel this to be the best way to secure a
long-term waste supply at a reasonable, controlled cost to the public.
Other ways are being considered.  They include districting, franchising,
and otherwise mandating  the flow of refuse within an area.  In each
case a community must make a long-term commitment to supply a certain
quantity of refuse necessary to defray the capital and operating costs
of the facility.  From  the communities standpoint, making these
assurances will often  depend upon whether  the disposal services being
                             -144-

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offered at the resource recovery facility are cost competitive and
as reliable as other disposal options.  Congress has recognized the
importance of long-term waste supply commitments by providing in
Sec. 4003(5) of the Resource Conservation and Recovery Act of 1976
that local governments be given the legal authority to enter into
long-term supply agreements with the private sector.
     A second key issue concerns the nature of energy markets for
the combustible fraction of solid waste -- markets for steam or
electrical energy of fuel produced by the resource recovery process.
As a general rule, income from energy production and dumping fees
should meet the capital and operating costs for the resource recovery
facility.  The availability of long-term, stable energy markets will
reduce the need to rely on dumping fees to meet plant costs.  In the
recently passed legislation, Congress, recognizing the importance of
recovery markets to the commercialization of proven resource recovery
technology, has mandated the Secretary of Commerce to develop ways
to encourage markets for recovered resources.
     There are, of course, other issues which are equally important
in evaluating the feasibility of establishing resource recovery
services.  For example, are local governments able to negotiate for
such services or are they limited, by law, to procurements made
through a competitive bids procedure?  Very often it will be difficult
for a city to adequately evaluate resource recovery services if it
is limited to accepting the lowest bid quoted in terms of a net dumping
fee.
     Before closing, there is an important observation to make about
the potential for solving our solid waste disposal requirements
                              -145-

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through resource recovery.   Even with the most favorable markets for




recovered energy and products it is likely that there will be residue




from the process which will require land disposal.  In addition, most




technologies being offered are unable to handle the wide variety of




volatile, toxic and otherwise hazardous industrial solid waste materials.




Hence, state and local governments should be under no illusion that




resource recovery means the end of land disposal for solid waste.  These




are a necessary adjunct to a totally integrated resource recovery plan.




     The RESCO plant demonstrates that an industry can benefit




from the energy to be derived from the solutions of our mounting




solid waste problem.  Regional associations of suburban communities




appear to be as logical to solve our solid waste problems as we have




found them in serving our other needs, such as water, sewerage, and




transportation systems.  However, they often lack the means to finance




these facilities and by solicitinq proposals to desian, build and




operate the facility, they can make -judicious use of private capital,




possibly converting to industrial revenue bonds which gives ownership




of the facility to the regional group after the amortization period.




     The Europeans have been an energy-short society for years,



and they have learned to recover the precious energy from solid




waste that we bury daily.  The technology is not new.  It's time



we removed the needless bureaucratic roadblocks preventing the use



of that technology.  To those of us who lived through it, it appears




the whole process currently  is out of balance, and it is the




public -- all of us -- that  suffers as a result.




                             -146-

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          THE IMPACT OF SOURCE SEPARATION AND WASTE REDUCTION
           On THE ECONOMICS OF RESOURCE RECOVERY FACILITIES
                           John H. Skinner*


                      Background and Introduction


     The rising costs and decreased availability of land, energy and raw
materials have created pressures for the recovery and reduction of solid
waste.  In recent years communities across the nation have considered
various options to reduce solid waste disposal requirements and simultaneously
conserve energy and materials.  These options can be grouped into the
following three broad categories.

     1.  Haste reduction is defined as the reduction or prevention
         of waste at its source, either through the redesign of
         products or the reduction of product consumption.  Examples
         include the use of reusable products or products with increased
         durability and longer lifetimes.

     2.  Source separation is defined as the separation of waste
         materials at the point of discard followed by separate
         collection and recycling.  Source separation currently
         accounts for virtually all post-consumer solid waste
         recycling.  Examples include collections by charitable,
         service and religious organizations, community and industry
         recycling centers, and municipal separate collection programs.

     3.  Mixed waste recovery is the processing of mixed municipal waste
         to recover useful materials or energy.  A number of technologies
         have been developed and are being applied for this purpose.  Host
         of them involve energy recovery through either waterwall
         combustion, production of solid refuse-derived-fuels or
         pyrolysis to produce liquid or gaseous fuels.  Mixed
         waste recovery systems also include a number of unit processes
         to recover metals and glass from mixed refuse.
     *  Dr. Skinner, Deputy Director, Resource Recovery Division, Office
of Solid Waste Management Programs, U.S. Environmental Protection Agency,
presented this paper at the Fifth National Congress on Waste Management
Technology and Resource and Energy Recovery sponsored by the flational
Solid Waste Management Association.  Dallas, Texas, December 9, 1976.

                               -147-

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     In recent years there has developed a debate concerning both the
relative importance and the potential  conflicts between these three
options.  Part of this debate has viewed these options from a national
perspective and has explored the importance of each in dealing with the
national solid waste management problem.  Another part of the debate
has focused on the choices and conflicts in the implementation of
combinations of these options at the local level.  This later issue will
be the r^in subject of this paper.   However, before proceeding along
these lines, a few of EPA's major findings concerning the national
policy significance of waste reduction and resource recovery will be
stated.  This is important to put this subject in the proper perspective
because a number of prevalent misconceptions have developed on this
issue.  One is that large scale mixed  waste processing systems can be
expected to solve the Nation's solid waste disposal problems in the
forseeable future.  Another is that the other two options - waste reduction
and source separation - are of only nominal or symbolic significance.
In this regard EPA has found that:l>2>3

     -  Even with an optimistic increase in the number of cities
        installing mixed waste recovery systems, the total national
        solid waste disposed of annually will increase significantly
        by the mid-1980's.

     -  Many mixed waste processing technologies are still in the develop-
        mental stage.  While accelerated implementation is expected in
        the future, it is not likely that more than 10 to 20 percent of
        the nation's solid waste will  be processed in such plants in the
        next decade.

        Source separation and waste reduction measures can make
        quantitatively significant reductions in solid waste disposal
        requirements.  However, there are market and institutional
        barriers to these options.

     -  Increased adoption of all three approaches is necessary in
        order to have a large positive impact on the amounts of solid
        waste disposed of nationwide.   Mo single approach in itself
        will yield desired reductions  in waste disposal levels.

The basic conclusion on this issue is  that from a national perspective
there is no choice between the various forms of resource recovery
and waste reduction.  No single "solution" can "do it all" and all
three options taken together will not obviate the need for well-designed
land disposal sites.

     Turning now to the second issue which has been raised, concerning
the potential conflict between the local implementation of the three
options.  Waste reduction, source separation and mixed waste recovery
each offer a number of different benefits to the local decision maker
                              -148-

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and involve different costs.  A few examples will  make this clear.
Waste reduction and source separation will reduce the requirements  for
both disposal and collection of solid waste, while mixed waste processing
can only reduce disposal requirements.  Conversely source separation
involves requirements for collection and transportation of separated
materials.   Source separation is generally less capital intensive than
mixed waste recovery, but large scale processing facilities enjoy certain
economies of scale.  Some waste reduction options, could effect product
consumption levels, prices and litter rates, while source separation and
mixed recovery may not impact these items at all.   Source separation may
result in recovering a few materials at higher economic values as compared
to mixed waste processing.  On the other hand, processing facilities
employing energy recovery may result in a higher recovery rate for  more
of the waste stream.  Any decision to locally implement combinations of
these programs should be made from a comprehensive analyses considering
overall costs and benefits.  In fact, the recently passed Resource
Conservation and Recovery Act of 1976 recognizes the importance of such
analyses and mandates:

     "research and studies concerning the compatability of front-end
      source separation systems with high-technology resource recovery
      systems."^

     This paper will address only one aspect of this subject, the
impact of source separation and waste reduction programs on the economics
of mixed waste recovery plants.  Such programs could cause significant
reductions in the quantity of recyclable materials in the waste stream.
Since such materials provide a source of supporting revenues for mixed
waste recovery facilities, their removal could impact adversely on  plant
economics, especially if such programs are instituted after a plant has
been designed and constructed.  This paper will present a preliminary
estimate of the order of magnitude of some of these economic impacts and
a discussion of their significance and relevance to recovery plant
implementation decisions.

     In the following sections two types of programs are analyzed:

     1.  paper recycling programs and their resulting reduction in
         the heating value, energy content and value of solid waste
         a fuel, and

     2.  metal and glass reduction and recycling programs and their
         resulting decrease in recycled material revenues for mixed
         waste recovery plants.

     It must be re-emphasized that the analysis will not consider the
relative costs and benefits of paper separation and container reduction
as compared to recovery of these products through mixed waste processing
plants.  Rather the analysis will consider only the impact of such
                                -149-

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programs on recovery plant economics.   Even if the impact on plant
economics is negative it would be beneficial  for communities to  carry
out such programs if the overall  system economics is improved or if the
benefits exceed the additional costs.

               Paper Recovery Through  Source  Separation

     Quantities and Recycling Levels.   Wastepaper makes up approximately
32 percent by weight of residential  and commercial solid waste*  (Table
1).  Several grades of wastepaper have significant potential for source
separation and recovery (Table 2).   Old newspaper represents approximately
20 percent of the wastepaper discarded in solid waste and most of this
is generated from residences and  households and is easily separated from
other wastes.  Old corrugated represents approximately 25 percent of
wastepaper discards and most of this is generated in commercial  and
industrial establishments.  Corrugated recovery from such sources has
been practiced for years.  Office papers represent approximately
13 percent of discarded wastepaper.   In the past few years a number of
office buildings have instituted  programs to  separate high grade office
papers for sale and recycling.  The theoretical maximum potential recovery
level for all three of these grades has been  estimated to be approximately
50 to 60 percent.'>P-48  However, actual recovery levels that have been
experienced have been much lower than  this.  Municipal separate  collection
programs (collecting primarily newspapers) have reported recovering from
5 to 20 percent of the total wastepaper available.5  While individual
office buildings have reported paper recycling levels ranging from 10
percent to as high as 70 percent the overall  level of office paper
recycling in most communities is  probably very low.   Other wastepapers
such as books, magazines and miscellaneous packaging and other papers do
not ..offer significant potential for recycling because of their high
contaminant levels, dispersed generation and  heterogeneous nature.

     Paper Value as a Fiber.  A key factor in decisions whether  to
recover wastepaper as a fiber is  the market prices for wastepapar.
Wastepaper prices vary with grade,  location and time and prices  ranging
from a few dollars per ton to over $100 per ton have been observed
(Table 3).  For certain high grade papers such as sorted white ledger (a
grade which can be obtained from office paper separation programs) the
fiber value is probably high enough to make source separation economically
viable under most circumstances.   For other grades such as mixed wastepaper,
old news and corrugated, the fiber value depends upon local paper markets,
and could vary significantly as prices change over time.  In the periods
     Throughout this report solid waste composition percentages are
defined as national average disposal levels after national average
recycling rates have been subtracted.  Similarly recycling and recovery
percentages are defined as increments over and above present national
average recycling levels and expressed as a percent of national average
disposal levels.
                                -150-

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when paper markets are strong, these grades may be extracted for recycling
through increased collections by community groups, private firms or
municipalities.  At times of low paper prices such papers may be discarded
with other municipal wastes.  It is these shifts in the price of wastepaper
in the local market areas, and the resulting increase or decrease in
paper recycling levels that may give rise to some degree of uncertainty
in the economics of energy recovery plants.

     Impacts on Energy Content.  In order to illustrate the impact of
paper removal on the energy content of solid waste two situations will
be described.  The first situtation is for a plant receiving wastes from
a service area with a fixed or constant quantity of waste.  For example,
this would represent a plant serving a fixed population community with
a constant per capita waste generation rate.  Prior separation and
recovery of paper would reduce the total  amount of solid waste received
by the plant and the energy recovered (and energy revenues) would be
reduced in direct proportion to the paper removal.  The order of magnitude
of this effect is presented for various paper recovery rates on Table 4.

     The reduction in energy available from the wastes generated in a
fixed service area does decrease significantly (greater than 20 percent)
at very high paper recovery rates.  However, in the range of actual
paper recovery rates experienced (10 to 20 percent paper recovery) the
reduction in total energy available is less than 10 percent.

     The second situation analyzed is for a plant with an expandable
service area, i.e., a plant which can expand its service area in order to
fully utilize plant capacity.  The fixed-no growth service area is an
unlikely situation for most parts of the country.  Most plants would
have some opportunity to compensate for waste reductions from paper
separation by expanding the service area to a larger population.  Such
reductions would also be offset over time by growth in the per capita
waste generation rate.  However, even in these situations there would be
a reduction in total energy recovered.  Since paper has a higher heating
value than the average for mixed municipal waste, its removal results in
a decrease in the average heating value of the remaining waste.  This
means that even if plant throughput was not reduced by a paper recovery
program, less steam or fuel would be produced for every ton of waste
processed.  These effects are also shown on Table 4.  The reduction in
heating value is minimal (less than 10 percent) even for high paper
recovery rates.  Removal of paper does not result in a significant
decrease in the heating value of the remaining waste.  Solid waste with
some of the paper removed will still burn.

     Economic Impact Estimates.  In order to illustrate the order of
magnitude of economic impacts of paper separation on energy recovery
plants, the results of a simple calculation are presented on Table 5.
This calculation makes a number of assumptions concerning fuel price,
energy recovery efficiency, heating value and processing costs as shown
in the table.  While these are not the actual figures for any particular
                               -151-

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plant, they are within the range of values that have been presented for
various energy recovery systems.  The results are presented in terms of
the disposal charge or tipping fee per ton of solid v;aste that would
have to be charged at the plant in order to cover fixed processing
costs.  Results are presented for both a fixed service area and a
service area which can be expanded to maintain plant capacity as paper
is removed.

     The results show that for the expandable service area the increase
in disposal charge is about $.65 per ton for the highest paper recovery
rate.  Far the fixed service area, since the energy recovery decrease is
greater and the fixed processing costs must be spread over a smaller
tonnage, the disposal cost increase is greater.  For the highest paper
recovery rate the disposal charge increases about 152.85 per ton.  For
the range of paper recovery rates that have been experienced in municipal
programs (10 to 20 percent) the disposal charge increases by $.70 to
$1.35 per ton.

     The actual numerical results derived above should be used with
caution since they are based upon a number of assumptions which may or
may not be valid for other resource recovery plants.  However, the
results do illustrate several interesting points.  Paper separation
programs that are instituted in areas where there are existing energy
recovery plants may reduce both the capacity utilization and energy
revenues of such plants.  However, for plants that can expand their
service areas to compensate for waste reductions from paper separation,
the disposal charge increase is likely to be insignificant (much less
than $1 per ton).  For plants with fixed service areas, disposal charges
could increase several dollars per ton at very high paper recovery
rates.  However, for "typical" paper recovery rates the disposal charge
increase would be much smaller (of the order of $1 per ton) even for
fixed service area plants.  For plants that are built after the institution
of paper separation programs, these impacts can be reduced even further
by designing such plants for full capacity utilization.  The major
negative economic impact occurs for a plant that suffers a precipitous
decline in delivered tonnage at a rate that cannot be compensated for by
expansion to additional sources of waste.  It is this situation that
should be of primary concern to owners and operators of mixed waste
processing plants.

                 Metals and Glass Separation or Reduction

     Alternatives for Metal and Glass Recovery.  Metals and glass make
up approximately 20 percent of municipal solid waste by weight.  Many
mixed waste recovery plants are considering extraction and recovery of
some of these fractions.  Ferrous metals recovery through magnetic
separation is a commercially established technology which will probably
be widely used in most recovery plants in the future.  However, glass,
aluminum and other nonferrous metals recovery is in the developmental
and experimental stage.  There are a number of uncertainties concerning
technologies.  Markets for recovered glass and nonferrous ruetal resources,
have just begun to be developed.  Given  this situation any analysis of
the  impacts of material separation or reduction programs becomes  somewhat
tentative, because the economics  are uncertain on both the cost and
revenue side.
                              -152-

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     There are several types of programs that could effect the
recovered materials revenues from mixed waste recovery plants:

     1.  Glass and metal source separation.  While several communities
         have experimented with programs for the source separation
         and separate collection of glass and metals this option has
         not been practiced widely to date.1

     2.  Aluminum can recovery programs.  The aluminum industry has
         instituted a can collection program that has resulted in
         the recovery of 25 percent of all aluminum cans nationwide
         and much higher rates in local situations."

     3.  Beverage container deposit programs.  Four States, Oregon,
         Vermont, Michigan and Maine have passed mandatory beverage
         container deposit laws.  In Oregon and Vermont where the laws
         have been in place for several years very high return rates
         (greater than 90 percent) for all beer and soft drink
         containers have been experienced with similar reductions in
         container waste generation rates.

For purposes of illustrating the impacts of such programs on the material
revenues of mixed waste processing plants, the beverage container deposit
case will be used as a model.  On the average, beverage containers make
up 45 percent of the glass, 38 percent of the aluminum and 15 percent of
the ferrous metal in mixed municipal waste (Table 2).  It will be assumed
that container deposit programs will result in a complete elimination of
the beverage container fractions from the waste stream.  While this is
certainly an exagerated impact it serves to maximize the reductions in
recovery plant material revenues.

     Impact on Gross Revenues.  Estimates of the gross revenue contribu-
tions for metals and glass recovered in a mixed waste processing plant
are shown on Table 6.  Gross revenues represent simply the recovered
material sale prices and do not account for the costs of extracting and
recovering these commodities.  Because of the uncertainties and variations
in some of these numbers the estimates are shown as a range rather than
a point value.  These variations are due to differences in:

     1.  recovery efficiences which depend upon the technology
         employed and the quality of the product recovered, and

     2.  recovered material sale prices which depend upon the markets
         and the product specifications.

The numbers shown represent the range of efficiencies and prices that
have been discussed in the resource recovery literature.  The upper
range represents pushing the technology to its limits and receiving top
prices for the products.  The lower range represents minimum efficiencies
                              -153-

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and relatively poor market conditions.   The gross revenues from ferrous
metals, glass and aluminum range from $2.75 to $6.00 per ton of solid
waste processed.  All other things remaining constant,  an elimination of
the beverage container fraction would reduce these gross revenues  by
$.70 to $1.60 per ton of waste processed.  However, as  will  be discussed
in the following sections, removal of glass and aluminum beverage  containers
may reduce revenues from other glass and aluminum products.   Moreover,
conclusions regarding the impact of beverage container  policies on the
overall economics of mixed waste processing plants must consider the
net revenue contributions after processing costs are accounted for.

     Impact on Net Revenues.  Net revenue calculations  are subject to
wide margins of uncertainty.  There has been very little analysis  of the
costs of processing specific components of the waste stream.  It is  very
difficult to separate the incremental costs of steel, glass  and aluminum
recovery from the overall plant cost figures.  It is even more difficult
to evaluate how these costs might change as a function  of changes  in the
quantity and composition of the wastes  processed.  Therefore, the  cost
presented are a very rough first approximation.

     The recovery plant considered is a refuse-derived-fuel  plant  that
recovers ferrous metals by magnetic separation and glass and aluminum by
a combination of heavy media separation, froth flotation, optical  sorting,
and electrostatic separation.  The approach used is to  estimate only the
incremental cost of separating the ferrous, glass and aluminum fractions.
This means that the basic costs of shredding and air classification  have
not been allocated among these products.  This is the correct approach
in determining whether or not materials recovery subsystems  should or
should not be included in a project—that is in terms of their incremental
contributions to processing costs and net revenues.  The results are
shown on Table 7.

     The incremental process costs for ferrous metals recovery have been
estimated separately.  Glass and aluminum recovery share many of the
unit processes in commofr making it impossible to separate the processing
costs for these two materials from each other.  These costs  estimates
include fixed and variable operating costs and capital  costs amortized
over the plant 1ife.

     The incremental process costs of ferrous metals recovery are
estimated to be in the range of $.50 to $1.00 per ton of solid waste
processed and the costs of glass and aluminum recovery  are estimated
to be from $1.70 to $2.00 per ton of solid waste processed.   These
process costs, when subtracted from the high gross revenue estimates
derived previously result in net revenue contributions  for ferrous
metals recovery ranging from $2.20 to $2.70 per ton and for glass  and
aluminum recovery ranging from $.85 to $1.15 per ton.  (It should  be
noted that for the low gross revenue estimates aluminum and glass
recovery is not economical, i.e. the incremental processing cost exceeds
the gross revenue contribution).
                               -154-

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     Removal of 15 percent of the ferrous metals would probably not
effect processing costs significantly and recovery of the remaining 85
percent would still be economically feasible.  Therefore, the impact of
removal of ferrous beverage cans on ferrous metal revenues is roughly
equal to the reduction in gross revenues which is about $.50 per ton.

     For glass and aluminum recovery the effect of beverage container
removal is more complicated to analyze.  Many aluminum recovery subsystems
are more efficient with respect to recovery of aluminum cans than other
aluminum products (such as foils).  A given reduction in aluminum cans
could result in a much greater reduction in the percentage of total
aluminum recovered.  In the extreme, removal of the aluminum can could
make recovery of the other aluminum fractions unprofitable.  Also, the
economic feasibility of glass recovery is closely linked to aluminum
recovery as many of the processing steps are combined for the two materials.

     Therefore, the impact of removal of glass and aluminum containers
could range between two extremes.  In the best situation net revenues
would be reduced only in proportion to the reduction in the container
fractions and would range from $.35 to $.45 per ton of solid waste
processed.  In the worst situation removal of the glass and aluminum
container fractions would make other glass and aluminum recovery economically
unfeasible and the net revenue loss would be from $.85 to $1.15 per ton
of solid waste.

     In summary, for plants recovering only ferrous metals, the removal
of beverage container materials could reduce net revenues by roughly
$.50 per ton of solid waste processed.  For plants also recovering
aluminum and glass, and receiving high gross revenues for these products,
beverage container removal could reduce net revenues by an additional
$.35 to $1.15 per ton.  As for the paper separation analysis, these
results could be extended to estimate the disposal charge impact for
both fixed and expandable service areas.  It was decided that this
further refinement would not be meaningful due to the uncertainties in
these numbers in the first place.  The net revenue reductions approximate
the disposal charge increases.
                               -155-

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                                Conclusions
     The previous sections presented estimates of the effect of paper
separation programs and beverage container reduction programs on the
economics of mixed waste recovery facilities.   These estimates are based
upon a number of assumptions concerning the composition of the waste
stream, technology performance and costs, and  recovered material market
prices.  As was pointed out, there is a certain amount of variability in
each of these parameters and the results could be different for plants
employing different technologies or for plants located in different
parts of the country.

     The analysis showed that the impact of paper separation programs on
plant disposal charges could range from a few  cents per ton to several
dollars per ton depending upon the paper recovery rate and the plant
capacity utilization.  However, considering the paper recovery rates
that have been experienced, and considering that many plants should be
able to compensate for waste reductions by expansion of service areas;
the likely increase in disposal charge for most plants would probably be
much less than $1 per ton.

     The analysis also showed that beverage container reduction programs
could reduce recovery plant net revenues from  $.50 per ton to over $1.50
per ton depending upon the technology performance and recovered material
market prices.  For plants recovering only ferrous metals the impact
would be in the lower end of this range.  Revenue reductions in the
upper range would only occur for plants recovering glass and aluminum as
well, and achieving high recovery efficiencies and receiving high market
prices.  Therefore, for most recovery plants the likely impact of beverage
container reduction programs would probably be much less than $1 per
ton.

     Given the uncertainties that exist in resource recovery technologies
and markets, possible cost changes within the  range of $1 per ton should
not be determining factors in community decisions.  Future costs cannot
be projected to this degree of accuracy.  Small changes in construction
costs, interest rates and material and energy  prices could produce
comparable effects.

     Of course, there is the possibility that  resource recovery markets
and technologies might develop to the point that the impacts of separation
and reduction programs could be greater than what is presently considered
likely.  This raises the question of what actions, if any, should be
taken by resource recovery plant operators to  guard against such negative
economic impacts.  Should communities contracting with recovery plants
be prohibited from engaging in municipal source separation programs?
Should there be penalties if a community (or State) passes a returnable
beverage container ordinance?  It is believed  that such drastic measures
are not necessary to protect resource recovery plant investments.
                                -156-

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     It is important to realize that over the 20 to 25 years lifetime of
a mixed waste recovery plant there will probably be a number of changes
that would impact on plant economics.  Many of these changes will  be
"uncontrollable" and will be brought about by private sector free  market
actions.  For example, increased use of plastic beverage containers
could reduce the metal and glass content of solid waste and produce
effects similar to beverage container deposit programs.  Private sector
paper recycling could produce effects similar to municipal source
separation programs.  Changes in the prices of fiber and energy could
effect the relative economics of paper separation versus energy recovery.
Recovery systems that are being built today are going to have to be
designed to accomodate such changes.

     Mechanisms and institutions need to be developed for managing these
uncertainties and share some of the potential risks and benefits between
local governments and recovery plant owners and operators.  Communities
should try to maintain the flexibility to implement new programs that
would improve the overall economics and environmental impacts of their
solid waste management systems.  Contract provisions or agreements that
foreclose future improvements are unwise.  However, provisions that
equitably allocate costs and responsibilities are also a necessity.  The
potential uncertainties concerning public policies for source separation
and waste reduction programs should be handled within such a framework.
                               -157-

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                                  Table 1
                    Material  Composition of Residential
                        and Commercial  Solid Waste*
        Material                                               Percentage

Paper and Paperboard                                             32.3
Glass                                                             9.6
Ferrous                                                           8.4
Aluminum                                                          0.8
Other Monferrous                                                   0,4
Plastics                                                          3.7
Rubber and Leather                                                2.6
Textiles                                                          1.4
Wood                                                              3.6
Food Waste                                                       16.8
Yard Waste                                                       19.0
Miscellaneous Inorganics                                          1.4
                                                                100.0
     *U.S. Environmental Protection Agency, Office of Solid Waste Management
Programs.  Fourth Report to Congress, Resource Recovery and Waste Reduction.
Draft, November 1976.
Mote:  Estimates on an "as generated" weight basis assuming normal moisture
       content of material prior to discard.
       These are national average disposal levels after national average
       recycling rates have been subtracted.
                                  -158-

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                                  Table 2
                Selected Product Composition of Residential
                        and Commercial  Solid Waste*
     Material,                                            Percent of
                                                      Total Solid Haste
Paper and Paperboard                                           32.3

  Newspaper                          6.0
  Office Paper                       A.I
  Corrugated                         8.2
  Books and Magazines                2.6
  Other Packaging                    8.4
  Other Nonpackaging                 3.0

Glass                                                          9.6

  Beer and soft drink containers     4.3
  Other containers                   4,5
  Other products                      .8

Ferrous                                                        8.4

  Beer and soft drink containers     1.2
  Other containers                   3.2
  Durable goods and other products   4.0

Aluminum                                                       0.8

  Beer and soft drink containers     0.3
  Foil                               0.3
  Other Products                     0.2
     *U.S. Environmental Protection Agency,  Office of Solid Waste Management
Programs.  Fourth Report to Congress, Resource Recovery and Haste Reduction.
Draft, November 1976.

Note:  Estimates on an "as generated" weight basis assuming normal moisture
       content of material prior to discard.

       There are national  average disposal levels after national  average
       recycling rates have been subtracted.

                              -159-

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                      -160-

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                                  Table 4
                    The Impact of Paper Recovery on the
                       Energy Content of Solid Waste

Paper Recovery
Rate
(percent)*

10
20
30
40
Fixed Service
Area Reduction in
Energy Available
(percent)**

5.3
10.8
16.0
21.5
Expandable Service
Area Reduction in
Energy Available
(percent) +

2.2
4.6
7.0
9.9

     *Defined increments above present national  average recycling  rates,
as a percent of present national  average rate of wastepaper disposal.

    **Reduction in energy content of a fixed quantity of waste  caused
by the removal of paper.

     +Reduction in average heating value per unit weight of waste.
Calculated from data by Niesson,  W.  R. and S. H.  Chansky, "The  Nature
of Refuse", Proceedings of 1970 National Incinerator Confernce.
                                   -161-

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                                  Table 5

                 Impact of Paper Recovery on the Disposal
                    Charge of an Energy Recovery Plant

Disposal Charge (per ton of solid waste)
Paper
Recovery Rate*

0
10
20
30
40
Expanded
Service Area

8.50
8.65
8.80
8.95
9.15
Fixed
Service Area

8.50
9.20
9.85
10.55
11.35

Assumptions:

  1.  Energy revenues $1.00/million BTU.
  2.  65 percent of input waste is converted to energy.
  3.  Heating value of solid waste with no paper recovery 10 million
      BTU/ton.
  4.  Fixed costs (capital costs and fixed operating costs) of $15 oer
      ton of daily plant capacity.
  5.  Other materials revenues are not included.

     *Defined as increments above present national average recycling
rates, as a percent of present national average rate of wastepaper disposal.
                                  -162-

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                        -163-

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                                 Table 7

               Net Revenues from Metal and Glass Recovery
                         ($/ton of solid  waste)
                             Ferrous Metals            Glass and Aluminum
                                Recovery	            __  Recovery 	__
Gross Revenues                   $3.20                      $2.85
   (high)

                             $-50  to $1.00              $1.70 to  $2.00


                            $2-20  to $2.70               $.85t0$1.l5
     *Derived from:  Resource recovery engineering and economic feasibility
for either a 650 or 1300 ton per day processing facility.   National Center
for Resource Recovery, Inc. Report prepared for the Metropolitan Washington
Waste Management Agency.  Washington, D.C., January 1975.
                                  -164-

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                                References
1.  U.S. Environmental Protection Agency.  Third Report to Congress,
      Resource Recovery and Haste Reduction.  Environmental Protection
      Publication SW-161.  Washington, U.S. Government Printing Office,
      September 1975.

2.  Skinner, J. H.  Reduce the Incentives to Waste,  Environmental
      Protection Publication SW-500.  U.S. Environmental Protection
      Agency, Washington, D.C., September 1975.

3.  Hutnber, Nicholas.  Waste Reduction and Resource Recovery - There's
      Room for Both.  Waste Age.  November 1975.

4.  The Resource Conservation and Recovery Act,  Public Law 94-580,
      October 1976.  Section 8002(e).

5.  Analysis of Source Separate Collection of Recyclable Solid Waste -
      Separate Collection.  SCS Engineers.  U.S. Environmental Protection
      Agency Study 68-01-0789.  August 1974.

6.  Optimization of Office Paper Recovery Systems.   SCS Engineers.
      U.S. Environmental Protection Agency Study 68-01-3197.

7.  Hansen, P. and J. Ramsey.  Demonstrating Multi-material Source
      Separation in Sommerville and Marblehead,  Massachusetts.
      Waste Age, February 1976.

8.  Press Release, The Aluminum Association, New York, Hay 11, 1976.
                                   -165-

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          REGIONALISM:  ITS ROLE IN RESOURCE RECOVERY
                       Stephen G. Lewis
                    The Mitre Corporation
THE ISSUE OF REGIONALIZATION
     Over the past three or four years we have learned a few things about
planning for resource recovery.  First, and most important, we have
learned just how difficult it really is to plan and establish a facility
that, in reality, is a complex manufacturing plant processing raw materi-
als, solid waste, provided for the most part by local governments.  From
these raw materials the plant produces energy products for sale such as
steam, gas, oil, refuse derived fuel, or electricity, and materials such
as ferrous metals, aluminum, or glass.  Because of the high cost of these
plants, the trend is to finance them through the issuance of revenue
bonds supported by financially strong revenue streams under contract.  The
revenue streams are derived from the sale of energy and materials, and
fees for refuse disposal from local governments and private refuse collec-
tors.  The job of putting the system together requires selection and nego-
tiation of markets, technologies and capable private firms for design, con-
struction, and operation.  It also requires selection of sites and defini-
tion of long term commitments to deliver refuse to the facility.
     One conclusion from this is that the resource recovery planning pro-
cess requires skills, time, money, conviction, and political and entre-
preneurial strength not possessed by most local governments.  Another con-
clusion is that a long term and reliable energy customer is needed, as well
as sites for the processing facility and for disposal of process residues
and emergency use.  Both the energy customer and the sites must be within
the boundaries of the local jurisdiction planning the facility, and most
local jurisdictions are hard pressed to come up with these.  A final con-
clusion is that there must be sufficient refuse generated within the
jurisdiction to supply the type of facility that is otherwise appropriate
for the area, based on energy and materials markets, site locations, and
private industry interest.
                             -166-

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     These conclusions point to the need in a number of cases for local
governments to join together in some manner and regionalize so that they
can expand the market opportunities, the siting options, or increase the
amount of waste available for processing to a level where the capital  in-
vestment for the facility is warranted.  It seems a pity that resource
recovery implementation is going to be dependent upon regionalization,
since it is such a difficult thing to bring about.  On top of the diffi-
cult technical and financial planning tasks required for resource recovery
itself, in regionalization we must also address what may turn out to be an
even more complex political and organizational planning task.
     Certainly, there is nothing new about forming regional organizations
or cooperative efforts.  In water supply, wastewater treatment, delivery
of educational services, local purchasing, and even police and fire pro-
tection there are numerous experiences to demonstrate that certain gov-
ernment functions or services can best be performed on a broader metro-
urban regional basis.  But the diversity of local environments makes it
unwise to expect that an effective approach for one area will necessarily
be applicable to another.  It is equally unwise to believe that such new
government forms are easy to define and create.
     The purpose of this paper is to illustrate why regionalization in
solid waste disposal and resource recovery is important, to discuss the
approaches that can be used and the problems in achieving them, and to
make some general recommendations which will hopefully speed up progress.

THE SOLID WASTE RESPONSIBILITY OF LOCAL GOVERNMENTS
     In the United States about 70% of the people are packed into densely
populated urban areas.  About 30% of these people live in the central  city
itself while the remainder (40%) live in communities surrounding the cen-
tral city.  For the most part, local units of government are individually
small.  Although there are almost 2000 cities with a population over
10,000, almost 60% of these are actually smaller than 25,000 people.  In
                             -167-

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total we have more than 30,000 units of local government.  It is clear
that, by far, the majority of these are extremely small.  Individual
counties are not much larger, with almost 80% of the 3000 counties having
a population of less than 50,000 people.
     Although figures are not very good, we have reason to believe that
many thousands of local governments are themselves responsible today for
their own solid waste disposal, and thus will have a key voice in what
their new procedure will be when the current one is no longer available.,
Estimates indicate that there are over 18,000 land disposal sites in the:
                                              *
country, of which some 6000 are state approved .  Almost 4000 of these
are publicly owned and operated.  Obtaining solid waste disposal capacity
                                              **
is certainly a problem, since in a 1973 survey   local governments ranked
the need for disposal sites their number one problem, and 46% of the gov-
ernments reported they had less than five years of disposal capacity re-
maining.
     In summary, there are thousands of local governments responsible for
deciding how to dispose of their solid wastes.  Among their decisions is
the one to regionalize or to find a solution by themselves.

THE REGIONALIZATION ARGUMENT
     The basic argument for regionalization in solid waste disposal and
resource recovery is that the function is a capital intensive one that,
within a certain size range and in the majority of cases, can be performed
at a lower unit cost at larger scales.  A second, but no less important
argument, is the need to provide both a site or sites for processing as
well as disposal of residue and nonprocessable items, and the possible
need for close proximity of processing with a secure energy customer, such
 Waste Age,"Survey of the Nation's Land Disposal Sites", January 1975,
 p.17.

  National League of Cities-U.S. Conference of Mayors, "Cities and the
  Nation's Disposal Crisis", March 1973.
                              -168-

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as a user of steam or gas.   A third and more philosophical  argument — but
one which may indeed be the most important -- is that the solid waste man-
agement objectives of this  nation will  not be served be providing resource
recovery solutions for only those few local governments who happen to have
the right conditions for it within their borders.
     The realities of these arguments have been recognized by many:
     •  National League of Cities, Cities and the Nation's Disposal
        Crisis. 1973, p.7 	"The solutions to [solid waste] prob-
        lems require:  (1)  resources and support functions that ex-
        ceed the internal capability of cities, (2) available land
        areas for disposal, which many cities increasingly lack
        within their political boundaries."
     •  U.S. Environmental  Protection Agency, Decision-Makers Guide
        in Solid Waste Management. 1976, p.95 - - -"Resource recovery
        systems require large quantities of waste delivered for pro-
        cessing at one site in order to achieve economies of scale . . .
        plants in the 500 to 2000 ton-per-day range are likely to be
        the most economical."
     •  Urban Systems Laboratory, M.I.T., Summer Study on the Manage-
        ment of Solid Hastes. 1968, p.5 - - -"In solid waste manage-
        ment there appears to be overwhelming cost advantages in being
        big."
     •  Committee for Economic Development, More Effective Programs
        for a Cleaner Environment - A Statement on National Policy.
        April 1974, p.50 - —"These considerations [community size,
        availability of land, expertise] lead to the suggestion that
        regional agencies may be desirable for management of solid
        waste collection, recovery, and disposal in many areas."
                                  -169-

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ECONOMIES OF SCALE IN RESOURCE RECOVERY TECHNOLOGIES
     There is sufficient data available for most resource recovery tech-
nologies to substantiate the statement that, in general, the cost of own-
ing and operating a resource recovery facility decreases as its size or
scale increases.  In Figure 1 this is illustrated with data on three dif-
ferent technologies (bulk incineration, refuse derived fuel, and pyrolysis)
prepared for three separate projects in different areas of the country.
Net cost per ton, or the estimated disposal fee in $/ton,is plotted against
facility size, and the only conclusions that should be made from the Figure
are that net disposal fee can decrease with an increase in facility size,
and the value of the decrease varies widely for different technologies, as
well as for the same technology when applied in different projects and at
different times.
     An essential statement to make about interpreting this type of data
is that it is virtually useless in predicting the cost of resource recovery
elsewhere.  Differences in cost of 100% or more for basically the same
system can occur for a number of reasons:
     •  The equipment and construction costs can be substantially
        different because of differences in the cost of land, site
        preparation, or the year in which the estimate was prepared.
     •  The basic technology actually can be quite different in
        design in terms of redundancy, design for overall avail-
        ability, or extent of processing.  Producing electric
        power from steam, for example, requires an additional
        large capital investment for a turbogenerator over the
        investment required for the production and sale of the
        steam itself.
     •  A number of cost elements are frequently left out of
        estimates, including bond expenses, contingencies,
        interest during construction, residue disposal, taxes,
                             -170-

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                                -171-

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        etc.   For line E in the Figure,  for example,  the inclusion
        of local  property taxes alone (which has been left out)
        adds  another $3.50 to the net disposal  fee.
        Projects  have different degrees  of risk built into the
        estimated net disposal  fee.  The system represented by
        line  A in the Figure was competing against the system
        represented by line C.   One problem was that  the expec-
        ted income from the sale of RDF  included in the compu-
        tations for system A was highly  speculative,  while that
        for the sale of electric power from system C  was quite
        firm.
     The issue, again, is that it is very difficult to translate cost data,
particularly  net disposal fee,  from one  project to another.
     Also shown on Figure 1 is  an example of a recent estimate for a 50 ton
per day (capacity) modular steam recovery incinerator, a so-called small
scale system (line F) now in operation in a city of approximately 30,000
people.  Steam is currently being sold to a local industry.  The lower point
shown ($8.00/ton) represents the net disposal fee to  be paid by  the city
when the quantity of steam sold at the contracted price is what  it was orig-
inally planned to be when the decision was made to construct the system.
The upper point ($10.00/ton) is computed from actual  experience  to date.
These data are provided in the Figure to illustrate an actual case in which
a local small scale resource recovery system was chosen.  Such a small scale
system can be installed in communities from 30,000 people up to  150,000-
200,000 people, provided there exists a reliable steam customer  whose steam
requirements  are compatible with what the system provides.  This is a
critical need since without the sale of steam, the net disposal  fee would
be much higher.  For example, the fee for system F (in the Figure) would be
about $17.00-$20.00 per input ton without the income from the sale of steam.
                            -172-

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     It appears at this point in time that small scale technology systems
are most likely with steam production, although under investigation now
are off-the-shelf small scale turbogenerator systems for waste heat re-
covery.  It is possible that these can convert, at a small scale, solid
waste to electricity for sale at competitive prices, and result in a net
disposal fee comparable with that realized for the small scale production
and sale of steam.  The importance of this, of course, is the vast expan-
sion of opportunities because of the marketability of electricity as
compared with steam, although matching electric power supply and demand
also presents formidable problems.  Other small scale system opportuni-
ties are possible with materials recovery, perhaps even refuse derived
fuel preparation (RDF); however, the problems of marketing small quanti-
ties of such materials are well known.
     This small scale system case is presented because it must be one of
the options to be considered by local decision makers.  If it is believed
that the net disposal fee for a small scale system (or local landfill)
dedicated to the community will be approximately the same as that for a
large scale regional system, then many local officials will probably opt
for the former.  This is because of the difficulties associated with re-
gionalization discussed later.  In any event, if that decision is pre-
sented to them, they will certainly find it a challenging onel
     As a concluding comment, it has to be recognized that the use of
small scale systems does not make regionalization unnecessary.  Even
with small scale systems, communities under 25,000 population probably
will find it necessary to team up with other communities in a joint
solution.  Furthermore, a concept likely to evolve is the use of a
group of small scale systems linked together as a network within a
region to form a single "system".  This system would function as a
single unit; it is a regional system in disguise.
                                  -173-

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THE TRANSPORTATION COST ISSUE
     An important cost element in any resource recovery system is the cost
involved in transporting the refuse to the facility.   This is particularly
important in regional systems.  In the case of a central city of about
1-1/2 million people the 3000 tons per day generated  represents the input
for a large scale system, probably without an increase in transportation
costs.  In fact, transportation costs actually can be reduced since the
facility may be more centrally located than existing  and planned landfills.
The cases we want to focus on, however, involve a smaller central city and
its suburbs, or a group of small to medium communities, within an area
spanning 50 miles or even greater, who may be able to jointly consider
their solid waste disposal problem.  Analyses performed recently show that
transport of solid waste over distances of 40 miles or more can be "econom-
ically feasible", when considering three key questions relating to economic
feasibility:
     (1)  The benefits of the economies of scale in processing
          achieved by having a larger quantity of solid waste
          available for processing.
     (2)  The alternative cost for solid waste disposal by
          whatever other option is available locally, consider-
          ing also projections about increases in this cost.
     (3)  The manner in which the overall regional costs of
          solid waste transport, processing and disposal is
          to-be apportioned.
     We want to illustrate in the next few figures how these questions
relate to the overall decisions that must be made about what communities
might be included in a regional system project.
     Figure 2 illustrates the tradeoff of processing costs with trans-
portation cost as the size of the region increases.  Note that an increase
in region size is equivalent to an increase in facility scale, which is
                                  -174-

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                           -175-

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the same as an increase in number of communities which participate, and
the same as an increase in the maximum distance over which solid waste is
transported.  Shown are four curves:
     •  Processing cost per ton which diminishes with scale.   (Note
        that the processing curve in reality is a set of discrete
        points representing specific designs at each scale.)
     •  Transportation cost per ton which increases with scale.
        This is shown as a step function with steps occurring at
        the points where each new community enters.
     t  The sum of processing and transportation costs, which, in
        this example, diminishes with scale up to about 1700 tons
        per day (four communities) and then increases.
     t  An assumed standard landfill (or otherwise whatever alter-
        native disposal system that is available) cost of $9.00
        per ton for each community.  Actually, each community
        probably has- a different alternative cost based on their
        landfill, incinerator, or small scale system option and
        the transport cost associated with that option.
     From the figure it appears that the best decision for the region Is
to scale the facility at 1700 tons/day and plan for participation by the
four closest communities; adding the fifth community causes the total
average disposal cost to increase.  But what if the fifth community -- and
possibly others — are willing to pay more than the minimum disposal plus
transportation fee of about $7.00 per ton.  This is possible as long as
the fee does not exceed the total cost of their alternative disposal
system, say landfill at $9.00/ton?  In fact, the range between the two
figures is a "bargaining range".  Under such a transportation cost shar-
ing arrangement, it actually may be better for all participating communi-
ties to enlarge the system beyond the point at which the total average
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cost is a minimum.  With this concept in mind, it is possible to define
more comprehensively what "economic feasibility" really means in a
regional resource recovery system.
     The concept of transportation cost sharing is not common in this
country.  This is because most of the large scale systems that have been
implemented have been located in densely populated, urban areas with ample
supplies of solid waste.  Therefore, it has not been required that out-
lying communities' tonnage be recruited, or when cost sharing did take
place, the arrangement has been such that each community could pay its own
transport costs.  There are, however, precedents for transportation cost
sharing in Europe, specifically in Paris and London, where large scale
facilities (or even an "integrated" set of smaller facilities) require the
waste contribution of distant municipalities.  These two cities have taken
the view that part of the cost of refuse transport is related to disposal
and hence, a basis for sharing costs has been established.  In both cases,
the cost sharing formulae are determined by the distance involved in trans-
porting refuse from the end of the collection route to the processing facil-
ity.  Reductions in disposal fees are granted to those municipalities which
have to travel more than a given distance to the processing plant.
     In real  practice, and when a number of independent local jurisdictions
are considering the issue, the overall  question of cost sharing is possibly
even more complex than has been depicted above.  Consider, for example, the
overall transportation schematic shown  in Figure 3.  The lowest cost total
regional design involving a number of individual communities may result in
different modes of transportation for three groups of communities:
     1)   Those communities (Group A) that are near the facility
          and thus may proceed directly to it from the end of
          their collection route.  This is direct packer truck
          haul.
                                  -177-

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                                   -178-

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     2)   Those larger communities (Group B) located more distant
          from the facility which may be assigned a transfer sta-
          tion and haul system that is dedicated to them.  This
          is termed single community transfer haul.
     3)   Those smaller communities (Group C) also located more
          distant from the facility which may share in the use
          of a transfer station and haul system.  This is shared
          community transfer haul.
     Note that in this overall regional transfer system each community, from
a local government accounting standpoint, has two types of transportation
costs:
     1)   Those involving the existing packer (collection) trucks,
          and thus are a part of the current ongoing annual ap-
          propriation for refuse collection.  In the regional
          system these costs are probably handled in the normal
          manner regardless of whether city collection or contract
          collection is the current practice.  In a sense, these
          costs are relatively invisible.
     2)   New costs associated with the transfer station and
          transfer haul.  These are paid to the owner-operator of
          the transfer-haul system, a private contractor or another
          government agency.  These are highly visible costs.
     The result of this transportation system is that Group A communities
incur no new costs, but may incur a change in the amount of existing col-
lection costs resulting from a change in the distance to be traveled from
the end of the collection route to the facility.  Group B communities have
the new transfer haul cost elements to consider, and possibly some change,
most likely a slight reduction, in collection costs because of the more
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advantageous location of their transfer station.  Group C communities incur
new transfer-haul costs and possibly added collection costs to deliver solid
waste to the shared transfer station.
     From all this the important question to raise is -- how should trans-
portation costs be shared and what cost elements should be considered in
the sharing arrangement?  This is one of the questions that can send the
best regional plan into a tailspin.  For example, these are a sample of the
problems:
     t  The host community may not want to share transportation
        costs with outlying communities at all, and yet if it
        doesn't, the plan is not economically feasible for any
        community.
     •  Based on the particular sharing plan and the costs in-
        volved, it may appear that certain communities are get-
        ting preferential treatment since their new costs, which
        again are highly visible, may be much lower than that
        paid by other communities.  In fact, the new costs could
        even be negative resulting from a regional system plan
        which calls for a particular community to direct haul a
        much longer distance.
     •  Based on what it believes it is to pay for the regional
        disposal service each community must decide if it is to
        participate.  This is done by comparing the cost of re-
        gional disposal with the cost of its alternative dis-
        posal options.  Because of the complexity of the cost
        elements involved, it is quite possible for the wrong
        comparison to be made.  It is also possible for local
        officials to make the correct decision, but be unwill-
        ing or unable to follow through because of the complex-
        ity of the issue and, thus the difficulty of selling it
        politically.
                                  -180-

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     But perhaps the real issue concerns who is in charge; who is really
making the decisions?  The answer to that is determined by how the re-
gional thrust is organized and managed.

SOME COMMENTS ON REGIONAL ORGANIZATION
     Experience has aptly demonstrated that voters are not moved by the
arguments of economies of scale, efficiency, and regionalization.  Metro-
politan plans have been defeated at the polls time after time.  Fragmented
metropolitan government is the result of fear of loss of power, prestige,
and responsibility, as well as a genuine concern that a regional body may
become more concerned about itself than its member units.  It is also the
result, in large part, to the values and life styles of families which
have moved to the suburbs.  This is a political fact of life that must be
reckoned with; the potential for regionalization, how one goes about it,
and what form is to be sought are all tied up in the political situation
unique to the area.
     The simplest regional mechanism to consider for resource recovery is
the intergovernmental  agreement in which one jurisdiction agrees to deliver
a service to another for a stipulated fee.   The advantage to this mechanism
is that it bypasses the need for organizational changes.   Another version
of this arrangement exists when a private company is to own and operate the
facility on a full service basis under a franchise arrangement with the
host or sponsoring community.   Refuse delivery and disposal agreements,
with this arrangement, exist between communities and the  private operator,
not the sponsoring community.   Because of a lack of experience with this,
communities seem unable to distinguish between the two arrangements.   But
there is an important difference indeed, since in one case a community must
perform, and in the other a private firm must perform!
     Other regional arrangements are much more complex than the inter-
local  agreement or private contract since they involve the creation of
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authorities, or special districts, or assigning the responsibility to an
existing regional body such as a county, Council  of Government, or state.
     Each regional  approach involves a unique assignment of responsibili-
ties and risks.  It is important to consider how the issues of siting,
contracting, and cost sharing are to be treated under each that is con-
sidered so that the arrangement is fair and equitable for all participants.

CONCLUSIONS
     There is no doubt that regionalism in resource recovery is important
to progress.  We certainly cannot afford to conclude that regionalization
is too difficult to consider, and thus assume that we will have some 18,000
small scale systems to replace landfills in existence today.  Nor is it
useful to assume that local governments will somehow be able to decide what
is best and act accordingly.  We must worry about the piecemeal approach to
resource recovery implementation in which a few communities implement pro-
jects for themselves leaving the surrounding communities without an econom-
ically viable solution.  Every community in the nation must have an economic
and environmentally sound means for solid waste disposal.  States must ac-
cept the responsibility to see that this occurs, but they must recognize and
cope with the issues discussed in this paper:  markets, siting, waste volume,
traffic, environmental impacts, and cost apportionment among local jurisdic-
tions.  This requires that states engage in rather sophisticated and detail-
ed economic planning to determine which jurisdictions should regionalize.
They must begin to understand the economic consequences in total and the
                                                                *
impact on each community of various siting and transport options .  Subtitle
D of the new Resource Conservation and Recovery Act of 1976 (PL 94-580)
recognizes this need and provides guidelines for starting the planning pro-
cess.
 In many cases the economic tradeoffs involved in such planning cannot be
 evaluated intuitively.  Computer models are available to aid in such
 planning.
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     In each state and in each local sftuation we eventually must come face
to face with the questions about mandatory participation in a regional pro-
ject.  Should the state, or a substate regional body, require communities
to transport and deliver their waste according to a plan, or should communi-
ties' participation be optional.  The answer is not at all clear.  States
must have strong, well managed programs and the fiscal, institutional, and
regulatory tools needed for implementation, but communities that can suc-
cessfully solve their solid waste problem within their boundaries should be
permitted to do so.
     It is more important than ever that efficient resource recovery systems
at both the large and small scale are available.  For many communities re-
gionalization will not be the answer.  For others a network of smaller facil-
ities will be preferred over a centralized system.
     It is quite clear that there is a much larger role for private industry
in resource recovery that in other municipal  service areas.  The role in-
cludes operation of resource recovery facilities, as well as collection and
transport operations.  Under this arrangement communities must realize that
in a regional project they may be contracting with a private firm,  not an-
other community, and so the traditional fears of regionalization may not be
relevant.  They should concern themselves with the wording of the contract
and not their long standing dislike and fear of the host community.
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                 DESIGN AND OPERATION OF THE PUROX
                    SYSTEM DEMONSTRATION PLANT
                            C.T.  Moses
                            J.R.  Rivero
                           Linde  Division
                     Union Carbide Corporation
       The PUROX System is a refuse processing plant which converts a low
quality, environmentally undesirable material into desirable products.  Munici-
pal refuse is converted into a clean burning, low sulfur fuel gas; an inert,
glassy aggregate; scrap iron for recycling; and a wastewater stream that has
been cleaned to existing discharge standards.  This conversion is accomplished
by gasifying the organic fraction of the refuse and slagging the inorganic material.
Water from the gasification is removed  from the gas stream and treated to required
standards.  The glassy aggregate that  is produced is an inert, non-leaching
material.  The  ferrous material in the refuse is removed after shredding by
magnetic separation.  The organic fraction is gasified to fuel gas.
       This paper will present a detailed process description of the 200 ton/day
PUROX System  demonstration plant in South Charleston,  West Virginia.  Equip-
ment description and product stream analyses are also included.
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SECTION I.  INTRODUCTION
       The development of the  PUROX System technology began In the Union
Carbide laboratories in  the late sixties with fundamental investigations into
the gasification of refuse.  As a result of these theoretical studies and  bench
scale demonstrations, the basic PUROX System technology, the gasification of
refuse in a vertical shaft furnace utilizing pure oxygen, was developed. The
initial development of the concept was carried out in a 5 ton per day pilot furnace
which was built and operated in the Union Carbide Technical Center in
Tarrytown, New York.  A history of the early  development of the process and a
general description of the operation of the pilot unit were presented in a paper
given by Dr. I. E. Anderson, the inventor of  the process, at the 1974 National
Incinerator Conference.    The successful operation of the unit resulted in the
conceptual design and economic evaluation of commercial scale PUROX System
plants. The favorable results of these initial evaluations led to the decision
by Union Carbide to finance and construct a  200 ton per day  full scale prototype
plant in South Charleston, West Virginia. Operation of the demonstration plant
began in April, 1974. Initial operation of this plant was described in a paper
                                                                        (21
presented in September, 1975 at the  80th National Meeting of the A.I.Ch.E.
       A schematic drawing showing  the basic operation of the shaft furnace is
presented in Figure 1.   Refuse is contacted countercurrently with hot gas
from the combustion reaction occurring in the hearth.  The hot gas transfers heat
to the refuse ,  and  the  gas  is  cooled in the process.   As  the solids
proceed down the shaft  they are heated by contacting  progressively hotter gas.
Initially,  as drying of the solid occurs, free  water in the refuse is vaporized.
As temperatures in the solid continue to rise, gasification of the organic portion
of the refuse begins to occur by pyrolytic reactions.   These reactions convert
from 50 to 60% of the original weight  of the refuse to gaseous products.  The
pyrolytic residue, which consists  of non-volatilizable carbonaceous material,
and the inorganic  portion of the refuse, is consumed in the hearth in a combustion
reaction with pure oxygen.  The oxygen  reacts with the carbonaceous fraction of
the char to liberate the  energy required to melt the inorganic materials into  a
                                   -185-

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fluid slag product.  The hot gases from this combustion reaction also provide
the energy to carry out the  drying and pyrolysis reactions in the  upper shaft.
       The details of the pyrolytic reactions  and the rates at which these
reactions proceed are extremely complex.  However, some msight into the
fundamental effects occurring in the converter can be obtained by considering
the gasification process to be operating in a heat controlled manner. The
drying,  slag formation,  and generally speaking, the pyrolysis reactions all
require that energy be supplied to carry them  out.  This energy must be supplied
by the char-oxygen reactions in the hearth.  If the organic portion of the char
is taken  to be essentially carbon, the char can react with oxygen in either of
two basic reactions which liberate energy:
               Reaction              Heat of Combustion
       (1) C  + 1/2 02 -» CO         3,950 Btu/lb carbon   2,960 Btu/lb oxygen
       (2) C  + 02 -»• C02            14,090 Btu/lb carbon  5,280 Btu/lb oxygen
If all the energy required for gasification and slagging  could be  supplied via
reaction  (1),  the energy yield of fuel gas per  unit of refuse processed would be
maximum.  In  practice,  using typical municipal refuse  with a nominal heating
value of 5,000 Btu/lb and a carbon, hydrogen, oxygen  composition approximately
that of cellulose, about 1/4 of  the incoming carbon is  found in the product gas
as C02.   The  conversion  of the  carbon  to  CO will not provide sufficient
energy for the gasification and slagging  requirements.   There are other
reactions which can affect the C02 level in the product gas; however, the carbon-
oxygen reactions are the primary source of energy for the conversion process.  It
has been shown that the oxygen required to convert refuse into gas and slag is
about 20% by weight of the refuse ot composition similar to that described below.

SECTION II.  PROCESS DESCRIPTION - 200 Ton Per Day Demonstration Plant
       The PUROX System  consists of the  following components: a front-end
refuse receiving and preparation system, a refuse gasifying system, an offgas
cleaning system, and auxiliary systems including an oxygen generating plant,
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a wastewater treatment system,  and a product gas compression and distribution
system.  Since one of the primary functions of the PUROX System plant might be
to provide a continuous supply of fuel gas to a municipal or industrial user, 24
hour per day, 7 day per week plant  operation is required. Figure 2 presents a
process view of the 200 ton per day demonstration plant  in South Charleston,
West Virginia.
       The processing of refuse in  the PUROX System plant begins in the refuse
receiving and storage building.  The purpose of this building is  to provide  one
day's inventory of refuse  at the  system's rated capacity  of 200 tons per day.
This storage is provided by a building 80 feet by  70 feet with a  12 foot concrete
wall on three sides to provide protection for the  structure during the refuse piling
operation.  Refuse is brought to the plant in conventional packer trucks, dis-
charged directly onto the  floor of the building, and piled against the concrete
walls using a Caterpillar  model  950 front loader.
       The front loader is used to carry refuse into the system for further
processing and to manage the refuse inventory.  The front loader loads about
one ton of material in its  bucket and conveys it to the  scale for  weighing and
discharge into the processing  system (see Figure 2 for PUROX System Schematic).
The scale used for weighing the front loader and its load is a Toledo model 820
full load cell platform scale with a  model 8130 digital  indicator.  It can  weigh
in a range from 0 to 40,000 pounds  in 20 pound increments.  The refuse entering
the system has a composition  similar to that indicated in Tables I  and II showing
component and ultimate analyses for typical municipal refuse.
       After weighing, the refuse Is dumped onto a conveyor which transports
the material to the shredder. The conveyor is a three foot wide  apron  conveyor
installed at a 45° angle with respect to grade. The shredder is  a  Heil (Tollemache)
vertical shaft hammermill equipped  with a 200 hp electric motor.  It is rated at
15 tons per hour shredding capacity.  Significant overcapacity is required  in the
shredder to allow a reserve for mechanical problems in the feed  system as  well
as routine maintenance.   Since the  PUROX System operation runs 24 hours  per day,
                                  -187-

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seven days per week, hammers can be run at most a few days before resurfacing
is required.  Wear surfaces on the interior of the shredder must also be built up
periodically.  The net effect of these requirements is that in the South Charleston
PUROX System operation 2-3 hours per day are required for maintenance on the
shredder.
       The overall control of the feed system rests with the feed system operator
who takes action in response to the requirement for fresh material by the converter.
In addition, there are several automatic control circuits built into the system to
prevent improper operation.  One of these control circuits provides overload pro-
tection for the shredder by stopping the feed conveyor whenever the amperage
drawn by the shredder motor reaches a set level. This allows the shredder to
continue grinding its charge without increasing its load by adding new material.
Once the material has been processed sufficiently to allow the load on the
shredder to drop below the overload condition, operation of the feed conveyor
resumes as control is returned to the  operator.
       In addition to the overload circuit described above,  the  shredder
is also equipped with an interlocked control circuit.  This control circuit
requires  that both the blower cooling the shredder drive motor and the
discharge belt conveyor for carrying material away from the shredder be
operating before the  shredder can be run.  This circuit ensures that the
shredder will not be  choked by discharging material or that its drive motor
will not overheat. If either of these conditions  occur, the shredder is
automatically shut down. The shredder is  also equipped with a restart
limiting timer which  prevents restarting the motor more than once per hour
to protect it from overheating.
        The discharge conveyor from the shredder is a high-speed, rubber-
belted device which transports material from the shredder to the feed conveyor
for the converter. As the shredded refuse travels along the belt conveyer, it
passes  through a magnetic separator which removes ferrous material.  The
magnet  picks up pieces of iron in the shredded refuse stream and discharges
                                    -188-

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it onto a second belt conveyor which runs perpendicular to the shredder dis-
charge conveyor.  The shredded, magnetically separated refuse has a composition
similar to that given in Table III.
       The shredded,  ferrous-free refuse is dropped from the belt discharge
conveyor onto a second apron conveyor for transport to the feeder.  The feeder
acts as an interface between the front-end refuse processing systems and the
converter where the refuse is consumed.  The mission of the feeder is two-fold.
It introduces the refuse into the converter and provides  a gas tight seal for  the
system.
       Once the refuse is in the converter, it is contacted countercurrently
with hot gas  produced  from combustion in the hearth. As the refuse passes
down the shaft and is contacted with hotter and hotter gas,  it undergoes
several reactions.  First, near  the top of the converter, free moisture is
driven off. As the temperature  of the gas at the surface of the refuse increases,
pyrolysis of the refuse begins to occur.  In these pyrolysis reactions, the
cellulosic material in refuse  is broken down into smaller molecular fragments
which contribute to the final gas composition.  At the same time, hot gas
from the combustion of char in the hearth undergoes shift and carbonization
reactions which reduce the amount of C02 in  the gas while forming CO and H2 .
The complex  mixture of gases and refuse undergoes a variety of reactions
leading to the final offgas composition as indicated in Table IV. The offgas
typically exits the converter  at 200 to 600°F  with a wet bulb temperature of
170-180°F.
       The hearth operation is  carried out at a temperature of about 3,000°F
in order to slag the inorganic portion of the refuse and combust the char residue
of pyrolysis.  To maintain this  condition requires refractory linings with service
temperatures well in excess of  3,000°F and a high resistance to slag corrosion.
Extensive operating experience has shown that standard refractory  and water
cooling on the  exterior shell  is sufficient to form and maintain a protective
slag "skull"  on the inside refractory surfaces.  The molten slag pours from  the
                                  -189-

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hearth into a water quench tank.  After quenching, the slag is withdrawn from
the bottom of the quench tank using a drag conveyor which deposits the slag in
a dumpster for removal.  The composition of the slag stream leaving the con-
verter is given in Table V. As can be seen from Table V,  the slag residue has
a bulk composition very similar to that of soda-lime or bottle glass which is
its main constituent.   Most of the inorganic materials in the refuse become
bound in the glassy slag.  Leaching tests have been conducted on the slag
using both acidic and pH  7 water. The results of these tests indicate that the
trace metal contaminants  do not leach from the slag sufficiently to create an
environmental hazard.   Table VI presents a comparison of leachate water
quality  obtained from 6-day percolation tests in a bed of  pure PUROX System
slag with U.S. Public Health Service recommended drinking water standards.
These results show that the slag  leachate compares favorably with drinking
water quality indicating that potentially leachable materials are well bound
in the glassy slag.  Table VII presents a comparison among 6-day leachate
samples from a pure  slag  sample  and  two different blends of slag and soil
that might be encountered in a landfilling operation.  The changes in leachate
quality  can essentially be attributed to the soil components themselves.
        While the inorganic fraction of the refuse exits as a molten stream
from the converter,  the organic fraction is converted into a fuel gas which
is further processed  in a gas cleaning system.  Particulate matter is collected
using a water scrubbing system followed by electrostatic precipitation.  The
material collected in  both of these units is recycled to the converter for gasi-
fication or slagging.  After gas cleaning, the offgas is cooled to 100T in a
condenser to remove wastewater  prior to the end use of the gas. Following
this step, the gas in  the demonstration plant is simply flared  as in Figure 2
since there is no user available.  In  a commercial plant,  a gas  ccmpression
and distribution system would handle the gas.
                                 -190-

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SECTION III.  SUMMARY OF OPERATIONS

       The 200 ton per day PUROX System demonstration plant has undergone
extensive testing since construction was completed in April,  1974.  While
it initially operated on as-received refuse, in late 1974, the  plant was modified
by the installation of shredding and magnetic separation equipment.
       More than 10,000 tons of refuse have been successfully processed through
the facility.  The main purpose of the plant was to develop and optimize the cost
and performance of a commercial-scale system.  Most of the  test runs were of
relatively short duration (about 1 to 3 weeks). These runs  provided data to
evaluate specific modifications or  operating conditions aimed at optimization
of the commercial process.  Additionally, an extended run was conducted for
the purpose of establishing system reliability.  During  the  three-month-long
run, about 7,000 tons of refuse were processed, with a demonstration system
reliability of about 93%.
                                -191-

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                 Table I: Component Analysis of Refuse
                                               Range (Wt.
Wet Basis
Paper
Food
Yard
Wood
Plastic
Textile
Rubber & Leather
Glass
Ferrous Metal
Nonferrous Metal
Dirt and Ash
Wt. %
38
20
13
3
1
1
1
11
7
1
4
(Moisture included in above)  26%
                                                  25-60
                                                  10-30
                                                  10-20
                                                   2-4
                                                0.5-2
                                                0.5-4
                                                0.5-3
                                                   5-25
                                                   5-9
                                                0.2-1
                                                   1-6
                             100%
                                -192-

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    Table II: Ultimate Analysis of As-Received Refuse
        Component
           H2°
           C
           H
           O
           N
           S
           Cl
           Metal
           Glass
           Ash
Weight %
  26.0
  25.9
   3.6
  19.9
   0.47
   0.10
   0.13
   8.0
   11.0
   4.9
 100.0
Higher Heating Value
  4992 Btu/lb.
                          -193-

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   Table III:  Ultimate Analysis of Shredded, Magnetically Separated Refuse*
               Component               Weight %
                  H20                    27.9
                  C                       27.7
                  H                        3.8
                  O                       21.2
                  N                        0.5
                  S                        0.11
                  Cl                       0.14
                  Metal                    1.7
                  Glass                   11.8
                  Ash                      5.2
                                         100.0

                  Higher Heating Value = 5140 Btu/lb
* Based on
        a) 90% removal of magnetic metal
        b) 10% non-metal in removed stream
        c) 15% removal of non-magnetic metal due to attachment
                                -194-

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       Table IV:  SUMMARY OF PUROX SYSTEM
FUEL

GAS ANALYSIS at 60 «F, 1
H2
CO
co2
CH.
4
C H
2 2
C,H.
2 4
C0H_
2 6
HH.
3 6
C3H8
C
4
C5
C H
6 6
C7H8
V
N2
Ar
°2
H2S
CH OH
ORGANIC VAPORS*
H20
GAS CHARACTERISTICS
C
atm. TYPICAL
23.6
38.3
23.6
5.9

0.7

2.06

0.3

0.3

0.2
0.5

0.4
0.3

0.1
0.2
1.0
0.5
0.1
0.05
0.1
0.15
1.64

& VOLUME
RANGE
21-23
29-42
20-34
4-7

0.2-1.5

1-3

0.1-0.5

0.02-0.7

0.1-0.6
0.1-0.8

0.1-0.6
0.1-0.6

0.05-0.15
0.1-0.7
0-1. S
0-0.5
0-0.2
.02-. 06
0.05-0.15
0.1-0.4
1-2
*Hlgher alcohols, aldehydes, ketones, organic acids



                         -195-

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           TABLE V
PUROX SYSTEM RESIDUE ANALYSES
Major Components
Silicon
Aluminum
Calcium
Sodium
Iron
Magnesium
Potassium
Phosphorous
Titanium
Manganese

Trace Compounds -
Barium
Copper
Zirconium
Strontium
Chromium
Lead
Tin
Nickel
Zinc
Vanadium
Cobalt
Silver
Molybdenum
Antimony
Berrylium
Sulfur
Chlorine

- Weight %, Expressed as Oxide
59.7 57-62
10.5 9-13
10.3 9-12
8.0 7-10
6.2 1-8
2.2 1-4
1.0
0.8
0.6
0.3
99.6
ppm
1000-3000
500-3000
300-1000
200-400
100-400
50-300
50-300
50-250
50-250
25-80
15-40
5-30
10
3-10
5
1000-3000
5000 - 10,000
-196-

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                            TABLE VI
        WATER QUALITY OF PUROX SYSTEM SIAG LEACHATE
Pure Slag
T.par.hatp
Material
Total Acid
Total Alka.
BOD
COD
Chloride
Cyanide
Fluoride
Aluminum
Arsenic
Barium
Cadmium
Calcium
Chromium
Copper
Iron
Lead
Selenium
Silver
Sodium
Zinc
Nitrate
Diss. Sol.
Sulfate
Sulfide
Manganese
(ppm)
10
20
0
5
12
0
0
<0
<0
<0
<0
2
<0
<0
0
0
<0
<0
1
<0
<0
27
1
<0
0
.7
.0
.93
.0
.0
.001
.03
.8
.01
.1
.001
.1
.01
.1
.33
.07
.01
.02
.10
.05
.2
.0
.3
.02
.02
U.S.P.H.S.
Limit


0
1

0
1
0

0


0
0
0









.2
.6-3.4*

.05
.0
.01

.05


.05
.01
.05







U.S.P.H.S.
Re comme nde d
Level

250
0
0

0




1
0




5
45

250

0


.01
.8-1.7

.01




.0
.3




.0
.0



.05
*Fluoride concentration is temperature dependent
                              -197-

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                             TABL2VII
Material

Total Acid
Total Alka
BOD
COD
Chloride
Cyanide
Fluoride
Aluminum
Arsenic
Barium
Cadmium
Calcium
Chromium
Copper
Iron
Lead
Selenium
Silver
Sodium
Zinc
Nitrate
Diss. Sol.
Sulfate
Sulfide
Manganese
SLAG + SOIL
Pure Slag
Leachate
(ppm)
10.7
20.0
0.93
5.0
12.0
0.001
0.03
0.08
0.01
0.01
0.001
2.1
0.01
0.1
0.33
0.07
0.01
0.02
1.10
0.05
0.2
27.0
1.3
0.02
0.02
INTERACTIONS
Slag Cont.
Silt + Slag
System
5.6
8.6
0.4
12.0
8.3
0.001
0.01
3.9
0.01
0.13
0.001
1.6
0.01
0.1
7.3
0.05
0.01
0.02
2.6
0.17
0.2
13.0
10.0
0.02
0.14
Slag Cont.
Silt + Slag
System

16.0
 7.9
 0
 9
 3.6
 0.001
 0.04
 3.8
 0.01
 0.1
 0.001
 3.0
 0.01
 0.1
 7.2
 0.05
 0.01
 0.02
 1.5
 0.05
 0.23
26.7
 2.7
 0.02
 0.02
                                 -198-

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                     REFERENCES
1.     Anderson, I.E., Proceedings of the 1974 National
       ASME Conference, Incinerator Division,  p. 337,
       April, 1974.

2.     Fisher, T.F., Kasbohm, M.L., and Rivero, J.R.,
       A.I.Ch.E. 80th National Meeting, September, 1975.

3.     Water Quality Criteria, 2nd Ed.,  June 1, 1974,
       State of California, p.  89.
                          -199-

-------
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                                  -200-

-------
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                                           -2P1-

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                 RESCO - FIRST YEAR OF OPERATIONS

                       John H. Kehoe, Jr.
                 Vice President -  General Manager
                     Energy Systems Division
                     Wheelabrator-Frye,  Inc.
     Our RESCO facility in Saugus, Massachusetts,  is  a  1200  tori

per day waste disposal system and power plant.  Wo placed  it into

operation in September, 1975, and began  delivering steam  to

General Electric on November 15, 1975.

     Our first year of operation has  been devoted  to  the  sequential

start-up and shakedown of the two  750 ton per day  boilers.   During

this start-up period we have  processed in  excess  of  250,000 tons

of refuse, produced over one billion  pounds of  steam,  and  recovered

an estimated 16,000 tons of ferrous metals.  We are currently

processing refuse at an average rate  of 800 tons per  day  and expect

to reach our capacity early next year.

     RESCO has proven to be an  environmentally  sound  operation.

The plant, operating at full capacity, has  surpassed  the  Massa-

chusetts air emission code of  .05  grains per SCF,  corrected to

12% coo'  Chemical and leachate analysis studies  have shown that

the plant's residue  is inert and will not  effect the surroundim,

marsh and shellfish environment.   The plant has operated completely

free of odor.  Noise recordings at the property lines are maintained

at less than 50 decibels.

     Research and development  programs conducted since the incep-

tion of operations have provided  us with  additional encouragement

that our  total recycling goal  is  achievable.   There are indications
                                  -202-

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that with further processing the ferrous metals can be upgraded


to a No. 1 quality.  The aluminum and non-ferrous metal content


has been estimated between  -5o to .7% concentration, and the tech-


nical feasibility of recovering a marketable product has been


demonstrated.  The aggregate residue has been found acceptable


for product applications, such as landfill cover, road base and


embankment fill, and for use in bituminous concrete and concrete


blocks.  Studies on its use in portland cement are encouraging


but as yet are not completed.


     At the present time, RESCO residue is being stored adjacent


to the plant site awaiting completion of studies to determine the


economic feasibility of recoverying non-ferrous metal and receipt

                                                              i-
of state approvals for its sale as a fill or aggregate material.


The land requirements for residue storage are approximately 3%


of that required to landfill the raw refuse from which it was


derived.



                            BACKGROUND


     Before discussing the RESCO operations in detail, I would


like to give you a brief understanding of the project organiza-


tion, the background experience upon which it is based, its


performance requirements, and structure of our energy and waste


disposal contracts.


     RESCO is operated as a joint venture between Wheelabrator-


Frye and M. DeMatteo Construction Company and organized as  "Refuse


Energy Systems Company."  The joint venture made  a substantial


equity contribution to the facility and arranged industrial revenue
                                  -203-

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bond financing for the debt portion of its investment.  No public




funds are committed or obligated to the project.




     System design and construction management were carried out




by The Rust Engineering Company, a wholly owned subsidiary of  Whoelabrator




Frye, and construction was undertaken by  M.  DcMntteo Construction Company.




     The plant design concept is based upon Wheelabrator's exclu-




sive U.S. license with Von Roll, Limited, of  Zurich, Switzerland.




It is the most advanced version of the over 120 Von Roll refuse-to-ener.gy




plants operating or under construction in Europe,  Australia,




Japan, ^nd Canada.  RESCO  is designed to meet more severe




environmental requirements and  a number  of specialized  demands




imposed  by site conditions and  unusual requirements  for reliability




and continuity of refuse acceptance and  steam production.  It'also




employs  several advanced design features  to enhance  cost  effective




and reliable  performance al  high  sLe^m  Li^inpt-jLaLuieb.




      Minimizing operating costs over  the  life of  the  plant were




considered essential  to  provide protection against inflation.




The  approximate  $40 million  capital  cost for  the  plant  recognizes




 these requirements  and  special  conditions.   It includes all  costs




 for  land,  maintenance,  shops,  roads,  weighing stations, vehicles,




 spare parts,  utilities,  and  a one-half  mile  pipeline and bridge




 system extending  across the  Saugus River to  the General Electric




 Company for  steam delivery,  condensatc  return, and electric  power.




      RESCO1s basic requirements are to accept an average of 1200




 tons per day of municipal and commercial refuse and deliver steam




 to General Electric at 625 psig and 825°F.  The plant  is operated
                                  -204-

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24 hours a day,  7 days a week.   Peak steam  delivery is 350,000# per




hour and not less than 65,000)'  per hour.   A minimum of 2.0 billion




pounds per year  of steam will be delivered to the customer.  The primary




uses of the steam are for electric power  production, processing,




and testing operations.




     Through close cooperation with General Electric, a long term




contract for the sale of steam to their Lynn River Works Plant was




consummated.  In addition, a combination of long and short term




contracts have been completed with eleven surrounding communities




and two districts of Boston for waste disposal services.




     Steam charges to General Electric are somewhat lower  than  their




cost to produce  steam from oil and will escalate or de-escalate with




variations in their oil prices.  The communities are charged a  base




disposal fee for each delivered ton of waste.  This fee is adjusted




annually at approximately 50 percent of the rate of change in a local




labor rate index.  Excessive increases in operating costs  or cKlc'c^




capital costs are absorbed by RESCO.





                           OPERATING EXPERIENCE




     The  success achieved in our  first year of operations  could




not have been accomplished without  the utilization  of  proven




experience  and  technology in the  design,  construction  and  start-up




phases  of  this  project.   Lvery basic subsystem  has proven




to be  operationally  sound and capable of  meeting  its  projected




life cycle.   This is  not to say  that operations  have  been




trouble free but reaffirms our  belief that  the  utilization of a




proven technology and  system design is essential  to avoid  the




 risk of excessive overruns  in capital and operating expenses.
                                  -205-

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Priorities




     Our first and primary r'esponsibility at RESCO is to provide an



environmentally sound and reliable disposal service to the communities



we serve.  To date, not one truck has been diverted to an alternate



disposal site.



     Secondly, the plant's steam production will permanently



replace approximately 40% of General Electric's required steam



generating capacity.  G.E. employs over 13,000 people at the Lynn



Plant, and continuous steam flow from RESCO will be essential



to insure normal operations.  Each refuse boiler and the two



back-up package boilers have achieved rated steam capacity and



steam quality specifications under full load operating condition!;.



Final tuning and control modifications should be completed by



year end, and G.E.'s transition to full dependency on RESCO steam



is expected to go  smoothly.



     These services must be provided in an environmentally sound



manner.   As mentioned earlier, RESCO has met and surpassed the



Commonwealth of Massachusetts and Federal  environmetnal  regulations.



     Finally,  there  is  a  strong commitment to  the  separation and



recovery of material resources from  the system's post-combustive



residue.   The  original  plant design  incorporated a capability  to



physically separate  ferrous metals.  At  the  time the  plant was



being  designed,  through construction and  after the  first year  of



 operations,  we have seen  no economically.viable recovery technology



 developed for the aluminmu,  non-ferrous  metals,  and  glass produce:d



 by the system.  We have seen the technical feasibility of recovering



 and upgrading these material resources however, and  are presently
                                    -206-

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evaluating the economics of recovery system designs and trying to develop




firm market commitments.  Based upon our present knowledge, we do not




anticipate these products generating more than S3 per ton of refuse




in net revenues unless there are significant increases and stabilization




in their market values.








                           PLANT DESCRIPTION




     The following discussion combines our specific operating




experiences with a physical description of the operating areas




of the facility.






Refuse Receiving and Handling Area




     This area of the plant incorporates the weighing station at the




entrance to the plant,  the queuing and receiving areas for the trucks,




the  storage pit for the refuse, the refuse mixing and furnace




loading operations, and the shredder plant.  All refuse trucks entering




and  leaving the plant must cross the semi-automatic  scales.  Tare




weight cards  are maintained on each municipal truck  to avoid delays.




The  reception area allows  adequate  turnaround and waiting space for




several trucks.  Sixteen  outloading bays are provided for  approximately




250  trucks per  day.  The  average turnaround time for each  truck has




been between  five and  seven minutes.  The  traffic  flow patterns




designed  into the plant operations have  proven  to be highly  efficient.




     The  refuse storage pit is  35' wide, 95' high,  and 200'  long and




has  a  capacity to hold over 6,000  tons  of  refuse.   The refuse mi' -




ing  and  loading is  handled by  two  overhead cranes which  have a refuse




 lifting  capacity  of approximately  3  tons per  load.   Initially, the



heavy  duty placed upon the  cranes  caused considerable  cable  and  brake
                                   -207-

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wear.  Changes in the operating control system enabled us to correct



the problem and achieve acceptable performance.



     The shredder is a 50 ton per hour, 1000 horsepower hammermill



installation.  Our original intent was to shred bulky metals, such as.



refrigerators, stoves, water tanks, etc.,  and large combustible itenis



such as sofas, tree trunks, etc.  The shredder operation has been



reduced to one day per month and only for bulky combustibles that would



normally require more than one hour retention time in the furnace for



complete energy conversion.  The furnace opening is 22' long and 4' wide



and  has proven to be sufficiently large to process all of the bulky metals



received without preprocessing.



     This inherent flexibility in the design has enabled us to eliminate



the  costly expense of operating and maintaining the shredder.  Based



upon the variation in bulky material delivered to RESCO over the last



year, we are  becoming convinced that future plants can be built without



the  need of  a shredder.








                            REFUSE COMBUSTION AREA



     Refuse  received  from  the  fecdhoppers  is burned on a Whcclabrator/



Von  Roll reciprocating  qrate  system without  the use of auxiliary  fuel.



 In addition  to the grates,  this  area  also  incorporates the  auxiliary



equipment which  automatically  controls the grate  speeds  and air distri-



bution.  The grate system  consists of  three  independently  controlled



grates separated by steps  over which  refuse tumbles  to provide complete



 combustion.   The first or  feed grate  controls the rate  at  which refuse



 is fed.   The second or combustion grate is maintained at a  speed  which



 will insure  an estimated 901 of the  combustion.   The  last  grate is the



 burnout grate which is controlled to insure the  completion of the



 combustion process and partial cooling of the inert residue.
                                   -208-

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     Combustion gas temperatures arc maintained in the range of 1600 -




1800T, which is sufficiently high to dcstoy odors.  Combustion and




overfire air systems are integrated with individual grate speed controls




to provide uniform and stable energy production from changing refuse




compositions while insuring complete burnout.




     Some recent design improvement incorporated at RESCO permit the




direct combustion of unpreprocessed municipal refuse at the higher




steam temperatures needed to achieve efficient electric generation.




They include air jets positioned to introduce air along the side walls




and under the stepped grate systems .  The air system provides protection




against corrosion that might occur  in the presence of reducing atmospheres,




limit slag buildup on the side walls, and add to the gas turbulence needed




to minimize hot spots on the furnace walls and boiler tubes.




     As is the case in any major plant start-up we encountered problems.




However, only two start-up problems were cause for concern.  These




problems included a failure in the  sliding grate shoe support shoes caused




by a departure in the specified metallurgy and unevenncss in the




hydraulic grate drives.  Remedial actions were identified,  modifications




made,  the problems disappeared.








                      STEAM PRODUCTION  (BOILER)AREA




     The  steam production area  incorporates  the most advanced design




in refuse boilers.  This design has evolved  from over  20 years and




4 million hours of operating experience with the Von  Roll  technology.




Also  included  ij  the  radiation  or water wall section of  the boiler  which




is located  in  the  furance area  and  is of a  conventional  design.




      The  hot  flue  gases  from the  furnace pass through  three convection




 sections which  transfer  the  heat  to produce  superheated  steam.   These
                                  -209-

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sections arc designated as the economizer,  evaporator,  and superheater.




Vertical pendant hung boiler tubes are constructed and  specially




designed with a mechanical rapping mechanism.




     The convection passes include economizer, evaporator and super-




heater sections.  Each section is constructed with pendant boiler tubes




which are equipped with specially designed boiler tube rapping mechanisms




to remove dust and scale from the tube surfaces.  This  unique cleaning




system enables the tubes to retain the protective oxide layer that is




normally removed when soot blower or steel shot is used for cleaning.




Recent European experience has demonstrated the effectiveness of this




cleaning system by eliminating shutdowns for tube cleaning.




     An automatic temperature regulatory system provides uniform steam




flow at full capacity without exceeding temperature ]imits as tho




heat contact of refuse varies.  These and other advancements combine




to promote  reliability and provide boiler availability percentages




in the same range as utility boilers  fired by  fossil fuel.




     The problems encountered in  this area of  the plant are  corrosion




of tube metal wastage.  Fortunately,  from our  experience with Von  Rol I 's




plants  in  Europe, we have been fully  aware of  the potential  for  corrc •-1 •




and  incorporated a boiler specifically  designed for  the combustion of




refuse.   With  the  knowledge we have gained about  solid waste and our




anticipated modificaitons, we believe we have  the fix.




      Before going  on, there are  two points I'd like  to make:




      1)   If you are  going to  burn refuse  and produce steam at  high pressure:




 and  temperatures you are  going  to have  corrosion.   You  arc not  going to




 control it by removing PVC's.   There  are  a myriad of other elements in




 municipal waste that contribute  to corrosion.
                                   -210-

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    • 2 )  Conventional boilers arc designed to burn homogeneous conventional




fuels.  Refuse is not a homogeneous fuel nor do you control its chemical




composition by preprocessing it to remove  non-combustibles.








     A few faulty welds in the pressurized section of the boilers,  insuf-




ficient shielding, a need for improved metallurgy in a portion of the




superheater exposed to direct radiation, and a failure of a steam




temperature controller represent the extent of difficulties encountered.




With few exceptions, all modifications have been completed.





                       AIR POLLUTION CONTROL AREA




     Air emissions from the plant are controlled by Wheelabrator/Lurgi




electrostatic precipitators, and emissions emitted to the atmosphere




through a 178 foot masonry stack.  The precipitators are operating at




approximately 99 percent efficiency.  This has permitted the system




to  surpass the local particulate emission requirements of  .05 grcins per




standard cubic foot, corrected to 12% CO,,.  Each precipitator handles




240,000 cuff/min. of flue gas at 425°F.  We have experienced no operating




problems in this area.





                  MATERIAL SEPARATION AND RECOVERY AREA




     This area begins with the collection of fly ash from boiler




and precipitator hoppers, riddlings and grate  siftings, and residue




from  the burnout grate.  These residues are presently transported




to  a  common and  redundant water  quenching and  washing system.  The




system  is continuously  neutralized to a pH of  approximately 7.   In




addition to cooling  the residue,  it removes  soluble   salts which could




be  an environmental  nuisance.  As  the residue  settles to  the bottom  of




the quenching system,  it  is  removed by  a  drag  chain conveyor which trans-




ports it to  the material recovery building.
                                   -211-

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     The material recovery system consists of a rotary trommel screen




with two inch holes, magnetic separators,  and appropriate conveying




and collection systems.




     The plus two inch material is classified as the bulky metal residue




and has a ferrous metal content of approximately 60%.  The minus two




inch material falling through the screen is conveyed to a permanent




magnet separator which collects the fine ferrous metals.  The ferrous




metal recovered represents approximately 7.5% by weight of the incoming




refuse, and the fine ferrous fraction is estimated to be 20% of the total




ferrous product recovered.  Both fractions are presently sold to a local




secondary market under short term contracts.




     The remaining  residue is aggregate material which contains the




glass and approximately a 2% concentration other non-ferrous me'tals.




Chemical and  leachate  analysis studies show  that the aggregate is  inert




and acceptable as a fill material.




     Research and development studies designed  to analyze  the




feasibility of upgrading the ferrous metals, of recovering a marketable




aluminum and  non-ferrous metal product, and  developing product applications




for  the aggregate are  all encouraging.




     Utilizing Wheelabrator  foundries, we  have  made  pig  iron  from  several




 samples of  the recovered  ferrous metals.   Working closely  with the major




 steel  companies, we have  made comparative  chemical  and metallurgical




 analysis.   The  results show, that  the  copper  content is  too high  for  No. 1




 grade  applications.  Further studies  have shown that copper  can  be




 separated  with  shredding  and further  magnetic  separation.  A program is




 underway  to determine economic  benefits  that can  be derived  from further




 processing to remove the  copper.
                                   -212-

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     Through size classification of  the aggregate,  we have produced




a 60%- aluminum and non-ferrous product which is salable.   In addition,




we are presently analyzing the small quantity of melted aluminum




product collected under the grates.   Although results to date look




favorable for aluminum recovery, there is the possibility that the




final recovery system requirements may make it economically impractical.




     The aggregate which comprises approximately 50% to 60% of the




residue from the plant has been successfully used in bituminous




concrete, decorative concrete for floorings and walls, and concrete block




applications.  It has also been proven acceptable as a road base and




embankment  fill material.  Research studies are continuing to expand




its product applications as a cement supplement and light weight




aggregate for construction.








                          COMMUNITY EXPERIENCES




     This status report on RESCO would not be complete without briefly




summarizing some of the benefits, other  than waste disposal, that  the




communities have received from  participation in the project.




     The  following benefits have  resulted  in a  reduction  of  collection




expenses which  in effect have reduced  their overall budgets  for waste




 collection  and  disposal.




         Because  no presorting or  separation  is  required at RESCO,



         the communities  have  been able to  combine  garbage, rubbish,




         and bulky  trash  collections into a  single  pickup  operation.




         RESCO routinely  supplies  to the  communities  scale weights  .




         on  each truck  delivery.  With this  data the  communities have



         been  able  to  reduce  the number of  collection  routes  and optimize




         loading of collection vehicles.
                                   -213-

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     Cost benefits have  been  derived  by  reduction  of  vehicular




requirements and shifting of  manpower to other  municipal  departments.








                               CONCLUSION




     The success we have achieved during the  first year of operations




at RESCO demonstrates,  on a commercial scale,  that refuse fired boilers




of this type can provide an environmentally sound  solution to the




municipal waste disposal problems facing the  urban areas of this country.




In addition, it demonstrates that private enterprise  can provide this




solution without tapping municipal, state or  federal  financial  or




taxing resources.



     However, it is only a partial solution.   There still is and will




be for many years to come a need for sanitary landfill for those wastes




generated that cannot be handled by resource recovery systems of all




kinds.
                                  -214-

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FEATURED ADDRESS

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                        FEATURED PRESENTATION

    FIFTH NATIONAL CONGRESS ON WASTE MANAGEMENT TECHNOLOGY
                                    AND
                     RESOURCE AND ENERGY RECOVERY
                       DALLAS, TEXAS - DECEMBER 1976

                                 PETER VARDY
                     VICE PRESIDENT-ENVIRONMENTAL
                    MANAGEMENT & TECHNICAL SERVICES
                         WASTE MANAGEMENT, INC.
    Welcome to the Fifth National Congress on Waste Management Technology and

Resource and Energy Recovery.  This is also the third Waste Management Technology

Conference co-sponsored by NSWMA's Institute of Waste Technology.

    As most of you will recall, the Institute of Waste Technology was established by

NSWMA's Board of Directors in the summer of 1974 in response to the Association's

expanding scope of activities and technical programs. The main purpose of the

Institute is to provide a national forum for technology assessment and planning for the

entire waste mamgement field.

    Through its three major member committees and two councils, the Institute has,

during the past two and one-half years, taken  a very active role in assisting government,

industry, members of NSWMA and its Legislative Planning Committee with technical

and planning expertise. The Chemical Waste, National  Sanitary Landfill and Industry

Resource Recovery Committees have reviewed and provided valuable  input into

legislation, regulations and technical information generated by Congress, the U.S.

Environmental Protection Agency, and state legislatures and regulatory agencies.

Through the varied activities of its committees, the Institute has also promoted the

development of new,  technically reliable,  economical and safe waste processing,

resource recovery  and disposal systems.



                                       -216-

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   Since my appointment as Chairman of the Institute in 1974, I have had the




privilege of working with many of you in Government, industry and the consulting




professions, and the opportunity to observe some rather profound changes in our




industry during this relatively short period of time.




   Permit me, at this time, to make a few brief and personal observations on




some of this industry's accomplishments and failures during the past two and




one-half years.




   During 1974, I said that there was a general feeling of euphoria concerning




developn _nt of resource recovery in this country and the great economic and




technical promise which it held for the solid waste management industry.  A




number of EPA-funded resource recovery demonstration projects were receiving




wide publicity and the construction of full-scale facilities was strongly en-




couraged by 'various government agencies.  This climate of extreme enthusiasm




generated immediate demands by a rather naive and misinformed public to eliminate




land as an acceptable sink for the disposal of residues and achieve, almost over-




night, total recovery from waste of material and energy resources.  Many




within and outside the solid waste industry were thus led to believe that




full-scale resource recovery, representing a new multi-billion dollor market




in equipment, facilities and services, was just around the corner.  In retro-




spect, of course, we recognize that such expectations were premature.




   By fall 1275, during our Fourth National Congress in Atlanta, the realities of




life have.become apparent and depression set in. The falacies of rapid scale-up;
                                     -217-

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the difficulties encountered in obtaining long-term financing on the strength of short-term,




fluctuating markets for recovered resources; serious difficulties encountered in the effective




control of waste; and the real impact on disposal fees of the  highly capital intensive




resource  recovery systems were reported by all who tried their hand at this new area of




opportunity.




    This year 1 sense that you will  find a very healthy spirit predominating at this




conference, a spirit which will be characterized by pragmatism and  cautious  optimism.




You will hear reports of some successes with full-scale facilities (information essential




to rational assessment of resource recovery alternatives), of communities moving  into




the area  of resource recovery cautiously and realistically, and of the readiness of the




financial community to fund such projects provided they are  approached in a business-




like and  responsible manner.




    The  Institute's  Industry Resource Recovery Committee, which has in its membership




eight of the country's leading systems and service companies in the solid waste management




field, has b?en very active in evaluating and disseminating information on all  aspects




of resource recovery systems, including waste processing technology, financing,  markets




for materials and energy products and peripheral  delivery and disposal system.  By




conducting roundtable seminars for  interested communities, assessing and disseminating




information on resource recovery projects around the country, and by providing continuing




technical assistance to government  and industry in  the promulgation of resource recovery




procurement and other implementation guidelines, the Committee is playing an important




and active role in promoting the advancement of responsible  and effective resource




recovery in this country.
                                         -218-

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     The Chemical Waste Committee,  in anticipation of overdue hazardous waste




legislation, regulation and enforcement has been actively engaged in the development




of a comprehensive Legislative Guide for a Statewide Hazardous Waste Management




Program.  This guide, incidentally, provides considerable background  material and




outlines the industry's version  of the guidelines which EPA must promulgate by Spring




1978 under the newly enacted P.L. 94-580. The Committee has also developed a model




manifest to complement the legislative guide and has been working closely with the




U.S. EPA Hazardous Wastes Management Division in reviewing and commenting on




the various studies undertaken by that division. During the coming year, the Committee




will be working on such projects as chemical landfill standards, monitoring requirements




for land disposal sites, the development of closure plans,  and perpetual care and long-




term responsibility problems associated with hazardous wastes.




     The newly enacted Resource Conservation  and Recovery Act of 1976 provides for




the establishment of a national hazardous waste management program under the auspices




of the  U.S. Environmental Protection Agency.  This law requires that,  within two years,




EPA must draft, promulgate and implement a comprehensive regulatory  program for




hazardous wastes affecting the generators, transporters, owners pnd operators of




chemical waste facilities.  The Chemical Waste Committee will continue its very




ambitious program of activities and will make the industry's experience  in this field




available to the U.S. EPA and states developing and implementing hazardous waste




management programs.




    At the 1974 San Francisco Conference, I had the pleasure of presenting a paper




entitled "Land Disposal: 1975-1990."  That presentation was made during a time when




resource recovery held center stage and, while I managed to stir  up some controversy
                                       -219-

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on that occasion, I had a strong feeling then that speaking out strongly for land




disposal was but a voice in the wilderness.  Two years have passed since that meeting




and a good measure of rationality has returned to the resource recovery area; yet, I




am sorry  to note that sanitary landfill is still the neglected stepchild of the waste disposal




field.




     I am sure that I need not project for you again the future role of land disposal.




There may be  disagreement as to whether materials and energy recovery, or other




waste conversion systems, could handle five,  ten or twenty per cent of the urban waste




generated ten years hence.  The fact remains that sanitary landfill is and will continue




tc be thg primary method of waste disposal in this  country at least through the end of




this century.  It is very disappointing that this simple fact  of life is not being communicated




to the public in clear and positive terms.




     In order that the sanitary landfill may properly fulfill  its important role  as a




primary, or even secondary, disposal system,  it is imperative that it regain a legitimate




status.  Thi? can only be accomplished with the full cooperation and  commitment of




the responsible federal and state agencies,  not only in the implementation of the provisions




of the Resource Conservation and Recovery  Act of 1976, but also in recognition of




government's responsibility — well in advance of the  timetable outlined in the Act —




to continue to provide reliable and environmentally acceptable disposal to land by




expediting the landfill permitting and approval process.




     With the help of government, we in the private sector can, and  indeed  must,




proceed  immediately to develop new, urgently needed land disposal sites, making




reasonable resource allocations and risk judgments and utilizing the best that today's




technology has to offer.  Delaying the establishment of new sites in anticipation of






                                         -220-

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new definitions and guidelines will prolong the existence of sub-standard or totally




unacceptable disposal facilities and will delay the development of in-field experience




which could lead to the promulgation of better and more realistic land disposal




guidelines and standards.




    The National Sanitary Landfill Committee has prepared a number of position




papers on varying important sanitary landfill subjects and has provided input to EPA




contract studies on landfill monitoring,  permitting and inspection. The Committee has




also embarked on a very ambitious program of  activities for the coming year which,  in




conjunction with  governmental  activities mandated by the Resource Conservation and




Recovery Act of 1976, should bring about renewed interest and substantial improvements




in sanitary  landfill design, development and operating practices.




    I would be remiss if I did not acknowledge the close and cooperative relationship




which the Institute of Waste Technology has developed with  the Association of State




and Territorial Solid Waste Management Officials and its past chairman Moses McCall.




We look forward to a continued close relationship with the State Solid Waste  Officials




in the years to come.




    As  the Resource Conservation and Recovery Act of 1976 moves into implementation,




we at the Institute of Waste Technology look forward to working closely with  the U.S.




EPA, the state agencies, and the Association of State and Territorial Solid Waste




Management Officials to accomplish the goals of the Act and make, what we hope




will be, a significant impact on future solid and hazardous waste management plans and




practices.




    I should like to take this opportunity to express my deep appreciation and gratitude




to the Institute's past and present council and committee chairmen: John Vanderveldt,




Wayne Trewhitt,  Sandy Hale, Don Shilesky, Gene Nesselson, Joe Ferrante and Jack



                                        -221-

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Lurcott, and the many dedicated and hard-working members of their committees, for




their tremendous contribution in time and effort to the Institute, the National Solid




Wastes Management Association and the entire industry.  I wish to express very




special thanks to Gene Wingerter and Jim Greco and their entire NSWMA staff for




giving so much of their time, energy, dedication and extraordinary talent to turn




the Institute of Waste Technology, in such a short time, into a most important,




visible, respected and effective arm of NSWMA and the industry as a whole.  They




have made my job not only an easy one, but a most  rewarding one.
                                        -222-

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LANDFILL AND CHEMICAL WASTES DISPOSAL

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                      SITE SELECTION FOR A CHEMICAL
                      WASTE LAND DISPOSAL FACILITY:
                        MINNESOTA'S EXPERIENCE
                          Robert A. Silvagni
                              Director
                        Division of Solid Wastes
                   Minnesota Pollution Control  Agency
BACKGROUND
        AS MANY OF  YOU KNOW,  MINNESOTA WAS SELECTED BY  ERA'S  OFFICE OF
SOLID WASTE TO CARRY  OUT ITS  CHEMICAL WASTE LAND DISPOSAL DEMONSTRATION
PROJECT.  THE FIVE  YEAR DEMONSTRATION WILL EXAMINE THE  ORGANIZATIONAL,
INSTITUTIONAL, TECHNICAL,  ECONOMIC, AND SOCIAL CONSIDERATIONS INVOLVED
IN ESTABLISHING AND MAINTAINING AN ENVIRONMENTALLY SECURE CHEMICAL
WASTE LAND DISPOSAL FACILITY.
        SPECIFICALLY,THE PROJECT WILL SEEK TO DEMONTRATE:
        3}  SITE  SELECTION METHODS;
        2)  SITE  PREPARATION  TECHNIQUES TO PREVENT 6ROUNDWATER
            INFILTRATION;
        3)  TECHNIQUES TO ADEQUATELY PREPARE WASTES FOR LAND  DISPOSAL;
        4)  MONITORING AND SURVEILLANCE METHODS;
        5}  SITE  MANAGEMENT TECHNIQUES INCLUDING WASTE  ANALYSIS,
            INVENTORY CONTROL, QUALITY CONTROL, AND COST ACCOUNT-
            ING PROCEDURES ;
        6^  LONG  TERM CARE, LIABILITY, AND LIABILITY  INSURANCE
            CONSIDERATIONS:
        7)  PUBLIC  EDUCATION  METHODS, and
        8)  INSTITUTIONAL REVIEW PROCEDURES,
                                    -224-

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        AT THE PRESENT TIME, THE PROJECT IS IN THE STEP ONE PHASE,
THE OBJECTIVE OF STEP ONE is TO PRODUCE A PRELIMINARY FACILITY PLAN.
THIS PLAN WILL INCLUDE THE SITE SELECTION METHODOLOGY, THE RESULTS OF
THE INITIAL PHASES OF SITE SELECTION, WASTE CHARACTERIZATION STUDIES, AND
A CONCPPTUAL FACILITY DESIGN.  STEP ONE WILL BE COMPLETED IN THE SPRING
OF 1977.
        STEP Two WILL CONTINUE FROM STEP ONE AND BRING THE PROJECT
THROUGH FINAL SITE SELECTION, ENVIRONMENTAL REVIEWS, ECONOMIC IMPACT
STUDIES, FINAL FACILITY DESIGN, AND PERMIT REVIEW AND ISSUANCE.  THE
LENGTH OF TIME FOR STEP TWO WILL DEPEND ON THE PUBLIC REVIEW OF THE SITE,
DESIGN, AND THE POTENTIAL FOR ADVERSE ENVIRONMENTAL IMPACT,   OUR CURRENT
PROJECTIONS ESTIMATE THAT STEP TWO WILL CONCLUDE BY MID-1978 WITH
FACILITY OPERATION COMMENCING IN LATE 1978.
        TODAY, I WOULD LIKE TO DISCUSS ONE OF THE MOST CRUCIAL ASPECTS
INVOLVED IN ESTABLISHING A CHEMICAL WASTE LAND DISPOSAL FACILITY. THAT
ASPECT IS THE SITE SELECTION PROCESS.  FlRST, A GENERAL OVERVIEW AND
ANALYSIS OF PAST SITE SELECTION METHODS WILL BE PRESENTED,  FROM THE
ANALYSIS OF PAST METHODS, THE APPROACH WHICH IS BEING USED IN MINNESOTA
WILL BE DESCRIBED.  FINALLY, THE MINNESOTA APPROACH WILL BE EVALUATED
WITH RESPECT TO ITS COST EFFECTIVENESS, ADAPTABILITY TO OTHER REGIONS,
AND THE LONG TERM CONSEQUENCES OF ITS USE.
ANALYSIS OF PAST f-ETHODS
        IN THE PAST, FACILITY ORGANIZERS HAVE EMPLOYED VARIOUS METHODS
FOR SELECTING THE LOCATIONS OF THEIR CHEMICAL WASTE DISPOSAL SITES.
THESE METHODS HAVE EMPHASIZED LAND COST, NEARNESS TO WASTE SOURCES, EASE
OF ACQUIRING THE LAND, AND EASE OF SITE APPROVALS.  TODAY, AS WE BEGIN
TO LEARN MORE ABOUT THE LONG TERM CONSEQUENCES OF DISPOSAL OF INDUSTRIAL
WASTES, CONSIDERABLY MORE EFFORT IS BEING DIRECTED TO SECURING SITES
                                   -225-

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WHI-CH CAN BEST PROVIDE PROTECTION OF GROUND AND SURFACE WATERS FROM



LEACHATE GENERATED.  IN SHORT, THE DECISION-MAKING ENVIRONMENT FOR



SELECTING A SITE FOR A CHEMICAL WASTE AND DISPOSAL FACILITY IS CHANGING



THIS NEW DECISION-MAKING ENVIRONMENT INCLUDES NEW TECHNOLOGY, LEGAL



INCENTIVES TO REQUIRE COMPREHENSIVE SITE EVALUATION PRIOR TO SITE



CONSTRUCTION, AND MORE OPEN PUBLIC REVIEW TO CONSIDER PRESENT AND FUTURE



LAND USE, LONG TERM CARE OF THE SITE, OPERATIONAL SAGETY OF THE SITE,



AND ALTERNATIVE METHODS TO MANAGE THESE WASTES,



        IN THE PAST, THE MOST POPULAR METHODS OF SITE SELECTION WERE



NORMALLY THOSE WHICH REQUIRED THE LEAST COST AND INVOLVED THE FEWEST



NUMBER OF PEOPLE AND GOVERNMENTAL AGENCIES.  USING LAND ALREADY OWNED



AND PARTIALLY DEVELOPED, ACQUIRING LAND FROM A SYMPATHETIC OR UNKNOWING



BUYER,  WERE THE EASIEST AND CHEAPEST METHODS OF SITE SELECTION.  TOO



OFTEN THESE HAVE ALSO PRODUCED THE BIGGEST HEADACHES AND POCKETBOOK



PAINS FOR SITE OWNERS.   SlTES WHICH HAVE BEEN SELECTED SOLELY ON THE



BASIS OF COST AND EASE OF PURCHASE HAVE OFTEN BEEN SITES WHICH HAVE



CAUSED CONSIDERABLE ENVIRONMENTAL DAMAGE, DAMAGE WHICH IS EXTREMELY



COSTLY TO CLEAN UP.



        BECAUSE THE OLD SITE SELECTION METHODS HAVE so OFTEN RESULTED



IN SOURCES OF POLLUTION, INDUSTRIAL WASTE DISPOSAL FACILITIES HAVE



ACQUIRED A PUBLIC IMAGE AKIN TO NUCLEAR POWER GENERATING FACILITIES.



IT HAS ALSO BECOME IMPORTANT TO CONSIDER THE GENERAL PUBLIC AND ITS



RESPONSE TO SITE SELECTION AS A FACTOR IN THE DECISIONS REGARDING SITE



SELECTION.  THE ISSUE OF PUBLIC EDUCATION IS AN IMPORTANT ELEMENT IN



ESTABLISHING A CHEMICAL WASTE LAND DISPOSAL FACILITY, BUT MUST BE THE



SUBJECT OF A SEPARATE DISCUSSION AT SOME OTHER TIME.  FOR NOW, I WOULD



PREFER TO CONCENTRATE  ON THE OVERALL APPROACH TO CITE SELECTION WHICH



IS BEING DEMONSTRATED IN MINNESOTA.
                                   -226-

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MINNESOTA'S APPROACH
        To UNDERSTAND THE APPROACH TO SITE SELECTION WHICH WE HAVE
DEVELOPED IM MINNESOTA FOR THE DEMONSTRATION PROJECT, KNOWLEDGE OF THE
DECISION-MAKING ENVIRONMENT IS IMPORTANT.  THE LEGAL INCENTIVES TO
SELECT AN ENVIRONMENTALLY ADEQUATE SITE ARE VERY STRONG. IN ADDITION TO
A STATE ENVIRONMENTAL IMPACT STATEMENT PROCESS, WE WILL HAVE COMPREHENSIVE
STATE REGULATIONS FOR ALL ASPECTS OF HAZARDOUS WASTE MANAGEMENT.   THE
PROPOSED STATE REGULATIONS WILL ADDRESS THE HANDLING OF HAZARDOUS WASTE
FROM THE SOURCE OF ITS GENERATION THROUGH TRANSPORTATION TO ULTIMATE
DISPOSAL.  THE RESPONSIBILITIES AND DUTIES OF EACH PARTY INVOLVED IN
WASTE MANAGEMENT ARE CLEAR AND WELL DEFINED.  WASTE FACILITY PROPOSERS
MUST SUBMIT DETAILED PRELIMINARY PLANS AND FINAL APPLICATIONS FOR REVIEW
BY THE STATE.  IF NECESSARY, REVIEW BY A PUBLIC HEARING WILL BE PROVIDED.
DURING THIS REVIEW PROCESS, PROPOSALS WILL BE EVALUATED WITH RESPECT TO
THE PROPOSED FACILITY'S CAPABILITY TO SAFELY HANDLE AND DISPOSE OF THOSE
WASTES WHICH ARE PROPOSED TO BE ACCEPTED, AND FINANCIAL ARRANGEMENTS
FOR   LONG TERM CARE MUST BE ASSURED.  IN ADDITION TO THE ATTENTION
PAID TO PROPOSED HAZARDOUS WASTE FACILITIES BY PUBLIC AGENCIES,
MINNESOTA, LIKE MANY OTHER STATES ENJOYS A HIGH LEVEL OF CITIZEN
PARTICIPATION IN ISSUES RELATING TO THE ENVIRONMENT, AND THIS PROJECT
IS CERTAIN TO CATCH THE ATTENTION OF THE GENERAL PUBLIC AS WELL AS THE
COMMUNITY ULTIMATELY SELECTED AS THE LOCATION FOR THE SITE.
        FROM THE PERSPECTIVE OF THE CHANGES COMING ABOUT IN THE
DECISION-MAKING ENVIRONMENT SURROUNDING THE CHEMICAL WASTE FACILITY,
THE BASIC GUIDELINES AND STEPS TO SITE SELECTION WILL NOW BE PRESENTED.

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       THE FIRST STEP TO SITE SELECTION IS TO DETERMINE WHAT THE FACILITY
WILL DO AND HOW IT WILL DO IT.  DETAILED SITE AND ENGINEERING PLANS ARE
NOT NECESSARILY REQUIRED AT THIS POINT, RATHER THE BASIC CONCEPTS
BEHIND THE FACILITY SHOULD BE FORMULATED.   QUESTIONS SUCH AS I   WILL THE
FACILITY HANDLE ONE WASTE STREAM OR A WIDE VARIETY?  HOW MUCH LAND WILL
BE REQUIRED?  1'llLL THE FACILITY HAVE WASTE TREATMENT PRIOR TO ULTIMATE
DISPOSAL?  WHAT ARE THE WASTE SHED AND WASTE CENTROID CHARACTERISTICS?
IS THEIR A NEED FOR NEARBY SEWER HOOK-UP?  ARE SOME OF THE FUNDAMENTAL
DETERMINATIONS  MADE PRIOR TO ANY SITE SELECTION WORK?
       THE SECOND STEP IN THE SITE SELECTION PROCESS IS THE MOST CRUCIAL
TO ITS OVERALL AND LONG TERM SUCCESS:  FORMULATION OF A WELL REASONED
SITE SELECTION CRITERIA.   How THIS CRITERIA SHOULD BE DEVELOPED WILL BE
DISCUSSED SHORTLY.
       THE THIRD STEP IN THE SITE SELECTION PROCESS IS TO DEFINE A MAJOR
GEOGRAPHICAL SEARCH AREA.  IN OUR CASE, THE MAJOR SEARCH AREA IS THE
SEVEN COUNTY METROPOLITAN TWIN ClTIES REGION.  IN OTHER CASES  IT COULD BE
AN ENTIRE STATE, A COUNTY, OR A CLUSTER OF COUNTIES.  THE SELECTION OF
THE MAJOR SEARCH AREA SHOULD DEPEND UPON THE GEOGRAPHICAL REGION TO BE
SERVED BY THE FACILITY.
       THE FOURTH STEP IN THE PROCESS IS TO APPLY THE CRITERIA FORMULATED
IN THE SECOND STEP AGAINST AVAILABLE INFORMATION AMD DATA ON THE MAJOR
SEARCH AREA TO IDENTIFY A NUMBER OF DISCRETE MINOR SEARCH AREAS,  SOURCES
OF DATA INCLUDE THE SOIL CONSERVATION SERVICE, MAJOR UNIVERSITY STUDIES,
STATE AND FEDERAL GEOLOGIC SURVEYS, LOCAL PLANNING CCHMSSIONS, WELL
DRILLING LOGS, STATE AGENCIES, AND LAND USE STUDIES PREVIOUSLY CONDUCTED.
       THE FIFTH STEP IN THE PROCESS IS TO IDENTIFY CANDIDATE  SITES BY
FURTHER, MORE DETAILED EVALUATION OF THE MINOR SEARCH AREAS USING THE
SITE CRITERIA AS A GUIDE.  AT THIS POINT,  SOf-iE ACTUAL INFIELD OBSERVATION
                                    -228-

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OF THE AREAS SHOULD BEGIN,  IF THE INFORMATION  IS REASONABLY ACCURATE
AND YOUR CRITERIA  IS CAREFULLY FORMULATED, LARGE LAND AREAS SHOULD BE
EXCLUDED FROfl FUTURE CONSIDERATION AT THIS POINT,  THE EMPHASIS UP TO
THIS STEP SHOULD BE TO ELIMINATE THOSE AREAS WITH THE GREATEST LIMITATION
TO USE AS A CHEMICAL WASTE LAND DISPOSAL FACILITY.
       THE SIXTH AND FINAL STEP IN THE SITE SELECTION PROCESS IS THE
SELECTION OF THE MOST FAVORABLE SITE WHICH ALSO MEETS MINIMUM PERFORMANCE
STANDARDS,   THIS  IS DONE BY CONDUCTING PROGRESSIVELY MORE DETAILED SITE
EVALUATIONS ON THE CANDIDATE SITES DEFINED IN THE PREVIOUS STEP WITH THE
SITE SELECTION CRITERIA AS A GUIDE FOR COMPARING SITES,  THE DATA BASE
FOR MAKING SITE EVALUATIONS AT THIS LEVEL DEPENDS ENTIRELY ON FIELD
INVESTIGATIONS AT THE CANDIDATE SITES,
       THE SIX STEP PROCESS OF SITE SELECTION ATTEMPTS TO CONDUCT A
COMPREHENSIVE SITE SEARCH BASED ON PRESENTLY AVAILABLE INFORMATION USING
A WELL REASONED SITE CRITERIA,  ONE OF THE STRENGTHS OF SUCH A PROCESS
IS THAT IT GIVES EQUAL CONSIDERATION TO ALL AREAS WITHIN THE MAJOR SEARCH
AREA.  BY INITIALLY CONSIDERING ALL AREAS WITHIN THE MAJOR SEARCH AREA AND
ELIMINATING THOSE PORTIONS WHICH HAVE OBVIOUS LIMITATIONS, A RATIONAL,
SYSTEMATIC, AND RELATIVELY COST EFFECTIVE APPROACH TO SITE SELECTION IS
ACHIEVED.
       IN FORMULATING A WELL REASONED SITE SELECTION CRITERIA, THE
FOLLOWING GUIDELINES SHOULD BE OBSERVED:
       l)  FIRST, THE CRITERIA SHOULD CONTAIN A NUMBER OE PARAMETERS
           TO BE EVALUATED.   SOILS, TOPOGRAPHY, GEOLOGY, HYDROLOGY,
           LAND USE, ENGINEERING SUITABILITY, AND TRANSPORTATION ARE
           OBVIOUS FACTORS TO BE CONSIDERED IN ANY SITE.  OF COURSE,
           OTHERS MAY BE INCLUDED.
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2)  SECOND, THE EVALUATION AND MEASUREMENT OF EACH PARAMETER
    SHOULD FOLLOW GENERALLY ACCEPTED METHODS AND TECHNIQUES,
    SUCH EVALUATIONS SHOULD STRESS OBJECTIVE AND QUANTIFIABLE
    MEASUREMENTS OF EACH PARAMETER,
3)  THIRD, THE INFORMATION REQUIRED TO MAKE INITIAL JUDGEMENTS
    SHOULD BE BASED ON AVAILABLE INFORMATION,  MOST SITE SELECTION
    EXERCISES HAVE AND ARE EXPECTED TO OCCUR NEAR LARGE INDUSTRIAL
    CENTERS,  THESE AREAS TYPICALLY HAVE BEEN STUDIED INTENSIVELY
    BY GOVERNMENT, ACADEMIC INSTITUTIONS, AND PRIVATE INTERESTS.
    SOIL MAPS, LAND USE STUDIES, WELL LOGS, GEOLOGIC PROFILES,
    AND DEMOGRAPHIC INFORMATION SHOULD BE READILY AVAILABLE AND
    FAIRLY CURRENT.  IN MORE REMOTE REGIONS WHERE LITTLE INFORMATION
    IS AVAILABLE, FACILITY PROPOSERS MAY HAVE TO COLLECT THEIR OWN:
    BACKGROUND DATA.
V)  FOURTH, EACH PARAMETER SHOULD BE EVALUATED INDEPENDENTLY
    RATHER THAN ON A WEIGHTED AVERAGE BASIS SO THAT THE IMPORTANCE
    OF EACH PARAMETER TO THE OVERALL EVALUATION CAN BE ASSESSED.
    WEIGHTED-AVERAGE METHODS SHOULD BE AVOIDED FOR TWO REASONS:
    FIRST, THE WEIGHT ASSIGNED TO A GIVEN PARAMETER IS MADE ON A
    SUBJECTIVE BASIS AND SECOND, THE RELATIONSHIPS AMONG PARAMETERS
    ARE NOT NECESSARILY ADDITIVE.  FOR EXAMPLE, ASSUME THAT A SITE
    UNDER CONSIDERATION IS EVALUATED ON ONLY THREE FACTORS:  LAND
    USE, SOILS, AND GEOLOGIC CONDITIONS.  AFTER INITIAL EVALUATION,
    EXCELLENT MARKS IN THE LAND USE AND SOILS ARE SCORED, BUT THE
    SITE LIES OVER AN ACTIVE FAULT.  WHEN WEIGHTS AND VALUES ARE
    ASSIGNED TO EACH PARAMETER AND THE SCORES ARE SUMMED, IT IS
    POSSIBLE THAT THIS SITE COULD COME OUT WELL AHEAD OF OTHER
                              -230-

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    OF OTHER SITES WHICH HAVE MODERATE MARKS FOR ALL PARAMETERS.
    I THINK MANY OF YOU WILL AGREE THAT SITING CHEMICAL WASTE
    I
    DISPOSAL FACILITIES OVER ACTIVE ''MJLTS IS ENTIRELY OUT OF THE
    QUESTION.  THIS PARTICULAR EXAMPLE MAY BE A BIT EXTREME, BUT
    IT DOES POINT OUT THE WEAKNESS OF THE WEIGHTED-AVERAGE METHOD
    OF INTERPRETING THE RESULTS OF SITE SELECTION.
B)  THE FIFTH GUIDELINE FOR DEVELOPING A WELL REASONED SITE
    CRITERIA IS THAT THE CRITERIA SHOULD ESTABLISH CERTAIN MINIMUM
    PERFORMANCE STANDARDS.  BY ESTABLISHING MINIMUM STANDARDS, THE
    SITE WHICH IS ULTIMATELY SELECTED WILL NOT ONLY BE THE MOST
    FAVORABLE AMONG THOSE CONSIDERED, BUT IT WILL BE ACCEPTABLE
    FROM THE STANDPOINT OF EACH MAJOR SITE PARAMETER.  To ILLUSTRATE
    THE IMPORTANCE OF ESTABLISHING MINIMUM STANDARDS, LET'S GO
    BACK TO THE PREVIOUS EXAMPLE WHERE LAND USE, SOILS, AND GEOLOGY
    ARE THE PARAMETERS, AND SUPPOSE THAT THE MAJOR SEARCH AREA LIES
    OVER AN ACTIVE FAULT.  THE SITE SELECTION PROCESS WILL PRODUCE
    A "MOST FAVORABLE" SITE WHICH ALSO LIES OVER THE FAULT,  AGAIN,
    DUE TO THE OBVIOUS LIMITATION OF AN ACTIVE FAULT, NONE OF THE
    SITES IN THE MAJOR SEARCH AREA SHOULD BE SELECTED REGARDLESS
    OF THE SCORES WHICH THEY MIGHT RECEIVE AFTER COMPREHENSIVE
    EVALUATION.
                              -231-

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iHE FINAL RESULT OF THE COMPUTER ASSISTED SEARCH IS THE IDENTIFICATION
OF MINOR SEARCH AREAS.
       THE USE OF THE COMPUTER IN PARING THE MAJOR SEARCH AREA DOWN
TO A DISCRETE NUMBER OF MINOR SEARCH AREAS HAS A NUMBER OF ADVANTAGES:
       l)  IT IS OBJECTIVE.
       2)  IT MAKES USE OF AVAILABLE INFORMATION.
       3)  IT MINIMIZES SUBJECTIVE JUDGEMENTS.
       *0  IT CONSIDERS THE ENTIRE MAJOR SEARCH AREA RATHER THAN
           ARBITRARILY SELECTED LOCATIONS WITHIN THE MAJOR SEARCH AREA.
       S)  IT IS VERY FAST.  As LONG AS THE RAW DATA IS IN PLACE, THE
           RATE LIMITING FACTOR IS THE TIME NECESSARY TO FORMULATE AN
           ACCEPTABLE RATING SYSTEM.
       6)  IT IS RELATIVELY INEXPENSIVE.  APPROXIMATELY $2,000 WAS
           REQUIRED FOR THE COMPUTER TIME, CODING, PROGRAMMING, AND
           INTERPRETATION OF RESULTS IN OUR CLASS.
DESPITE ITS STRENGTHS, THE COMPUTER-ASSISTED SITE SELECTION TECHNIQUE
DOES HAVE SOME LIMITATIONS.
       ij  THE ACCURACY OF THE RAW DATA IS HIGHLY DEPENDENT ON THE AGE
           AND COMPLETENESS OF THE ORIGINAL SOURCE.  IT IS ALSO
           DEPENDENT UPON THE PERSON INTERPRETING THE DATA.
       2)  THERE ARE LIMITATIONS TO THE KIND OF DATA STORED IN THE
           COMPUTER.
       3)  THE COLLECTIVE JUDGEMENTS OF A PANEL OF "EXPERTS" MAY
           INTRODUCE CERTAIN BIASES INTO THE INTERPRETATION OF THE DATA.
           EVEN THOUGH CERTAIN CONCLUSIONS CAN BE REACHED 'FOLLOWING
           THE COMPUTER ASSISTED PROCESS, PROJECT ORGANIZERS MUST
           UNDERSTAND THAT CONSIDERABLY MORE TIME AND RESOURCES MUST BE
           BE EXPENDED TO REACH CONCLUSIONS REGARDING THE FINAL SHE
           SELECTION.
                                   -232-

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CONCLUSIONS




       THE SITE SELECTION PROCESS WHICH HAS BEEN PRESENTED TODAY IS



THE RESULT OF A MAJOR CHANGE IN THE DECISION-MAKING ENVIRONMENT



SURROUNDING THE ESTABLISHMENT OF NEW CHEMICAL WASTE DISPOSAL FACILITIES.



THIS DECISION-MAKING ENVIRONMENT IMPOSED BY STATE AGENCIES, LOCAL



AUTHORITIES, AND MORE RECENTLY THE FEDERAL GOVERNMENT,WILL REQUIRE



WASTE DISPOSAL FACILITY ORGANIZERS TO MORE CAREFULLY CONSIDER THE SHORT



AND LONG TERM ENVIRONMENTAL CONSEQUENCES OF A PROPOSED WASTE FACILITY



AND ITS LOCATION.



       THE SITE SELECTION PROCESS PRESENTED TODAY APPEARS TO BE A



RATIONAL, SYSTEMATIC, AND THOROUGH METHOD OF SELECTING A SUITABLE



LOCATION FOR A CHEMICAL WASTE FACILITY,  WlTHIN THE CONSTRAINTS OF THE



DECISION-MAKING ENVIRONMENT IN MINNESOTA, IT ALSO APPEARS TO BE A COST



EFFECTIVE METHOD FOR SITE SELECTION BY EMPHASIZING THE USE OF CURRENTLY



AVAILABLE INFORMATION WHICH IS QUICKLY AND EFFICIENTLY MANAGED BY A



COMPUTER AFTER INSTRUCTION FROM A VARIETY OF KNOWLEDGEABLE PEOPLE.



       I WOULD LIKE TO AGAIN THANK THE NSWMA FOR THIS OPPORTUNITY TO



PRESENT THIS STATUS REPORT ON THE DEMONSTRATION PROJECT AND HOPE THAT



WE MAY RETURN TO DISCUSS OTHER RESULTS OF THE PROJECT AS THEY BECOME



AVAILABLE.
                                    -233-

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       I WOULD LIKE to MOVE NOW FROM THE SUBJECT OF SITE CRITERIA TO
THE SUBJECT OF HOW WE, IN MINNESOTA, HAVE APPROACHED THE EVALUATION
OF A MAJOR SEARCH AREA.  To AID IN THIS EVALUATION, A COMPUTER WAS
USED TO STORE, COLLATE, AND PRODUCE INTERPRETIVE   "DATA MAPS"SHOWING
THOSE AREAS WITHIN THE MAJOR' SEARCH AREAS WHICH CAN BE ELIMINATED FROM
FURTHER CONSIDERATION AND IDENTIFY THOSE AREAS WHICH SHOW THE LEAST
LIMITATION ON THEIR USE AS A WASTE DISPOSAL SITE.  THIS COMPUTER BASED
TECHNIQUE WAS DEVELOPED BY THE UNIVERSITY OF MINNESOTA IN ITS CENTER
FOR URBAN AND REGIONAL AFFAIRS FOR APPLICATION IN A WIDE VARIETY OF LAND
USE RELATED EVALUATIONS.
       THE FIRST STEP IN MAKING USE OF THE COMPUTER-ASSISTED
TECHNIQUE IS TO ASSEMBLE THE AVAILABLE INFORMATION AND PLACE IT IN
THE COMPUTER.  FOR THIS PARTICULAR SYSTEM, THE MAJOR SEARCH AREA WAS
BROKEN INTO 40 ACRE PARCELS,  THE TOTAL NUMBER OF PARCELS WAS
APPROXIMATELY 47/000.  NEXT, THE AVAILABLE INFORMATION WAS COLLECTED,
INTERPRETED, AND ENCODED IN A FORM UNDERSTANDABLE TO THE COMPUTER.
SOURCES FOR THIS DATA BASE INCLUDED:
AERIAL PHOTOS, U.S. GEOGRAPHIC SURVEY TOPOGRAPHIC MAPS, SOIL MAPS
FROM THE SOIL CONSERVATION SERVICE AND THE UNIVERSITY OF MINNESOTA.,
LAND USE PLANS, AND LAND OWNERSHIP SURVEYS.  NEXT, A COMMITTEE OF
TECHNICAL EXPERTS AND PUBLIC AGENCY REPRESENTATIVES FORMULATED A
RATING SYSTEM WHICH EVENTUALLY BECAME AN INSTRUCTION SET FOR THE
COMPUTER,  THE COMPUTER WILL TAKE THE DATA AND INSTRUCTIONS AND PRINT
OUT A SERIES OF INTERPRETIVE MAPS SHOWING THE DEGREE OF LIMITATION FOR
EACH LOCATIONAL FACTOR.  WlTH APPROPRIATE INSTRUCTIONS, THE COMPUTER
CAN ALSO OVERLAY THE RESULTS OF AN INTERPRETIVE MAP FOR ONE FACTOR ON
OTHER MAPS TO GIVE A TOTAL PICTURE OF WHERE THE MINOR SEARCH AREAS
MAY LIE AND WHAT AREAS CAN BE ELIMINATED FROM FURTHER CONSIDERATION

                                   -234-

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                   GROUND WATER PROTECTION SYSTEMS-
                      WHERE THEORY MEETS PRACTICE

                           John Reinhardt, Chief
                    Solid Waste Management Section
              Wisconsin Department of Natural Resources
The possible pollution of ground water by landfill sites is becoming of
greater concern to the public.  In a number of instances, raising it as
an issue is used by the opposition to block the establishment of a
disposal site.

     "How serious are the impacts of land disposal sites on ground
      water?"

     "Isn't this issue really an over reaction on the part of environmental-
     ists and alarmists?"

     "After all, no one ever died from drinking leachate did they?"

In my opinion, the impact of landfills on ground water can be very
serious.  The issues raised by the potential for ground water pollution
by landfill sites will have far reaching impacts on the solid waste
industry if in some areas, landfills will be permitted in at all, where
they will be located, how they will be designed, who actually will own
them and the economics of disposal.

As far as I know, to date, it has not been established that any human
has died from leachate.  Maybe someone in the audience can correct me on
this.  This is probably due only to the difficulty in getting water
polluted with leachate past one's nose.  Damage assessment at many older
existing landfill sites in Wisconsin indicates many cases of undrinkable
water in the immediate vicinity of the landfills due to the landfill.

The Congressional Record,  September 27, 1976 documents the serious
economic consequences of ground water pollution.  Congress is requested
to provide $650,000 for the correction of the ground water pollution
problem at the Llangollen landfill in New Castle County, Delaware.
$2,000,000 already has been spent on the problem.   The operating costs
of the present barrier well protection system is 5200,000 per year,  and
total estimated costs for correction range from an estimated $15,000,000
to $25,000,000.  An expenditure of this magnitude, by any public or  i
private landfill owner, would certainly be a financial disaster.  Admittedly,
the Llangollen landfill was an old existing site established at a time
when little or nothing was known about the undesireability of establishing
a site in a gravel pit.  However, sites are being established today, in
which you and I are playing a role, which could have such an impact if
we are wrong in our analysis of what ground water protection systems are
required or if these systems fail.
                                  -235-

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Landfill site operators, consultants and regulatory officials are all
facing a common dilemma, viewed from different prospectives, in establish-
ing land disposal sites for residuals.  On one hand is the strict
environmental (and in some instances legal) stance that under no cir-
cumstances shall a disposal site change the ground water quality - "zero
discharge".  On the other hand is the viewpoint that the waste must go
somewhere as it is produced every day.  The urgency of the need to
dispose of waste, as it is generated, means a few wells or a minor trout
stream must he sacrificed here or there to prevent the garbage from
piling up on the streets; the old "end justifies the means" concept.

In between these two extremes, landfill sites must be found that provide
a high degree of protection of the ground water and also meet other
economic, social, political, legal,  and environmental constraints and
requirements.

The purpose of this presentation is  to describe some of the problems
with putting the theory of ground water protection systems into practice
and to provide a framework for a forum discussion of some of the dilemmas
in addressing the ground water protection aspects of landfill site
location.

The objectives of this presentation  are to:

     *Provide several definitions of the ground water which must be
     considered in ground water protection systems.

     *Point out several reasons why  the ground water protection systems
     must be considered in landfill  site location.

     *Describe some of thp more classical ground water protection
     systems.

     *Raise some of the more pertinent issues facing the location of
     landfills from a ground water protection standpoint.

"What is 'ground water'?"  The lack  of a clear understanding of, and
agreement on, the various definitions of ground water on the part of the
designer can result in a regulatory  agency asking for a re-evaluation of
some of the proposed concepts for ground water protection systems.  If
ground water is to be protected, one has to know what it is.  Ground
water is usually technically defined as water below the ground water
table.  Davis & De Wiest in their text book "Hydrogeology", define
"water table" as "the surface in unconfined materials, along which th'e
hydrostatic pressure is equal to the atmosphere pressure."  While this
is one of the more widely accepted technical definitions, statutory
definitions may vary from this. Chapter 162.02(2) of the Wisconsin State
Statutes defines ground waters as, "subsurface water supplied for human
                                  -236-

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consumption."  This could be interpreted to mean all water under ground.
Section 147.015(13) of the Wisconsin State Statutes, which establishes
the WPDES  (Wisconsin Pollution Discharge Elimination System), specifies
waters of  the state to include ground water without defining ground
water.  The differences in definition must be addressed in any ground
water protection system.

Another definition of ground water, which must be considered is the
definition established by court cases.  The outcome of a future lawsuit,
for alleged damages to your neighbor's ground water, could depend on the
definition put forth in a past court suit.  It wasn't too long ago in
Wisconsin  that a court suit talked in terms of water flowing in "underground
rivers".

An understanding that must be understood are different meanings to
ground water is necessary if ground water protection is to be meaningfully
addressed  in landfill site location.

Another term that must be understood is "aquifer".  It generally is
technically defined as "a formation or group of formations, or part of a
formation  that contains sufficient saturated permeable intervals to
yield or be capable of yielding significant quantities of water to wells
or springs."  There is, at times, a tendency to ignore shallow aquifers
capable of providing water only to domestic wells.  It is important that
the designer and others with an interest in ground water protection
system understand from the start if the system needs to protect all
ground water or only certain types or classes of aquifers.

A below the zone of saturation landfill in tight clay could be polluting
the ground water as defined technically, by statutes and by court cases,
but not harming any aquifers because water cannot be withdrawn from the
clay in significant quantities even for domestic wells.

Why protect the ground water?  First, there have been for some time
various state statutory obligations.  Also, of present and future
significance is the Safe Drinking Water Act on the Federal level.  You
can be sued by your neighbor if you pollute his ground water.  Not
protecting ground water is considered anti-social; neighbors appreciate
landfills even less than they usually do if the landfill can pollute
their ground water.  Neighbors near proposed landfill sites are greatly
influenced by past ground water pollution from landfills.   Environmental
groups and others who oppose a particular landfill or, in fact,  oppose
any landfill anywhere, can successfully stop a landfill from being
established or from continuing operation if they can show that ground
water may be polluted.  Politically, no elected official can be in favor
of a Jandfill which may pollute ground water.  Thus, an elected
Official must oppose any landfill which may pollute the ground water.
                                -237-

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In summary, the issue of ground water protection must be addressed and
resolved by those groups who are represented in the audience if landfill
is to provide a viable, residual disposal solution into the future.
The problems of putting theory into practice, in ground water protection
systems, must be overcome in a manner that they work in the field and
in a manner that the public can have confidence in them.  If the "doers"
ignore the issue as they believed the "refuse has to go somewhere";
the end justified the means, then, the alternative may be the creation of
many unwisely conceived resource recovery and processing concepts in
the guise of protecting the ground water.

How can_ the ground water be protected7  The concept, in theory, is easy;
the implementation, in practice, is difficult.  In concept, contaminants
from residual disposal must be prevented from reaching the ground water,
either entirely to meet statutory definitions or limited to some amount
that is legally specified or would not make the water unusable.  The amount
of degradation which can be tollerated will depend on if the water is
to be used for drinking, cooling, irrigation, etc.

The traditional problem solving procedure, used in large scale engi-
neering projects, is probably the best approach to developing ground
water protection systems.  This approach can be especially effective
when incorporating systems concepts of looking at alternatives and re-
evaluating solutions into it.

A clear understanding of what is to be protected, in terms of the legal,
social and technical definitions of ground water, is needed.  Also, a
clear, written definition of other economic, political, and social
constraints to the problem is desirable.

A good physical definition of the actual area where the waste will be
placed, along with the surrounding area, is needed.  The physical
definition of topography, surface water, geology, soils, hydrogeoLogy,
inter-relationship of aquifers, etc., is needed to assess alternate
solutions.

Theoretically, the anticipated time-rate of production of contaminants
should be determined, and the ability of the physical site location to
attenuate them should be established.  The difference between contaminant
loading and the natural ability of the physical site to protect the
ground water should then be addressed through engineering design of
man-made site modification systems.  Unfortunately, only in a crude way
has contaminant production been defined in terms of quality and quantity
at this time.  Assessing the contaminant variation from landfills with
time is extremely difficult.  If all landfills were located in homogeneous
soils with readily defined flow systems, the capacity of the site to
handle contaminants could be more easily addressed.  As soils and flow
systems in nature are not always easily defined, the task is usually
difficult.
                                  •€38-

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Thus,  the  theoretical approach is easy  to describe, but as most of you
know  through your own experience, at  this time, there  is a long way
between  theory  and practice.  Landfill  disposal site location and design
for ground water protection are not yet a science, let alone a well-
developed  art.  Some say  it is a black  art; others say it is an emerging
art at best.  However,  the development  of ground water protect system theory
and practice has come a long way in the past  ten years.  The more
traditional 10  year time-lag of knowledge from theory  to practice,
through  laboratory, pilot projects, etc., has been short-circuited.  The
need  to  do something now has necessitated placing theory directly into
practice in many cases.  Only time will tell  if the theory works.  It
may not  have always been  the wisest course, but then we place waste at
the curb every  day and  something is better than nothing.  In my opinion,
the theory that is available should be  utilized to the maximum, even if
it is sometimes in an imperfect state.  In order that  ten years from
now,. the  imperfect art we practice,  today can be called even a fledging
science, we must utilize  it to its maximum today.

Also, of prime  importance is that the problem not be viewed from the
standpoint of meeting some minimum regulation.  Minimum regulations
are just that—solutions designed around such a narrow concept are
usually  short-lived and in the long run inadequate.

What are some of the major ground water protection systems which are
proposed and in use today?  They can be categorized as natural pro-
tection  systems, man-made systems, or combinations of both.

The most obvious approach to protecting the ground water is to limic the
amount and/or rate of leachate production by reducing water coming into
contact with solid waste.  The diversion around the landfill of surface
water around the landfill from areas outside of the landfill is one of
the first  engineering considerations that should be made in landfill
design.  Traditional storm water design equations and concepts should be
used.  The solutions are expressed in the field in terms of ditches,
storm sewers, and berms.  Some civil engineers, who would not think of
designing  a highway or parking lot without computing the size of
ditches and storm sewers to protect the project from storm water, do
not see  the same need when designing landfills.  The possibilities of
surface water entering the landfill through sand stringers, where these
sand stringers  extend or surface outside the landfill,  should be examined.
The sand stringer can be sealed with clay, both inside and outside the
landfill.  As simple as this may seem, this approach often is not taken
in landfill design.

The location and design of cover dirt sources and stockpiles must be done in
a manner that they do not route surface water into the fill.   All earth
moving activities connected with a landfill should be designed in a
                                  -239-

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manner that they do not add water to the fill or if possible in a manner
that conducts water off the site.  Many cases of unnecessary leachate
production at landfills have resulted from not considering this problem.

Leachate production can also be reduced by detailed consideration of the
handling of precipitation on the landfill site proper.  Detailed phasing
plans for each cell which route surface water in a manner that it can be
directly away fill will reduce leachate.  Every gallon of water that is
pumped or drained off of a refuse cell is one less gallon to infiltrate
and produce leachate.  A design of the final contours and cover to
reduce infiltration can also greatly reduce leachate production.  The
final contours should channelize water and provide the shortest possible
length of overland flow.  Runoff can also be increased by increasing the
slope and choosing a cover material that has a low permeability and will
not readily crack.  As an extreme, a man-made material such as plastic
or rubber can be used to attempt to obtain zero infiltration.

The impacts of various concepts are easily evaluated by utilizing traditional
engineering design procedures utilized in storm water design.  Rational
approaches to evaluating designs are also given in the many Soil Conservation
Service manuals.

Obviously, once leachate is produced, consideration must be given to
handling it in a manner to not pollute ground water.  Natural systems to
handle leachate once it is produced are generally preferable to man-made
systems.  Man-made systems are usually expensive to build, operate, and
often require long-term maintenance and operation.  Which system or
combination of systems should be used is dependent on detailed definition
of the site location in terms of soil type, geology, hydrogeology, and
other physical criteria.  Hopefully, the site is located so that the
underlying soils will attenuate the leachate so it will not pollute the
ground water, or so it would flow through the hydrogeologic setting in a
manner not to create a problem.  This approach takes advantage of soils,
upward ground water gradients, flow paths for contaminants that will
not impact on ground water use in a detrimental manner, and possibly others.
Thomas Clark, in the July-August 1975 issue of Ground Water gives a
detailed mathematical approach to evaluating a natural attenuation site.

Artificial systems vary all the way from man-made fabric liners used in
concepts which completely collect and treat leachate to wells installed
into the center of a landfill in case leachate "has to be withdrawn at a
future date".

Liners can be classified in terms of man-made materials such as rubber
and plastic or natural materials such as clay.  The use of man-made
materials usually is based on the concept that no leakage will occur,
This implies collection and treatment of leachate.  Use of clay or other
natural materials usually implies some leakage will occur.  Thus, the
site location still must be considered as part of the ground water
protection system.
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Use of liners usually will call for leachate collection and treatment at
some time and in some manner, as in many areas of the United States
infiltration  through the cover will exceed the exfiltration through the
lined bottom and sides of the fill.  If the leachate is not withdrawn,
it will ultimately build up to where it will spill out on the ground.
All the problems associated with leachate collection and treatment must
be addressed.  This includes the problems associated with the long-term
operation, maintenance, and financing of these systems.  While there is
some question about the theory of treating leachate, increasing numbers
of projects are being reported, where treatment either is being done or
proposed.  Usually the collected leachate is treated in an existing
municipal waste water treatment plant.

The combination of natural and man-made systems are being proposed for
new disposal sites and many have actually been built in the field.
These include the concept of below the zone of saturation location of
landfills in tight soils with the maintenance of inward gradients by
leachate withdrawal.  This and other such concepts were discussed in
some depth as early as 1972 by George Hughes in the Illinois Geological
Survey Environmental Geology Notes.

Barrier wells, under drains, spot sealing of permeable soils are
other concepts proposed or in use.  One recent concept proposes to use a
clay liner and air from an air compressor to restrict leachate from
flowing out of the landfill and carbon dioxide from migrating out of the
landfill.  The problems of ground water pollution caused by methane and
carbon dioxide migration are just beginning to be addressed.

One interesting concept of choosing between complete collection and
treatment of leachate and no protection for the ground water is using
the shallow flow system adjacent to large rivers or discharge areas
which handle polluted ground water without producing major problems.  A
location is chosen adjacent to a large river where the ground water flow
system is primarily horizontal toward the river.  Preferably, the
site is adjacent to a flood plain where development of wells will never
occur.  The flow path of the contaminants should be long enough in
time and distance that when they reach the river or discharge point,
they will not have a detrimental impact on the surface waters.  Of
course, the problems with flow laterally along the river bank must also
be evaluated, along with any problems due to reversal of ground water
gradients during high river flow periods.  Basically, this is a deliberate
pollution of a portion of the shallow ground water resource which is unlikely
to even be used to overcome the many problems with locating in other
settings.  The approach is based on the concept that it is better to use
part of the ground water flow system where the pollution will be minor in
extent and the result predictable.  An interesting version of this
approach will a step-by-step mathematical design was presented in the
April 1975 issue of Public Works by Dilaj and Lenard.
                                  -241-

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Unfortunately, such questions as what is a natural attenuation site,
which man-made system is needed to protect the ground water to what
extent, etc., largely depended on a number of resource allocation ques-
tions which are, to a great degree, unresolved.  Two of the most per-
tinent are:

     *To what degree can the ground water be used for waste assimilation
     from a technical, legal, social, environmental and regulatory
     standpoint?

     *How can the problem of waste load allocation to air, water and
     land be resolved in the context of federal and state regulatory
     programs and other constraints placed on the problem by society?

Two major questions must also be resolved ultimately if man-made systems
are to prove usable in the long run.  These are:

     *How can the issue of long-term responsibility and liability for
     ground water protection at landfill sites be resolved?

     *How can the public be assured that the technical concepts are adequately
     translated into engineering design and then actually constructed
     and operated into the field in keeping with the engineering design.
     This appears to be a major problem in the immediate future which
     must be overcome.  Evaluation of how viable present concepts are
     will be difficult, if not impossible, if they are not properly
     converted to engineering design, constructed in the field, or
     evaluated from data gathered in the field?

If the theory and design of ground water protection systems ever are to work
in practice, quality control of construction and operation in the field
is a necessity.  If the studies and designs are only made to obtain an
approval and license from a regulatory agency, then all is lost.
Unfortunately, it is not uncommon to find engineering plans being
ignored in the field and in some instances, the landfill operator unable
to read the plans and unwilling to retain the necessary professional
help who can.

Last, but not least, translating the theory of ground water protection
systems, into practice, requires monitoring and evaluating performance.
Some view such activities as research projects for state regulatory
agencies.  In my opinion, monitoring and evaluation of ground water
protection systems are of great value to the landfill owner.  It provides
him proof against charges of his neighbors that he is polluting the  '
ground water.  It provides information for him on which to make future
investments in landfills.  It allows early corrective action when designs
do not work.  It also provides the landfill site with some degree of
public credibility.
                                 -242-

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Certainly, the subject matter and issues raised in this presentation can
only be covered in some depth by a four or five-day conference.   However,
this forum presents an opportunity for a wide cross-section of those
involved in landfill siting to put forth their views on the issues
raised.  If those present think the issues can be ignored,  there are
others who will not ignore them but will provide answers none of us will
like.
                                -241-

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References

Congressional Record - 11179, Volume 122, September 27,  1976, No. 147.

Clark, Thomas P.  1975, "Survey of Ground Water Protection Methods For
Illinois Landfills", Ground Water, pp. 321-331, July-August 1975.

Dilaj, M. and Lenard, John F., "Leachate Control at Landfills Based on
Hydrogeologic Studies", Public Works,  pp. 91-122, April  1975.

Hughes, G. M., 1972.  "Hydrogeologic Considerations in Siting and
Design of Landfills", Illinois Geological Survey.  Environmental
Geology Notes, no. 51.
                                  -244-

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              CONSIDERATIONS FOR STATE HAZARDOUS
                       HASTE PROGRAMS

                       John P.  Lehman
                          Director
              Hazardous Waste Management Division
                    Office of Solid Waste
              U.S.  Environmental  Protection Agency

* CONGRESSIONAL INTENT  FOR STATES TO ASSUM2 HAZARDOUS

     WASTE PROGRAM
  EPA  GUIDELINES TO ASSIST STATE PROGRAM DEVELOPMENT
* INTERIM AUTHORISATION POSSIBLE
* FEDERAL GRANTS PROVIDE) FOR  INITIAL  DEVELOPMENT AND

      IMPLEMENTATION
• STATE  PROGRAMS TO BF,  "EQUIVALENT" TO  FEDERAL
0 STATE  PROGRAMS TO 3E  "CONSISTENT" KITH FEDERAL

     CT'.iER STAI"^1 PROGRAMS
                                 -245-

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      GOALS Q:-' STATS HAZARDOUS  WASTK









1)    COGNTZJVNC53 OVER HAZARDOUS  WASTE




          - SOUSCS3




          - QUANTITIES




          - TYPES




          - DESTINATIONS
2)    CONTROL OVER HAZARDOUS WASTE




          - STORAGE




          - TRANSPORTATION




          - TREATMENT




          - DISPOSAL
3)   CAPABILITY TO




          - PROVIDE TECHNICAL ASSISTANCE




          - ENFORCE REGULATORY PROGRAM
4)   ALTERNATIVES TO  INADEQUATE PRACTICES
5)    PREVENTION OF PUBLIC  HEALTH AND ENVIRONMENTAL DAMAGES
                             -246-

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      ELEMENTS OI-' AN EFFECTIVE  STATE PROGRAM
1)    LEGISLATIVE AUTHORITY
2)    ADEQUATE  RESOURCES
3)   PUBLISHED CRITERIA AND STANDARDS
4)    FACILITY  PERMIT SYSTEM
5)    TRANSPORTATION MANIFEST SYSTEM
6)    SURVEILLANCE AND ENFORCEMENT  FUNCTIONS
                               -247-

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         SUGGESTi\0_ S^QUgNCB_01-' DEVET.pPMSNT









1)    HAZARDOUS WASTE SURVEYS







          - ESTABLISH SCOPE OF PROBLEM









2)    STATE PLAN







          - HAZARDOUS WASTE SUBSET OF SWM PLAN




          - FACILITY CAPACITY NEEDS









3)    LEGISLATION







          - NEW OR  AMENDMENTS









4)    REGULATIONS









5)    PERMIT PROGRAM









6)    GENERATOR REPORTING









7)    TRANSPORT MANIFEST SYSTEM









8)    SURVEILLANCE AND ENFORCEMENT
                              -248-

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        FULL" AUTHORIZATION OF STATE PROGRAM
          0 STATES CAN APPLY AT ANY TIME









(?)        ° ALL PROGRAM ELEMENTS IN PLACE  (EQUIVALENT)









(?)        ° CONSISTENT WITH FEDERAL AND OTHER




            STATES'  PROGRAMS









(?)        ° FRAMEWORK AND RESOURCES FOR ENFORCEMENT




            IN PLACE









(?)        ° SINGLE LEAD AGENCY




            (SEVERAL MAY BE INVOLVED, BUT ONE MUST




            LEAD)









(?)        ° INTERSTATE COOPERATION POLICY
                             -?49-

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     "INTERIM"  AUTHORIZATION OF  STATED PROG t
-------
         ISSUES CONCERNING STATE PROGRAMS
0 FEDERAL DEFINITION OF HAZARDOUS WASTE
     - BROAD OR NARROW SCOPE
0 INTERPRETATION OF
     - "EQUIVALENT"
    ' - "CONSISTENT"
     - "SUBSTANTIALLY EQUIVALENT"
0 CAN STATE PROGRAMS BE MORE STRINGENT THAN FEDERAL
     PROGRAM?
0 ARE WASTE NON-IMPORTATION POLICIES FAIR TO OTHER
     STATES?  ARE THEY "CONSISTENT"?
0 SHOULD STATE PROGRAMS BE SELF-SUSTAINING?  HOW?
     USER FSSS?
                              -251-

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           CONTROL OF HAZARDOUS WASTES IN CALIFORNIA

                              by
                  Harvey F. Collins'1' Ph.D.

The California Department of H3a1th's hazardous vMste control
program was started in the fall.of 1973 pursuant to the Hazardous
Waste Control Act of 1972, which authorized the Department to:
(1) estciblish and enforce regulations for the handling and dis-
posal of hazardous wastes; (2) provide for appropriate surveil-
lance of hazardous waste processing and disposal practices in the
state; (?) conduct appropriate studies relating to hazardous
wastes; end (4) maintain a technical reference center on hazardous
waste disposal, recycling practices, and related information for
public ard private use.
Regulations.  The Department adopted regulations governing hazardous
wastes in June, 1974.  These regulations list wastes determined to
be hazardous and extremely hazardous, establish requirements for
producers and haulers of hazardous wastes and for operators of
waste disposal sites, and specify approval by the Department of
Health as a prerequisite to the disposal of extremely hazardous
wastes.  The regulations also established fees to be paid by
   California Department of Health, Sacramento, CA
                                -252-

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 operators of disposal sites accepting hazardous wastes.  The foes
 support the regulatory activities of the Department's program,
 which is not funded from the State Treasury.

 We have recently finalized hazardous waste regulations which the
 Department proposes to adopt within the next few months after
 a public hearing.  These regulations will greatly expand the
 Department of Health's regulatory activities.  Where the present
 regulations apply only to operations at waste disposal sites that
 receive hazardous wastes from more than one source, the proposed
 regulations will apply to operations at all disposal sites that
 receive hazardous wastes.  They will also apply to all transfer
 stations, storage facilities, and treatment facilities that receive
 hazardous wastes.  The proposed regulations are far more detailed
 than the present regulations and explicitly prohibit undesirable
 procedures which we have observed at seme of the disposal sites.

 Surveillance nnd  Enforcement.  The program presently has personnel
 operating out of  Sacramento, Berkeley and Los Angeles.  Our
 Inspectors make field  inspections to ensure  that hazardous wastes
 are properly handled and disposed of.  These Inspectors: (1) visit
 plants and facilities where hazardous wastes are generated, processed,
 and stored, (2) field-monitor the haulers of hazardous wastes to
 discourage Illegal disposal  at unauthorized disposal sites; and
 (3) visit hazardous waste disposal sites to Inspect the sites and
 audit records of receipt of hazardous wastes.  Since April  1976
when we Initiated our. Intensive field efforts, we have visited
 161 factories or plants which generate hazardous wastes and have
made 210 visits to sites where such wastes are disposed of.
                                -253-

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A  total of  /C  Illegal hazardous waste disposals  or unsafe  handling
practices  has. been found by our  Inspectors.   In most cases  these
Irregularities were rectified by  Informing  the waste handler of  the
law and providing him with guidance on proper methods to handle  and
dispose of  his waste.   In four cases the violations were serious
enough that we have sought legal  action.


Thr Hazardous Waste Control  Act requires  that each load  of hazardous
waste transported in California be accompanied by a manifest v;hich
describes the composition and volume of the waste.  Disposal :.K?
operators are required to sign the manifests when the waste loads
are accepted at their sites and mail copies to the Department on a
monthly basis.
We receive several thousand manifests each month and enter the
reported information into a computer.  Each month the computer
prepares a report that shows the  types and volumes of hazardous
wastes disposed of, the firms which generated the wastes, and the
disposal sii.cs used.  The computerized data aids the Department  1n
Its enforcement program and 1n program planning.

S_tud1es (Field Surveys).  The Department 1s conducting studies of
the generation of all hazardous wastes, including those which a>-e
disposed of on land owned by waste producers.  We are visiting
plants and  factories to determine the volumes and typos of  Industrial
wastes produced and how they are  disposed of.  The data will aid  the
Department  1n  its regulation of the management of hazardous  wastes
                                 -254-

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and 1n its development of periodic publications which will report to
the industries what types of wastes are available from other indus-
tries for use by them.

We have enlisted the help of local agencies to survey some of the
counties.  Six counties^ ' have been surveyed with the aid of
                                                    (2)
county or other local  agencies.  Nine other counties  ' are now
being surveyed by county health agencies with financial and technical
aid from the Department.  Fifteen other counties will  soon be sur-
veyed by Departmental  and county staff.  In February we expect to
have an estimate of the amounts of all  hazardous wastes disposed of
throughout the state,  including wastes  disposed of on  land owned by
waste producers.

                           PROBLEMS

Difficulties we have encountered have mostly resulted  from adminis-
trative problems inherent in the initial developmental phase of a
regulatory program.  The one significant exception is  that we do
not have a practical means to discourage clandestine disposal  of
   Amador, Alameda, San Benlto,  Santa Cruz,  Monterey,  and  Ventura
(2}
v 'Kern,  Kings,  Fresno, Madera,  Mariposa,  Merced,  San  Joaquln,
   Stanislaus,  Tulare
                             -255-

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hazardous wastes.   The throat of revocation of a permit needed to



handle hazardous wastes would provide a proper disincentive against



such activity, as  would the threat of iRposltion of a stiff monetary



fine.





Our proposed regulations will require that all operators of facilities



who transfer, store, treat, or dispose of hazardous waste have a



permit Issued by the Department and will provide for revocation of



the permit of any who violate the regulations.  We have proposed



.legislation for review by the Health and Welfare Agency and by the



Governor that would prohibit the hauling of hazardous waste by



persons who do not hold a license Issued by the Department and



which would authorize the Department to revoke the license for due



cause.





The  proposed  legislation would also ^.thorlze imposition of a sub-



stantial monetary fine for violations.  The Federsl Resource Recovery



Act  of 1976 provides a precedent for such  legislation, as 11 empowers



the  EPA  to  Impose monetary fines on violators of federal requirements.
                                   -256-

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    CONSIDERATIONS REGARDING HAZARDOUS
   WASTE REGULATORY POLICY ALTERNATIVES
             Rosalie T. Grasso
                  Manager
             Research Program
National Solid Wastes Management Association

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The Resource Conservation and Recovery Act 1976 (P.L. 94-580) at the
outset recognizes the greater potential for health and environmental harm
by requiring a greater degree of regulation than non-hazardous wastes
management.  The option to have or not to have a hazardous waste manage-
ment program has been eliminated with the passage of this Act.  We are
not here to discuss the greater potentials for harm in hazardous waste
management, but to discuss the different regulatory philosophies and
attendant enforcement options.  In conjunction with the need for health
and environmental protection, the law also stresses resource conservation.
This term is normally associated with resource recovery and materials
policy decision-making.   However, a policy of resource conservation
pervades all sections of the law, including Subtitle C, Hazardous Waste
Management.  Therefore if resource conservation (that is, the maximum
utilization of materials and optimum protection of resource -- land,
water and air) is adopted as a regulatory philosophy, the implementation
agency will bias its decision-making in the permit process with policies
to provide further requirements for materiel  recovery from residuals,
or energy potential, rather than solely a concern for the safe deposition
of hazardous waste to the land.  The Association through IWT-Chemical
Waste Committee and its  testimony throughout the legislative history of
               on
P.L.  94-580 and/several  EPA guidances on hazardous waste management has
supported consideration  of priority management alternatives(in order)
which are - waste reduction, waste separation, waste exchange, energy/
material  recovery, treatment secure landfill.   Given this scheme of
descending alternatives, the implementation agency-Federal,state-will
and can be expected to implement this philosophy in the permitting process.
For example, requiring that a specified percentage of a waste stream be
                                     -258-

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recovered or the prohibition of mixed wastes entirely in order to facil-
itate recovery.

The third goal of the act in relation to protection of public health and
environment is the prohibition of open dumps.  This will be evidenced
as an affirmative, direct aggressive program of enforcement to identify,
close or upgrade undesirable disposal options.  However, a less apparent
consideration is whether or not in developing regulatory provisions such
degree of control is mandated; thereby, resulting in severe financial
impact on acceptable disposal alternatives that open dumping is indirectly
fostered as a viable option.
In the development of a regulatory program and its components - rules,
standards, regulations, permit process, inspection and enforcement --
the maximum protection of human health and the environment, conservation
of resource, and the closing of improper disposal "lethods will  predominate
in the selection of regulatory options.

Criteria
Criteria for determining whether or not a waste is hazardous should be
based upon the characteristics of a waste rather than its functional
origins.  That is, a waste is hazardous because it is carcinogenic
(characteristic) rather than its generation by a commercial/industrial
activity (origin).  The identification of waste by source is an inventory
method, not a sole criteria for determination of degree of hazard.  The
conscious decision to solely regulate waste stream from commercial/
industrial should be based upon the known volume and types of hazardous
waste from those sources as a percentage of the total  volume of hazardous
wastes and the degree of hazard evidenced existing budgetary and staffing
                                     -259-

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limitations must also be reflected in determining the level  of enforcement
program feasible.  That is, if only given number of hazardous waste
sources can be monitored and regulated, selection should based upon the
type sources proportion to overall volume of hazardous waste generated
and the degree of hazard in specific waste stream type.  An  example,
several sources may generate a particular type waste (e.g.  "sludge").
The sources may be commercial, industrial, or institutional  facilities.
Based upon a given criteria for determining a hazardous waste, only a
few waste streams may be classified as hazardous, some of which may be
industrial and/or institutional.

Regulations should be based on criteria for waste characteristics  with
established thresholds as in given LD   -mg/ky body weight.   This  reg-
ulatory alternative will narrow and focus enforcement capabilities.
This alternative is preferable rather than a process of elimination
based on function, size or type of industry.

The development of criteria should consider —- oral toxicity, dermal
toxicity, acidity, alkalinity, inhalation toxicity, bioaccumulation,
genetic effect, aquatic toxicity, phytotoxicity, infectious, corrosivity,
flammability, and reactivity.  While data may not be available for all
waste types, the criterium should not be eliminated but developed.
Different levels of hazard can be determined on the basis of
     o direct exposure;
     o dilution-waste, leachate;
     o existing standards-air, water, transport.

The level of hazard should not solely focus on the impact of land  disposal
of hazardous waste.  The law requires Environmental Protection Agency  to
develop and promulgate criteria for hazardous waste determination  as
                                      -260-

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well as listing hazardous wastes.  Consequently, regulatory programs
in the long term can be expected to develop based upon waste characteristics
rather than solely upon point of generation of a waste.

The permit process can be responsive to this development and may provide
exemptions based upon level of toxicity, etc., volume, rather than by
specific identity of a source type.  Options may be available in deter-
mination of numeric levels for each characteristic dependent upon a
specific methodology testing such as standard leaching test, standard
attenuation procedure and NIOSH documentation.  Two generic approaches
can be taken in selecting numeric criteria for designating hazardous waste--
     o compatibility with existing definitions and
     o use of a reasonable scenario describing a manner in
       which a waste may pose a hazard.

If the latter generic approach is utilized, criteria may develop on the degree
of hazard posed by a v;aste characteristic at a point iii time in the inanacie-
ment program.  Permit ^nd licensing requirements may reflect that difference-
in degree of hazard, in transport, storage, processing and disposal.  Reg-
ulatory standards based upon criteria will  be different than those based
solely upon point of origin since no differentiation in degree of hazard
may be mad,e.
     Options in implementation of criteria-based regulatory program—
     o who shall  apply criteria? generator? transporter? disposer?
     o who incurs the expense of applying criteria?
     o how often must waste be tested? Each load? Only when a
       change in Stream occurs?
     o what if cost of testing is prohibitive?

Inventory Methods
Inventory methods based on criteria system will  vary from currently
practiced survey methodologies.  How a question  is asked and to whom is
                                    -261-

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crucial.  Questions usually are volume oriented and perhaps should be
weight oriented (weight of metals in solution versus gallons generated).
All possible sources of hazardous waste should be inventoried rather
than a selected SIC manufacturing population.  Most surveys previously
conducted are industrial surveys - not hazardous waste surveys.  The
results of the surveys determine the size, scope of program required,
whether or not environmental program coordination is required, type
and priority of regulation.  Program levels should be given priority
on degree of hazard rather than by category of industry.  Methods of
listing wastes on an inventory questionnaire may be by source, common
or generic name.  The usage of uniform waste listing approaches is
crucial in the comparison of information gathered in a survey
compilation to information received through a manifest system.

Regulations
Currently, most existing state programs place primary responsibility and
regulatory control  on .the disposal  site operator.  Frankly, this is the
weakest link in the decision-making chain.  By the time a waste has
reached a disposal  site all major economic decisions have been made.
The generator's, hauler's, storage  facility operator's  decisions
override those possible economic options which may be available to
the disposer.  In effect, he has no economic recourse but to dispose
of the material  in  most cases.  While this scheme places full  weight of
responsibility upon a landfill operator, since his capability to respond
is limited, the hazardous waste management program - especially enforce-
ment-is weakened and possibly rendered ineffective.  The new Federal law
clearly sets forth responsibilities of the generator, transporter, and
disposer.  But regulations to be developed will determine degree of
responsibility with the expectation that the responsibilities of the
                                      •262-

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generator will expand significantly.  Alternatives also exist in
regulatory process  in developing permits, providing for exemptions and
variances, degree and frequency of inspection.  The alternatives break-
down into two categories - administrative and technical.  In most cases
administrative procedures for review are addressed in already enacted
Federal and state laws.  However, a degree of consistency in administrative
processes is hoped  for, especially in those situations where several
environmental permits are required.  For example, Washington State has
provided for a "one stop" permitting process and the Minnesota Environ-
mental Quality Council is reviewing such a proposal.  The EPA should  be
cognizant of this procedure in reviewing state's application for interim
and permanent authorization.

Technical: decide actual  economic impact to applicant,especially if
best available technology is considered as a criteria in facility design
review and applied to monitoring, leachate collection, site selections,
emission control  requirements.  The purchasing of materials, system
design, service provisions will  be affected and costs significantly
increased.  Stress should be placed on performance rather than operating
standards.  That is, a level of protection rather than specific method
of accomplishment should  be considered in the permit review process.
Technical  determinations  can be applied to--
     --definition determine scope of program, and level  of enforcement
     --permit requirements, length of time of permit
     —financial  responsibility and establishing degree  of
       liability of unanticipated damage
     --manifest requirements

Time Frame
The scope of hazardous waste program is also dependent on time frame
for development and implementation.  The time frame of Federal law
                                     -263-

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appears to be 3 years.  The time frame cf reference varies for
administrator, operator, generator.  Administrator may determine -
18 months intervals - 3 year with review.  However, hazardous waste
facility operator makes determination on 10 year intervals.   An
administrative planner may think of two stage program - 18 months
develop regulatory program, 1 year for implementation, and 3 year review
schedule.  All involved parties must recognize the impact on program plannina
of a start versus long time frame.

Interstate Compacts
The law provides for "establishment of such agencies,  joint  or otherwise,
as they may deem desirable for making effective agreements or compacts."

While compacts for air and water programs are contiguous, hazardous
waste management occurs in economic corridors which are not  necessarily
contiguous or encompassed by geographic rec.ion.  Therefore,  compacts
between states which are not contiguous may be expected, especially in
the enforcement of a manifest program.
                                     -264-

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                   The  Role of 208 Regional  Planning
                Organizations in Solid Waste Management
                                  by
                     Robert A.  Colonna,  President
                        Decision Systems,  Inc.
       When the Federal Water Pollution Control Act (FWPCA) was passed in
1972, Section 208 called for areawide water planning,  and implementation
programs to carry out these plans.  The objective of this section was to
provide adequate State and regional planning to protect the ground and
surface waters of this Nation.

       The complexity of Lac: problem ib LhaL major metropolitan areas dis-
charge millions of tons of industrial and municipal wastes each year into
the ocean, inland waterways and on the land.  Only some of these wastes
are discharged into sewers for primary and secondary treatment.  The balance
is dumped, untreated, into these  three sinks:  the ocean, inland waterways,
and on the land.  Even the wastes which reach treatment plants are only
regulated with respect to the water effluent; the solid portion, which con-
tains many potciitially hazardous materials,  is disposed in many cases,
without adequate regulation.

       Each year, this Nation generates 135  million tons of municipal
waste, 270 million tons of industrial wastes, and 40 million wot tons of
sewage sludge  — and  these quantities are growing every year.  Approximately
907. of the municipal  wastes, and  over half of the industrial wastes and
sewage sludge  are deposited on the land.  If not disposed of properly,
leachate  from  these wastes reaches ground water which, at best, is  left
discolored and odorous, and at worst,  is rendered non-potable.  Approxi-
mately 90 million gallons of  leachate  is generated nationally  each year,
                                      -265-

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an unknown portion of which readies ground water.   Once ground water is
contaminated it is too costly to attempt to clean it up and it must be
abandoned as a drinking water supply.   Alternatives may mean transporting
water great distances, also a costly remedy.  Since 507= of the Nation
uses ground water for drinking, this is potentially a serious nationwide
problem, and one which cannot be ignored.

       An implicit part of the 208 water planning and management program
is the development of a residual management plan which can be implemented.
Specifically, sewage sludge processing and disposal was to be covered by
Section 208 according to the legislative intent of the Act.  However, since
many localities and regions currently combine sewage sludge and municipal
wastes  (garbage and trash), and since, in the absence of pretreatment regu-
lations, many industrial wastes empty, untreated, into sewage treatment
systems, the residuals problem cannot easily be segmented.

        Section 208 of the FWPCA defines residuals as any solid or  semi-
solid waste m-iterlal vhich may result in ground or t,urfai_u wai_er contam-
ination if disposed of improperly on the land.  As you can see, the de-
finition is very broad, and docs include mixed municipal wastes.   Like
most laws, the language of 208 is broad  in  its scope and leaves to the
states  and local government a narrowing of  the definition  according to
their priority needs.
        A major question that has arisen  in  the progress of 208  is  "what
is  the  role  of existing local,  regional,  and  State  solid waste  planning
agencies"?   It  is  the intent of  the 208  program  to  involve these agencies
as  an  integral part  of  the process.   They  have  the  solid waste  or  residuals
expertise,  and  in  many  cases have  developed or  are  developing a residuals
plan.   These plans contain  the basic  data  and analysis for good decision
making, and  if  utilized,  should accelerate the  achievement of 208  goals.
 It  is  the intent of EPA to insist  that  these agencies  be  used and  not
 ignored.   Guidance to this effect  has been given to all 208 agencies in
 a series of ten regional  seminars  over the past six months.
                                        -266-

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       However, in spite of these efforts to include existing solid waste
management planning agencies and service companies,  some may be overlooked
by the 208 agencies.   In most cases this will he through an oversight —
not being aware of the work that is already being done to insure proper
solid waste disposal.  All oi you who  are a part of an existing solid
waste planning department, or a member of a local association of NSWMA
should find out from the Water Planning Division of EPA, the name and address
of the 208 agency in your area, and contact them directly with your infor-
mation concerning current solid waste management activities in your region.

       Another difficulty is the variability in level of involvement at
the State level.  In all cases, the Governor has the authority to desig-
nate regional 208 agencies.  In regional areas which are not so designated
(and, in the extreme, this may be the entire State) a State agency, also
designated by the Governor, assumes the 208 planning and management
function.  So some states have chosen to engage in an active role, while
others pass the responsibility (and the funds) to the regional agencies.

       The operational system  for dealing with residuals is in place, to
some extent, in every community.  Private companies and government
agencies are collecting, processing, and disposing of municipal wastes
already.  Many arc performing  these tasks in an economical and environ-
mentally-sound manner.  In  the case of  sewage sludge and industrial wastes,
there is less public visability, so, to date, only the most responsible
companies and agencies have  been concerned with the environmental  impacts
of  its methods of waste disposal.

       The  208 program  is more  than a planning program, which  is  a fact
that has escaped many in  trying  to understand the goals of  the program.
It  is the  intention  of  the  program to develop a residuals plan and imple-
ment it  through  "an  appropriate management agency".  Herein  lies  additional
opportunity  for misinterpretation by  the  208  agency.   In many  parts of the
country, regional  or local  management agencies  already  exist  for  residuals.
                                       -267-

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Such management agencies might reside in a COG, a public works depart-
ment, a sanitary district, etc.  In the case of private sector perfor-
mance of services, the' management agency might be the one that develops
the bid specification, and issues the contract for services.  In any
event, 208 intends for there to be implementation of its plans, other-
wise the entire process will have been a waste of time and money.

       Regional agencies which do not have management authority, will
need to form a new agency, with the political and financial backing of
the local governments in the region.  Since bonding authority is fre-
quently required for capital-intensive solutions, it is important for
the management agency to have  this authority.  An example of how this
lias worked successfully is the Southeast Oakland County  (Michigan)
Incinerator Authority.  In this case, fourteen communities  formed an auth-
ority to purchase, own, and operate an incinerator.  Moreover, they agreed
to share cost and performance  data on their waste collection systems in
an effort to work toward more  efficient  .systems.  Some communities
performed waste collection themselves while others decided  to contract
to private haulers; but all used the incinerator for volume reduction
and  subsequent disposal.

        If a cognizant management agency  does  not currently  exist,  it
would be appropriate  for  208  agencies to begin the process  of developing
a management agency early  in  the planning  cycle  since  it  will  take  some
time and political effort  to  develop  such  an  institution, and  the  plan
can  then be better  tailored  to meet  the  realistic authority and financial
capability  of  the management  agency.

        Finally,  the  latent information  on the additional -monies available
 in  the  208  program  is as  follows:   $137  million  dollars will  be available
 to  Regional  Offices  by the end of December.   Some  portion of  this money
 will be used  to raise the federal  share of existing grants  from 75% to
 100%.  Additionally,  some portion will  go directly  to states.   Finally,
                                        -2S8-

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a great deal of discretion will be exercised by  regional  offices on
how this money is spent.   Therefore, the amount  of new funds to be
spent on residuals will be up to each region, with some guidance
provided by EPA headquarters.
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  THE ROLE OF THE PRIVATE SECTOR IN REGIONAL SOLID WASTE
                    MANAGEMENT PLANNING

                       Mary Ann Dean
                          Manager
                    Legislative Program

     To date, there has been little participation by the
private solid waste management sector in regional solid waste manage-
ment planning.   This is partially because legislative initiatives for
regional solid waste management olanning are just now getting
underway.   While states such as Michigan, Missouri, California and
Florida provide for county plans, the recently enacted Federal
"Resource  Conservation and Recovery Act of 1976" is the first require-
ment for states to consider comprehensive regional planning for solid
waste management, including hazardous waste management and resource
recovery.
     Under the new Federal law, the U.S. Environmental Protection
Agency is  required to publish guidelines by April 1977 for identifying
regional solid waste management areas.  The States with the help of
municipal  and local officials are responsible for designating regional
planning areas and agencies, as well as determining which functions will
be conducted on a state level and which functions will be conducted on
a regional or local level.  The law specifically requests that con-
sideration be given to designating existing 208 wastewater treatment
agencies.
     It is unclear, however, whether designation of existing
208 agencies will be for both planning and implementation.  Under the
                                -270-

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Federal Water Pollution Control Act of 1972, there are two separate


designation processes, one for planning and one for implementation.


The majority of 208 planning agencies designated to date have been


general purpose units of government who have responsibilities in other


areas as well, such as in transportation and in housing and community


development.  In general they do not have the authority necessary to


implement these plans.  This authority is provided by the second


designation process for 208 wastewater treatment management agencies.


To be designated as a management agency an agency must have the


authority to directly or by contract design, construct, own and


operate new and existing facilities, incur indebtedness, and raise


revenues.


     The new Federal "Resource Conservation and Recovery Act of 1976"


combines the designation process for both planning and implementation

                                      r
without defining the criteria of either.  The concern of the private


solid waste management industry is that while designation of existing


208 planning agencies may be appropriate for solid waste management


planning, designation of 208 management agencies may be very


inappropriate.  Local or municipal wastewater treatment agencies


are likely to be designated as the implementation agencies.  These


agencies are largely unfamiliar with solid waste management issues or


problems, or with the private sector in\olvement in this field.


Unlike the solid waste Industry which is predominantely serviced by


the private sector, municipal wastewater treatment facilities are


generally publically owned and operated.
                                  -271-

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          EPA's Office of Water Planning and Standards and Office of

Solid Waste recognized the low priority being given by the 208 agencies

to land disposal problems, particularly the problems of potential

migration of leachate into ground waters.  In response the agencies

made a formal agreement to allocate both funds and technical expertise

to these problems.  As mentioned earlier, EPA has conducted 10 regional

seminars this year to encourage the 208 planning agencies to become

aware of residual management planning, including solid waste, hazardous

waste and resource recovery planning.  For the first time, many of

these 208 agencies began thinking about solid waste management planning.

EPA has also outlined a suggested minimum level of study by 208 agencies

for residual management.  The agencies are asked to estimate landfill

capacity in the area, examine soil conditions, locate existing surface

and groundwater supplies.  The agencies are also asked to determine
                       •«
if existing sites have adequate life and are in compliance with

regulatory policies, and if they are not, the agencies are asked to

include in their plan suggestions for new site locations.  Clearly

the public and private solid waste management sector needs to become

involved in providing these agencies with the necessary input

to insure that all alternatives have been considered.  The

Association and industry members have attended many of the

regional seminars in an attempt to become more familiar with the

agencies and their problems and to illustrate the concern of this

industry in addressing these problems.  However, there are over

149 designated 208 planning agencies in various stages of their

planning process.  Therefore it will require a major undertaking by

the solid waste management industry to develop a working relationship


                                   -272-

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 with each of  these agencies  in addition to  any  new  agencies  designated under




 the "Resource Conservation and Recovery Act."   I might  add that  this  is  only




 the first stage of involvement.  The  Act clearly intends  for these plans  to




 be implemented. Who  implements, and  how they are implemented will be equally




 important and will shape  the operational capability of  the private solid




 waste management industry in the future.




                   There are  sev'eral ways for the private  sector  to become




 involved.  Most 208 agencies use advisory committees in developing their




 plans.  Membership on an  advisory  committee will be governed by  their




 Administrative Procedure  Regulations.   But clearly  the  first step is  getting




 involved  and  requesting it.  The agencies also  seek public involvement through




 public hearings, meetings and  newsletters.  The Association  on behalf of the




 solid waste management industry has requested to be placed on the newsletter




 mailing list  by all 208 agencies,  and in return will provide  technical and




 planning  information  to these  agencies.




                   In  addition  to becoming involved  in the planning process of




 the existing  208 planning agencies, the  private sector needs  to become




 actively  involved  in  the  implementation  of the new  Federal act.  The new




 Federal act specifically  requires  public participation  in the development,




 revision,  implementation  and enforcement of the regulations  and enforcement




 of  the act.   Federal  guidelines are required to be  designed  to foster coop-




 eration among Federal, State,  and  local  governments and private industry.




.Agencies  receiving Federal financial assistance are requested to consider




 existing  solid waste  management services as well as facilities proposed for




 construction.   However, while  the  mechanisms have been  outlined by the legis-




 lation to allow for public participation, the private sector must take the




 initiative in getting involved.
                                         -273-

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                  Involvement needs to be on several levels, Federal, state,




regional and local.  On the Federal level, private industry needs to be first




involved in providing input to EPA on factors to be considered in establishing




guidelines for identification of regional planning areas.  These guidelines




are already being drafted and, will be promulgated next April.  Information




is necessary on the size and location of appropriate areas for solid waste




management areas, including resource recovery and hazardous waste management,




the volume of solid waste which should be included, and the means of coordi-




nating regional planning with other related planning in the area and with




the overall state plan.  These guidelines must be flexible if they are to




deal effectively with the existing services and facilities.  EPA will recommend




usage of existing 208 unless they receive information illustrating where an




existing 208 is not appropriate.




                  The second area of involvement is on the state level.   The




state, in cooperation with local governments will not only designate tlie areas




and agencies, but also wilL identify what areas of solid waste management will




be handled on a state level and what will be done on a regional or local level.




The process is designed to give maximum flexibility to state and local govern-




ments.  Therefore, the number of regional and local planning agencies and the




level of planning delegated to each agency will vary from state to state.




Several states such as Alabama, Tennessee, Arkansas and Indiana have already




passed legislation authorizing local authorities to expand their jurisdiction




.to include solid waste.  Alabama, for example, recently passed legislation




authorizing sewer districts to provide solid waste collection and disposal




systems.  The relationship between local and county plans with the new overall




regional plans to be developed will have to be defined state by state. California,




has been the first to my knowledge in defining this relationship.
                                          -274-

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                  The State Solid Waste Management Board in California has

already passed a resolution stating that the state approved county solid

waste management plans will be recognized and adoped as the solid waste

management component of the 208 plans.          t

                  Finally, on a local and county level industry will have to

continue its involvement in the planning process, while a regional level

industry will need to become involved in providing information to be utilized

in the formulation of the plans, such as demographic data, statistical data

on the amounts of waste generated and other information necessary to determine

what functions can best be handled on the regional level.

                  In conclusion, regional planning has expanded the areas in

which industry must become involved.  Participation in each area will vary

according to the agency involved, states and regional and local agencies

will develop individual schedules and procedures for preparing plans and

participating in the formulation of those plans.  There are potential benefits

of regional planning, given the proper guidance, assistance and support.
                           **
Whether the private solid waste management industry shares in those benefits

will depend on their ability to become involved in both the planning and

implementation process.
                                         -275-

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               LINERS - VIABLE OPTIONS AND THEIR APPLICATIONS

                             Henry E.  Haxo, Jr.
                               Matrecon, Inc.
                                Oakland, Ca.

     We are all well aware of the vast quantities of wastes that are discarded by
our highly technological and urban society.  In spite of the many efforts to de-
                           these wastes
velop new methods of disposing of/or utilizing  them    f  we can expect that the
storage and disposal of wastes on land will continue to rise for many years.  At
the same time, we can also expect an increasing potential for pollution of the
ground and surface water by these wastes or by leachate being generated in the
wastes, percolating through, and carrying with it dissolved and suspended biologi-
cal and chemical products.
     Proper selection, design, construction,  and operation of waste storage and
disposal sites  can minimize pollution. However, the availability of acceptable
disposal sites is decreasing because of environmental and economic impact.  Fur-
thermore, there are geographic areas of high humidity and rainfall or high water
tables which pose special problems.
     The concept of lining a disposal site with impervious barriers is being con-
sidered as a means of controlling leachate from wastes and preventing it from en-
tering the ground water system.  A wide variety of impervious materials has been
used to line ponds, lagoons, canals, and small lakes.  Materials such as these
might also be used to control leachate and hazardous wastes.  However, little is
widely known about the behavior of these materials on prolonged exposure to land-
fill leachate and to other hazardous wastes.
     In this paper, we discuss the various materials which might be used as im-
permeable barriers, with particular emphasis on those potentially useful in lin-
ing sanitary landfills.  We report on progress in two current engineering re-
search projects sponsored bv EPA to assess various liner materials exposed to
landfill leachate and to hazardous wastes.
                         LINING ft SANITARY LANDFILL
     The sanitary landfill is an acceptable and recommended method of disposing
of solid wastes when sound engineering principles are followed in site selection,
design, construction, and day-to-day operations are highly controlled to minim-
ize odor, vector attraction, fire hazards, blowing of paper, and maintenance of
good appearance.
                                       -275-

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           Nonetheless, leachate containing a wide range of chemical and organic
 constituents, such as shown in Table I, can be generated in a landfill by water
 entering the fill, dissolving salts and products of the decomposition of the
 refuse.  Such leachates can contaminate and pollute the ground water.   It is
 estimated that more than 60% of the landfills in the United States will produce
 leachate during their lifetimes.
 TABLE I - RANGE OF COMPOSITION OF 1'YPICAL LEACHATES FROM SANITARY LANDFILLS

                Constituent                     Concentration
	Range*	

             Iron                                200 - 1700
             Zinc                                  1 -  135
             Phosphate                             5 -  130
             Sulfate                              25 -  500
             Chloride                            100 - 2400
             Sodium                              100 - 3800
             Nitrogen                             20 -  500
             Hardness (as CaCO )                  200 - 5250
             COD                                 100 - 51,000
             Total residue                      1000 - 45,000
             Nickel                             0.01 -  0.8
             Copper                             0.10 -  9.0
             pH                            '     4.00-8.5

 * All values except that for PH are in mg/1.
           To prevent the seepage of leachate,  with its  high concentration of
 pollutants,  into the surface and ground water, landfills can be isolated from  the
 ground by placing an impervious  layer between the landfill and the ground.
           The concept of using an impervious  barrier as a liner for a  landfill is
 basically simple as is illustrated in Figure  1.   An impervious material is  placed
 upon a properly  prepared surface that is graded  for drainage.   The amount  of sur-
 face preparation depends on the  specific type  of  liner  material being  Installed
 and  on the soil  base on which  the  liner  is being placed.   This  surface must be
 free of stumps and  rocks  and should be  compacted.   The  liner can be several  feet

                                       -277-

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             LL.
             Q
             01
             CO

             <
             CL
             LU
             O

             O
             O
-278-

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     in thickness or only a fraction of an inch; it can be compacted native fine-
     grain soil, clay, asphaltic concrete, polymeric membrane, or other artificial
     barrier.   Porous soil or sand should be placed on the liner through which leach-
     ate can flow and on which refuse can be compacted in the manner normally done in
     sanitary landfills.  Leachate percolating through the refuse will be intercep-
     ted by the barrier and drain through the porous layer.   It can be collected for
     ultimate  disposal in a sanitary sewer system or a leachate treatment system, or
     be recycled through a landfill to hasten stabilization  of the fill.
     It is these liners which we will discuss in this paper.  Let us consider
first the requirement of a liner and the environment in which it must exist.
                    ENVIRONMENT OF A LINER IN A LANDFILL
     The primary purpose and function of a liner is to prevent the passage of
pollutants, such as leachate, for extended periods of time.  In the case of a
landfill, it may mean decades until the fill has stabilized and the potential
for leachate generation has fallen to safe limits.  To fulfill its function, a
liner must be impermeable to water and the contaminants and must maintain its
structural integrity.
     Liner failures vary with the type of material.  A liner can crack, be punc-
tured, fail at a seam or interact with the medium being confined.  The useful-
ness of a liner depends upon the material and the environment in which it is ex-
pected to operate.
     Some of the environmental conditions at the bottom of a landfill should have
little or no adverse effect on a given material, while other conditions may be
quite deleterious.  Conditions which exist at the bottom of a landfill that prob-
ably affect the service life of a liner are:
          1)  The liner is placed on a prepared surface, which has been
          graded to allow drainage, compacted, and presumably free of
          rocks, stumps, etc., but which may settle to cause breaking or
          cracking of hard material.  A brittle or weak material would fail.
          2)  Anaerobic condition with no oxygen to cause oxidation.
          3)  No light which normally degrades many organic and poly-
          meric materials.
          4)  Generally wet-humid conditions, particularly if leachate
          is being generated regularly, which could result in the leaching
          of ingredients from a liner.

                                           -279-

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          5)  Cool temperatures of 40 - 70 F normally, although higher
          temperatures are generated within the fill when   aerobic de-
          composition takes place.

          6)  Generally low pH from acidic leachate.
          7)  High concentration of ions in the leachate which, in the
          case of clay, may ion-exchange and flocculate the clay and
          thus increase permeability.
          8)  Considerable dissolved organic constituents in the leach-
          ate which may degrade some of the liners of organic materials.
          9)  Only modest head pressure, since drainage above the liner
          is designed to take place continually through the porous soil
          placed on top of the liner.
     The effects of these environmental conditions will differ on the various bar-
rier materials.  However, it appears at present that mechanical failure during in-
stallation or during operation of the fill due to settling of the soil may be the
most significant source of failure of a liner.
             POTENTIAL MATERIALS FOR LINING SANITARY LANDFILLS
     Typical of the wide range of materials which have been or are being used as
barriers to the seepage of water and hazardous toxic wastes in holding ponds, pits,
lagoons, canals, reservoirs, etc., are those listed in Table II.  Selection of lin-
er materials for a specific job depends upon the type of fluid or waste being con-
fined, the types of materials which can perform for the lifetime needed and econom-
ics.  Often several materials can be used and the choice then becomes one of eco-
nomics and the length of time which the liner should function.  At times it may be
desirable to use combinations of materials.
     Some of the earliest man-made lining materials are those based upon compacted
soils, asphalt, and portland cement.   These are admixed materials which are gener-
ally formed or mixed-in-place at the site.   Several of the more well known admixed
materials are discussed below:
          1.  Native fine-grain soil,when available nearby,  is imported
          to'tne site and compacted as a liner.   Permeabilities of 10
          cm/sec, can be achieved.  This is often used for containing
          water.
                                        -28C-

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TflBLE II. POTENTIAL MATERIALS FOR LIKING SANITARY LANDFILLS^

Compacted native fine-grain soils.
Bentonite and other clay sealants.
  - Bentonite - polymer sealants.
Asphaltic compositions
  - Asphalt concrete.
  - Hydraulic asphalt concrete.
  - Preformed asphalt panels laid on concrete surfaces.
  - Catalytically-blown asphalt sprayed on soil.
  - Emulsified asphalt sprayed on soil or on fabric matting.
  - Soil asphalt.
  - Asphalt seals.
Portland cement compositions
  - Concrete with seals.
  - Soil-cement with seals.
Soil sealants
  - Chemical
  - Lime
  - Rubber and plastic latexes.
  - Penetrating polymeric emulsions.
Liquid rubbers sprayed
  - Rubber and plastic latexes.
  - Polyurethanes.
Synthetic polymeric membranes
  - Butyl rubber -
  - ^lasticized polyolefin.
  - Lthylene propylene rubber (EPDM).
  - Chlorosulfonated polyethylene (Hypalon).
  - Chlorinated polyethylene (CPE).
  - Polyvinyl chloride (PVC).
  - Polyethylene  (PE).
                               -281-

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2)  Bentonite and treated bentonite are well known in the pe-
troleum industry and also in the sealing of ponds and lakes.
These are expansive clays and can be mixed in or deposited on
permeable soils to form adequate seals for water.  Water perm-
eabilities of 10   cm/sec can be achieved with these materials.  How-
ever, with saline waters these materials will eventually lose impermeability.
3)  Conventional asphalt concrete, hot-mixed and hot-laid, is
widely used for paving and is readily available.  Contractors
are experienced in its placement and have the necessary equip-
ment.  It presents a hard surface, resistant to traffic  and
impact forces,  and as resistant to acids and to aging, espec-
ially in the absence of light and air.   As  it  is designed to have
a voids content of about 5% ,  it  is  not  completely impervious •
therefore, a. surface treatment to seal t>-e wot^s ">?« *•«>.
4)  Hydraulic asphalt concrete, also hot-mixed and hot-laid,
is especially designed to be impervious.  Low permeability
is achieved by controlling the gradation of the aggregate and
the asphalt content to obtain a virtually voidless structure
after compaction.  Its other properties are similar to those
of asphalt concrete.  Hydraulic asphalt concrete is mixed, laid,
and compacted with the same equipment used for conventional as-
phalt concrete, but is more difficult to handle.
5)   Soil-cement is made by mixing the in-place soil with port-
land cement and water, and compacting the mixture.  As the port-
land cement hydrates, the mixture becomes a hard, low-strength
Portland cement concrete.  Soil-cement is sometimes used as a
surface for pavements with low- traffic volume, and is extensiv-
ely used for the lower layers of pavements, where it is called
"cement-treated base."  Strong soil-cement can be constructed
with many types of soil, but permeability varies with the nat-
ure of the soil; the more granular the soil, the higher the
permeability.  With fine-grained soils, soil-cements with perm-
eability coefficients of about 10   cm/sec are achievable.  In
practice, surface sealants are often applied to the soil-cement
to obtain a more waterproof structure.  Aging characteristics
                              -282-

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          of soil-cement are good, especially under conditions where wet-
          dry and freeze-thaw cycling are minimal.  Some degradation of
          the cement can be expected in an acid environment.
          6)  Soil asphalt of mixed-in-place asphalt surfacing is made
          by mixing a liquid asphalt with the in-place soil or with im-
          ported aggregate.  It is widely used  for low-cost pavements
          for low-volume traffic.  Permeability characteristics can be
          controlled by the amount and type of asphalt added.  Soil as-
          phalt is more flexible and resistant to cracking than asphalt
          concrete or soil-cement, and has good aging characteristics in
          the absence of light.
          7 )  Catalytically-blown asphalt membranes have been used ex-
          tensively as linings for canals and reservoirs and to seal off
          layers of expansive soils under pavements.  This type of as-
          phalt is produced by air-blowing in the presence of a catalyst
          (phosphorous pentoxide or ferric chloride), which produces an
          asphalt which has a high softening point, yet remains flexible
          at low temperatures.  Membranes are applied to compacted, smooth
          soil surfaces by spraying the hot (200 to 220 C) asphalt in two
          successive applications to insure a continuous film free of pin-
          holes and holidays.  Aging resistance is good when protected
          from light.  It is usually covered with a protective layer of
          soil to prevent damage by traffic and deterioration by light.
          8)  Bituminous seals of asphalt emulsion can be applied on soil
          at temperatures above freezing.  They form continuous films of
          asphalt after breaking of the emulsion and evaporation of the
          water.  The films are less tough and have lower softening points
          than films of hot-applied, catalytically-blown asphalt. However,
          toughness and dimensional stability can be achieved by spraying
          asphalt emulsions onto a supporting fabric.  Fabrics of woven
          jute, woven or nonwoven glass fiber,  and nonwoven synthetic fi-
          bers have been used with various anionic or cationic asphalt
          emulsions to form linings for ponds and canals.
     Polymeric membranes are assuming increased importance as liner materials be-
cause of their very low permeability to many fluids and water.  These membranes
are made in the plastics and rubber industry and are manufactured in the form of
sheeting of 10 to 125 mils thickness and widths up to 20 feet.  Compounds based
                                       -283-

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on the same polymers can vary considerably among liner manufacturers, depending
upon the grade and price.  They are made both with and without fabric support.
Generally, the sheeting is made by calendering of two plies and fabric, if de-
sired.  The two plies are used to avoid pinholes through the sheeting.  Both
vulcanized and nonvulcanized or thermoplastic polymers are used.  The liners
are brought to the site in the form of preassembled panels which are then
seamed in the field.  Field seaming is one of the major problem areas in the
use of polymeric liners.  Heat sealing, cementing and solvent welding are used
both in the factory and in field seaming.  Vulcanized sheetings have presented
the most problems, particularly on the field.  Cold-curing adhesives usually
are required to make the seams.
     The polymers which are being used for the manufacture of liners, or show
particular promise, are discussed below:
          l)   Butyl rubber is a copolymer of isobutylene and isoprene,
          usually supplied as a vulcanized compound.  This rubber is
          well known for its impermeability, both to air and water.  A
          butyl rubber sheeting was the first polymeric material to be
          used for pond lining and an installed liner has shown no deg-
          radation after more than 20 years of service.
          2)   Chlorinated polyethylene (CPE)is a thermoplastic material
          produced by the chlorination of polyethylene.  As a completely
          saturated material, it is not susceptible to ozone and has
          good crack and low temperature resistance.
          3)   Chlorosulfonated polyethylene  is a saturated rubber
          having excellent weathering, ozone, and sunlight resistance.
          When vulcanized, it is highly resistant to a wide range of
          chemicals, but is generally supplied in an unvulcanized form
          which swells in oil and some chemicals.
          4)   Elasticized polyolefin is a recently developed material
          which is furnished in a thermoplastic form.  It has excel-
          lent chemical and weathering resistance.
          5)   Ethylene propylene rubber is a terpolymer of ethylene
          propylene with a minor amount of diolefin to allow it to be
          vulcanized.  It has excellent weathering and ozone resistance
          and is sometimes used in blends with butyl.
                                       -284-

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         6)  Polychloroprene, or neoprene.is  supplied  as  a vulcanized
         rubber compound.   It features oil and chemical resistance;
         however,  it  is relatively expensive  and  is usually used  in
         special applications.
         7)  Polyethylene is well known as a  film in construction and
         has high  chemical  and weather resistance if supplied  in black
         compounds.   It is  easy to puncture during installation.
         8)  Polyvinyl chloride is the most widely used polymeric liner.
         The PVC compound is thermoplastic, containing 30 to 50% plasti-
         cizer and about 2% stabilizer.  Because  of plasticizer volatil-
         ity, these materials are generally covered to avoid loss of
         plasticizer  and to furnish protection from light.
               CURRENT RESEARCH IN THE EVALUATION OF LINERS
    The Municipal  Environmental Research Laboratory of EPA is  sponsoring two en-
gineering  research projects which are being  conducted by our  laboratories with
the assistance of  the Sanitary Engineering Research Laboratory of the University
of California, Berkeley:
         • Evaluation of liners for sanitary  landfills.
         • Evaluation of liners for impounding hazardous wastes.
    The overall objectives of these studies are to determine the present state
of liner technology as it might be applied on a practical scale 'to confining
wastes.  Specifically, we are evaluating a variety of  liner materials, exposed
over a 3 to 3>j year period, to leachate generated in municipal refuse, and to
a range of hazardous  wastes.  These projects are now scheduled for completion
in mid-1978, at which time we expect to be able to make an assessment of the
performance of the different liner materials and  to estimate their service
lives, based upon  the changes in their properties and  permeabilities during
the exposure period.  Ultimately, we expect to be able to write specifications
for liner materials based upon performance.
    We shall concentrate our discussion on the first of these projects, liners
for sanitary landfills; however, much that is said about this project is also
pertinent to the second.
                                      -285-

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            9 ) To determine the composition of the shredded refuse from
            a  blend of grab samples  taken during the loading of  the cells.
            10)  After the refuse in the cells is saturated, i.e. brought
            to "field capacity", to  generate leachate by adding  one inch
            of tap water every two weeks (26 inches per year) and allow
            leachate to pond on the  liner at a depth of about one foot.
            11)  To monitor the simulated landfills, characterizing the
            leachate during exposure period to insure proper conditions
            exist in the refuse.
  Experimental Program -
       To simulate the actual conditions which exist at the bottom of a landfill,
  24 generators were constructed, as shown in Figure 2.  Each consists of a 10-
  foot steel pipe, 2-feet in diameter, mounted on a concrete base in which a lin-
  er approximately 2-feet in diameter is sealed in position with epoxy.  Two spec-
  imens of each of the 12 primary liner materials were mounted;  one group of 12  to
  be exposed for one year and the second group for two years.  Draining can be per-
  formed above and below the liner to measure the permeability of the liner.  The
  pipes were lined with a polyethylene sleeve and the interiors  of the concrete
  bases were coated with a chemically-resistant epoxy resin.  The pipe was sealed
  to the base  with a neoprene sponge gasket and mastic seal to insure airtightness.
       Each pipe was filled with 24  cubic feet of shredded municipal refuse com-
  pacted to 1240 pounds per cubic yard at a water content of 30%; a soil cover of
  1.75 feet was then placed on the refuse, followed by three inches of drain rock.
  This design  simulates approximately one lift of refuse in a sanitary landfill.
       For our tests, we selected 12 primary liner materials, six of them admixed
  materials:
                           Paving asphalt concrete
                           Hydraulic asphalt concrete
                           Soil cement
                           Soil asphalt
                           Bituminous seal
                           Emulsion  asphalt on fabric
  and six polymeric liner membranes:
                           Polyethylene
                           Polyvinyl chloride
                           Butyl rubber
                           Chlorosulfonated polyethylene
                             (nylon  scrim reinforced)
                           Ethylene  propylene rubber
                           Chlorinated polyethylene.
Elasticized polyolefin had not  been developed when the  selection was  made.
Therefore,  it was not included  in the initial program.
                                         -286-

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LINERS FOR LANDFILLS -
General Approach -
    Considering the wide diversity in the types of materials which are candi-
dates for lining landfills and the urgent need for information regarding their
performance and durability in a landfill environment, our overall plan has
been:
         1^   To expose a variety of representative liner materials to
         typical landfill leachate under conditions simulating real-
         life and measuring the physical properties as a function of
         exposure time, for a period of 3 to 3>j years.
         2)   To select for exposure testing 12 types of liner materials
         from among those which have been successfully used in lining
         pits, ponds, lagoons, canals, etc., to prevent seepage of wa-
         ter or various wastes and which appear suitable for lining
         sanitary landfills.
         3)   To accelerate the possible effects of the leachate by se-
         lecting thinner liners than normally used in the field.
         4)   To expose liner specimens to leachate on a pilot scale
         which simulates, as closely as possible,  those conditions that
         a liner would encounter at the bottom of a real landfill.
         5l   To expose specimens of sufficient size so that physical
         tests can be made to measure the effects of exposure to leach-
         ate and, if appropriate,  a typical seam can be incorporated
         for testing.
         6)   To subject the liner specimens to appropriate tests for
         the specific type of liner.   Properties would be measured
         which could be expected to reflect on the performance of the
         respective liners in sanitary landfills.
         7)   To seal the liner specimens in individual simulated land-
         fills so that whatever seepage might come through can be col-
         lected and tested.   This cell and generator would perform as
         a large permeameter.
         8)   To create equal conditions in all simulated fills,  so that
         valid comparison between liners can be made.
                                      -287-

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    iHRLDDED REFU6E
    COMPACTED TO fl PT.
    THICKNESS
       CONCRETE
IEACHATE DRAIN FROM REFUSE*
TO COLLECTION BA(j
                                0
                                          0
                                          -\
                                                        DRAIN ROCK  V THICI"
                                                    • 50IL COVER
                                                     iVVFT. THICK
                                                    • POLYETHYLENE LINER
                                                    - REFUSE COLUYSN-
                                                     4PIRAL-WELD PIPE,
                                                     Z+" DIA. * 10 FT. HIQH
-MASTIC 6EAL

   5AND
   LINEK •SPECIMEN
  -CA'iT EPOXY RESIN RINQ
   QRAVEL
   LEACHATE. DRAIN THEU LINER
  TO COLLECTION BA
-------
     Soils and clays were specifically excluded by EPA from this study as they
were included in other  investigations, such as that being carried on by Dr. Wal-
lace Fuller at the University of Arizona.
     After loading the  cells with ground refuse, they were brought to field ca-
pacity by incremental additions of tap water over a month.  Afterwards, two gal-
lons of water were added biweekly to equal 26 inches per year of water entering
the fill.  One foot of  leachate was allowed to pond on the liners.
     The 24 cells operated  satisfactorily, yielding consistent leachate among
the generators.  The leachate compositions were measured on a regular basis.
They showed a relatively high amount of organic acids, particularly butyric acid,
a chemical which swells many rubbers.
     During the first few days after the cells were loaded there was a slight
rise in temperature after which the temperature fell to ambient and remained
at that temperature, approximately 15 to 20 C.  During this time conditions in
the cell went from aerobic  to anaerobic.

     The tests which were selected for the polymeric membrane liners and the ad-
mixed liners are shown  in Tables III and IV.   These tests were performed on both
unexposed and exposed specimens.
     The tests used in  the monitoring of the refuse and leachate are given in
Table V.  Most of these were performed on a monthly basis,  although the tests
for the individual organic acids were performed on a quarterly basis.
Results of one year's exposure to leachate -
     After one year of  exposure to leachate, the first group of 12 liners was
recovered from the leachate generators and their properties measured.  Overall,
the effect of this exposure upon the physical properties was minor. There were
small losses in the tensile strengths of all liners, except polyethylene and
EPDM, neither of which  lost strength.  The elongation at break increased in all
cases; the modulus, or  stiffness, generally dropped, except in the case of poly-
ethylene, ethylene propylene and butyl rubbers, where it remained essentially
the same.  In all cases, the liners softened.  The tear strength and puncture
resistance increased, undoubtedly due to the increase in elongation.  In seam
strength there were some major losses; however, those seams  which had been
heat sealing retained their strengths best.
                                        -289-

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	TABLE III.  TESTING OF POLYMERIC MEMBRANE LINERS	
Water vapor permeability, ASTM D96, procedure BW.
Thickness and weight per square foot.
Tensile strength and elongation at break, ASTM D412.
Hardness, ASTM D2240.
Tear strength, ASTM D624, Die C.
Water absorption or extraction at RT and 70 C, ASTM D570.
Splice strength, in peel and in sheer, ASTM 413.
Puncture resistance - Fed. Test Method Std. No. 101B, Method 2065.
Density, ash, and extractables.
	TABLE IV.  TESTING OF ADMIXED LINER MATERIALS	
Permeability                           Back pressure permeameter
Density and voids                      ASTM D1184 and D2041
Water swell                            Calif. Div. of Highways 305
Compressive strength                   ASTM D1074
Sliding plate viscosity of asphalts    Calif. Div. of Highways 348
Microductility of asphalts             Calif. Div. of Highways 349
   TABLE V. TESTING OF REFUSE AND LEACHATE DURING MONITORING
              Temperature
              Amount of leachate
              Total solids
              Volatile solids
              pH
              Chemical oxygen demand (COD)
              Total volatile acids (as acetic acid)
              Individual organic acids
                   Acetic
                   Propionic
                   Isobutyric
                   Butyric
                   Isovaleric
                   Valeric
                   Caproic

                                 -290-

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     As for the permeability of the liners, during the first year none of the
polymeric membranes allowed leachate to pass.  There was,  however, leakage
through the soil asphalt and asphalt concrete liners.  The epoxy seal around
the hydraulic asphalt disintegrated, allowing the leachate to bypass the liner.
     As the absorption of leachate by the liner material is an indication of
its permeability, the leachate absorption of each liner was determined and the
results are shown in Table VI.

        TABLE VI. WATER AND LEACHATE ABSORPTION BY POLYMERIC LINERS

Data in percent absorbed by weight
Polymeric Liner
Butyl rubber
Chlorinated PE
Chlorosulfonated PE
Ethylene propylene rubber
Neoprene
Polybutylene
Polyethylene
Polypropylene
Polyvinyl chloride
Water
1 year
1.60
13.10
17.40
1.40
22.7
0.25
0.20
0.28
1.85
Leachate
1 year
1.78
9.0
20.0
5.95
8.73
0.33
0.25
0.40
6.72

     The column on the right is the absorption in leachate the first year for the
same material.  As can be seen, there is not a one-to-one relationship between
the water and leachate absorption.  This reflects the dissolved solids content of
the leachate, both inorganic and organic.  In the case of the materials which are
highly hydrocarbon in character, the swelling of both in water or leachate is very
similar.  However, in the case of the chlorinated materials, there is a substan-
tial amount of water absorption, particularly in the case of the chlorinated poly-
ethylene, Chlorosulfonated polyethylene and neoprene.  The PVC had rather low ab-
sorption in water but, in leachate, the absorption may be significant.
     In view  of the relatively  small changes  in  the  liner materials which occurred
during the first year of exposure, the EPA has increased the total exposure  time
for the remaining specimens from two years to about  three and one-half years. Cer-
tainly two years would be insufficient to establish  long-term trends  as to the
service life  of these liners.

                                        -291-

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                   LINERS FOR CONTAINING HAZARDOUS WASTES
     Our second project deals with the evaluation of liners exposed to nonradio-
active hazardous wastes.  As in the case of leachate from landfills, the impound-
ment of the hazardous wastes on land can also present the potential for pollution
of ground and surface water.  Barriers, such as membrane liners, have been used
for this purpose for approximately 25 years.  However, information as to relative
performance and service lives of various liners in highly characterized hazardous
wastes is meager.
     Our general approach was:
          1) To expose at least 12 different liners in six or more wastes,
          under conditions which simulate real-life, and determine their
          properties as a function of time.
          2)  To select liner materials which are, or potentially could
          be, used for lining ponds containing hazardous wastes.
          3)  To design and construct exposure cells which would simu-
          late the condition under which the liner would exist in a pond.
          4)  To select a range of hazardous wastes of various types
          which would be encountered in industry.
          5)  To highly characterize these wastes so that the liner be-
          havior can be predicted for confining actual wastes in a given
          installation.
     The design of the exposure cell for this study is shown in Figure 3.  It ii5
made of sheet steel coated on the interior with a chemically-resistant epoxy res-
in .  It features:
          1)  Specimens of one square foot area, with field type seam.
          2)  A depth of waste of one foot.
          3)  It can be used for liners of various thicknesses.
     The materials which were selected for this project are shown in Table VII,
and represent a broader group than were used in the landfill project.  Bentonite
and fine-grain soil are included.  As for the polymeric materials, we included
the same types of materials as were used in the sanitary landfill project, and
added three additional, (1) neoprene, (2) an elasticized polyolefin, and  (3) an
experimental polyester film, all of which  feature      oil resistance.

                                       -292-

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                               01
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                                U4 
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               TABLE VII. LINER MATERIALS FOR HAZARDOUS WASTES
                                                                      Thickness
SOIL AND ADMIXED MATERIALS	in inches
Asphalt emulsion on nonwoven fabric                                      0.3
Compacted native fine-grain soil  (from Mare Island. California)         12.0
Hydraulic asphalt concrete                                               2.5
Modified bentonite and sand                                              5.0
Soil-cement with seal                                                    4.5
                                                                      Thickness
POLYMERIC MEMBRANES	in mils
Butyl rubber-reinforced                                                   34
Chlorinated polyethylene  (CPE)                                            32
Chlorosulfonated polyethylene - reinforced                                34
Elasticized polyolefin                                                    25
Ethylene propylene rubber (EPDM)                                          50
Polychloroprene (neoprene) - reinforced                                   32
Polyester (experimental)                                                   7
Polyvinyl chloride (PVC)                                                  30
     The six types of hazardous wastes selected for use in this project are:
                    - Acidic wastes
                    - Alkaline wastes
                    - Pesticide wastes
                    - Oil refinery tank bottom wastes
                    - Lead wastes from gasoline tanks
                    - A cyclic hydrocarbon waste
     So that the length of exposure time would be practical, we made the final se-
lection of combinations of liners and wastes after we had performed a series of
preliminary bench tests of liners in the various wastes.  We did not select as-
phaltic liner materials for confining oily wastes, nor did we use clays to con-
fine briney and acidic wastes.  Where a polymeric liner swelled badly in aromatic
waste, we deleted that combination.
     These exposures have been underway for about 10 months.  At 12 months the
cells will--be dismantled and the liners recovered and tested.
                                       -294-

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     In addition to the primary liners, we have:
          1)  Suspended additional small specimens of liners in the
          wastes.
          2)  Lined 12 small tubs with various membrane liners and
          filled them with hazardous wastes for exposure to the
          weather.
          3)  Mounted a variety of liner specimens on a rack for
          outdoor exposure.
       FIELD EXPERIENCE IN THE USE OF LINERS FOR WASTE DISPOSAL SITES
     The experimental work which has been described is on a laboratory or, at
best, pilot scale only.  We have attempted to simulate the actual conditions en-
countered in full scale service but we recognize the many limitations of the ex-
posure conditions compared with the complexity and diversity of actual field dis-
posal sites.  Each waste disposal or storage installation has its own unique
characteristics as to the materials being confined, the geology of the site, the
weather, etc.
     The ultimate functioning of a liner in a given landfill will depend upon
proper site selection, design of the disposal installation, and proper construc-
tion and operation of the disposal site.  Of particular importance is the con-
struction and field seaming when membrane liners are used.  We start with highly
impermeable materials which, in order to function properly, should be placed
intact and with impermeable seams.
     There is considerable experience in the use of liners for impounding water,
industrial fluids, and wastes in the chemical,  petroleum,  and metals industries.
Their use in lining sanitary landfills is recent and field experience is very
limited.  A few experimental installations are about 10 years old, but the first
full-scale lined sanitary landfill is only five years old.  There are now several
landfills lined with asphalt concrete and bentonite clay and three with polyvinyl
chloride.  A butyl rubber liner has been used to line a disposal site for incine-
rator residue;  chlorosulfonated polyethylene and chlorinated polyethylene liners
have been used in two small pilot landfills.  Polymeric liners are presently
being considered for a number of new installations.
                                CONCLUSIONS
     Lining land waste storage and disposal sites shows great promise of allevi-
ating and, hopefully,  solving potential environmental problems of ground water

                                       -295-

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pollution arising from disposal of solid and liquid wastes on the land.  The con-
cept of using impervious liners to isolate and control leachate from solid wastes
appears to be feasible and is now being put into practice.  There is a wide r
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        THE IMPORTANCE OF SOIL ATTENUATION FOR LEACHATE CONTROL1

                           Wallace H.  Fuller
                     Soils, Water and Engineering
                      The University of Arizona
                          Tucson, AZ  85721
                              INTRODUCTION


        Almost all of man's waste now ends up on land.   In fact,  reliable

estimates place the amount that reaches the soil at about 90 percent,  U.S.

tPA (1973},Hershaft (1972).  Air and streams are only transport systems to

the soil, and dumping in the ocean has become very unpopular, even to  the

extent of enactment of legislation prohibiting such action, U.S.  Congress

(1972).   The soil, thus, stands between life and lifelessness, not only in

food production but in biodigestion of waste, destruction of disease,  and

retention of hazardous pollutants.  It is a unique body.   It is this unique-

ness which attracts our attention today.   It is this uniqueness that has

protected us in the past from the polluting hazards of our wastes, which now

is threatened by point-source overburden  of today's wastes.

        By understanding how the chemical, physical and biological character-

istics of the soil and geologic material  interact with wastes, we can  begin

to develop practical management metnods for safe disposal, Fuller, et  al. (1976).

        The soil must now be considered for its role as a waste treatment/

utilization system, Figure 1.  The economic shift with time will  be from soil

as a treatment to soil as a utilization system.  This shift, of course, will

not be sufficient to relieve the soil from the burden of waste disposal.  Yet

certain constituents (such as paper, landscaping trash, food residues  and

other natural organics) will be utilized  for soil building and not merely
 This research is supported in part by the U.S.  Environmental  Protection Agency,
 SHWRD, Cincinnati, OH.


                                    -297-

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referred to disposal.   Further, a certain limited proportion of solid waste
can go into relief for energy sources as methane, Figure 2.   Yet there is
waste (sludge), even in this system, that will  require disposal  on land (or
soil).
        The soil  must be regarded as a permanent resting place for all poten-
tially hazardous  pollutants.  The shift in thinking here is  from classic soil
science for food  production where plant nutrients are stored in the soil in an
"available", temporary or transient form (cation and anion exchange) to per-
manently fixed forms.

                               OBJECTIVE
        Management of wastes to minimize their potential for long-range
pollution requires the manipulation of the components of disposal habitats
based on a thorough knowledge of the way these components interact toward
element migration and attenuation.   This is the theme or objective of the
presentation today.


                  MAIN COMPONENTS OF DISPOSAL HABITATS
        To understand what keeps potentially hazardous pollutants from
migrating into underground water sources and other locations where they
might enter the food chain, there are 3 systems which require examination
  **r
and Study.  They  are the 3 main components of waste habitats:
        1)  the porous medium through which the constituent  is being trans-
            ported,
        2)  the solution carrying the pollution constituent, and
        3)  the constituent itself, i.e. the soluble element involved.
        The characteristics of each component markedly  influences attenu-
ation in soils.  The characteristics of each component that have been found
                                    -298-

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to influence migration and attenuation will be discussed separately.




     The porous medium or soil — Some prominent physical soil factors in attenu-




ation are listed in Table 1.  Texture refers to particle size distribution and




therefore represents gravel, sand, silt, and clay.  Sand is found to be negatively




correlated to attenuation and clay positively.  Sands and gravels retain solubilized




polluting constituents very poorly to not at all.  Structure refers to arrange-




ment of soil particles and controls rate of solution flow through the soil,




water-holding capacity, solution flow rate, and may not be favorable if too




stable.  For example, Molokai is highly structured even though it is a clay.




It most often acts like a sand.  Solutions pass through so rapidly, the polluting




constituents may not diffuse into the clay and have contact time sufficient to




react to attain maximum attenuation.




     Stratification defines the layering of soil and geologic material into




horizontal lenses of sand, silt, and clay, or gravel.  Flux is a term better




described as rate of low through a porous medium.  Compaction defines the




density.  A compact soil may or may not favor attenuation depending on its extent.




Excessive compaction may perch water and prevent necessary flow downward and may




encourage lateral movement or seepage to the surface just as will cementation




layers.  Wetting and drying influences the migration potential of pollutants




both favorably and unfavorably; for example, dehydration (a) favors retention




of constituents in the leachate by lowering the solubility as a result of




precipitation while at the same time (b) opens the soil for more rapid downward




migration through the shrinking and cracking processes.  Rehydration again puts




some of the constituents back into solution but also closes the cracks.  The




overall effect of wetting and drying of disposal materials and particularly




landfill leachates, however, is believed (from our experiences with soils)




to favor Tetention of pollutants in place.  Specific research on this




factor for wasite leachates is yet in its infancy.
                                       -299-

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        Some prominent factors in attenuation according to Fuller (1976),
Fuller and Korte (1975), and Korte,  et al.  (1975),  relate to chemical  charac-
teristics of soils,  Table 2..   They may be grouped into the three broad areas;
(a) surface area and clay content, (b) lime and pH  (or acidity and alkalinity)
and (c) content of the hydrous oxides of Fe, Al, and Mn.   Attenuation  in  soils
has been positively correlated with  soil surface area and clay content, and
is negatively correlated with sand.   The more alkaline soil  pH values  favor
precipitation of most heavy and trace elements and  therefore attenuation.
Lime favors the development of a less acid soil  and more alkaline pH soil
habitat.  The abundance of hydrous oxides in soils  also favors attenuation,
particularly Fe and Mn.  How practical it is to alter the hydrous oxide
content in soils remains to be demonstrated.
        Leachate Components -- Prominent leachate characteristics affecting
attenuation, according to our ongoing research, Table 3,  include the concen-
tration of (a) organic constituents  (TOC), (b) soluble salts, (c) acidity and
alkalinity of the solution (pH), (d) specific heavy and trace elements, (e)
soluble Fe.  In general, when the leachate or leaching solutions passing
through the soil are relatively high in TOC, soluble salt, specific polluting
element, and acidity less are the chances for attenuation.  Soluble Fe con-
tent is positively correlated with attenuation.   The mechanism(s) for this
interrelationship is (are) not known at this time.
        Specific element factors --  Prominent factors in specific element
attenuation reported in Table 4 relate to elements  selected by the U.S. EPA
as As, Be, Cd, Cr, C8, Fe, Pb, Ni, Hg, Se, Zn, and V as possessing potentially
hazardous characteristics as pollutants.  The elements differ greatly with
respect to migration rates through soils and geologic materials depending on
their  (a) capacity to form anions or not, and (b) indiviudal chemical  char-
acteristics in reacting to form soluble and insoluble compounds with their
                                  -300-

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environmental constituents at the various pH and Eh habitats available.
Lead, for example, migrates very slowly through most soils, whereas Cd moves
comparatively rapidly.

               RANKING ELEMENTS AND SOILS FOR ATTENUATION
        Recognizing the pitfalls of ranking elements and soils for attenuation,
Korte et al. (1976), felt their research with 10 soils representing the 10
major orders of soil in the U.S. provided a rare opportunity to do so.  The
data presented in Figures 3 and 4 display quantitatively the relative mobility
of the elements (As, Be, Cd, Cr, Cu, Ni, Pb, Hg, Se, Zn and V) and the relative
effectiveness of the soils in attenuating them.  The elements naturally
separated into cations and anions as previously discussed.  The soils repre-
sent all ranges of physical and chemical characteristics described earlier.
By knowning the  characteristics and climatic location of these soils and com-
paring them with one's own, these figures can be useful in the selection of
the most favorable disposal sites depending on the kind(s) of metals present.
        The divalent Cu and Pb may be found to be the least mobile while Hg
only weakly attenuated, Figure 3.  Molokai (tropical clay), Nicholson (temper-
ate-humid, clayey loam), Mohave (arid, calcareous, clayey) soils were the
most effective in attenuating the metallic elements.  Wagram (temperate-humid
sand) and Anthony (alluvium) soils were the least effective for attenuation.
        The metals that form anions, Figure 4, in the leachate reorder from
Figure 3 based largely on pH and abundance of the hydrous oxides of the soils.
Thus, attenuation is more efficient for soils lower in pH and/or higher in
free oxides of iron.  Free lime may or may not significantly decrease their
mobility, Fuller, et al. (1976).
                                    -301-

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                          NATURAL SOIL LINERS
        Among the most outstanding soil  parameters that influence attenuation
of the heavy and trace elements are clay content, lime, pH, and hydrous
oxides, Table 5.  With these and other known parameters certain low-cost
liners for disposal sites are suggested, Table 6.  Disposal excavations,
typified by landfill sites, may be lined easily to various thicknesses of
lime, clay, and other natural soil and geological material.  All  sites
require modification if migration of poll-utants is to be retarded because
all in situ lanc| materials permit migration of at least some polluting con-
stituents found in waste leachates and waste solutions.
        Agricultural Limestone - Limestone occurs abundantly throughout
the U.S.  Moreover, the agriculture industry uses large quantities of lime
for crop nutrient control and acid abatement of soils.   The agricultural
sieve sizes have proved suitable for land-sit liners, Fuller, et al.  (1976).
Certain heavy metals (Pb, Cu, Al) were found to be absorbed by limestone to
a greater extent than others (Ni and Zn).  Limestone may act to (a) adsorb
the metal ion directly, (b) react to form less soluble compounds as carbonate
and/or (c) raise the pH level of the leachate as it passes through the liner
barrier so precipitation may take place due to reduced solubility.
        Lime-slurries containing sulfur oxides from air pollution control
may be expected to react the same way since they contain unspent limestone.
The sulfur compounds may add an additional attenuating dimension to these
slurries.
        Hydrous Oxides - Although the research with hydrous oxides of Fe
shows them to be highly reactive with certain metal ions, and earlier
research indicates attenuating possibility, Korte, et al. (1975), the
                                    -302-

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technique of managing the iron sulfate mining waste residue for liner
purposes yet needs to be worked into a practical liner program.  Documented
laboratory evidence for the attenuating influence of the hydrous oxides of
Fe for certain metallic pollutants is provided also by Fuller, et al. (1976).
        Organic Wastes - The abundance of nutshells (pecan, walnut, etc.)
which are highly resistant to biodegradation appear to have great capacity
to adsorb metallic ions.  Lining disposal  sites with ground nutshells can
reasonably be expected to initiate fixation of certain heavy metals at the
disposal sites.
        Natural Soil  as Sealant - The author has had considerable practical
experience in the area of completely sealing artificial lakes using natural
clayey materials taken from the lake-bed excavations.   Partial and complete
sealing against leaking may be achieved depending on (a) compaction technique,
(b) clay content of soil, (c) dispersion of clay with sodium, (d) and
thickness of the liner, Fuller, et al.  f(1976).
        Flux - In addition to liners the density of the floor and sides of
the disposal sites can be modified to control the rate of flow (flux) of the
liquid vehicle carrying the pollutant.   Thus the natural soil material can
be altered in such a way as to act as a liner by permitting the soluble
constituents more time to linger in the vicinity of the soil constituents
responsible for attenuation.

                      RESIDUAL MANAGEMENT:  SOILS
        In addition to the use of natural  soil  liners and soil modification
for pollution control, wise site selection and management must become an
essential part in the attempt to achieve maximum retention of potentially
hazardous pollutants.   Some such residual  management practices are outlined
in Table 7.
                                   -303-

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        Perhaps one of the most critical  practices in site selection  is  to
avoid disposing of wastes in river bottoms,  sand and gravel  pits where there
is no hope for retention and attenuation.   Most of these locations feed
directly into aquifers and underground water storage.   Equally undesirable
are locations where impervious "gumbo till"  or clay stratifications impede
water leakage downward.   If such layers traverse the disposal  site lateral
flow can take place and seepage may bring leachates and hazardous pollutants
to the surface slopes.  Surface contamination associated with  the usual
erosion of rainfall offers serious hazards to water pollution  and food
chain entry.

                     RESIDUAL MANAGEMENT:   LEACHATES
        At least two prominent characteristics of leachates  (municipal solid
waste landfill leachates, in particular)  may be managed to aid in the
control of migrating metals through soils.  They are (a) mixing of organic
and inorganic and inorganic source materials and/or solutions, and (b)
aeration, Table 8.   Certain inorganic soluble metal compounds  found in
leachates migrate more rapidly through soils when associated with organic
substances.  Mercury, lead, and copper compounds are notable in this  respect.
Chelation or sequestering mechanisms protecting the metals are thought to
be operative more extensively than precipitation and absorptive mechanisms.
Attenuation of some elements appear to be negatively correlated with  total
organic carbon (TOC) content of leachates.
        Aeration of leachate solutions (anaerobic) results in  precipitation
development, Korte, et al. (1975).  The precipitate is readily detected by
the dark coloration of the solution during exposure to air directly or by
aeration techniques.  If landfill or excavation sites were lined at the
                                  -304-

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bottom with plastic pipes perforated to permit pumping of air through the
leachates, retention of organic and inorganic constituents may be encouraged.

                            ACKNOWLEDGEMENT
       Nic Korte, Elvia Niebla, Bruno Alesii, Juan Artiola-Fortuny, Joe
Skopp> and Dan O'Donnell; each have played a significant part in the progress
of this U.S. Environmental Protection Agency -- supported research program.
Tne help, so generously provided by Mike H. Roulier, U.S. EPA project
officer is gratefully appreciated.
       The work upon which this publication is based was performed pursuant
to Contract No. 68-03-0208 with the U.S. Environmental Protection Agency,
Solid and Hazardous Waste Research Division, Municipal Environmental Research
Laboratory, Cincinnati, OH 45268, in cooperation with the Arizona Agricultural
Experiment Station, The University of Arizona, Tucson, AZ 85721.
                                  -305-

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                              REFERENCES

1.   Fuller, W.H.   1976.   Migration of Selected Hazardous Metals, Asbestos
    and Cyanide through Soils.   Solid and Hazardous Waste Research Div.  Rept.
    U.S.  Environmental Protection Agency, Cincinnati, Ohio, 290 pp.  (in press).

2.   Fuller, W.H.,  Colleen McCarthy, B.A.  Alesii, and Elvia Niebla.  Liners
    for Disposal  Sites to Retard Migration of Pollutants.   In:  Residual
    Management by Land Disposal.   Proceedings of the Hazardous Waste Research
    Symposium, February 2-4, 1976, Tucson, Arizona.  W.H.  Fuller, ed.   EPA-
    600/9-76-015,  U.S. Environmental  Protection Agency, Cincinnati,  Ohio,
    280 pp.

3.   Fuller, Wallace H. and Nic Korte.  Attenuation Mechanisms of Pollutants
    through Soils.   In:   Gas and Leachate from Landfills, Formation,
    Collection and Treatment.   Proceedings of a research symposium,  March
    25-26, 1975,  New Brunswick, New Jersey.  L.J.  Genetelli and J. Cirello,
    eds.   EPA-600/9-76-004.   U.S. Environmental Protection Agency, Cincinnati,
    Ohio, 1976.  196 pp.

4.   Hershaft, A.   1972.   Solid waste treatment and technology.  Environ.
    Sci.  and Technol.  6:412-421.

5.   Korte, N.E.,  J. Skopp, E.E. Niebla, and W.H. Fuller.  1975.  A baseline
    study on trace metal  elution from diverse soil types.   Water, Air, and
    Soil  Pollut.  5:149-156.   D. Reidel Publ.  Co.,  Dordrecht-Holland.

6.   U.S.  Congress.   1972.  Marine protection, research, and sanctuaries act
    of 1972.  Public Law 92-532, 92nd Congress H.R. 9727.   Washington, OCI. 23,
    1972.

7.   U.S.  Environmental Protection Agency.  1973.  Report to Congress on
    Hazardous Waste Disposal.   Report 2nd Print, pp. 1-168.
                                  -306-

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                                FIGURES






Figure 1.   Soil:  A waste treatment system.



Figure 2.   Methane production from solid organic wastes.



Figure 3.   Relative mobility of Cu, Pb, Be,  Cd, Ni, and Hg through ten soils.



Figure 4.   Relative mobility of Se, V, As, and Cr through ten soils.
                                    -307-

-------
-308-

-------
IR R I CATION
  WATER
Fig. 2.  Methane production from solid organic wastes
                        -309-

-------
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                               -310-

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                                          -311-

-------
                                TABLES
Table 1.  Some prominent physical soil characteristics influencing attenuation
          of metals.
Table 2.  Some prominent chemical soil characteristics influencing attenuation
          of metals.
Table 3.  Some prominent waste leachate characteristics influencing attenuation
          of metals.
Table 4.  Some prominent factors in specific element (metal) attenuation in
          soils.
Table 5.  Some soil characteristics associated with attenuation.
Table 6.  Suggested low-cost soil liners for disposal excavations that aid
          in attenuation.
Table 7.  Residual management of soils for pollution retention.
Table 8.  Residual management of leachates as an aid in attenuation.
                                     -312-

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TABLE 1.  SOME PROMINENT PHYSICAL SOIL CHARACTERISTICS
          INFLUENCING ATTENUATION OF METALS
                  1.   Texture
                  2.   Structure
                  3.   Stratifications
                  4.   Flux
                  5.   Compaction
                  6.   Cementation - Fe, Caliche, lime, clay
                  7.   Wetting and drying
                      (hydraulic conductivity)
                                  -313-

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TABLE 2.  SOME PROMINENT CHEMICAL SOIL CHARACTERISTICS



          INFLUENCING ATTENUATION OF METALS
              1.  CLAY CONTENT




              2.  SURFACE AREA - REACTION SITES



              3.  LIME CONTENT




              4.  HYDROUS OXIDES - Fe, Mn, Al





              5.  pH-ACIDITY & ALKALINITY




              6.  TOTAL DISSOLVED SOLIDS - (SALTS)
                                    -314-

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TABLE 3.  SOME PROMINENT WASTE LEACHATE CHARACTERISTICS
          INFLUENCING ATTENUATION OF METAL

              1.   TOTAL ORGANIC CARBON COMPOUNDS (TOC)
              2.   TOTAL SOLUBLE SALTS (Elec. Cond.)
              3.   ACIDITY AND ALKALINITY (pH Values)
              4.   SPECIFIC HAZARDOUS ELEMENT CONCENTRATIONS
                  (As, Be, Cd, Cn, Cu, Pb, Ni, Hg,  Se, In, V)
              5.   TOTAL SOLUBLE IRON CONTENT
                                  -315-

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TABLE 4.  SOME PROMINENT FACTORS IN SPECIFIC ELEMENT (METAL)
          ATTENUATION IN SOILS
          ELEMENTS
          As, Be, Cd, Cn, Cu, Pb, Ni, Hg, Se, Zn, V, Fe

              1.  AN IONIC REACTION
                      As, Cn, (Hg), Se, V
              2.  CATIONIC REACTIONS
                      Be, Cd, Cu, Pb, Ni, Zn (Fe)
              3.  SPECIFIC ION CHARACTERISTICS
                      e.g. Pb_ vs Cd_
                                  -316-

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Major
Clay
**
Mi neral s




Clay
?5 Silt
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Total Mn


Free Iron
oxides

Surface
Area

Column bulk
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Electrical
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Cation
exchange
capaci ty
Soil Paste
PH



Order




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-317-

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TABLE 6.  SUGGESTED LOW-COST SOIL LINERS FOR DISPOSAL EXCAVATIONS THAT
          AID IN ATTENUATION


                   1.  AGRICULTURAL LIMESTONE
                   2.  LIME-WASTE SLURRIES
                   3.  HYDROUS OXIDES OF Fe, Mn, and Al.
                   4.  ORGANIC WASTES
                   5.  SOIL MATERIALS AS SEALANTS
                                   -318-

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TABLE 7.  RESIDUAL MANAGEMENT OF SOILS FOR POLLUTION RETENTION


          1.  TEXTURE — Choose finer textured soils (Clays, loams).
                         Avoid heterogeneous mixtures

          2.  DEPTH -- Choose deep rather than shallow soils.

          3.  DRAINAGE — Choose good drainage but not aquifers

          4.  REACTION -- Choose the least acid soils, and

          5.  HYDROUS OXIDE CONTENT — Choose soils highest in Fe, Al,
                                       and possibly Mn.
                                   -319-

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TABLE 8.  RESIDUAL MANAGEMENT OF LEACHATES FOR POLLUTION CONTROL
1.  SOURCES OF LEACHATE — Avoid mixing non-compatible leachates, e.g.
        Organic and Inorganic:  Municipal Wastes with Industrial Wastes.

2.  AERATION — Aeration precipitates organic as well as inorganic
        constituents and thus retards migration.
                                    -320-

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                 THE APPLICATION OF SEWAGE SLUDGES TO

                         E. Epstein and J. F. Parr.?/

     Interest In the appliction of sewage sludge on land in the United States

as a viable means of disposal and/or utilization has increased because of

certain legislative actions and economic considerations (Colacicco et al., 1977).

Legislative actions have imposed strict limitations on sewage disposal by

incineration (Air Quality Act of 1967), by fresh water dilution (Water Pollution

Control Act Amendments of 1972), and by ocean dumping (Marine Protection, Research,

and Sanctuaries Act of 1972).  Moreover, the costs for certain methods of sludge

disposal, e.g., trenching, landfill, and incineration, have increased tremen-

dously in recent years (Colacicco et_ al^., 1977).  The situation is further

intensified by the dramatic increase in sludge production resulting from imple-

mentation of more advanced wastewater treatment methods.  Based on current trends,

the present annual U.S. sludge production of approximately five million dry tons

is expected to exceed ten million tons by 1985.

                        Composition and Properties

     Sludge is predominately organic matter (40 to 60 percent) and, thus can be

a valuable resource when applied to the land.  Its potential use on land will be

limited by the level of contamination from toxic chemicals and pathogens.

     Sludge can be applied to land as a liquid (2 to 10 percent solids), as

dewatered filter cake (18 to 25 percent solids), as a compost (40 to 70 percent

solids), or as a heat dried product (94 to 99 percent solids).
I/ Research on composting of sewage sludge reported herein was partially supported
   by funds from the Maryland Environmental Service, Annapolis, Maryland, and the
   United States Environmental Protection Agency, Cincinnati, Ohio.

2J Soil Scientist and Microbiologist, respectively, Biological Waste Management and
   Soil Nitrogen Laboratory, Beltsville Agricultural Research Center, Agricultural
   Research Service, U.S. Department of Agriculture, Beltsville, Maryland.
                                      -321-

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     Table 1 shows the composition of sludge from eight North Central States




(Sommers, 1977).  The composition varies depending on the extent of treatment




and industrial contamination.




     The composition of composted sewage sludge depends on the characteristics




of the sludge (raw or digested), its source (industrial or domestic), and the




composting process technology which concerns the nature and amount of bulking




material that is used (e.g., refuse or woodchips), and whether the compost is




cured, screened, and stored before use.  Table 2 shows the properties of raw and




digested sludge composts.   The sludges were obtained from the Washington, D.C.,




Blue Plains Wastewater Treatment Plant and composted with woodchips.   These sludges




are essentially from domestic sources and, thus, relatively low in trace metals.




                            Potential Problems




Odors




     Odors can be a major problem in land application of. sludge.  Hydrogen




sulfide (I^S), ammonia (NH^), indoles, skatoles, and mercaptans produced during




sludge treatment are malodorous.  Avoidance of odors during land application




requires immediate incorporation of sludge into the soil.  Sites must be selected




with respect to population density, soil and drainage characteristics, and the




prevailing wind direction.  Composting of sludge under proper conditions




eliminates putrefying odors so that land application of compost does not require




special precautions (Epstein and Willson, 1975).




Heavy Metals




     Land application of sewage sludge can result in soil enrichment of toxic




trace elements (often referred to as heavy metals).  It has been shown that




such enrichment can cause direct phytotoxic effects on plants resulting in




repressed growth and yield.  Heavy metals may also accumulate in plant tissues
                                      -322-

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which could then enter the food chain through direct ingestion by humans or




indirectly through animals (Page, 1974; Chaney and Giordano, 1977).  The elements




in sludge of greatest concern are Zinc (Zn), Copper (Cu),  Nickel (Ni), and Cadmium




(Cd).  The first three are important because sufficiently  high levels of these




elements in soil can cause direct phytotoxic effects on plants, resulting in




repressed growth and yield.  The element of greatest concern to human health




where sewage sludges and sludge composts are applied to land is Cd.  While Cd




is not usually phytotoxic it is readily absorbed by plants, can accumulate in




edible parts, and enter the food chain.  Most human exposure to Cd comes from




food (principally grain products, vegetables, and fruits).  High levels of Cd in




foods can be toxic to humans (Sandstead ej^ a^., 1974).   Dietary Cd accumulates




primarily in the liver and kidney and at high concentrations can result in liver




damage and kidney failure.  Environmental pollution of soils with Cd and sub-




sequent accumulation of Cd in rice resulted in the itai-itai ("ouch-ouch")




disease which occurred in the Jiatsu River basin of Japan  (Yamagata and




Shigematsu, 1970).   The World Health Organization has established that the




maximum permissible level of dietary Cd should not exceed 70 pg/person/day.  The




United States Food and Drug Administration "Total Diet Study" (Duggan and




Corneliussen, 1972) shows that we are already approaching  this level and




consequently a further increase in our dietary intake of this element would not




be acceptable.




     A second source of human exposure to Cd is from smoking tobacco which usually




contains 1 to 6 ppm Cd.  In this case, Cd is absorbed by the lung and can




contribute significantly to the total body burden.




     The availability of heavy metals to plants, their uptake, and accumulation




depend on a number of soil, plant, and miscellaneous factors listed in Table 3.
                                      -323-

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For example, toxic metals are more available to plants when the soil pH is




below 6.5.  Thus, the practice of liming soils to a pH range of 6.0 to 6.5




is recommended to suppress the availability and toxicity of heavy metals to




plants.  Soil organic matter can chelate or bind metal cations making them




less available to plants.  The application of organic amendments such as




manures and composts can also lower the availability of heavy metals through




chelation and the formation of complex ions.  Soil phosphorus can interact with




certain metals thereby reducing their availability to plants.




     The cation exchange capacity (CEC), an expression of the soil's capacity




to retain metal cations, is important in binding heavy metals which decreases




their availability to plants.  Generally, the higher the clay and organic




matter content of soils, the higher their CEC value.  Heavy metals are relatively




less available to plants in high CEC soils  (clays or clay loams) than in low




CEC soils (sands or sandy loams).  Soil moisture, temperature, and aeration are




factors which interact to affect plant growth, uptake, and accumulation of




metals.  For example, increasing the soil temperature can increase plant growth




and the availability and uptake of heavy metals as well.




     Plant species, and varieties as well, vary widely in their sensitivity to




heavy metals.  For example, some vegetable  crops are very susceptible to injury




by heavy metals; corn, soybeans, and cereal grains only moderately susceptible,




while forage grasses are relatively tolerant.  Generally, the older leaves of




most plants will contain higher amounts of  heavy metals than the younger tissues.




Moreover, the grain and fruit of plants accumulate lower amounts of heavy metals




than the leafy tissues.  This observation is illustrated in Table 4 which shows




the effect of sludge application rates on the Zn and Cd content of corn grain




and leaves.  As the sludge rates increased, both the Zn and Cd concentrations




increased in the plant tissues.  However, considerably lower amounts of these




metals were accumulated in the grain than in the leaves.




                                      -324-

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      It is noteworthy that heavy metals differ in their relative toxicities to




plants and in their reactivity in soils.  For example, on an equivalent basis,




Cu is generally more phytotoxic than Zn, while Ni is considerably more phytotoxic




than  either Zn or Cu.  For reasons as yet unexplained, heavy metals can revert




with  time to unavailable forms in soil.




USDA  Guidelines to Limit Heavy Metal Loadings on Agricultural Land




      In 1976 USDA recommended certain guidelines!' to limit the application of




heavy metals on agricultural land from either the landspreading of sewage sludges




or sludge composts.  These guidelines are based on the best available knowledge




from  scientists at a number of State Agricultural Experiment Stations as well as




USDA.  Two categories of land were delineated:  (1) privately owned land, and




(2) land dedicated to sludge application, e.g., publicly owned or leased land.




      Table 5 shows the maximum allowable cumulative sludge metal applications




for privately owned land.  It is suggested that sludges having cadmium contents




greater than 25 mg/kg (dry weight) should not be applied to privately owned




land  unless their Cd/Zn is <_ 0.010.   That is, the Cd content of the sludge




should not exceed 1% of the Zn content, so that Zn will accumulate to phytotoxic




levels before sufficient Cd can be absorbed by the plant to endanger the food




chain.  Annual rates of sludge application should be based on the nitrogen




requirements of crops.   Cadmium loadings on land should not exceed 1 kg/ha/year




for liquid sludge and not more than 2 kg/ha/year for dewatered sludge.   The




soil  should be limed to a pH of 6.5 when the sludge is applied and maintained




at a pH of 6.2 thereafter.




     On publicly controlled land up  to five times the amounts of sludge-borne




metals listed in Table 5 may be applied if the sludge is mixed into the 0 to 15 cm







3/ Copies of the draft document are  available from the Office of Environmental




   Quality Activities,  USDA,  Washington,  D.C.  20250.
                                       -325-

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of surface soil.  Where deeper incorporation is practiced, proportionally higher




total metal applications may be made.  These metal applications apply only to




soils that are adjusted to pH 6.5 or greater when sludge is applied.




Pathogens




     Sewage sludge contains human pathogens, many of which are destroyed or




reduced in number during sewage treatment.  Further reduction can be accomplished




by heat drying, composting, lime stabilization, or pasteurization.  Data indicate




that disease problems related to soil application have been caused primarily by




use of raw sewage effluent, raw sludge, and night soil (Sepp, 1971; Parsons ^t




al. , 1975).  Parsons et^ jil. (1975) summarized various data (Table 5) on the




survival of certain pathogens in soils and on plants.  While most pathogens




survive in soil only for several days or a few weeks, the eggs of intestinal




worms such as Ascaris lumbricoides can survive for a number of years.




     Soil moisture, pH, and temperature greatly influenced the survival of




pathogenic organisms.  Adsorption and movement of pathogens in soil is affected




by the clay and organic matter content.  Movement of bacteria through soils wa:3




generally restricted to the upper few centimeters (Romero 1970).  However, Bouwer




et_ al. (1974) showed that in porous soils subjected to high flow rates of sewage




effluents, bacterial movement can occur to a depth of several meters.




     Bitton (1975) cites several references regarding adsorption of viruses




on soil particles and their movement through soils.  Migration of viruses




through soils was generally limited to the upper 50 cm.  However, in porous media




or where fissures, fractures, or cracks in the substratum occur, movement of




viruses to groundwater is possible (Hori ^t ^al. , 1970).  Epstein et^ a^. (1976),




Surge et al. (1977), and Kawata et: al. (1976) showed that sewage sludge




composting can effectively destroy coliforms, salmonella, and enteric viruses




when composting temperatures exceed 55°C for several days.  Recent stuides at
                                       -326-

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Beltsvllle, using an aerated pile method for composting raw sludge, showed that




f,, bacteriophage, a virus similar to some animal viruses but far more resistant




to destruction by heat, was completely destroyed during the first 2 weeks of the




composting period.




Miscellaneous Problems




     Application of sludge to land can result in excess salts since ferric




chloride, alum, and lime are added during wastewater treatment to flocculate and




precipitate the suspended solids.  There are a number of concerns associated with




the use of sludge on land; e.g., lack of public acceptance, adverse environmental




effects from odors and runoff, storage and distribution problems, and climatic




constraints.  Public opposition to hauling and surface application of sewage




sludge can be a major problem.  Residents along hauling routes near application




sites often object to the use of sludge on land.  Improper soil or site manage-




ment can cause excessive runoff of effluent, nitrate pollution of ground or surface




waters, odors and other environmental problems.  Sludge application to land may




have to be curtailed during winter months necessitating costly storage.  Land




application usually requires immediate incorporation into the soil to avoid




runoff and odor problems and is, thus, dependent on weather conditions.  The




costs of land spreading will also be dictated by land values near urban areas,




and the probable future limited use of the land where sludges containing high




quantities of heavy metals or persistent organic constituents are applied.




                                  Benefits




     The major benefits from use of sludge on land is from the macro- and




micronutrients it contains and from improvement of soil physical conditions.




Sewage sludge can provide nitrogen (N), phosphorus (P), Calcium (Ca), sulfur (S)




and other essential plant micronutrients.  Larson (1974) estimated that sewage
                                       -327-

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sludge produced in the United States could provide 2.5% of the nitrogen, 6% oi




the phosphorus, and 0.5% of the potassium sold as commercial fertilizers in IS'73.




Most of the nitrogen in sewage sludge is in the organic form and not readily




available for crop growth.  Epstein (1976) indicated that 65 and 44 percent of




the organic N fraction in raw and anaerobically digested sludge, respectively,




was mineralized after 5 weeks of incubation in soil.  Sludge application to land




often produces higher yields than comparable applications of commercial fertilizers




based on N content (Dowdy et^ al^. , 1976).  This increase is most probably due to




improved soil physical properties.  The addition of organic matter such as sludge,




green manure, animal manures, and composts are known to improve soil physical




properties as evidenced by increased water content, increased water retention,




enhanced aggregation, increased soil aeration, greater permeability, increased




water infiltration, and decreased surface crusting.  Addition of sludge to sandy




soils will increase their ability to retain water and render them less droughty.




In clay soils the added organic matter will increase permeability to air and




water, and increase the infiltration of water into the soil profile.  The




improvement of soil-water relationships in clay soil will provide more avail-




able water for plant growth.  The added organic matter, particularly to clay




soils, improves tilth, reduces compaction, and increases soil aeration and




rooting depth.




Laud Application




     Wastewater treatment can be primary  (sedimentation), secondary (anaerobic




digestion or extended aeration), or tertiary (chemical treatment) and, accordingly,




produces primary, secondary, and chemically stabilized sludges.  Untreated effluent




is not recommended for land application since it may contain human pathogens.




Treated effluents or liquid sludge  (1 or  10% solids) can be applied by standard




irrigation equipment (Dowdy et_ ajL. , 1976).  Two projects utilizing liquid
                                      -328-

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effluents for both irrigation and nutrient supplementation of crops are the




EPA-Muskegon County Project in Michigan and the Chicago-Fulton County Project




in Illinois.  Liquid sludge may also be injected into soil with specialized




equipment including, chisels and sweep injectors, and disc and moldboard plows.




Surface application systems consist of tank vehicles either tractor-drawn or




truck mounted which spray the liquid sludge directly on the soil or crop.




Filter cake sludge (20 to 23% solids) can be spread with a bulldozer or a




tractor-drawn manure spreader.   Heat-dried sludge may be applied with a




fertilizer spreader.




Composting of Sewage Sludge




     There are at least four reasons for composting organic wastes such as




sewage sludges.  These include (a) abatement of odors through sludge stabili-




zation; (b) destruction of pathogens by heat generated during the composting




process; (c) production of a hygienic material that can be uniformly applied to




land; (d) and narrowing the C/N ratio of the biomass being composted.




     Several years ago the Agricultural Research Service of the U.S.  Department




of Agriculture at Beltsville, Maryland, developed a windrow method that has




proved to be suitable for composting digested sludge (Epstein and Willson, 1974).




This method, however, was not acceptable for composting undigested (raw) sludge




because of the greater level of malodors associated with undigested sludges.




This same research group has now developed a method for composting undigested




sludges (Epstein and Willson, 1975; Epstein e_t ja. , 1976).  The method is widely




referred to as the Beltsville Aerated Pile Method,  wherein undigested sludge




(22% solids) is mixed with woodchips as a bulking material, and then composted




in a stationary aerated pile for a period of 3 weeks.   Other bulking materials




such as paper, leaves, or agricultural residues can be used in lieu of woodchips.




Sufficiently high temperatures are attained (above  60°C or 140°F) to effectively







                                       -329-

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destroy pathogens.  During composting the pile is blanketed with a layer of




screened cured compost for insulation and odor control.   Aerobic composting




conditions are maintained by pulling air through the pile by means of a vacuum




system.  The effluent air stream is conducted into a small pile of screened




compost where odorous gases are effectively absorbed.




     The finished compost can be used as both a fertilizer and soil conditioner.




Large -quantities have been used as a top soil substitute by the National Capitol




Park Service and Maryland State Park Service in land reclamation and development




projects.  Other uses for the compost include stripmine and gravel pit revegetation




and reclamation projects, turfgrass production, tree nurseries, and the




production of field crops.  Recent research at Beltsville suggests that on a




total metal basis, heavy metals are less available to plants in composted sewage




sludges than they are in uncomposted raw and digested sludges-1'.  The exact




reason for this is not known but it is the subject of continuing research.




     The Beltsville Aerated Pile Method has been adopted by a number of




municipalities, including Bangor, Maine; Durham, New Hampshire; and Camden, New




Jersey; and more are likely to follow, since sludge stabilization by composting




and subsequent utilization of the compost on land is a more viable alternative




to such environmentally unacceptable disposal methods as ocean dumping, landfill,




and incineration.




                                 Conclusions




     Intensive cropping systems often accelerate the depletion of soil organic




matter thus causing the deterioration of soil physical properties which in turn




leads to increased runoff and erosion, increased nutrient losses and decreased




soil productivity.  Both heavy (clays) and light (sands) soils could greatly







47 R. L. Chaney and E. Epstein, unpublished data.
                                       -330-

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benefit from the application of sludge or sludge composts as a result of improving




their chemical and physical properties.  The continuing high costs of inorganic




fertilizers has caused developing countries to consider the utilization of




urban and municipal organic wastes as fertilizers to sustain crop production.




Pathogen problems can be minimized with improved sanitary conditions, develop-




ment of appropriate process technology for composting sludge, and restriction




in the use of raw sludges on crops that are eaten raw.




     Where sludges and sludge composts are applied to land, steps should be




taken to prevent the accumulation of heavy metals in food chain crops.  In




cases where industries are utilizing sanitary sewers to discharge effluents




containing heavy metals, abatement and/or.pretreatment methods should be




implemented.  While it is hoped that such action would be voluntary, regulatory




agencies should exercise their authority to limit the influx of heavy metals




where necessary.  Heavy metals in food crops can be minimized by good soil and




crop management practices.  For example, maintenance of soil pH near 6.5,




proper crop selection, and proper management of organic matter can reduce uptake




and accumulation.  In addition to agronomic crops,  sludge and sludge composts




can be very beneficial for use in the development of parks, reclamation and




revegetation of stripmined lands and gravel pits, and for nursery use in the




production of turfgrass, ornamentals, and trees.
                                      -331-

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                              LITERATURE CITED




1.  Bitton, G.  1975.  Adsorption of viruses onto surfaces in soil and water.




    Water Res. 9:473-484.




2.  Bouwer, H., J.  C. Lance, and M. S.  Riggs.  1974.  High-rate land treatment




    II.  Water quality and economic aspects of the Flushing Meadows Project.  J.




    Water Poll. Cont. Fed. 46:844-859.




3.  Bulge, W. D., W. N. Cramer, and E.  Epstein.  1977.  Pathogens in sewage




    sludge and sludge compost.  Amer. Soc. of Agr. Eng. Trans. Paper No.




    76-2560.  (In press).




4.  Chaney, R. L. and P. M. Giordano.  1977.  Microelements as related to




    plant deficiencies and toxicities.   In Soils for Management and Utilization




    of Organic Wastes and Wastewaters.   Soil Sci. Soc. Amer., Madison, Wisconsin.




    (In press).




5.  Colacicco, D.,  E. Epstein, G. B. Willson, J. F. Parr, and L. A. Christiansen.




    1977.  Cost of sludge composting.  Agricultural Research Service, Northeast




    Regional Publication, U.S. Department of Agriculture, Beltsville, Maryland.




    (In press).




6.  Dowdy, R. H., R. E. Larson, and E.  Epstein.  1976.  Sewage sludge and




    effluent utilization in Agriculture.  In Land Application of Waste Materials.




    p. 138-153.  Soil Cons. Soc. Amer., Ankeny, Iowa.




7.  Duggan, R. E. and P. E. Corneliussen.  1972.  Dietary intake of  pesticide




    chemicals in the United States  (III),  June 1968 - April 1970.  Pesticide




    Monitoring Jour.  5:331-341.




8.  Epstein, E.  1976.  Impact and possibilities of reuse of sludge and




    sludge compost in agriculture.  In Agrochemicals in Soils.  Int. Soc. of




    Soil Sci. Symposium.  Jerusalem, Israel.  June 13-18, 1976.
                                       -332-

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 9.  Epstein, E. and G. B. Wlllson.  1974.  Composting sewage sludge.   In




     Proceedings of the National Conference on Municipal Sludge Management.




     p. 123-128.  Information Transfer, Inc., Rockville, Maryland.




10.  Epstein, E. and G. B. Willson.  1975.  Composting raw sludge,   ^n




     Proceedings of the National Conference on Municipal Sludge Management and




     Disposal,  p.  245-248.  Information Transfer, Inc., Rockville, Maryland.




11.  Epstein, E., G. B. Willson, W. D.  Surge, D.  C.  Mullen, andN.  K.  Enkiri.




     1976.  A forced aeration system for composting sewage sludge.   J. Water




     Poll. Cont. Fed.  48:688-694.




12.  Hori, D. H., N. C. Burbank, R. H.  F.  Young,  L.  S. Lau, and H.  W.  Klemmer.




     1970.  Migration of polio virus type 2 in percolating water through




     selected Oahu soils.  Tech. Rep. No.  36.  Water Resources Research Center,




     Univ. of Hawaii, Honolulu.




13.  Hukuhara, T.,  and H. Wada.  1972.   Adsorption of polyhedra of cytoplasmic




     polyhedrosis virus on soil particles.  J. Invert. Pathol. 20:309-316.




14.  Kawata, K., W. N. Cramer, and W. D. Burge.  1976.  Destruction of




     pathogens in sewage solids through composting.   Presented as a working




     paper at the World Health Organization Seminar on Solid Waste Management.




     WHO Regional Office, Manila, The Philippines.




15.  Larson, W. E.   1974.  Cities' wastes may be soils' treasure.  Crops and




     Soils.  27:9-11.




16.  Page, A. L.  1974.  Fate and effects of trace elements in sewage sludge




     when applied to agricultural lands.  A literature review.  USEPA Project




     No. EPA-670/2-74-005.  96 p.
                                       -333-

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 17.   Parsons,  D.,  C.  Brownlee, D. Wetter, A. Maurer, E. Haughton,  L. Kornder,




      M.  Slezak.  1975.   Health  aspects  of sewage  effluent  irrigation.  Pollution




      Control Branch,  British Columbia  Water  Resources  Services,  Victoria, B.C.




      75  p.




 18.   Sandstead,  H.  H.,  W.  H. Allaway,  R. G.  Burau, W.  Fulkerson, H. A.




   1  Laithinen,  P.  M. Mewberne,  J.  0.  Pierce,  and B. G. Wixson.  1974.




      Cadmium,  zinc, and lead.  Geochemistry  and  the Environment.   1:43-56.




 19.   Sommers,  L. E.   1977.  Chemical composition of sewage  sludges and  analysis




      of  their  potential use as fertilizers.  J.  Environ.  Qual.   (In press).




.20.   Sepp,  E.   1971.  The  use  of sewage for  irrigation -  A  literature review.




      State  of  California Department of Public  Health,  Bureau  of  Sanitary




      Engineering,  Sacramento,  California.




 21.   Yamagata, N.  and I. Shigematsu.   1970.  Cadmium pollution in  perspective.




      Bull.  Inst. Pub. Health.  19:1-27.
                                       -334-

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Table 1.  Total Elemental Composition of Sewage Sludge from several
          United States Municipalities (Sommers 1977).-'

Component
Organic C.
Inorganic C.
Total N
NH+-N
NO~-N
Total P
Inorganic P
Total S
Ca
Fe
Al
Na
K
Mg
Zn
Cu
Ni
Cr
Mn
Cd
Pb
Hg
Co
Mo
Ba
As
B

Minimum
6.5
0.3
<0.1
<0.1
<0.1
<0.1
<0.1
0.6
0.10
<0.10
0.10
0.01
0.02
0.03
101
84
2
10
18
3
13
<1
1
5
21
6
4
2/
Concentration-
Maximum
	 % 	
48.0
54.3
17.6
6.7
0.5
14.3
2.4
1.5
25.0
15.3
13.5
3.1
2.6
2.0
ppm
27800
10400
3515
99000
7100
3410
19730
10600
18
39
8980
230
757

Median
30.4
1.4
3.3
1.0
<0.1
2.3
1.6
1.1
3.9
1.1
0.4
0.2
0.3
0.4
1740
850
82
890
260
16
500
5
4
30
162
10
33
I/  Data compiled from over 200 samples from 8 states.
2]  Values expressed on 110°C weight basis.
                                   -335-

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Table 2.  Composition of Raw and Digested Sludges  from the Washington,  D.  C.
          Blue Plains Wastewater Treatment Plant,  and their Respective
          Composts Processed at the USDA Composting Facility,  Beltsville,  Md.
Component
PH
Water, %
Organic carbon, 5
Total N, %
NH,-N,ppm
Phosphorus, %
Potassium, %
Calcium, %
Zinc, ppm
Copper, ppm
Cadmium, ppm
Nickel, ppm
Lead, ppm
PCB^, ppm
BHC-/, ppm
DDE-, ppm
DDT , ppm
Raw
Sludge
5.7
78
'. 31
3.8
1540
1.5
0.2
1.4
980
420
10
85
425
0.24
1.22
0.01
0.06
Raw Sludge
Compost
6.8
35
23
1.6
235
1.0
0.2
1.4
770
300
8
55
290
0.17
0.10
<0.01
0.02
Digested
Sludge
6.5
76
24
2.3
1210
2.2
0.2
2.0
1760
725
19
-
575
0.24
0.13
-
Digested Sludge
Compost
6.8
35
13
0.9
190
1.1
0.1
2.0
1000
250
9
-
320
0.25
0.05
0.008
0.06
\l Polychlorinated biphenyls as Arochlor 1254.
2] The gamma isomer of benzene hexachloride is also called lindane.
^/ DDE results from the dehydrochlorination of DDT.
                                      -336-

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Table 3.  Major Factors Affecting Heavy Metal Uptake and Accumulation by Plants
Soil Factors

     1.  Soil pH - Toxic metals are more available to plants below pH 6.5.

     2.  Organic matter - Organic matter can chelate and complex heavy metals
         so that they are less available to plants.

     3.  Soil phosphorus - Phosphorus interacts with certain metal cations
         altering their availability to plants.

     4.  Cation Exchange Capacity (CEC) - Important in binding of metal
         cations.  Soils with a high CEC are safer for disposal of sludges.

     5.  Moisture, temperature, and aeration - These can affect plant growth
         and uptake of metals.

Plant Factors

     1.  Plant species and varieties - Vegetable crops are more sensitive to
         heavy metals than grasses.

     2.  Organs of the plant - Grain and fruit accumulate lower amounts of
         heavy metals than leafy tissues.

     3.  Plant age and seasonal effects - The older leaves of plants will
         contain higher amounts of metals.

Miscellaneous Factors

     1.  Reversion - With time, metals may revert to unavailable forms in soil.

     2.  Metals - Zn, Cu, Hi and other metals differ in their relative
         toxicities to plants and their reactivity in soils.
                                      -337-

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Table 4.  Effect of Sludge on Zn and Cd Content of Corn
Sludge Applied
Tons/acre—
0
17.5
35
70
105
Zn
Grain
ppm
27
41
46
36
45

Leaves
ppm
35
180
224
168
143
Cd
Grain
ppm
0.04
0.11
0.21
0.17
0.20

Leaves
ppm
0.41
1.11
1.74
1.89
1.69
_!/ Application rates are on a dry weight basis.
                                    -338-

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Table 5.  Maximum Allowable Cumulative Sludge Metal Loadings for Privately
          Owned Land as a Function of the Soil Cation Exchange Capacity.
                          Soil Cation Exchange Capacity (meq/lOOg)
Metal                     0^_J          5_               15
                               (Maximum metal addition, kg/ha)
Zn                         250            500            1000
Cu                         125            250             500
Ni                          50            100             200
Cd                           5             10              20
Pb                         500           1000            2000
                                     -339-

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Table 6.  Survival of Certain Pathogens in Soil and on Plants  (Parsons,
          et al., 1975).
Organism
                                   Media
                               Survival Time
                                   Days
Coliforms



Fecal streptococci

Salmonella




Salmonella typhi


Shigella



Tubercle bacilli
Entamoeba
  histolytica cysts
Enteroviruses
Ascaris ova
Soil Surface
Vegetables
Grass and Clover

Soil

Soil
Vegetables and Fruits
Grass or Clover
Soil
Vegetables and Fruits

On Grass (raw sewage)
Vegetables
In Water Containing Humus

Soil
Grass

Soil
Vegetables
Water

Soil
Vegetables

Soil
Vegetables and Fruits
     38
     35
     6-34

    26-77

    15->280
     3-49
    12->42 (and over
           winter)

     1-120
    180
    10-49

     6-8
    
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                  LONG-TERM CARE AND LIABILITY ISSUE
     Related to Hazardous Waste Treatment, Storage, and Disposal Sites

                         by Michael Shannon*
Introduction

     In the period that led up to Earth Day 1970, this country was
coming to the realization that maintaining the quality of the human
environment was the most important challenge of our age.  It was
within this context that the Congress enacted the first solid waste
legislation in 1965, initiating a concerted effort to improve solid
waste management practices, and the course of extensive envrionmental
pollution across the Nation.

     The Federal solid waste program was organized to carry out
provisions of the 1965 Solid Waste Disposal Act and was, at that time,
within the Department of Health, Education, and Welfare.  With the
coming of Earth Day 1970 and the assembly of the main Federal environ-
mental programs into a single agency, the Office of Solid Waste became
a part of the U.S. Environmental Protection Agency.  The year 1970 also
saw an amendment to the Solid Waste Disposal Act — the Resource Recovery
Act, which provided a new emphasis towards recovery of valuable materials
and energy from waste residuals.  As a result of EPA's 1973 report to
Congress, Disposal of Hazardous Wastes, mandated by Section 212 of the
amended legislation, a strong thrust to bring some control to the manage-
ment of hazardous wastes throughout the United States was begun at EPA.

     The new law of the land is the Resource Conservation and Recovery
Act of 1976 which was signed by President Ford on October 21 and desig-
nated as Public Law 94-580.  The new law phases out open dumping of
solid wastes, upgrades land disposal, provides Federal financial and
technical assistance to State and area-wide programs which are environ-
mentally sound and makes optimal use of opportunities for resource
recovery. Limited Federal support for resource recovery demonstrations
would be provided through the mechanism of loan guarantees.  Expanded
Federal technical assistance and information efforts would be authorized
to assist States, local governments and industry in every aspect of
solid waste management.  Those who treat, transport, store, or dispose
of hazardous wastes will need to obtain permits for their activities.
This paper will focus on several non-technical aspects of the hazardous
waste management regulations.
     *Mr. Shannon is a program manager with the Implementation Branch,
Hazardous Waste Management Division, Office of Solid Waste,  U.S.
Environmental Protection Agency.
                                     -341-

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     The problems of perpetual or long-term care and liability
of hazardous waste management facilities are of vital concern to
the public.  Facilities as used here include hazardous waste
treatment, storage, and disposal operations/sites.  In fact, the
recently passed 1976 Resource Conservation and Recovery Act contains
elements which are adddressed to these issues.  Specifically, Subtitle
C - Hazardous Waste Management, Section 3004.6 "Standards Applicable
to Owners and Operators of Hazardous Waste Treatment, Storage, and
Disposal   facilities" states that the standards shall include "such
additional qualifications as to ownership, continuity of operation,
and financial responsibility as may be necessary or desirable."  In
order to protect the public and the environment from harm, this Act
recognizes that certain measures are necessary to ensure financial
responsibility and long-term care of hazardous waste management
facilities.

     These requirements are included because from a regulatory
standpoint, technical standards and record-keeping and reporting
requirements must be re-enforced by incentives for good management
and complete protection.  The requirements give the public the
knowledge that persons in the business of hazardous waste manage-
ment are responsible and can be held accountable for their
actions.  In addition, financial responsibility and continuity
of operations requirements give the owners or hazardous waste
management facilities a degree of protection against the financial
aspects of pollution incidents and lawsuits. The mere fact that
there is a law increases the visibility and responsibility of
persons in the industry and simultaneously gives the public a
vehicle for comparison and to bring suit.

     There are two related approaches that have to be considered
in implementing long-term care and liability provisions.  The
first approach relates to continuity of operation and ownership
requirements or to the transfer of site operations from one operator
to the next, as well as the final closing and subsequent monitoring,
surveillance, and maintenance of the hazardous waste facility. This
paper will address the problem of assuring adequate funds for site
closure and long-term care at any point in the life of the site.
Once such provisions have been established, the financial responsi-
bilities can be transferred with a change in site operators.
                                    -342-

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          THE DILEMMA OF LIABILITY
                    AND
           PERPETUAL CARE ISSUES
                Prepared by

              Michael Shannon
    Hazardous Waste Management Division
 Office of Solid Waste Management Programs
   U.S.  Environmental Protection Agency
          for presentation to the

          Fifth National Congress
                  of the
National Solid Waste Management Association
              Dallas, Texas

             December 9, 1976

-------
                   THE DILEMMA OF LIABILITY
                             AND
                     PERPETUAL CARE ISSUES

                      by Michael Shannon*
Introduction

     In the period that led up to Earth Day 1970, this country was
caning to the realization that maintaining the quality of the human
environment was the most important challenge of our age.  It was
within this context that the Congress enacted the first solid waste
legislation in 1965, initiating a concerted effort to improve solid
waste management practices, and the course of extensive environmental
pollution across the Nation.

     The Federal solid waste program was organized to carry out
provisions of the 1965 Solid Waste Disposal Act and was, at that time,
within the Department of Health, Education, and Welfare.  With the coming
of Earth Day 1970 and the assembly of the main Federal environmental
programs into a single agency, the Office of Solid Waste Management
Programs became a part of the U.S. Environmental Protection Agency.
The year 1970 also saw an amendment to the Solid Waste Disposal Act —
the Resource Recovery Act, which provided a new emphasis towards
recovery of valuable materials and energy from waste residuals.  As
a result of EPA's 1973 report to Congress, Disposal of Hazardous
Wastes, mandated by Section 212 of the amended legislation, a strong
thrust to bring some contol to the management of hazardous wastes
throughout the United States was begun at EPA.
     *Mr. Shannon is a Program Manager with the Implementation
Branch, Hazardous Waste Mangement Division, Office of Solid
Waste Management Programs, U.S. Environmental Protection Agency-
                                -344-

-------
     The problems of perpetual or long-term care and liability
of hazardous waste management facilities are realistic and
are of concern to the public.  Facilities as used here include
hazardous waste treatment, storage, and disposal operations/
sites.  In fact, the recently passed hazardous waste management
legislation contains elements which are addressed to these
issues. Specifically, the language of the 1976 Resource
Conservation and Recovery Act under Subtitle C - Hazardous
Waste Management, Section 3004.6 "Standards Applicable to
Owners and Operators of Hazardous Waste Treatment, Storage,
and Disposal Facilities" states that the standards shall include
"such additional qualifications as to ownership, continuity of
operation, and financial responsibility as may be necessary or
desirable."  In order to protect the public and the environment
from harm, this Act recognizes that certain measures are necessary
to ensure financial responsibility and long-term care of hazardous
waste management facilities.

     These requirements are included because from a regulatory
standpoint, technical standards and record-keeping and reporting
requirements must be re-enforced by incentives for good management
and adequate protection.  The requirements give the public the
knowledge that persons in the business of hazardous waste
management are responsible and can be held accountable for their
actions.  In addition, 'financial responsibility and continuity
of operations requirements give the owners of hazardous waste
management facilities a degree of protection against the financial
aspects of pollution incidents and lawsuits.  The mere fact that
there is a law increases the visibility and responsibility of
persons in the industry and simultaneously gives the public a
vehicle for comparison and to bring suit.

     There are two related approaches that have to be considered
in implementing long-term care and liability provisions.   The
first approach relates to continuity of operation and ownership
requirements or to the transfer of site operations from one
operator to the next, as well as the final closing and subsequent
monitoring, surveillance," and maintenance of the hazardous waste
facility. This paper will address the problem of assuring adequate
funds for site closure and long-term care at any point in the life
of the site.  Once such provisions have been established, the
financial responsibilities can be transferred with a change in
site operators.
                               -345-

-------
     The second approach encompasses the financial responsibility
of operators of hazardous waste managment facilities.  Here the
concern is more with the assessment of liablity for damage
occurrences related to hazardous waste.  The reauirement of
liability insurance is discussed as the means for insuring financial
responsibility.
Long-term Care

     Previous experience with the long-term care of hazardous
waste managment facilities is limited.  One method of ensuring
long-term site care is to require deposit of a cash bond or
maintenance of a surety bond by the hazardous waste management
facility operator.  The bond must be of sufficient size to assure
proper site closing and site monitoring, surveillance, and main-
tenance for a specified number of years. The appropriate bonding
level should consider site characteristics (size, geology, hydrology,
etc.), the particular hazardous waste destined for storage, disposal,
the degree of waste treatment prior to disposal, and the likelihood
of off-site damages (i.e., proximity to population centers, etc.)
should be considered as well, although it has not previously been
a factor, when choosing an appropriate bonding level.  A surety
bond would probably be less burdensome to the site operator than
a cash bond of an equivalent amount.  The premium paid for a surety
bond presumably being less than the cost of a loan needed for
deposit of a cash bond.

     In the case of a cash bond, adequate provision for perpetual
site care is assured if the annual real rate of return (i.e., the
return on the principal over and above the rate of inflation) offsets
the cost of site upkeep.  A portion of the bond could be used to
correct major site deficiencies or to offset damages caused by
leachate run-off or migration.  Sufficient funds would have to
remain in escrow to provide for annual site upkeep subsequent to
such expenditures.  If a change in facility operators occurs (in
advance of site closure), then the former site operator should be
allowed to withdraw the bond's principal and the new operator
required to deposit an equivalent amount.

     An alternative to the required bond deposit is assessment
of a perpetual care fee on each user of the waste facility.
The user surcharge would be fixed on a volumetric basis.   In
general, facility site operators have not varied this fee with
the type of incoming waste.  The aggregate fees are deposited
                                -346-

-------
in an account, and when a level sufficient to maintain long-term
care of the site has been reached  (including accrued interest),
the fee may be discontinued.   (Of course, the fee may be calculated
such that the desired fund level will not be reached until the
site is full.)  The major drawback to this method of financing
long-term- site care is that the operator can cease facility
operations without having accumulated a fund large enough to
assure adequate facility closure and perpetual care.

     Either a cash or surety bond can be combined with a perpetual
care fee to provide for perpetual site care.  A cash bond deposited
with a State could be withdrawn when an equivalent amount accumulated
through aggregate perpetual care fees has been deposited by the
site operator.  Alternatively, a surety bond, equal to the difference
between the apparent required sinking fund and the expected size
of the sinking funds for that year (i.e., cumulative perpetual
care fees plus accrued interest), could be required of the site
operator.  The apparent required sinking fund would be a site
specific reserve sufficient to provide for routine maintenance,
surveillance, and monitoring costs, as well as contingency funds
in the event of major facility repair.  In essence, this method of
assuring long-term care would require the site operator to purchase
declining term insurance to protect a State against early close-out
of site operations.

     A combined surety bond/perpetual care fee was suggested as
an adequate means of financial security for one of serveral low-level
radioactive waste sites in the United States.  The apparent required
sinking fund was to be calculated on an annual basis, i.e., varying
with the amount of waste deposited at the disposal site.  An
appropriate size for the contingency fund was calculated on the basis
of the "expected value" of major site repair costs (i.e., the sum of
projected repair costs multiplied by their respective probabilities
of occurrence).  Alternatively, a contingency reserve sufficient to
cover the estimated cost of major site repair, given the need for
such action, could be required as part of the apparent required
sinking fund.

     Rather than accumulate a perpetual care fund for each
hazardous waste management facility,  a mutual trust fund is
another option that could be developed for all sites within
a given jurisdiction (e.g., within a State).  This proposal
could be funded by any of the foregoing mechanisms.  The trust
fund would provide a larger reserve to cover unexpected site
repairs or damage claims.  Also, due to the pooling of the risk
                                    -347-

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of major site repair, the contingency reserve required of each
site operator would be less than that needed if a separate
sinking fund was maintained for each site.  Private operators
might not be as careful in site construction and maintenance
if they are not directly liable for these costs, however, the
enforcement aqency would have to provide the incentive for
continued site care.

     Another option for long-term site care is a convenant which
is placed on the land to prohibit the transfer of site maintenance
responsibility with the deed unless the new owner accepted the
responsibility and was capable of guaranteeing continued site
maintenance.  The question then arises of what constitues capability
to guarantee site maintenance.  The owner would probably have to
offer some sort of financial security in order to guarantee site
maintenance.  A long-term care fund, similar to the alternatives
just mentioned, might well have to be established.  Thus, this
method of ensuring long-term care is not really a discrete proposal,
but rather a different context for posing the problem of adequate
financial security for long-term care.
Liability

     Some States which have hazardous waste management legislation
require that disposal sites be deeded to the State and that
performance bonds be posted to obtain a license to operate
(e.g., Oregon, Washington).  These requirements should improve
long-term care of disposal sites and reduce the liability problem
for the private sector.  Previous owners, however, could still be
held liable for damages which arose from their actions. Oregon, or
any State, if acting as a proprietor could be open to suit or there
may be State statutes permitting tort claims against the State.

     Just a's there are questions about private and public sector
roles in long-term care and liablity, there are questions regarding
liability for consequences concerning incidents entirely involving
the private sector that occur after a change in ownership of the waste
or that occur as a result of operations by a previous owner
of the facility.  The confusion over responsibility partly
stems from the fact that the liability laws and the judicial
processes vary from State to State and from municipality to
municipality.  As a consequence, it is possible to hear opinions
that liability for damages from a hazardous waste can be entirely
transferred from a generator to a disposer of the waste or that
most States adhere to the rule that the generator always bears
at least some of the liability.
                                    -348-

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     In an effort to better understand some of the information
regarding long-tern liability, this part of the paper will focus
on first, a discussion of the assessment of liability for
occurrences related to hazardous wastes.  Next there will be
a discussion of nuclear liability insurance followed by the
hazardous waste service industry experience with liability
insurance.  The final part is a discussion of the implementation
of the insurance technique as a tool for insuring financial
responsibility and long-term care of hazardous waste management
facilities.

     There are two areas of law that apply to hazardous waste
in connection with damages - tort liability and criminal lav;.
Tort liability is resolved in a civil action brought by a private
plaintiff representing his own interest.  In criminal action,
a public official will bring suit on behalf of broad social
interests.  The "Rivers and Harbors Act of 1899" has sometimes
been used by Federal officials as the legal basis in a criminal
liability case against polluters.  Hazardous waste management
is covered by specific statute in only a few States and covered
by the 1976 Resource Conservation and Recovery Act.

     Since civil actions are the most common to hazardous waste
damage cases, the four theories of tort liability including
negligence, strict liability, nuisance, and trespass will be
discussed.  Although the distinctions between the four theories
are sometimes not clear at the applied level the following
discussion summarizes their main features.

     Negligence bases liability on the failure to use the proper
degree of care in conducting an activity.  It usually involves
an operational defect or omission of a reasonable precautionary
measure.  The concept of reasonableness is based to some extent
on generally employed standard practices but varies with the facts
of the particular situation.

     At the other end of the spectrum, the theory of strict
liability imposes liability without regard to the degree of
care or precautions taken to prevent damage.  Losses are auto-
matically shifted to the party who initiated the damage-causing
activity.  The application of this theory is generally applied
to those activities that pose a considerable threat to others
even when conducted with every possible precaution.
                                    -349-

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     The concept of nuisance falls between the theories of
negligence and strict liability with regard to the requirements
for liability.  Applications generally involve unreasonable
interferences with the use and enjoyment of land resulting from
the actions of other parties.  Emphasis is on the invasion of
the injured party's rights rather than on the reasonableness of
the initiator's conduct with the courts using discretion on
balancing the interests involved. Although negligence is not
always a requirement for proof of nuisance, proof of negligence
is often accepted in support of an allegation that a nuisance
exists.  Nuisance can look very much like the strict liability
concept when liability is based on the results of an activity
without regard to the care or precautions employed.

     Trespass usually involves an unauthorized entry onto the
land of another or an invasion of property rights.  The entry
or invasion need not be by a person, but may be accomplished by
something within the control of that person, which brings escaping
hazardous wastes within the scope of trespass.

     The success of a plaintiff's legal action depends on his
successful presentation of proof of damages.  The elements of
proof required vary among the liability theories but in general
include:  1) necessity of showing injury; 2} establishment of
causation; 3) establishment of fault.  These three elements of
proof deserve more detailed explication.  The injury can take
various forms:  1) actual physical injury to person or property,
which is the most significant form; 2) infringement of legally
protected rights; 3) anticipated injury.  The view that infringe-
ment of a legal right constitutes injury in itself usually arises
in a trespass case which primarily involves unauthorized entry
onto the land of another.  Here suit is brought not for an actual
injury, but rather for vindication of a right.  Anticipated injury
by trespass or nuisance involves suits brought in prohibitory
injunctions.  Injunctions traditionally are granted to a complaining
party only if it can prove the likelihood of direct injury to his
rights.

     Physical injury from the polluting effect of hazardous
wastes can take a variety of forms including loss of or damage
to human life, livestock, crops, water supplies, aquatic life, etc.
In cases where compensatory damages are sought through litigation,
the plaintiff normally must quantify his injury in monetary terms
which may be possible in some situations, but not very feasible
in others.  Traditionally if an injury cannot be measured, it
                                   -350-

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goes uncompensated.  If the plaintiff is unable to prove damages,
he still may be awarded an injunction especially if something
unique is injured or there is a denunciation in property value.
The judge or jury may adjust damages to reflect their interpretation
of an injury.

     The plaintiff must also prove the source of the injury.
In some cases involving a hazardous waste incident, the cause
and effect relationship will be obvious.  In a groundwater
pollution incident, as the distance between a disposal facility
and the injury increases and as the spread of leachate is affected
by natural processes, the positive identification of a source
becomes more difficult.  Incomplete knowledge about the movement
of a groundwater pollutant generally makes a causal relationship
difficult to prove especially if the alleged incident occurred
over a long period of time.  However, a good case might be possible
if direct evidence in a case of injury from groundwater pollution
can be obtained.  For example, if a dye or other tracer is deposited
at the site of the pollution incident and it then appears at the
place of injury.  The courts in some cases may accept indirect
proof based on circumstantial evidence.  It is difficult to generalize
with regard to the evidence necessary for proof, but there are
several key factors.  Included are the proximity of the incident
to the injury site, the time relationship between the incident
and occurrence of injury, the existence of a physical connection
and the elimination of other possible sources for the injury.

     In addition to proof of injury and of a causal relationship,
the plaintiff in some cases may also have to prove that the
injury resulted from improper conduct on the part of the defendant
through fault or culpability.  Negligence is of primary interest
here since the underlying basis of this theory is the failure to
conform to a certain standard of conduct which is based on the
conduct of the hypothetical "reasonable man".  Compliance with
industry-used practices is not necessarily a successful defense
against negligence actions.  Proof of. negligence by a defendant
poses a formidable obstacle where the activities in question
occurred on the defendant's property and involved operations
exclusively within the defendant's knowledge.  Some courts have
accepted general proof of negligence in place of proof of specific
details.  On the other hand, allegations of negligence have been
turned down in courts because of an absence of a reasonable
basis for the anticipation of harm in connection with conducting
lawful activities.
                                   -351-

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     Other cases decided under the strict liability theory have
imposed liability for injury from escaping pollutants without
regard to fault.  Liability here is viewed as an integral part
of conducting hazardous activities, and this approach stresses
accountability through compensation for injuries.  The strict
liability theory only requires the plaintiff to show injury and
a causal relationship with the defendant's operations.  The
strict liability concept in various forms has been accepted
in 30 States with the number grov/ing at a rate of about one per
year.  Guidelines for defining hazardous activities include six
factors:  1) degree of risk to the person or property of others;
2) seriousness of potential harm; 3) risk elimination by exercise
of reasonable care; 4) common usage of activity; 5) appropriateness
of activity relative to place where carried on; 6) value of the
activity to the community.  These guidelines were applied to a
Maryland case where an owner of a large gasoline tank in close
proximity to a water well was held liable when gas leakage
contaminated the well.

     Environmental law and case law is very meager on the subject
of responsibility of a polluter or a waste generator and someone
acting on his behalf to manage or control the pollution.  In
addition to assigning direct liability to the person causing
the damage, there is a secondary type of liability for aiding
or instigating an environmental occurrence.  In this unsettled
area of law, it is generally necessary to rely on the established
law of liability of contractors.  This is of great importance
in hazardous waste management because of the importance of off-site
treatment and disposal of hazardous wastes.

     A typical definition of a hazardous waste management firm
acting as an independent contractor is one who exercises an
independent employment and contracts to do specified work according
to his own methods, without being subject to the supervision and
control of his employer (waste generator) except for the results
desired.  This definition is important when establishing whether
or not a relationship between hazardous waste generator and a
management firm is that of an independent contractor or employer -
employee.  The kind of relationship will answer in many cases the
question of the liability of the employer for personal injury or
property damage to others from wrongful acts of the contractor
or his employees.  The general rule in the United States is that
the employer is not liable for the wrongful acts of one who is
found to be an independent contractor.  There is no absolute test
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for determining whether a person is an independent contractor or
an employee; each situation must be determined on its own facts.
The degree of control exercised by the employers is a cannon
factor, however.

     An exception to the non-liability of an employer occurs
when he (or his agent) negligently hires an incompetent contractor
who the employer knew or should have known, had he used due care,
was not qualified to perform the work.  Another exception occurs
when an employer is aware of a violation of a law by his independent
contractor and does not protest or attempt to rectify the violation.
In this situation the employer cannot escape liability.

     A valuable source of information for its relevance to the
implementation of liability and insurance requirements is a report
entitled Nuclear Insurance - An Estimate of the Cost of the Nuclear
Hazard.  It is valuable because of its description of the insurance
mechanism used for covering liability due to nuclear hazard.  The
Price-Anderson Indemnity Act of 1957 (an amendment to the Atomic
Energy Act of 1S54) initiated and fostered the nuclear insurance
and indemnification program in the United States.  The Act was
extended in 1976 to an effective date of 1985.

     The main features of the Act regarding insurance requirements
are:  1) the Nuclear Regulatory Commission (NEC, formerly AEC)
requires financial protection for licensees; 2) the amount of
financial protection must be the amount of liability insurance
available from private sources; 3) the Federal Government provides
an indemnity above the financial protection required of the
licensee (the maximum indemnity for each nuclear incident for all
persons indemnified is $560 million); 4)  the NRC is authorized
to collect a fee from all persons with whom an indemnification
agreement is executed (the fee is based on generating capacity);
5) the NKC has the responsibility for implementing and administering
the Price-Anderson Act.

     The scope of coverage of government indemnification includes
practically all nuclear incidents involving transportation, storage,
or reactor operation whether nuclear fuel or nuclear waste.  Coverage
extends to any person legally liable for an incident.  The maximum
indemnification of $560 million was legislatively set in the 1957
Act as a realistic and affordable ceiling after testimony from
nuclear experts, insurance underwriters,  and others was evaluted.
The fee charged for coverage, however,  is not specified on the
basis of risk estimation.
                                   -353-

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     The "nuclear energy hazard" being insured is defined as "the
radioactive, toxic, explosive, or other hazardous properties
of nuclear materials, when such materials are at the designated
facility or are being transported to or from the facility."
Unlike traditional liability, bodily injury and property damage
liability are combined for nuclear hazard.  Also, the policies
are continuous rather than for a specified period of years.

     The nuclear liability insurance offered by two worldwide
liability polls is currently $125 million for each nuclear site
insured.  The nuclear liability insurance premiums were established
for the two pools by rating and underwriting bureaus.  Since
there originally was not actuarial experience, the premium rate
formula was based on judgment.  The underwriters established
a base rate for the first $1 million of insurance with the percent
of the base rate per $1 million of insurance declining for additional
increments.  The factors considered in establishing a base rate
are:  1) reactor type; 2) intended use (power, test, research);
3) designed power load; 4) location in relation to population
and property exposure; 5) degree of containment.  The premium cost
for a nuclear power plant in 1971, which had the insurance limit
per location of $82 million, ranged from $170,000 to $325,000.

     A unique feature of the nuclear insurance policy is a
credit rating plan which exists because of the judgmental
factors used in setting premiums.  A part of the premiums (67% to
75%) goes into a reserve fund for possible refund.  The credit
is determined on the basis of loss experience over the preceding
10 year period.

     Fran the viewpoint of the consumer who ultimately must bear
the cost .of the insurance, the added electricity cost due to
nuclear insurance is 0.5% of their electric bill.
                               -354-

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     The determination of a fair rate of liability insurance
is a significant problem to the insurer  (and to the insured)
when a decision is made to extend coverage to a new area such as
hazardous waste management.  A basic function of an insurance
company is to respond to new needs in spreading risk for a business
firm which is in a new and risky business and is concerned with
unknown costs of insurance.  In evaluating a hazardous waste
management facility risk situation, an insurance company is
concerned with three elements:  frequency, severity, predictability.
To an insurance company, most risk situations are completely
insurable from the private sector  (exclusions would be nuclear
occurrences and climatic castastrophe) especially if the occurrences
are predictable.  The high severity of an occurrence is not a
critical insurance problem as long as the frequency is low.  The
high frequency, high severity risk occurrence is a troublesome
insurance problem.  Risk assignment or actuarial experience
concerning the interrelated elements of a hazardous waste framework
are generally lacking regarding occurrences because of the infancy
of hazardous waste management.

     Two specific problem areas appear of concern to insurance
companies regarding risk coverage.  The first problem, which may
be peculiar to hazardous waste, is the delayed effect of some
incidents.  This actually adds a fourth element to a hazardous waste
risk situation.  Not only is there limited knowledge about the
frequency, severity and predictability of a hazardous waste
occurrence but experience on the suddenness of an occurrence
versus delayed effects is almost nonexistent.  Ordinary liability
policies will cover accidental and sudden risk situations but
to cover the long-term consequences of hazardous waste incidents,
special policies may be required.

     Communications with the insurance company which until several
years ago offered fleet and landfill coverage to National Solid
Waste Management Association (NSVJMA)  members, indicated that the
company's underwriters were greatly concerned about the potential
for a major groundwater or surface water pollution case.  Most
of the firms covered by the group insurance policy were strictly
solid waste landfill firms.  Although the liability coverage
was dropped for NSWMA members because of a poor experience
(loss)  on the fleet operations, an underlying factor was that the
insurance company was aware of and somewhat apprehensive about the
delayed aspect of a groundwater or surface water pollution occurrence.
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     Another significant problem area is the social aspect of an
insurance company providing liability insurance to protect the
activity responsible for an environmental damage occurrence.
According to a spokesman for the insurance industry, public interest
groups and their "hang the polluter" attitude have generated
opposition against relieving a polluter (private company)  from a
burden associated with an occurrence.  This attitude has impeded
the field of pollution liability insurance and made it difficult
for insurance companies to enter new fields, e.g., hazardous
waste facility liability.  Pressure from environmentalists has
made it very difficult for oil tanker companies to obtain oil
spill insurance.  Some companies, as a result, have been forced
to obtain liability insurance coverage from European companies.

     There are two kinds of liability insurance.  One is the
insured peril coverage for direct loss or damage to person(s)
or property such as from a fire or explosion.  The peril inclusion
in a liability policy includes things not unique to hazardous
wastes and should not present any problem for hazardus waste service
firms.  The other area of liability insurance is civil action
protection against a loss causing event sustained by a plaintiff -
commonly called "an occurrence" by an insurance company.  As far
as the concept of liability is concerned regarding insurance,
the insurance company is not concerned about whether or not the
occurrence is due to trespass, negligence, nuisance, or strict
liability.

     A progressive hazardous waste service firm obtains liability
insurance from a competitive desire to offer the best and most
secure service.  Ideally, a hazardous waste generator would select
a service firm who is technically qualified.  If interested in
doing business, the service firm in turn would analyze the waste
stream to determine if it is capable of treating, storing or
disposing of the waste.  Any subsequent agreement to do business
usually means the signing of a contract.  Upon pick-up and
receipt of the waste under a contract, the title changes hands
and the service firm assumes liability for the hazardous waste.
Generators normally would insist on this provision in their
contracts.  Actually a service firm, according to contract, would
intend to assume liability for problems that are his "sole"
responsibility.  What this actually means in terms of a lawsuit
and shared responsibility has yet to be tested in the courts.
Punitive damages are excluded from coverage by the insurance
company and must be borne by the activity.
                                -356-

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     Information is particularly limited regarding the scope
of insurance coverage.  It appears that most insurance coverage
by either the generator or the service fir?-, is the insured peril
coverage and not coverage for a civil action to protect against
lavjsuits based on serious hazardous waste occurrence.  The average
liability.coverage under the NSWKA group policy was $100,000 per
occurrence for bodily and personal injury and $300,000 per occurrence
for property damage.  The insurer would offer whatever a company
wanted to buy with some policies having coverage as high as
$5,000,000/510,000,000.  One hazardous waste service firm (not
under the NSWMA policy) has coverage of $500,000 bodily, $500,000
personal and $3,000,000 for property for each occurrence.  The
firm's annual insurance cost is estimated at about $10,000 or
less than a penny per gallon.  However, this policy is for insured
peril coverage and does not address the accidental and long-term
occurrences.  Other than nuclear insurance, the closest experience
to hazardous waste is for damage from water and air pollution
whereby it costs $50,000 per year for $1,000,000 of liability
insurance to cover exclusions from a general liability policy.

     When areas of new coverage are offered, insurance underwriters
rely heavily on positive technical aspects of an operation such
as chemical processing or detoxification which reduces the
potential hazard.  They also require compliance with applicable
standards.   Because of a lack of actuarial experience, rates
are set artificially high with the service firm reliant upon
insurance company competition and credit rebates to reduce the
cost of insurance.  A high risk situation may require an insurance
corr.pany to reinsure the activity with a specialty insurance
company.  This allows the insurance company to share or to spread
its risk and gain added experience and a second judgment.  Most
importantly it means insurance coverage is provided.
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S ummary/Conclusions

     Long-term care and financial responsibility regarding
hazardous waste facilities under the new Act appropriately call
for regulation at the State level of government.  States are
able to implement regulations for facilities located in the same
geographic area and account for problems unique to an area.
They will be able to incorporate local peculiarities into the
long-term care and insurance standards.  Federal standards,
i.e., minimum acceptable provisions for long-term care or Federal
approval of each State's regulations, would be necessary in order
to avoid discrepancies between States.

     Although standards are not required until 18 months
after Bill enactment, a combined surety bond/perpetual care fee
appears to be an equitable and effective method of ensuring
long-term site care.  A mutual trust fund, pooling the risk of
environmental damage and major site repair, could encourage
investment in the hazardous waste management industry.  A trust
fund, however, could not be established unless there was strict
enforcement of hazardous waste management regulations.  Formulation
of specific long-term facility care regulations would be a State
responsibility.  "Acceptable" regulations will have to be generally
defined by EPA.

     A discussion of liability indicates three things.  Firstly,
problems such as quantifying damages and proving causation related
to hazardous waste incidents will always exist.  Secondly,
although environmental law, including hazardous waste law, is
incomplete end often contradictory, it is likely that as it
evolves the use of the strict liability theory will increase.
Thirdly, these things will in turn increase the necessity for
hazardous waste generators to hire competent hazardous waste
management firms.  Despite these desirable changes in hazardous
waste management and law, incidents will occur for which generators
and service firms will need some form of financial protection.
Insurance is one such form of protection.

     Recommendations for liability insurance are somewhat more
difficult to make.  Less is known about insurance as it relates
to hazardous occurrences.  What can be said is that the financial
responsibility requirement requires that an operator have insurance
against a hazardous waste pollution incident versus the standard
liability protection.  Many questions, however, need answers
before standards can be set for financial responsibility.  Should
                                -358-

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the amount of financial protection required for an incident be
set at the amount of liability insurance available from private
sources?  Can it be assumed that the private insurance industry
would be able to provide "adequate" liability coverage and that
government indemnification will not be required?  Is it reasonable
to require a hazardous waste management firm to obtain coverage
over all aspects of operating a hazardous waste facility including
transportation accidents, contamination incidents and other
risk activities associated with long-term consequences even after
closure of a facility and/or a change in ownership?  To an insurer,
one thing is clear, the operator of a facility, as a condition
for obtaining insurance, would be required to meet all standards
associated with the operation of a hazardous waste management
facility as a condition for obtaining insurance.

     Hazardous waste disposal sites, for example, will ultimately
reach full capacity and must be closed; but the potential for
occurrences still remains.  Regardless of the kind of firm
originally owning such a facility or the current ownership whether
public or private, liability for damages is an important fact
or burden that someone may have to bear.  Certainly the possibility
exists that the owner and operator of a closed hazardous waste
facility still under his ownership could be held liable for long-
term damages.  The problem is complex when ownership has changed.
In order to provide protection in the event of future occurrences
after closure, the liability insurance requirement must include
coverage for long-term damage regardless of whether ownership
is retained or not.
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                  LONG-TCRM SITE KAINTtC/.dCE PROBLEMS
                    AND THE POTENTIAL FOK LIABILITY

                                  By

                             John 
-------
     The purpose of this paper  is to review the technical aspec    f




sanl.tary landfill post-operation problems, their causes, and t\-  r




solution.








     First, the problems.  The  principal so-called post-construction




liability and "perpetual care"  problems  Include the  impact of gas or




leachate on the environment, settlement  performance of  landfill, erosion




of landfill cover soil, various aesthetic  issues, and the impact of the




landfill on property values.
GAS
     Landfills produce gas, varying only  in total quantity and the time




frame In which It is produced.  Carbon dioxide, one of the principal




gases of decomposition of refuse, has  liability association, principally




related to its solubility in water, creating a weak acid, corrosive




environment, and increasing water hardness.  Relatively little concern




Is directed to preventive, or remedial, action insofar as carbon dioxide




Is concerned, and as such it will not  be addressed further in this



paper.








     Methane, the other principal gas  from refuse decomposition, is




highly combustible in certain concentrations in air, a characteristic




that gives methane a dual personality.  On the positive side, methane




can be a definite asset, representing, in certain cases, an economically




recoverable energy resource.  On the negative side are hazards and




liabilities associated with uncontrolled  release of the gas from the
                                    -361-

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fill confines, with an accompanying possibility of fire, or when accum-


ulated in confined areas, explosion.





     The production of methane gas as a function of time Is of interest


for at least two reasons: (1) to evaluate the expected "active gas life"


of a landfill, and (2) to consider the feasibility of recovery of methane


for energy.  Consider that methane gas is generated only from the organic


matter which may be characterized as in Table 1.
                                TABLE 1
                METHANE GENERATION FROM ORGANIC MATTER
    n, =„!,- M,.-* .-              	Active Life	    Composition
    Organic Hatter              Half Life	30% of Life        (*)

                                 (years)          (years)
Readily Biodegradable           0.5 - 1.5          i - 3             9


     Food Wastes


Moderately Biodegradable          5-25          15-80           91


     Paper Products


     Garden Waste


     Textlle Products


     Wood


Non-biodegradable                50-00             —              o


     Rubber


     Plastic
                                    -362-

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     It should be noted that more  than 90 percent of methane gas produced




Is generated from the moderately biodegradable fraction of which paper




products predominate.  To merely close a site does not stop gas production




which may continue for 20 to 100 years.








     The potential for gas hazard  is probably present to varying degrees




at the majority of landfills.  The  liability aspects of landfill-




produced methane are generally recognized throughout the industry.




Concern for methane sterns from its  combustibility when present in concen-




trations between 5 and 15 percent  by volume in air.  While fire alone is




concern enough, combustion initiated within a confined space can result




In an explosion.  If migrating methane accumulates in a poorly-




ventilated area (i.e., building subfloor, basement, closet, utility




vault, storm drain) and achieves combustible concentrations, d hazard to




public safety and/or property exists.  Since methane is usually present




!n concentrations above the combustion range within landfills, it always




must pass through the combustion range as it is diluted with air.




Fortunately, under the majority of  circumstances, a combustion energizer




such as an open flame is not present during passage through the critical




range and combustion does not occur.  The numerous instances on record




of fires and explosions resulting  from landfill-originating methane,




however, serve to warn that all too often gas migration proves hazardous.








     The movement of gas to the limits of a refuse fill  and into the




surrounding soils occurs by two basic processes:  convection, or movement




In response to pressure-temperature gradients;  and diffusion,  or movement




from areas of high gas concentration to regions of lower concentration.
                                    -363-

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Gas flow Is greater through materials with large pore spaces and high




permeability (i.e., sands, gravels) and  lower  In materials of lower




permeability (i.e., clays).  Gas migration from landfills Is therefore




dependent In part on the geological environment of the site.  In general,




a landfill constructed in a sand-gravel environment experiences greater




vertical and lateral movement of gases than one in a clay environment.








     Being lighter than air, methane tends to  rise and will exit prefer-




entially through the landfill cover if it is of sufficient permeability.




A cover of clay with small diameter pores tends to retain moisture in




Its pores and is thus relatively impermeable,  and tends to restrict gas




loss.  Any type of soil may be made less permeable by saturation with




rain or irrigation water, or by paving or frost.  In such instances gas




flow through the cover will be impeded, and lateral migration will be




encouraged.  Also, rain water may  infiltrate the refuse and increase the




moisture content, which in turn increases the  rate of decomposition, and




thus the gas production.  This condition, occurring in combination with




the decreased permeability of surface soils, can result in significant




seasonal variation in the extent of gas migration.   Where a groundwater




table exists beneath a disposal site, It provides an absolute limit to




the depth of gas migration.








     The gas produced within a landfill must escape; the geologic-




hydrologic environment and construction of a particular site combine to




determine the direction the gas will flow, either through the cover,




laterally, or In both directions.  Uncontrolled relief of the gas may




mean Its release occurs in an undesirable area, leading to environmental
                                    -354-

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and hazard problems.  Controlled  relief means  release  Is  !n a manner




compatible with environmental security and safety.








     Placement of a thick, moist, vegetative final cover may act as a




gas-tight lid that forces gases to migrate laterally from the landfill.




If the site  is converted  into a paved parking  lot, this may prevent




gases from venting into the atmosphere.








     In 1968, seepage of methane  from a landfill caused an explosion In




a National Guard armory in Winston-Salem, North Carolina that took the




lives of three men and seriously  injured two others.  Two workmen in




Milwaukee were killed when methane seeping into a deep storm sewer




trench ignited.  In 1975, small buildings at two separate fills In




Michigan suffered structural damage due to methane explosions, while in




Vancouver, Canada a newly-poured  foundation slab was structurally damaged




by an explosion in the underslab  air space Initiated by a cigarette.




The list of  similar incidents Is  certainly much larger and continues to




Increase annually.  Law suits are evolving around methane hazard and its




effect on adjacent property value, public safety and health, and on




vegetation stress.








LEACHATt:








     Leachate Is liquid which has percolated through solid waste and




emerges from a landfill carrying with it soluble and suspended substances.




However, leachate production may be years in Its Initial  showing and is




not always produced from landfills.  It requires substantial water
                                   -365-

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Infiltration (say 2 Inches of water per foot of refuse thickness) to




produce leachate at all.  Leachate production will probably occur when




annual rainfall exceeds 30 Inches, and will probably be of no concern




when less than 20 inches of rainfall occurs per annum.








     The sources of water which ultimately produce leachate Include




rainfall which either infiltrates the refuse soil cover or flows off the




surface of the disposal site.  Some of the portion which infiltrates the




surface will percolate  Into the solid waste below as net Infiltration.




Other sources of water  infiltration include runoff from surrounding




land, and water entering through the bottom or sides of the fill.  The




moisture created by waste decomposition Is so little as to be of no




Impact.  Obviously, liquid wastes placed  in the landfill during  landfilling




may contribute to leachate production.








     The first water entering the solid waste is absorbed much as a




sponge absorbs water.   Eventually, however, the solid waste reaches a




level of moisture content known as field  capacity.  At this moisture



content further addition of water causes  leachate to leave the solid




waste.  Leachate is formed before the refuse Is fully saturated because



solid waste is not homogeneous, channels  exist, and some of the waste




does not absorb water readily.  These factors may cause water to con-




centrate in some areas  and create leachate even though all portions of




the fill are not at field capacity.








     Typically, leachate production should not be noticed until after




the refuse has received at least two  Inches of net infiltration per foot
                                    -366-

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of refuse thickness.  Even then production should be  limited, as the




refuse still has the ability to absorb additional water before it reaches




Its maximum degree of saturation.   If a  landfill is well managed (good




cover application, good drainage, uses Impermeable soil cover, Is dense




and well compacted, etc.), then leachate production may not occur until




well after the site is closed.  This statement  is applicable even in




a-reas of high annual precipitation, and obviously true, almost without




exception, where annual rainfall  Is less than 20 Inches per year.








     Although the landfills of the  past were principally uncontrolled




dumps and filling took place with little if any technical supervision,




the cases of reported leachate damage are remarkably  few.  We are aware,




however, of a few serious cases of  environmental pollution as reported




In the literature, and in addition  must  recognize that what was below




ground and never measured may never be known.  Today, and in the future,




we will be required to determine  the migration or control of leachate




through monitoring systems.  We expect that the sound engineering princi-




pals Incorporated into current and  future landfill design and operations




will support upgraded performance standards.  In some instances this




will mean the leachate is encouraged to move outward  from the refuse and




seek attenuation in the surrounding soil and water environment.  If the



monitoring data supports the design predictions, then all is well and




good.








     A real dilemma may be In the offing as regulatory bodies and dischar-




gers of chemical, toxic, and hazardous wastes apply pressures on landfill




operators to accept these more difficult, non-municipal wastes.  The
                                   -367-

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operator finds a unique opportunity to Increase revenues at the encourage-




ment of regulator and disposer alike, who judge, rightly or wrongly, the




landfill to be the best repository for these wastes.  Now, however,




think what will happen when monitoring data reveals an adverse parameter




performance, and then another and yet another.  What then will be the




posture of the regulatory body?  The discharger?  And not the least, the




public?  What can the operator do?








     Suppose, however, that the site receiving these wastes is a full




containment site (no leachate migration), and that there Is a continual




building of leachate (net infiltration).  Sooner or later the landfill




will be fully saturated and the contained liquid must be properly




handled.  Again, the leachate will exhibit those characteristics which




reflect the materials deposited therein.  The cost of handling and




treating may in fact far exceed the revenues received when the operator




was thanking the regulatory body and discharger for the short-term




revenue wlndfal1.








     The most important effect of uncontrolled leachate migration !s



water quality degradation, but there are other deleterious consequences.




The effect on fish and/or plants  in areas contaminated by leachate are




often serious.  Visual effects and malodor are two environmental impacts




resulting from leachate.








SETTLEMENT
     A sanitary  landfill will settle as a result of waste decomposition,



filtering of fines, superimposed  loads, and  its own weight.  Bridging





                                   -368-

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that occurs during construction produces voids.  As the waste decomposes,




fine particles from the cover material and overlying solid waste often




sift Into these voids.  The weight of the overhead waste and cover




material helps consolidate the fill, and this development is furthered




when more cover material is added or a structure or roadway is con-




structed on the fII1.








     The most significant cause of settlement is waste decomposition,




which Is greatly influenced by the amount of water in the fill.  A




landfill will settle more slowly if only limited water is available to




decompose the waste chemically and biologically.  In Seattle, where




rainfall exceeds 30 inches per year, a 20-foot fill settled four feet in




the first year after  it was completed.   In Los Angeles, where less than




15 Inches of rain falls per year, three years after a landfill had been




completed a 75-foot-high area had settled only 2-3 feet, and another




section that had been 46 feet high had settled a mere 1.3 feet.  A




demonstration grant we are currently completing in Sonoma County, Cali-




fornia showed up to 20 percent settlement at the completion of stabiliza-




tion by leachate recirculation.  This settlement occurred even though




the refuse was placed at a relatively high density of 1000 pounds per




cubic yard.








     Settlement also depends on the types of wastes disposed of, the




volume of cover material used with respect to the volume of wastes




disposed of, and the compaction achieved during construction.  A fill



composed only of construction and demolition debris will not settle as




much as one that is constructed of residential solid wastes.  A landfill
                                    -369-

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constructed of highly compacted waste will generally settle less rapidly




than one that Is poorly compacted.  If two landfills contain the same




types of wastes and are constructed to the same height, but one has a




waste-to-cover volume ratio of 1:1 and the other a ratio of '»:!, the one




with the lower ratio will settle  less.








     Differential settling may form depressions that permit water to




pond and infiltrate the fill.  In Houston, Texas it is reported that a




one to two-acre section of a completed landfill dropped one to three




feet overnight.  Settling may cause structures on the landfill to sag




and possibly collapse; underground utility lines that serve buildings or




traverse the site may shear.  Settlements will continue for many years




after the site Is closed, and may be incident dependent, e.g., a sudden




flood.








EROSION








     Erosion results when sheet runoff of a covered landfill is non-




uniform, and when the underlying cover soil is erodable (non-cohesive




soil, devoid of vegetation, loose, etc).   Differential settlement due to




the decomposition of refuse material at different rates can lead to the




redirection of surface drainageways which in turn collect water and lead




to erosion of the cover material.  The Improper design or placement of




drainage ditches, culverts, driveways, or streets may also lead to




premature erosion of cover material and exposure of refuse.  Wind erosion




may also adversely affect the durability of landfill cover and must




therefore be considered among the long-term maintenance problems.  Gas
                                    -370-

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migration may adversely  stress  erosion  resistant  vegetation,  thereby




Indirectly  fostering  erosion.








PROPERTY VALUES
     A  landfill can  Impact  significantly on  land  values  in tangible as




well as  Intangible ways.  The  value of  a completed  landfill may be on




the order of  50 to 80  percent  of  the  value of  similar zoned adjacent




property. The reason for  the reduction  Is obvious:  Increased  improvement




and maintenance costs.








     The Impact on adjacent properties  may be  far more  intangible.  The




mere potential of: (1) future  malodors  appearing' (2) future  gas hazard',




andj (3) unsightliness  caused by vegetative stress,  erosion and grade




changes  induced by settlement, are enough to have a negative  effect upon




property values.








VISUAL AESTHETICS
     Aesthetics,  In particular  the visual aspects of a completed land-




fill, cannot be  Ignored as a potential  long-term problem or even as the



cause for a legal complaint.








NEED FOR QUALITY  CONTROL








     The foregoing discussion identifies the most prevalent problems




which can surface subsequent to closure of a landfill.  This Is not
                                    -371-

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meant to Indicate that sanitary  landfills are not a practical or economic




means for the disposal of wastes.  On  the contrary, sanitary  landfilling




Is the principal means for the disposal of the nation's waste.  The




point to be made is that a sanitary  landfill requires careful planning




and engineering to control potential problems.








     Now let us examine what can be  done In the way of preventive or




remedial actions which should be taken to preclude post construction




maintenance, decline  in property values, or property damage and litiga-




tion.  In each case it will be seen  that preventive action taken during




landfill design and construction is  less costly than remedial steps




taken after a landfill has been closed.








METHANE GAS CONTROL
     There are three basic approaches to the control of methane gas:




(1) control of the production,  (2) prevention of migration by means of




Impervious barriers to flow,' and  (3) venting.








     Controlling rate of production, although technically feasible, is




not practical at present.  The  future holds promise  in  (1) rapid sta-




bilization of refuse through leachate recircuiation which will result In




a relatively early cessation of gas production, and  (2) exhaust venting




Internally of the refuse limits thus drawing oxygen  through the methano-




genlc bacteria environment.  Since the oxygen is toxic  to these micro-




organisms, this procedure wi11  limit methane production.
                                    -372-

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     Impermeable membranes consisting of natural clay; plastic, rubber,




or similar film sheet; and asphalt can be utilized to control gas flow.




Soil barriers are most effective when maintained at a high saturation




level.  Soils utilized for cover sealing, however, may develop cracks as




a result of drying or large differential settlement occurring across the




surface of the fill.  For this reason, the thinner flexible polymeric




membranes or reinforced rubber are often preferred for migration control.




Barriers typically are best implaced during  landfill construction, as




subsequent installations are often costly, less extensive than required,




and occasionally impossible to accomplish.   During construction, barriers




can be placed to cover the base and lateral  surfaces of the fill space.




Installation after fill completion might be  limited to trenching in the




area requiring protection and insertion of a membrane into the trench,




followed by backfilling.








     Venting systems may be either passive (relying on naturally occur-




ring pressure or diffusion gradients) or induced exhaust (blowers are




utilized to create a pressure gradient), the selection being dependent




on site conditions.  The passive systems rely on imposition of material




of high permeability, such as gravel, in the path of the gas flow, the




effect being to present a path for gas flow more conducive to flow than



the surrounding medium, and thereby redirecting flow to a point of




controlled release.  These systems usually consist of a gravel blanket




or continuous trench backfilled with gravel.   Passive systems are ir.ost




effective In controlling convective gas flow, less so in instances of




diffusive flow.  Since most of the flow Is diffusion ralated the designer




must judge the effectiveness of his selection based on the character of




the flow regime.






                                   -373-

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     Induced flow systems, particularly  those employing suitably designed




vertical wells, have proven very effective  in the control of  lateral




migration,whether convection or diffusion  induced.  Typically these




systems Incorporate a series of vertical wells emplaced in large diameter




bore holes, not unlike those being considered in gas recovery  (for fuel)




systems.  Wells are spaced at  intervals  along the margin of the landfill




requiring protection, either located  interior to the limit of fill, or




externally In the surrounding  native  soils, depending on system require-




ments.   The wells are connected by manifolding to a central exhaust




blower which draws gas from the well  field.  The gas flow in the volume




of refuse or soil influenced by each well  is therefore toward the well,




effectively controlling migration.  Systems combining both recovery and




migration control should be considered whenever practical.








     Gases collected by exhaust systems  are generally disposed of by




direct stacking, incineration, or by  passage through various sorption




media.   Gases from passive vent systems  usually are allowed to direct




discharge; in certain cases, the gases are combusted as in "tiki torches."




In all  instances, uncombusted  gas must be exhausted at a location where




It Is not subject to careless  ignition,  generally in a protected enclo-




sure, or above normal reach.   Direct discharge may release noxious odors




and the designer should always be prepared for a backup burner system to




control odors, if objectionable.








     The success of any control system Is measured by a monitoring




system throughout the gas production  life of the landfill.
                                    -374-

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LEACHATE CONTROL








     The objective of any  leachate control system  is to prevent the flux




of landfill-produced contaminants to the groundwater and/or surface




water regimes.  Many soils have an ability to attenuate waste residues




and thus reduce the contaminant flux to the hydrologic system.  Where




possible this natural ability of the soil to treat  leachate should be




employed.  Where compatible with the environment and relevant regulations,




it Is by far the simplest and most economical method of leachate control.




Many fine-grained moderately permeable silt and clay rich soils offer




excellent potential for natural control of landfill-produced contaminants.








     The slope of the water table indicates the general direction of




leachate movement.  The actual path may be influenced by other factors




such as difference in specific gravity of leachate from water, variations




and/or stratification of earth materials, the topography and elevation




of the top of the zone of saturation, and by external factors such as




streams that intercept the water table, and/or pumping wells.  The third




dimension, the vertical component of flow, must always be considered.




Close to streams that receive groundwater discharge there may be an




upward movement of groundwater.  In such areas, the natural flow system




controls the movement of leachate - extensive groundwater pollution is




prevented but undesirable quantities of contaminants may reach the




stream.








     In situations where natural control  systems are deemed to be insuffi-




cient, because of inadequate or poorly understood soil  conditions, or
                                    -375-

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for other reasons, facilities for leachate containment, collection and




treatment may be developed, and in practice are imperative.  Leachate




control can be accomplished by controlling the generation rate and




chemical composition, for example by design of the fill so as to minimize




Infiltration, by recirculation, by control of pH, and by full or partial




containment through the use of liners.








     The quantity of leachate produced, and thus the amount requiring




treatment after collection, can be greatly reduced by careful site




design and good management.  By using a thick final cover of well com-




pacted clayey soil graded to relatively steep slopes and well vegetated




with erosion-resistant plants, It may be possible to reduce and perhaps




preclude the production of leachate.  The ultimate control would be to




eliminate infiltration into the landfill by placement of an impermeable




liner between the refuse and cover soil.








     Waste may be deposited upon essentially impermeable in-sltu soil or




bedrock where careful bottom grading directs leachate along the bottom




of the fill to suitable collection facilities.  Handling and treatment




of the leachate beyond the collection point requires a site specific




design solution.








     In recent years public concern over the pollution potential of




landfill produced leachate has grown tremendously.  As a result of this




concern, and because of the difficulty  in procuring the most desirable




sites for landfill, there has been an Increasing interest in the use of




Impermeable membranes or liners that will Intercept leachate at the base
                                    -376-

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of burled refuse and thus prevent  It from entering  the soil beneath the

landfill site.  Leachate thus  intercepted must be collected and removed

for treatment before release  Into  the environment.  A liner can be

employed so ar to utilize land for solid waste disposal that otherwise

may be unsuitable from a hydrogeologic viewpoint.  A liner of suitable

material, carefully Installed  beneath the entire fill area, is a positive

method of leachate control.


SETTLEMENT CONTROL

                    \
     Subsidence In landfills has been tentatively determined to be a

function of the Initial compaction of refuse materials, compaction of

refuse materials due to surcharge  loads, volume reduction caused by

biological decomposition of the organic constituents of the refuse,

volume reduction caused by saturation, the nature of refuse materials

such as compressibility, and volume reduction resulting from removal of

teachable materials.  Minimization of heterogeneity may be accomplished

by mixing the refuse with inert material, addition of water to an optimum

moisture content to facilitate compaction, and maximized compaction.

Shredding and baling also contribute to volume reduction and therefore

minimize settlement.


     Leachate reelrculatlon can greatly shorten refuse stabilization

time, thereby inducing maximum settlement in minimum time.  This approach

lends Itself to early use of the site for development purposes.
                                    -377-

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    EROSION CONTROL








         Erosion control  measures include planting vegetation;  use  of  mulches




    such as straw,  hay,  wood chips;  soil  stabilization,  structural  coverage,




    as  well as  energy dissipators and rip-rap protection for  flowing water.








         Planting vegetation is an important and effective method of pre-




    venting and limiting  erosion, but vegetation alone will not provide




    adequate protection  on soils that are unstable because of their struc-




    ture,  nutrient  availability, internal water movement,  or  excessively




    steep slopes.








         Mulch  plays  much the same role as vegetation -  intercepting rain




    and preventing  soil  displacement by impact and retarding  runoff.   It




    also enhances viability of seedings by conserving soil  moisture.








         Soil  stabilization includes compaction to increase relative density




    and the addition  of  gravel and clay to reduce erodability.   Chemicals



    may also be added to the topsoil to reduce erosion.








         Drainage channels or watercourses with steep gradients should be




    lined with  suitable  structural coverage - sod, concrete,  asphalt,  rip-




    rap, or gunnite.








    VISUAL AESTHETICS
         landscaping,  contouring,  and general  maintenance procedures  are the



i    principal  means for controlling the appearance of a landfill.   In
                                        -378-

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addition to being aesthetically attractive, trees can also help prevent



wind erosion.








PROPERTY VALUES
     One problem that cannot be  fully controlled at this time is the



Intangible problem of the  impact of  landfills on property values.  The



answer to this problem, however, is  in the  implementation of appropriate



quality control techniques as discussed  in  the previous paragraphs.



With proper quality control, landfills can  become technically sound



products and minimum degradation in  property values should result.








CONCLUSION
     The major point to be made  in all of the foregoing is that a sani-




tary landfill requires careful planning, engineering, and design, plus




sound operation to insure that long-term maintenance problems will not




prove a source of liability.   If properly designed and operated, a




sanitary landfill can actually increase the value of surrounding land.




When completed, properly designed and engineered landfill  sites can be




converted to community assets as parks, golf courses, green spaces, ski




hills, and other attractive uses.  What a community might otherwise




consider an undesirable neighborhood liability can evolve into an attrac-




tive park or, In the case of a commercial/industrial development, a




highly desirable taxable asset.
                                   -379-

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               ECONOMICS OF LANDFILL LOCATION
                     BY JOHN W,  THOMPSON
          OFFICE OF SOLID WASTE  MANAGEMENT PROGRAMS
            u.S, ENVIRONMENTAL PROTECTION AGENCY

     TRADITIONALLY, THE LOCATION OF LAND DISPOSAL SITES HAS
BEEN PREDICATED ON TWO IRRATIONAL FACTORS; "OUT OF SIGHT,
OUT OF MIND" AND "CHEAP LAND HOLDS DOWN DISPOSAL COSTS."
WHILE THESE ATTITUDES HAVE STRONG PUBLIC APPEAL, THE LONG-
RANGE COST MAY BE MORE THAN TAXPAYERS CAN OR SHOULD SUPPORT,
ASSUMING ALL SITES UNDER CONSIDERATION ARE ENVIRONMENTALLY
ACCEPTABLE, RATIONAL DECISIONS AS TO THE LOCATION OF NEW
DISPOSAL SITES SHOULD BE BASED ON AN ECONOMIC APPRAISAL OF
THE LONG-RUM COSTS.

     IN RECENT YEARS, MANY COMMUNITIES OPTED FOR NEW SITES
15 TO 50 MILES FROM THE CITY.   ALTHOUGH CITIZEN OPPOSITION
AND THE PRICE OF LAND WERE LOW,  THE DECISION REQUIRED THE
CONSTRUCTION OF TRANSFER FACILITIES THUS INCREASING CAPITAL
AND OPERATING COSTS.  OTHER COMMUNITIES WITH CLOSE IN SITES
ACQUIRED SHREDDING FACILITIES WITH THE IDEA OF INCREASING
THE VOLUME OF SOLID WASTE PLACED IN A SITE.   WHILE THIS
DECISION MAY HAVE LENGTHENED THE LIFE OF THE SITE TO SOME
EXTENT IT ALSO INCREASED TOTAL SYSTEM CAPITAL AND OPERATING
COSTS SUBSTANTIALLY.
                                  -380-

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     RECENTLY, THE OFFICE OF SOLID WASTE MANAGEMENT PROGRAMS
(OSWHP) IN EPA CONDUCTED A STUDY OF LANDFILL,  SHREDDER, AND
TRANSFER STATION COSTS. ^    RESULTS INDICATED THE PRICE OF
LAND IS SUCH A SMALL PORTION OF TOTAL DISPOSAL COSTS, THAT
PAYING A VERY HIGH PRICE FOR LAND ADJACENT TO THE COMMUNITY
MAYBE A SOUND ECONOMIC DECISION.  THIS IS ESPECIALLY TRUE IF
THE LAND CAN BE ACQUIRED IN LIEU OF TRANSFER OR SHREDDER
FACILITIES.
     USE OF SHREDDING OR TRANSFER FACILITIES IS AN INTERMEDIATE
REHANDLING STEP BETWEEN COLLECTION AND DISPOSAL.   THE RECENT
OSWMP EXAMINATION OF THE COSTS OF THESE PROCESSES INDICATED
THAT:

    •   SHREDDING OPERATIONS COST ABOUT $7.46 PER TON OF
        SOLID WASTE PROCESSED
    •   TRANSFER OPERATIONS COST $5.21 PER TON, EXCLUSIVE OF
        COLLECTION, AND DISPOSAL COSTS IN 1975.
    •   THE COST OF LAND WAS LESS THAN 4 PERCENT OF SOLID
        WASTE DISPOSAL COSTS BASED ON THE 17 SITES SURVEYED.
    •   IN MOST INSTANCES PAYING A HIGH PRICE FOR LAND CLOSE
        TO THE CENTER OF WASTE GENERATION OR ADDING LINERS
        AND LEACHATE CONTROL WILL ADD LESS TO THE COST OF
        WASTE MANAGEMENT THAN WOULD INSTALLATION AND OPERATION
        OF SHREDDING OR TRANSFER FACILITIES.
                                 -381-

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     SW DISPOSAL COSTS ARE THE LOWEST COST ITEM IN MUNICIPAL
gOLID WASTE MANAGEMENT
     THE FOLLOWING TABLE OF 1975 SOLID WASTE COSTS SHOULD
HELP SUBSTANTIATE THE FACT THAT LAND DISPOSAL IS THE LEAST
COSTLY OPERATION IN SOLID WASTE MANAGEMENT IN MOST COMMUNITIES.

     ITEM                COMMUNITIES RF.PORTING   AVERAGE COST PER TON
COLLECTION                       102                   $21.OO2
SHREDDING QQ-MILE HAUL)           7                     7.46
SHREDDING ONLY                    10                     5.83
TRANSFER (17-wiLE HAUL)           11                     5.21
LANDFILLING MIXED SOLID WASTE     W                     3.33
LANDFILLING SHREDDED SOLID WASTE   3                     1.84

     THE 17 LAND DISPOSAL SITES SHOWN ABOVE PLACED AN AVERAGE
OF 380 TONS PER DAY,  COSTS RANGED FROM $1.30 PER TON FOR
ONE SHREDDED SITE TO $6.72 PER TON FOR A LOW TONNAGE SITE WITH
HIGH ENVIRONMENTAL STANDARDS.  THESE FIGURES INCLUDE LAND
AND DEVELOPMENT COSTS BUT NOT INTEREST.
                                   -382-

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        AND OPERATING COSTS FOR 17 PERMITTED LAND DISPOSAL SITES
CAPITAL COSTS PER TON PLACED       OPERATING COSTS PER TON PLACED
LAND                $ .13          LABOR AND FRINGES     $1.20
DEVELOPMENT           .13          STATIONARY EQUIPMENT    .04
STATIONARY EQUIPMENT  .01          VEHICLE 0 & M           .84
VEHICLES              .39          ADMIN. & OTHER          .31
TOTAL               $ .66          TOTAL                 $2.39
                                                           .66
                                                          $3.05
     LAND COSTS FOR THE ABOVE SITES AVERAGED 13 CENTS PER
TON OF SOLID WASTE PLACED AND RANGED FROM  .02 TO 39 CENTS
PER TON.  TYPICAL LAND COSTS REPORTED FOR  NEWLY ACQUIRED
LAND AVERAGED ABOUT $2,000 PER ACRE (RANGING FROM $163 TO
$10,600).  NATURALLY, THE DEPTH OF THE FILL, AMOUNT OF
COVER, NON USEABLE LAND, AND SOIL COMPOSITION HAD AN EFFECT
ON TONS PLACED PER ACRE.  THE 17 SITES AVERAGED 16,400 TONS
OF SOLID WASTE PER ACRE RANGING FROM 4,000 TONS IN FLORIDA
TO 34,000 TONS IN CALIFORNIA.

     DEVELOPMENT COSTS ARE ANOTHER IMPORTANT CONSIDERATION
IN LOCATING A SANITARY LANDFILL.  IN THE OSWflP STUDY CITED
ABOVE, DEVELOPMENT COSTS FOR DESIGN ENGINEERING, PERMITS,
ROADS, FENCES, LEACHATE COLLECTION, DRAINAGE, VENTING, AND
OTHER ASSOCIATED COSTS AVERAGED .13 CENTS PER TON; THE SAME
AS LAND COSTS.  THE DEVELOPMENT COSTS RANGED FROM 0 TO 88
CENTS PER TON.  BASED ON DATA COLLECTED, LOW PRICED LAND WAS NOT
                                  -383-

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 ALWAYS THE MOST EXPENSIVE ITEM IN THE LOCATION OF A SITE.
OFTEN A ROAD COSTING $30,000 TO $150,000 WAS NEEDED.  SEVERAL
CITIES REPORTED EXTENSIVE COSTS IN GETTING UTILITIES TO THE
SITE OR HAD A CONSIDERABLE AMOUNT OF DRAINAGE TO DO BEFORE
THE SITE COULD BE OPENED.

     VALUE OF LAND IN RELATION TO TRANSFER COSTS.   IN RECENT
YEARS, MANY COMMUNITIES HAVE LOCATED SITES AT CONSIDERABLE
DISTANCES FROM THE SOURCE OF WASTE GENERATION.   THIS HAS
MADE IT NECESSARY TO INSTALL ONE OR MORE TRANSFER STATIONS
AND A FLEET OF TRACTOR TRAILER TRUCKS FOR MOVING SOLID WASTE
TO THE SITE,  |'10ST TRANSFER STATIONS HAVE BEEN  JUSTIFIED ON
THE BASIS THAT LOST TIME FOR COLLECTION VEHICLES IN NON
ROUTE ACTIVITIES MORE THAN COMPENSATE FOR COSTS OF OPERATING
A TRANSFER STATION,  WHILE MOST TRANSFER STATIONS ARE JUS-
TIFIED, HAULING SOLID WASTE A LONG DISTANCE BY  ANY MEANS IS
A COSTLY OPERATION,

     AVERAGE HAULING COSTS PER TON WERE ESTIMATED AT $2.70 BASED
ON 10 SITES.  THIS INCLUDES DRIVERS AVERAGE WAGES OF $5,00
PER HOUR AND 20 PERCENT FRINGE BENEFITS,  ABOUT 52 CENTS OF
THE PER TON COST WAS FOR VEHICLE DEPRECIATION.   MOST TRANS-
FER FACILITIES USED TRACTOR TRAILER VEHICLES WITH A 30,000
POUND NET WEIGHT CLASSIFICATION.  ON A MILE BASIS, COSTS WERE
                                  -384-

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ABOUT $1.36 FOR A 15 TON LOAD OR ABOUT 9 CENTS PER TON MILE.
THIS MUST BE DOUBLED TO COMPENSATE FOR THE ROUND TRIP.  THUS,
EACH MILE CLOSER TO THE TRANSFER STATION THAT A DISPOSAL
SITE IS LOCATED REDUCES TRANSPORTATION COSTS BY 18 CENTS PER
TON.  IF WE ASSUME A SITE HOLDS, 16,000 TONS PER ACRE, EACH
MILE CLOSER TO THE TRANSFER STATION A DISPOSAL SITE IS
LOCATED WILL REDUCE HAULING COSTS BY $2,280 PER ACRE OF LAND
USED.  THIS SAVING IN TRANSPORTATION COSTS COULD BE APPLIED
TO THE PURCHASE OF MORE EXPENSIVE LAND CLOSER TO THE TRANSER
STATION.

     ANOTHER WAY TO LOOK AT HOW COSTLY AN INTERMEDIATE
PROCESSING STEP LIKE A TRANSFER AND HAULING OPERATION CAN BE
IS TO ASSUME VERY EXPENSIVE LAND COULD BE PURCHASED WITHIN
THE CITY LIMITS IN LIEU OF A TRANSFER STATION AND LOW COST
LAND IS MILES AWAY.  COST SAVINGS OF $5.21 PER TON FOR
OPERATING AND CAPITAL COSTS OF THE TRANSFER FACILITY MULTIPLIED
BY 16,000 TONS PER ACRE WOULD MAKE THE LAND WORTH $83,000
PER ACRE AS A DISPOSAL SITE.  SIMILARLY ONE COULD JUSTIFY
TAKING NEARBY LAND WHICH IS LOW PRICED OR SUBMARGINAL, AND
MAKING IT ENVIRONMENTALLY SUITABLE FOR LANDFILLING BY INSTALL-
ING LINERS AND LEACHATE CONTROL IN EXCHANGE FOR A LONG HAUL
OR THE NEED FOR A TRANSFER FACILITY.
                                  -385-

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     OTHER FACTORS SUCH AS POLITICAL AND ENVIRONMENTAL
CONSIDERATIONS CAN NEGATE THE ARGUMENT FOR DISPOSAL SITES
ADJACENT TO THE COMMUNITY.  BUT, PLANNERS AND DECISION
MAKERS SHOULD AT LEAST MAKE AN ATTEMPT TO EVALUATE, ON A
LONG RUN COST BASIS, ALTERNATIVES TO TRANSFER AND LONG
DISTANCE HAULING OF SOLID WASTE BEFORE REACHING A CONCLUSION
ON THE LOCATION OF DISPOSAL SITES,

VALUE OF LAND IN RELATION TO SHREDDING
     SHREDDING OR THE GRINDING OF WASTE INTO UNIFORM PARTICLE
SIZE IS ANOTHER ALTERNATIVE STEP FOR REDUCING LANDFILL
(LAND) COSTS.   ADVOCATES OF SHREDDING GENERALLY LIST HIGH
COMPACTION, LITTLE OR NO COVER MATERIAL AND VECTOR CONTROL
AS PRIMARY JUSTIFICATIONS FOR SHREDDING.   BASED ON THE 1975
OSWMP STUDY OF 7 SHREDDER OPERATIONS, WITH A 21 MILE ROUND
TRIP HAUL TO A DISPOSAL SITE, TOTAL COSTS WERE $7.46 PER
TON,  OF THIS AMOUNT, $5.76 WAS FOR OPERATING COSTS AND
$1.70 FOR CAPITAL COST EXCLUDING INTEREST.  THE HAULING
COSTS OF $1.47 PER TON ON A 21 MILE TRIP BASIS, INCLUDED
DRIVERS WAGES AND FRINGES AND WERE INCLUDED IN THE OPERATING
COST,
     THERE HAS BEEN CONSIDERABLE AMOUNT OF LITERATURE PUB-
LISHED IN RECENT YEARS ON THE USE OF SHREDDING AND HIGH
DENSITY COMPACTION TO EXTEND THE LIFE OF A DISPOSAL SITE.
MOST INFORMATION INDICATES SHREDDING CAN EXTEND THE LIFE OF
                                  -386-

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A DISPOSAL SITE BY 25 TO 33 PERCENT WHEN DAILY COVER IS USED
AND UP TO 60 PERCENT IF DAILY COVER IS NOT REQUIRED.  HEAVY
DUTY COMPACTORS CAN INCREASE SITE LIFE BY 10-15 PERCENT.
WHILE THESE CLAIMS MAY BE TRUE, IF THE LAND COST is ONLY $
.13 PER TON PLACED, HOW MUCH ADDITIONAL CAPITAL AND OPERATING
COSTS CAN OR SHOULD A COMMUNITY SPEND FOR BETTER UTILIZATION
OF THEIR DISPOSAL SITE THRU SHREDDING AND HIGH DENSITY
COMPACTION?  ASSUMING A COMMUNITY CAN EXTEND THEIR SITE
CAPACITY BY ONE THIRD THROUGH SHREDDING, THE VALUE OF THE
LAND SAVED IS WORTH ONLY 6-7 CENTS A TON.  ON LAND WORTH
$10,000 PER ACRE THIS WOULD RESULT IN A LAND SAVING OF ONLY
30 CENTS PER TON WHILE COSTING ABOUT $5.83 PER TON FOR
OWNERSHIP AND OPERATION OF THE SHREDDING FACILITY EXCLUSIVE
OF THE HAUL COST.

     DISPOSAL OF SHREDDED MATERIAL WAS LESS COSTLY THAN
DISPOSAL OF CONVENTIONAL SOLID WASTE.  THREE SITES PLACING
ONLY SHREDDED MATERIAL REPORTED OPERATING COSTS OF $1.32 PER
TON, AND CAPITAL COSTS OF $ .52 FOR A TOTAL OF $1.84 PER
TON.  THIS WAS 55 PERCENT LESS COSTLY THAN THE $3.33 FOR
PLACING CONVENTIONAL WASTE.   (THESE DATA INCLUDE LAND, AND
EQUIPMENT DEPRECIATION BUT NOT INTEREST).  HOWEVER, SEVEN OF
                                  -387-

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THE SHREDDER FACILITIES PLACED THE SHREDDED MATERIAL INTO A
TYPICAL DISPOSAL SITE ALONG WITH DEBRIS FROM ALL OTHER SOURCES.
THUS THE ADVANTAGES OF RELAXED STANDARDS FOR COVER MATERIAL AND
VECTOR CONTROL WERE LOST.  MOREOVER IN SOME CASES, THE
ECONOMIC ADVANTAGE OF LOWER COSTS FOR A SHREDDED SITE WERE
OFFSET BY THE NEED FOR OPERATING A SECOND SITE FOR NON-
SHREDDED WASTES SUCH AS CONSTRUCTION DEBRIS, INDUSTRIAL
MATERIAL, STUMPS, YARD MATERIAL AND BULKY ITEMS.  THE
OPERATION OF A SECOND SITE REDUCED ANY ECONOMY OF SCALE IN
THE UTILIZATION OF EQUIPMENT AND LABOR ASSOCIATED WITH ONE
LARGE DISPOSAL SITE.

     ALTHOUGH SHREDDING is A NECESSARY PART OF RESOURCE
RECOVERY, SHREDDING PRIOR TO LAND DISPOSAL IS NOT NECESSARY
AND CAN BE A VERY COSTLY OPERATION.  USING A TOTAL CAPITAL
AND OPERATING COST FOR SHREDDING OF $5.83 PER TON LESS $1.49
LOWER LAND DISPOSAL COSTS, THE NET COST OF SHREDDING IS
$4.34 PER TON.  ASSUMING THE TYPICAL LAND DISPOSAL SITE WILL
HOLD 16,000 TONS PER ACRE AND THE WASTE WAS NOT SHREDDED,
COST SAVINGS TO THE COMMUNITY WOULD EXCEED $69,000 PER ACRE
BURIED.  THIS COST SAVINGS COULD BE USED FOR THE PURCHASE OF
NEW OR ADDITIONAL LAND OR LINERS FOR SUBMARGINAL LAND.
                                   -388-

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     IN RECENT YEARS  MANY  COMMUNITIES HAVE BEEN UNDER PUBLIC
PRESSURE TO  IMPROVE THEIR  SOLID WASTE MANAGEMENT PRACTICES.
IN MANY INSTANCES THEY  REACTED BY CONSTRUCTING SHREDDER
FACILITIES AND TRANSFER STATIONS, AND LOCATING LAND DISPOSAL
SITES LONG DISTANCES  FROM  THE SOURCE OF WASTE GENERATION
WITHOUT CONSIDERING THE LONG RUN ECONOMIC COSTS.  IN MANY
INSTANCES (1) PAYING  A  HIGH  PRICE FOR LAND CLOSE TO OR
WITHIN THE CITYj  (2)  INVESTING CAPITAL IN LINERS AND LEACHATE
CONTROL ON SUBMARGINAL  LAND  OR (3) ANNEXING LAND TO THE
CURRENT DISPOSAL  SITE THRU EMINENT DOMAIN WOULD HAVE BEEN
SUBSTANTIALLY THE LEAST COSTLY ALTERNATIVE ASSUMING ENVIRON-
MENTAL ASPECTS ARE EQUAL.

     TOLEDO, OHIO WAS CONFRONTED WITH THE PROBLEM OF LOCATING
A NEW DISPOSAL SITE.  AFTER  CONSIDERATION OF MANY SITES AND
ALTERNATIVES, TOLEDO  ARRIVED AT WHAT WE BELIEVE WAS THE
CORRECT DECISION.  THEIR NEW 160 ACRE SITE IS LOCATED WITHIN
THE CITY LIMITS.  IT  IS SERVED BY TWO MAJOR HIGHWAYS AND 17
ACRES ARE SET ASIDE FOR A  SHREDDING FACILITY IF AND WHEN A
MARKET FOR THE WASTE  BECOMES REALITY.  IN PURCHASING THE
LAND, IT WAS NECESSARY  TO  ACQUIRE 28 RESIDENCES ON 55 PARCELS
OF LAND.  MUCH OF IT THRU EMINENT DOMAIN. AVERAGE LAND COST WAS $LO,600 PER
ACRE.  BASED ON AN ESTIMATED PLACEMENT OF 28,000 TONS PER ACRE IN A 35 FOOT
DEPTH, LAND COSTS WILL BE APPROXIMATELY 38 CENTS PER TON.
                                   -389-

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THIS IS A VERY LOW SOLID WASTE DISPOSAL COST WHEN CONSIDERED


AGAINST OTHER ALTERNATIVE COSTS IN SOLID WASTE MANAGEMENT.





     IN SUMMARY, DECISION MAKERS SHOULD EVALUATE THE LONG


RUN CAPITAL AND OPERATING COSTS FOR ALL PHASES OF THEIR


SOLID WASTE MANAGEMENT SYSTEM IN LIGHT OF THE FACT THAT LAND


AND LAND DISPOSAL OF SOLID WASTE MAY BE ONE OF THE LOWEST


PRICED VARIABLES IN THEIR OVERALL SOLID WASTE SYSTEM.
I/ COST ESTIMATING HANDBOOK FOR TRANSFER, SHREDDING AND
   SANITARY LANDFILLING OF ^OLID WASTE,  85 P.  Booz
   ALLEN AND HAMILTON.  AUGUST 1976.  PRINTED COPY $5.00
   PB-256-WJ-1UP.  NATIONAL TECHNICAL INFORMATION SERVICE,
   U.S. DEPARTMENT OF COMMERCE, b285 PORT ROYAL ROAD,
   SPRINGFIELD, VIRGINIA  22161


2/ EVALUATING THE ORGANIZATION OF SERVICE DELIVERY IN SOLID
   WASTE COLLECTION AND DISPOSAL.  SAVAS, E.S.j COLUMBIA
   UNIVERSITY, OCTOBER 1975.
                                  -390-

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               GROUNDWATER PROTECTION ISSUES

                     Eugene A.  Glysson
                Civil Engineering Department
                   University of Michigan
                    Ann Arbor,  Michigan
      The subject of groundwater protection has become a very

 important issue in solid waste management.  Various methods

 of protection have been described and evaluated.

      The various strategies might be summarized as follows:

 I.  Separation

     A.   Distance:

      This implies physical distance such that the native soil

 will have a chance to attenuate the potential pollutants.   The

 efficiency of such separation is obviously dependent on many

 factors among which is the type of soil itself.

     B.   Barriers:

      The implication here is that the barrier be installed on-

 site before the waste is discharged.  The barrier may consist

 of a number of materials that have been very well described by
     2
 Haxo /  among which are:

         1.  Selected soils

         2.  Plastic membranes

         3.  Asphalic derivations

         4.  Portland cement derivations

II.  Monitoring

     A.   Wells

      The use of wells in strategic locations within and around

 the periphery of the landfill is a well established practice.
                               -391-

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The detection capability of such a system is very helpful in



giving warnings or alaying fear (whichever is the case) with




respect to the apparent migration of leachate from the refuse




mass.



    B.  Under drains



     With the advent of the wider use of the barriers mentioned




earlier an accompanying system of collection drains is often



considered.  The justification for such a system is to:




        1.  Assist in the detection of a break or leak in the



            barrier.




        2.  To provide a means of collection and extraction




            of any potential pollutants before they can migrate



            away from the site.




     It is the ability to not only detect the presence of a




possible source of trouble but to do something in a positive



way to prevent any subsequent damage or danger that is the



most important feature of an acceptable design.




     The attenuation of various metal ions by the soil has been



investigated and discussed by Fuller .  In addition to the



heavy metals and other ions mentioned in his investigation



there is the question of the attenuation of some of the chlori-



nated hydro carbons and various pesticides and herbicides which



may be placed in a hazardous waste fill.  It would be a rea-



sonable assumption to say that the various factors which were




stated by Fuller would probably apply to these more complex




materials as well.  However, considering the risks involved,



we should understand their behavior more thoroughly and addi-




tional research should be conducted on the attenuation and
                               -392-

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migration of these materials.



     Much has been reported in the literature on the biologi-



cal activity within the solid wastes placed in a landfill.



Some of this information has been based on research on refuse




placed in a lysimeter where conditions can be monitored and



controlled.  Other work has been carried out in landfill cells



in a more natural setting with conditions being monitored but




with less ability to maintain them in a designated condition.



We also have information on sewage sludge digestion both anaero-



bic and aerobic which may or may not be applicable to solid




waste decomposition.



     A basic question needs to be considered with respect to




the biological degradation of solid wastes.  Under normal con-




ditions this process is a natural one which serves to reduce




the volume of the waste and to return it to a stable form



which possesses less threat to the environment.  In the pro-



cess gases and various liquids containing organic acids and




other solubolizing components are formed.  These may give rise



to problems of themselves.  However, the question I raise is




that of the presence of toxic materials being disposed of along



with the normal mixed municipal refuse.  What happens if the



toxic materials interfere with the development of the bio-mass



which is usually counted upon to produce the aerobic and anaero-



bic decomposition of the material to stabilize it?  If biologi-



cal action is not materially interfered with it has been shown



by several investigators that the toxic substances are made



much more mobile by the products of decomposition and will mi-




grate much more forcely.  It has been recommended therefore
                               -393-

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  that toxic substances not be mixed with biodegradable organic



  materials in the same location within the sanitary landfill.



III.   Construction




       In the development of hazardous waste fills,  or sanitary




  landfills in general for that matter, in some locations liners



  have been required.   As experience is gained by those who are




  using various lining methods their successes and problems should




  be brought out for the benefit of all.  Haxo  has  described the



  research directed toward evaluating the performance of several



  liner types.  There is a need for developing a standardized




  methodology for testing liners in such a way as to more accurately



  predict their performance under expected landfill  conditions.




  An established set of standards would also allow the prospec-



  tive user to specify and subsequently receive a predictable




  product.



       Due to the limited time wherein data gathering and ex-



  perience with various liners has been possible we are unable




  as yet to predict accurately the life of such liners.  However,




  based on the knowledge that plastics have a long life in land-



  fills there is every confidence that several liner materials



  will provide the protection necessary.  As practioners we



  should ask for as candid a report on the application of these



  methods to be made public in as short a time as possible.



       We have long been accustomed to being governed by various



  regulations set forth by established regulatory agencies at



  all levels.  The requirements as set forth in these regulations




  are usually set at such a level as to provide the necessary



  protection or performance in the best judgment of the group
                                 -394-

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formulating the regulation.  This minimum requirement is often



translated into the maximum provided without regard to the



possibility that corrective measures that may be required later




may be much more inconvenient and expensive than some foresighted




additional provisions beyond those required being provided at



an earlier time.



     Such a precautionary situation may be illustrated in con-




junction with the problem of gas  (CH.)  migration from a land-



fill.  It is most certainly cheaper to install gas barriers and




the necessary venting prior to completing the landfill construc-



tion than to have to return to the site in an emergency situa-




tion to correct a problem which has subsequently developed.



     We should continue to request and support research on the




conditions which influence and determine the production and




migration of gas so that the need for protective measures can



be more accurately anticipated and the necessary precautionary




measures taken before damage or injury occurs.



     Fuller  has made mention of the use of some natural ma-



terials such as nut shells for the initial fixation of certain



heavy metals.  There are other natural materials such as tree




bark or wood chips which are resistant to degradation and con-



tain lignon that should have an attraction for heavy metals



which might be useful for such a purpose.  It should be noted




that these materials have a specific retention capacity and



when that is exhausted they will no longer retain more metals.



The quantity of these natural materials necessary, therefore,



must be determined based on the anticipated amount of heavy




metals to be attenuated from the leachate expected to be
                               -395-

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generated from the material in the landfill.  Any method which

is successful in reducing the amount of leachate will assist in

prolonging the time of effective attenuation.

     In conclusion it is my observation that the field of solid

waste management is moving rapidly towards a much more sophisti-

cated level where a great deal of technical information is re-

quired.  The only way that this type of information can become

widely enough available to all who need it is for those who are

in a position to gain it through practice or research to pass

it along freely through organizations such as the NSWMA.



REFERENCES

1.  Fuller, W. H., "The Importance of Soil Attenuation for
    Leachate Control," Proceedings 5th National Congress
    NSWMA, Dallas, December, 1976.

2.  Haxo, H. E., Jr., "Liners-Viable Options and Their Appli-
    cations, " ibid.
                               -396-

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EFFECTIVE STATE PROGRAMS

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     THE IMPORTANCE OF AN EFFECTIVE STATE SOLID WASTE
                   MANAGEMENT PROGRAM
                    William G. Bentley
     Director,                                 Vice President.
Division of Solid Waste Management      Association of State and
New York State                           Territorial Solid Waste
Department of Environmental              Management Officials
 Conservation
     The need for capable systems of management for solid wastes
Is finally being realized by the people of our country.  The
"findings" of the U.S. Congress and the developments In every
state are proofs that these activities are properly located In
state government.  These recognized needs, findings, and devel-
opments acknowledge the importance of an effective state solid
waste management program.

     The elements in consideration here are: Ij Is It Important
(of much significance or consequence) that we have an effective
(adequate to accomplish the purpose) program for the management
of the detritus from our effluent society ? and  2) Is the state
somehow the best suited or most appropriate level of government
to conduct such an Important function?  Let's begin with whv
it's important to have an effective solid waste management program
tho,  it hardly seems necessary for the group assembled at the
Filth National Congress on Waste Kanagrnent.

     Proper management of solid wastes Is a requirement for our
national well beln?.  There Is sufficient evidence at hand to
recognize that Improper practices In the solid waste field en-
danger human health.  We know of the environmental degradation
that results from solid waste Incorrectly managed.  And, further,
we now appreciate the waste of resources and energy which we
have allowed with our "throw away" life style.

     We have, as a nation, somewhat belatedly come to recognize
the vast quantity of material that is discarded.  Whether you
use five pounds per person per day, a thousand tons per person
a year, Include or exclude certain sources, the sheer mass Is
staggering.  Just to accomodate this pile we are using space or
acreage that In most instances could be better used in other
ways.  The successes in air and water pollution control are
                              -398-

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adding to the solid waste problem.  Things that used to go up
the stack or down the drain are commonly special problem addi-
tions to the land disposal burden.

     Incineration of the combustible part of the waste stream
has been a serious air pollutor which requires large capital
outlays to correct.  The production of leachate from dumped or
buried trash is a well recognized threat to ground and surface
waters.  Methane migration from landfills is a continuing and
perhaps, increasing problem.  Since open burning has been
stopped to protect air quality more organic material is de-
composing in landfills increasing the possibility of the haz-
ards of uncontrolled gas migration.

     Where the methane can be captured it can be a useful re-
source.  This idea of recovering resources is only scratching
at the surface of its potential, however.  The big picture is
one of tremendous waste - of resources and energy.  A country
made great, in large part, by seemingly boundless resources
and cheap energy can no longer afford the throw away style of
life.  We are running out of domestic sources. Importing more
and adversely effecting the nation's balance of payments.  The
costs, the savings to be realized, the tons of materials,
dollar values, etc. etc. are too familiar to this audience to
need repeating here.

     Enough has been said, where it probably needed no re-
minder, about the importance of an effective solid waste man-
agement program.  Health, environment and economy require it.
The element perhaps less accepted and certainly not as abun-
dantly reviewed in literature, press and professional con-
ference Is the appropriateness of the concentration of program
effort at state level.

     Last year, at the Fourth Congress, Moses HcCall in his re-
port on "The Role of the State in Solid Waste Management" said
"the state level this is 'where it's at' program wise".  He
further observed that state governments have the obligation of
assuring that local governments provide for efficient, en-
vironmentally sound solid waste services for their inhabitants,
either by the public or the private sector.

     There are a tremendous number of local governments.  In
New York State, for example, there are approximately 1600 units
of local government.  Most local governments represent small
populations, limited territories, narrow economic bases and fre-
quently, part time government.  They most commonly have neither
resources or capacities to carry out an effective solid waste
management program within their own jurisdiction.

     At the opposite end of the government scale is the Federal
establishment.  The Federal government has provided a very
limited solid waste management program, especially as compared
                             -399-

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to their entry into air and water pollution control activities.
This is quite appropriate in recognition of the relative
uniqueness of the states.  Their variation in size, physical
land characteristics, geology, economic development, and popu-
lation distribution;  all of which Influence solid waste man-
agement, point to the level below the Federal as most appro-
priate.  This also agrees with the concept that governemnt
should be as close to the governed as the desired effect will
allow.

     Further support for keeping the management program below
the Federal level deriveu from the nature of the solid waste
problem in as much as it doesn't commonly accumulate to become ar
Interstate and international problem  as Is often the case with
air and water pollution. In apparent, recognition of these sev-
eral arguments the Congress in Its "findings" in the Resource
Conservation and Recovery Act of 1976 said "—. the collection
of and disposal of solid wastes should continue to be primarily
the function of State, regional and local agencies	".

     There is a strong theme throughout PL94-580 in support of
State solid waste management programs.  The appearance of such
terms as "providing technical and financial assistance to State
and local government", "Authorization of State  Programs",  and
"Authorization of Federal Financial Assistance" are Indicators.
The amounts of the authorized funds for support of State pro-
grams and planning Is adequate proof that the Congress intends
to create effective solid waste management programs at the
state level.

     To be effective the programs must provide  results.  They
must safeguard the health and welfare of the people, protect
the environment and conserve and recover resources and enercy.
It requires complete programs to accomplish such difficult ptoals.
The complete program regulates, assists and lea'l^.  State pro-
grams must Include these functions to achieve results.

     The USEPA "Solid Waste Management Strategy" recognizer
the importance of effective State solid waste management pro-
grams.  In Mr. Train's letter of October 31. 197''* introducing
the strategy a?id included in the document vi<3 says;.  '' A fur-
ther element which we believe Is Integral to a  viable waste.
management and resource  conservation program is n strong and
effective State and local program".  And further, he states,
"Greater attention by EPA will be required to assist Statca
and local governments	".  The Strategy itself, makes the
statement,."This strategy relies heavily on the States".  The
strategy document and Mr. Train's letter say that liPA Is
attempting to  "strengthen the State role" and  "will assist
States  In developing their programs".

     Testimony Is support of the need for effective solid
waste management and recognition of the appropriate role of
the State is provided by the following summary  comments.
                              -400-

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Ten years ago only two states had administrative programs in
solid waste;  now all do.  That all the States have reccnized
and accepted this responsible role is significant.  These
state programs could not have come to pass in our democratic
system without support of the people, Including local govern-
ment entities which by their support have placed themselves
under the jurisdiction of the state program.  The United
-States Environmental Protection Agency in its "Solid Waste
Management Strategy" and that Agency's Administrator,
I'ir. Russell Train, recognize the importance of the State pro-
grams and declare the intention to assist and to strengthen
the role of the State.  And, finally, in both Importance and
time, the United States Congress, has passed a progressive
act PL9^-580. which directs the intention of the Federal Gov-
ernment  to support and assistance of State programs for solid
waste management.

     The urgency for adequate means and mechanisms to be brought
to bear on the solid waste management problem Is not debatable.
We all recognize the significance to human health, environ-
mental protection and resource conservation.  We know that
Federal, State and local governments each have Important func-
tions In the solid waste management task.  Each has a piece of
the action.  The starring role, however, as we have now seen,
is actually and appropriately being played by the State.

     In summary, the importance of an effective state solid
waste management program is substantial, is recognized and is
being supported by words, deeds and dollars.
                            -401-

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GOVERNMENT RESOURCE RECOVERY PLANS

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         RHODE ISLAND SOLID WASTE MANAGEMENT CORPORATION

          TOWN HALL PRESENTATION QUESTIONNAIRE RESPONSE




  Considerations for implementing resource recovery in Rhode Island


  I.  Material supply

      A.  Tonnage-We are presently considering a 1200 ton per day
                  design figure.

      B.  Collection-Each jurisdiction in the state is responsible
                     for the collection of its own raw solid waste.
                     The Solid Waste Management Corporation has
                     no authority to involve itself in the collection
                     of waste.

      C.  Deliveryof solid waste to the facility- The Corporation
          will seek binding contracts with municipalities to guarantee
          tonnage to a resource recovery facility.

      D.  Waste Characteristics-The waste to be delivered to the
          facility will not have any special characteristics that
          should be noted.

 II.  Facility Fundina

      A.  Financing Options - -The Corporation can employ a variety
          of funding options including revenue bonds, private
          capital, and other approaches.  We cannot, however, employ
          general obligation bonds.

      B.  Indebtness Limitations-No such limitations are imposed
          in our legislation.

III.  Economics of Existing Disposal Methods

      A.  Operating costs-The Corporation does not at present
          operate any facility.

      B.  Affect of Existing Disposal Economics-Rhode Island probably
          enjoys the cheapest landfill operating costs in this part
          of the country.  This is attributable to the competitive
          nature of the private landfill business in the state.  We
          feel, however, that the remaining life of the existing
          privately owned landfills is a key factor.  The Corporation
          was created by the state and given its mandate to establish
          a statewide resource recovery system because it is foreseen
          that landfilling cannot be considered a long term solution.
          There is only one operating municipal incinerator in the
          state, and the costs of operating this facility are thought
          to be in excess of $10 per ton.
                                -403-

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         TOWN HALL PRESENTATION QUESTIONNAIRE RESPONSE (Cont.)
     C.   Remaining Years of Use of Existing Facility-Our estimate
         of the remaining life of the landfills presently approved
         by the Health Department, is 5 to 7 years.   This could be
         optimistic, however,  as environmental standards become
         more stringent and more rigidly enforced.

     D.   Environmental and Other pressures affecting existing
         disposal methods - The state health department has
         recently enacted a new licensing program which will place
         more stringent controls over the operation of disposal
         facilities.  It should also be noted that several muni-
         cipalities have enacted local ordinances prohibiting
         importation of out-of-town waste, thus limiting the
         regional use of state approved landfills in several
         instances.

IV.  Resource Recovery Systems Choices

     A.   At present we have not eliminated any significant
         technology for consideration in our R.F.P.

 V.  Energy and materials markets

     A.   Markets identified based on preliminary evaluation of
         our market study results indicate that there is a strong
         market possibility for steam, pyrolysis gas and oil,
         and electricity.  The potential market for refuse derived
         fuel in simple or processed form is still being explored.

     B.   Potential Markets for Materials-In the same manner we
         feel that there is a good potential market for light and
         heavy ferrous metals, and aluminum and other non-ferrous
         metals.  No determination has as yet been made regarding
         glass, paper fibers or other materials.

VI.  Other institutional, legal concerns

     A.   Institutional-Legal Concerns-

         Under Section 13 of the legislation establishing the
         Solid Waste Management Corporation, any municipality
         in the state that seeks to dispose of its municipal
         waste beyond its own borders must use a facility or
         arrangement designated by the Corporation.   The Corpora-
         tion has already started exerting this control over
         the disposal of waste, and is presently negotiating
         contracts with 6 municipalities whose wastes are being
         sent to a privately owned landfill under the auspices
         of the Corporation.  Through this program we are now


                               -404-

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      TOWN HALL PRESENTATION QUESTIONNAIRE RESPONSE (Cont. )
  B.
collecting a surcharge from these municipalities.

Contract Period-The Corporation can legally enter into
      long torm contractual commitments.
  C.   The  st;
      is a qiiasi-public state agency and as such does act for
      the State.   The Corporation's plans, as is the case with
      any stcite agency, must be reviewed in terms of compliance
      with an overall State Guide Plan.
       te role-The R.I. Solid Waste Management Corporation
:kam
                              -405-

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                          Middlesex Countv, New Jersey

                     RESOURCE RECOVERY FACT SHEET
BACKGROUND

     MIDDLESEX COUNTY'S ACTIVE INVOLVEMENT IN SOLID WASTE MANAGEMJENT
BEGAN IN 1972 WHEN THE COUNTY PLANNING BOARD OBTAINED A GRANT FROM
THE U.S. ENVIRONMENTAL PROTECTION AGENCY TO PREPARE A COMPREHENSIVE
SOLID WASTE MANAGEMENT PLAN AND PROGRAM FOR THE COUNTY.


REFUSE QUANTITIES!

     IN 1975

          OVER 1 MILLION TONS OF SOLID WASTE WERE GENERATED IN
          MIDDLESEX COUNTY.

          1.7 MILLION TONS WERE DISPOSED OF IN MIDDLESEX COUNTYi
          40X IMPORTED FROM OUTSIDE OF THE COUNTY, INCLUDING 300,000
          TONS OF REFUSE FROM NEW YORK CITY .

          eox OF THE COUNTY'S REFUSE is FROM INDUSTRIAL SOURCESI
          40X IS FROM MUNICIPAL (HOUSEHOLDERS, ETC.) SOURCES.

          MIDDLESEX COUNTY is THE 2ND LARGEST REFUSE SHED IN NEW
          JERSEY, AFTER THE HACKENSACK MEADOWLANDS.
          POPULATION GROWTH, INCREASED EMPLOYMENT, INCREASED REFUSE
          IMPORTS WILL RAISE THIS DISPOSAL FIGURE TO OVER 2.5 MILLION
          TONS/ YEAR, OR OVER 8,000 TONS/DAY.


COSTSi

     IN 1975

       -  THE COUNTY'S MUNICIPALITIES AND INDUSTRIES SPENT APPROXIMATELY
          tZO-SS MILLION ON REFUSE COLLECTION AND DISPOSAL.

          80X + FOR COLLECTION AND HAULINGi LESS THAN 20X FOR DISPOSAL.

     BY 19B5

       -  THESE COSTS MAY DOUBLE TO $50 MILLION ANNUALLY.


REMAINING DISPOSAL CAPACITY AND COSTS

     *   AT PRESENT MIDDLESEX COUNTY CONTAINS B REGIONAL-SCALE LANDFILLS
        AND 10 SMALL MUNICIPAL-TYPE DISPOSAL SITES.

     *   FIVE OF THESE SITES (FOUR PRIVATE) RECEIVE SOX OF THE TOTAL
        REFUSE DISPOSED OF IN THE COUNTY.

                                     -406-

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     *  BY 1980,  THREE OF THESE,  INCLUDING THE  COUNTY'S LARGEST  LANDFILL,
        WILL EXHAUST THEIR PRESENT CAPACITY.

     *  BEFORE 1985 ONLY ONE OF THE COUNTY'S  EXISTING REGIONAL LANDFILLS
        WILL REMAINi ALTHOUGH THE REMAINING CAPACITY OF THIS SITE IS
        EXTENSIVE,  THIS SINGLE SITE WILL NOT  BE ABLE TO ACCOMODATE
        THE REFUSE  REQUIRING DISPOSAL IN 1985.

     *  AS A RESULT, FOUR NEW LANDFILLS CONTAINING OVER 600 ACRES OF
        LAND WILL BE NEEDED IN THE COUNTY BY  1985.  BY THE YEAR  2000,
        13 NEW LANDFILLS CONTAINING A TOTAL AREA OF ALMOST 2,000 ACRES
        WILL BE NEEDED TO MEET THE COUNTY'S REFUSE DISPOSAL NEEDS.

     *  ALTHOUGH IMPROVED OPERATING PRACTICES AND INCREASED DESIGN
        HEIGHTS (TO 60 FEET) MAY REDUCE THE NUMBER OF DISPOSAL SITES
        AND TOTAL ACREAGE REQUIREMENTS SOMEWHAT, THE SITES THAT  WILL
        OPERATE WILL BE MUCH LARGER IN AREA AND OPERATING LEVELS THAN
        ANY PRESENTLY IN OPERATION IN THE STATE.

     *  LAND FOR THESE NEW SITES WILL HAVE TO BE FOUND NOT FROM
        MEADOWLANDS AND OTHER ''UNUSABLE1' AREAS, BUT FROM PRIME
        INDUSTRIAL AND COMMERCIAL LAND NEAR REGIONAL HIGHWAYS.

     *  THESE SITES WILL ALSO BE LOCATED IN LESS DEVELOPED SUBURBAN
        AREAS REMOTE FROM CENTERS OF REFUSE PRODUCTION.  AS A RESULT,
        HAULING COSTS WILL GO UP AND SO WILL  THE COST OF ACQUIRING,
        DEVELOPING AND OPERATING TRULY SANITARY LANDFILLS.  THE
        POTENTIAL IMPACT OF NEW REGIONAL LANDFILLS ON COMMUNITY
        DEVELOPMENT, ENVIRONMENTAL QUALITY AND  LOCAL TRANSPORTATION
        PATTERNS COULD ALSO BE SUBSTANTIAL.

     THE PROSPECT OF THIS TYPE OF ''MAXIMUM LANDFILL STRATEGY1'  IS
NOT APPEALING TO OUR BOARD OF FREEHOLDERS AND OTHER PUBLIC OFFICIALS
IN MIDDLESEX COUNTY.


RESOURCE RECOVERY

     FORTUNATELY, THE PLAN ALSO CONCLUDES THAT  ANOTHER MORE WORKABLE
ALTERNATIVE EXISTS - RESOURCE RECOVERY.

     *  THE SOLID WASTE DISPOSED OF IN MIDDLESEX COUNTY THIS YEAR
        CONTAINS THE ENERGY EQUIVALENT OF OVER  2 MILLION BARRELS
        OF FUEL OIL.

     *  IT ALSO CONTAINS ENOUGH FERROUS METALS  TO SUPPLY A SMALL
        STEEL MILL FOR A YEAR.

     *  IT CONTAINS LARGE QUANTITIES OF NON-FERROUS METALS, SUCH
        AS ALUMINUM AND BRASS, AND NEARLY 30,000 TONS OF GLASS.

     *  AT PRESENT FUEL PRICES THE ECONOMIC VALUE OF THE COUNTY'S
        MUNICIPAL REFUSE ALONE IS OVER *8 MILLION PER YEAR.  IF
        WE ADD CREDITS FOR THE ''NON-DISPOSAL" OF THIS REFUSE,  ITS
        VALUE INCREASES TO OVER $9 MILLION PER  YEAR.

     *  THESE ENERGY RESOURCES AND RAW MATERIALS ARE VALUABLE AND
        SHOULD NOT  BE LOST.          -407-

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THE PLAN

     *  IN RESPONSE, THE PLAN RECOMMENDS THE DEVELOPMENT OF A MIXED
SYSTEM OF RESOURCE RECOVERY FACILITIES AND SANITARY LANDFILLS TO
RECOVER THE MAXIMUM FEASIBLE QUANTITY OF ENERGY AND MATERIAL RESOURCES
CONTAINED IN THE COUNTY'S SOLID WASTE AND PROVIDE SAFE. SANITARY AND
ECONOMICAL DISPOSAL OF THOSE MATERIALS THAT CANNOT BE RECOVERED.

     *  SPECIFICALLY, THE PLAN RECOMMENDS THE DEVELOPMENT OF 2-3
LARGE-SCALE RESOURCE RECOVERY FACILITIES IN THE URBAN PORTIONS OF OUR
COUNTY BY IQBO-SS AND THAT THIS SYSTEM BE EXPANDED TO THE RAPIDLY
GROWING SUBURBAN AREAS AS SOON AS POSSIBLE THEREAFTER.

     *  EACH OF THESE INITIAL FACILITIES WOULD PROCESS 1,000 - 1,500
TONS/DAY OF SOLID WASTE AND MAY COST APPROXIMATELY $30 MILLION EACH.

     *  BY 1981 AS MUCH AS 60X OF THE SOLID WASTE DISPOSED OF IN THE
COUNTY COULD BE PROCESSED FOR RESOURCE RECOVERY.

     *  INCREASED ENERGY PRICES AS WELL AS THE INCREASED COST OF NEW
LANDFILLS WILL MAKE RESOURCE RECOVERY COMPETITIVE WITH THESE CONVENTIONAL
DISPOSAL METHODS BY 1980.

     *  THE PLAN RECOMMENDS THAT THE FACILITIES BE CONSTRUCTED AND
OPERATED BY PRIVATE INDUSTRY AND THAT A COUNTY IMPROVEMENT AUTHORITY
BE CREATED TO FINANCE THEM.

     THE PLAN WAS COMPLETED IN DECEMBER 1974 AND ACCEPTED BY OUR BOARD
OF FREEHOLDERS IN MARCH 1975.  SINCE THAT TIME A NUMBER OF IMPORTANT
STEPS HAVE BEEN TAKEN TOWARD THE IMPLEMENTATION OF THIS PLANi

     i)  THE DEPARTMENT OF SOLID WASTE MANAGEMENT PROGRAMS WAS ESTABLISHED
IN APRIL 1975.  THE DEPARTMENT is DIVIDED INTO THREE PROGRAM AREASI
RESOURCE RECOVERY, HAZARDOUS WASTE MANAGEMENT AND TECHNICAL ASSISTANCE.

     2)  A PERMANENT POLICY ADVISORY COMMITTEE ON SOLID WASTE MANAGEMENT
WAS ESTABLISHED IN MAY  1975.  THIS GROUP CONSISTS OF LOCAL ELECTED
OFFICIALS, REPRESENTATIVES OF THE PRIVATE SOLID WASTE  INDUSTRY, THE
REGION'S INDUSTRIAL WASTE PRODUCERS, ENVIRONMENTAL GROUPS, AND REPRE-
SENTATIVES OF THREE ADJACENT COUNTIES.  THIS GROUP ADVISES THE FREEHOLDER
BOARD AND OUR DEPARTMENT ON ALL ASPECTS OF SOLID WASTE MANAGEMENT
PLANNING AND PROGRAMMING IN THE COUNTY.

     3)  THE COUNTY APPLIED FOR AND WON IN JULY 1975 AN ENERGY RECOVERY
IMPLEMENTATION GRANT FROM THE U.S. EPA TO BEGIN TO IMPLEMENT THE RESOURCE
RECOVERY PORTION OF THE PLAN.  THE FOLLOWING PROGRAM ELEMENTS WERE
INCLUDEDi

       -  A DETAILED ANALYSIS OF THE MARKETS FOR RECOVERED ENERGY AND
          MATERIAL PRODUCTS.

       -  A DETAILED ECONOMIC, ENGINEERING AND ENVIRONMENTAL ASSESSMENT
          OF EMERGING RESOURCE RECOVERY TECHNOLOGIES.

       -  AN ANALYSIS OF ALTERNATIVE FINANCIAL AND MANAGEMENT APPROACHES
          INCLUDING THE QUESTION OF PUBLIC OR PRIVATE  OWNERSHIP.
                                    -408-

-------
       -  AND A DETAILED SITE SURVEY

     *)  A PROGRAM MANAGER FOR RESOURCE RECOVERY, OR. EDWARD JABLONOWSKI,
WAS EMPLOYED IN JULY 1975.  IN AUGUST OF THAT YEAR A CONSULTANT, ROY F.
WESTON, INC., WAS SELECTED BY THE PAC AND CONFIRMED BY THE FREEHOLDER
BOARD TO ASSIST IN THE PROGRAM TASKS.

     5)  A DETAILED REQUEST FOR SYSTEMS DEVELOPMENT PROPOSALS WILL
BE ISSUED IN LATE 1976 AND THE INITIAL SYSTEM(S) SELECTED IN MID-1977.

     6)  THE FIRST RESOURCE RECOVERY FACILITY IN THE COUNTY MAY BE
UNDER CONSTRUCTION IN THE NORTHERN AREA OF THE COUNTY BY 1978 AND IN
FULL OPERATION BY 1980-81.

     7)  THE POSSIBILITY OF COMBINING THE RECOVERY OF ENERGY RESOURCES
FROM MUNICIPAL REFUSE AND THE DISPOSAL OF SEWERAGE SLUDGE FROM THE
MIDDLESEX COUNTY SEWERAGE AUTHORITY AT A FACILITY IN THE CENTRAL AREA
OF THE COUNTY is CURRENTLY BEING STUDIED, UNDER CONTRACT, BY PROFESSOR
HELMUT SCHULZ OF COLUMBIA UNIVERSITY.
                                     -409-

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            RICHMOND METROPOLITAN AREA RESOURCE/RECOVERY PLAN

                                   by
                           C.F.  Wilkinson,  P.E.
                        Director of Public Works
                            City of Richmond

                                   and

                             M.E. Fiore,  P.E.
                         Virginia Branch  Manager
                              Roy F.  l/eston
BACKGROUND

The City of Richmond, as well as many other local ities'throughout the
country, is attempting to solve two problems,  disposal of solid waste and
conserving natural  resources, with one decision.  Richmond hopes to do
this by burning solid waste to generate steam and  then recovering ferrous
and non-ferrous metals from the incinerator's residue.

The Richmond Metropolitan area (Figure 1) has a population of over 500,000
people living in the City of Richmond and the separate counties of Henrico
and Chesterfield.  A diversified industrial and commercial base supports
this population and has resulted in continued strong growth and develop-
ment in the region.

As the State Capital, the City is the center of the State political  scene.
It is located almost midway between Washington, D.C. and the Morfolk-Tide-
water areas - - two of the fastest growing areas in the country.  The City
has established itself as a strong and progressive industrial and financial
center.  While considered by many as the tobacco capital of the world, the
City has a diversity of industrial and commercial  activity which has con-
tributed to Richmond's reputation as a recession-free City.  In addition
to stable industries, $200 million dollars of new construction is undei—
way in the Richmond area, including a $50 million  dollar Federal Reserve
Bank.   These factors added to the approximately 60,000 government employees
who work in the Richmond area help to create a financially secure and stable
area.

The pressures of growth have had their impact on solid waste management
in the area.  Although sanitary landfills have served the area well  in the
past,  their capability for future disposal is limited.  Currently, three
landfills are operated by the City of Richmond, two by the County of Henrico
and two by the County of Chesterfield.  Sanitary landfill ing has been and
is the principal method of disposal in this area.   Consultants estimate
that present landfills will  be depleted in ten to  fifteen years (Figure 2)
                                  -410-

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FIGURE 1   RICHMOND METROPOLITAN AREA

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                      -112-

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and that potential additional  space will  be depleted shortly thereafter
because of the projected increase in volume of solid waste.  Restrictions
on available sites, limitations on potential sites, and increased environ-
mental and operating costs are eroding the usefulness of sanitary land-
filling as the sole method of disposal in the region.  This is particularly
true  in the long run.

TASK GROUP FORMED

The Richmond Metropolitan Area can ill afford to face further years without
a solution to the solid waste problem.  To provide a permanent, long range
plan, the Solid Waste Utilization and Task Group was formed in 1973, re-
presenting the City and two counties in the region plus the Commonwealth
of Virginia; the Virginia Electric and Power Company; Reynolds Metals Com-
pany; and Wheat, First Securities, Inc.  The group has embarked upon a
program to find and implement solutions to the area's solid waste problems.

The formation of the Task Group alone  indicates the significant local com-
mitment that exists within the region.  To reinforce that commitment, the
Task Group obtained a pledge of funds from the local governments to  initi-
ate the Resource Recovery Program.

One of the first tasks of this group was to visit other cities (such as
Nashville and St. Louis) with Resource Recovery Projects.  After observing
these operations, a subcommittee of the Task Group was assigned to prepare
a request for proposals to be forwarded to consultants with experience
in Resource Recovery.  This work was accomplished, and the proposals were
received in the fall of 197*1 from eight consulting firms.  After detailed
analysis and discussion, Roy F. \)eston, Environmental Consultants-Designers,
was selected for the Phase I  Study.  Actual work began in June 1975.

FUNDING
The Solid Waste Program was divided into several phases with Phase I  being
totally funded by the local governmental agencies participating in the Pro-
gram (see Figure 3).  During its Phase  I effort, the City, in behalf of
the Task Group, applied for and received a federal  grant to finance a con-
tinuation of the program, Phase II.  The Task Group felt especially for-
tunate In receiving this grant because only seven other cities received
grants from EPA to  investigate implementation of an energy recovery systems.

Work of Phase  I was initiated in June 1975 and was essentially completed
in Hay 1976.  Phase II of our program is now underway, and we anticipate
completion by mid-1977.  The total  cost of Phase I  and Phase II will  be
$118,000.
                                 -413-

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PHASE I — PROGRAM OUTLINE

The Phase I  work plan included collection and validation of all  existing
field data,  field evaluation of existing systems,  in-depth interviews with
local officials, and discussions with local  operating agencies and  State
regulatory agencies to permit the project team to  become familiar with  the
existing solid waste system in the area.  Existing State and local  regu-
lations, ordinances, administrative structures, the legal  framework, and
unique social, economic, and political  character of the area were reviewed.
Available markets for by-products generated  by a resource recovery  program
were assessed, concentrating on potential users of secondary materials,
particularly paper, glass, ferrous and  non-ferrous metals.  A review of
energy and fuel needs in the metropolitan area, including an inventory  of
existing facilities for power generation, fuel storage and distribution,
and major users of both fuel and energy, was performed.  Using this informa-
tion, processing alternatives were identified and  evaluated using the present
system of sanitary landfill ing and its  potential for the future as  the  basis
for economic comparison.  The total evaluation included the cost and facility
requirements of waste transportation and waste transfer as well  as  the  pro-
cessing and  disposal for it.

PHASE I—SURVEY RESULTS (Table 1}

The materials and energy survey indicated that local and regional markets
did exist for products produced from a  potential Richmond area Resource
Recovery system.  Letters of interest were received from local materials
markets indicating interest in ferrous  and non-ferrous metals as well as
in paper.  (See Figure k.)  No local market  for glass recovery was  indi-
cated, other regional markets outside the region are available and  may  be
developed as part of a subsequent phase.

A detailed energy market survey was completed using questionnaires  and
interviews to establish intent and interest.  Figure 5 shows the scope
of the energy markets we sought.

The Energy Survey indicated strong interest  by industrial  and utility or-
ganizations  in purchasing a competitively priced gaseous or liquid  fuel;
electricity  and steam are also saleable commodities.  A solid refuse fuel
(RDF) proved to be the least desirable  of all potential energy or fuel
rorns for our local markets.  Required  equipment modifications,  storage
and handling costs, and air pollution control concerns all may be reasons
for this lack of concern.

TECHNOLOGY ASSESSMENTS
An assessment of the existing technology was prepared for the Task Group
to identify technical options which offer potential  for the region.   Tech-
nical options capable of producing energy and materials that were saleable
                                  -415-

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      2500 r
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                                                   Industrial
                                                   Steam
                                                   Complex
    FIGURE 5  FUTURE WASTE MANAGEMENT SYSTEM WITH
              SANITARY LANDFILLING AND ENERGY RECOVERY
                             -418-

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to the local markets were emphasized.  A comparison of options was made,
based upon market compatabi1ity, demonstrated reliability,  full  scale
operation, capital and net operating costs,  environmental  concerns,  and
applicability to the local situation.  Technologies evaluated included
energy recovery incineration,  pyrolysis, preparation and sale of an  RDF,
materials recovery, and alternative methods  of land disposal, including
shredding and baling of refuse.

Based upon reliability, technical soundness, and cost, we determined that
steam produced by energy recovery incineration should be the leading can-
didate for implementation.  Three markets for this steam exist in the
metropolitan area and are currently being studied.  These markets are the
Richmond Downtown Steam Loop,  an industrial  complex south of the regional
area, and the Chesterfield Power Station of  the Virginia Electric and Power
Company (VEPCO).  The Downtown Steam Loop and the industrial complex offer
the best potential for long term implementation, while the power station
offers a market with declining needs because of VEPCO's conversion from
fossil-fired to nuclear power plants.

It should be noted that comparing energy recovery alternatives with sanitary
landfill ing still  shows significant economic advantages for landfill ing.
The problem with the availability and location of landfill  sites, however,
would indicate that the selection of a waste menagement system cannot be
made solely on .the basis of costs.  For that reason, the regional study
to implement a resource recovery system is still underway.   Regardless of
what system is used, however,  sanitary landfilling will still be a function-
ing part of any solid waste management system.  Figure 5 indicates the re-
gional sanitary landfill needs if energy recovery can be implemented success-
fully.

ENERGY MARKET DEVELOPMENT

One of the two energy markets which appears  most feasible is the Downtown
Steam Loop.  The Steam Loop in downtown Richmond, presently served by the
Medical College of Virginia (MCV) power plant, has a seasonal steam demand
that varies from approximately 20,000 pounds per hour (summer) to 130,000
pounds per hour (winter).   This system provides steam to the existing loop
that services MCV, the Capital District, and several other State, Federal
and City buildings.  (See Figure 6.)

Steam and energy demands coupled with operational and cost considerations
resulted in a waste-management concept using refuse to supply a portion of
the steam demand,   A refuse facility with the capability of providing
60,000 'Ibs/hr of steam could be used as a base load steam plant.  The ex-
isting MCV power plant would be maintained to supply steam during peak
demand periods, thus conserving fuel and perhaps eliminating the need for
the planned expansion of that facility.  In  addition, the refuse/steam
                                 -419-

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FIGURE 6  DOWNTOWN STEAM LOOP
              -420-

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plant could be readily expanded to serve future downtown  area  development.
If future building utilities were designed to use the  steam  loop,  greater
economies in operation of the refuse system could be achieved.

The second feasible market for steam produced from refuse is the  Bermuda
Hundred Industrial Complex.  The area is composed of a cluster of four
steam-in tensive industries located in the Bermuda Hundred area of Chester-
field County.  It has a combined continuous steam demand  of  200,000  to
300,000 pounds per hour.  The industries have shown a  preliminary interest
in refuse steam.   Steam of appropriate pressure and quality  would be pur-
chased from the system at a price negotiated after comparison  with present
energy cost.  A conventional water-wall incinerator boiler system has been
proposed to generate the 200,000 to 300,000 pounds per hour  of steam re-
quired at the Bermuda Hundred Complex.

ENERGY SYSTEM OPTIONS

Two system options are being considered for implementation.   First is the
modular concept which uses preengineered, prefabricated systems which can
be stacked to obtain the desired capacity.  Significant cost advantages
appear to be available if this concept is workable for a  regional-scale
facility (300 to 500 tons/day).  The second system option is the  more
conventional water-wall incinerator design approach, using large  inciner-
ator/boiler units specifically sized, engineered, and  built  to specific
design criteria.   An evaluation of these concepts is being prepared  as
part of a subsequent study.  The cost advantage of the modular concept
can best be illustrated by reported net operating costs for  a  300 ton/day
facility which approaches $2.00/ton.  A similarly sized conventional  sys-
tem could be expected to have a net operating cost of  greater  than $5.00
per ton.  Although these costs do not include some specific  site  and
equipment costs such as land, utility distribution, and feed water treat-
ment, the costs are comparable and justify the need for further  investigation.

TRANSPORTATION CONSIDERATIONS
The location of potential  regional  processing and disposal  sites  and  the
distance that wastes must  be hauled for disposal  are significant  costs
to a regional system.  With Downtown Richmond considered  as approximately
the center of waste generation in the study area, the Downtown  Steam
Loop concept requires almost no adjustment to existing hauling  routes.  The
Burmuda Hundred area, however, would require hauling waste  distances  of
20 to 25 miles in addition to a waste transfer station.   For transportation
costs alone, the Bermuda Hundred alternative then may cost  the  region
$^ to $5 per ton more to operate annually.
                                 -421-

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PHASE I—CONCLUSIONS

In general,  the Phase I  study concluded:

      1)   Steam energy is the most  marketable energy  commodity  in  our  area.

      2)   Materials recovery has local  market interest  and  applicability
          to the technical  alternatives evaluated.

      3)   The Downtown Steam Loop and the industrial  complex  are our pri-
          mary energy market for implernentation.

      4)   The Downtown Steam System offers economic advantages  because no
          extraordinary hauling costs will be required.

      5)   The Downtown Steam System cannot supply a market  for  all  regional
          refuse generated  and that the industrial complex  alternative must
          be developed in a total management  system.

      6)   Recovery of ferrous and non-ferrous metals  from  incinerator
          residue is cornpatable with the alternatives evaluated for imple-
          mentation and with the economic goals  of the  Richmond area.

PHASE I I--PROGRAM

Based on  these conclusions, the Task Group recommended  authorization of
the energy recovery alternatives.  The local  governments approved  the  Phase
II program without any additional funding required.   Accordingly,  the  City
executed  a contract with the consultant,  Roy  F.  Weston, and work began on
Phase II  in September 1976.  This study is expected to  establish system
capacity, system cost, revenue structure, energy distribution cost, indirect
cost, institutional arrangements, cost sharing,  and the administration and
implementation schedule.

The emphasis of our Phase II effort is more institutional  then  technical.
While answering some technical questions, the program will  deal mainly with
those questions asked most  often by local decision-makers.  These  are  ques-
tions generally asked:  Who will own and operate the  system?   How  will
costs be  allocated?  How will we guarantee that  our wastes  are  delivered
to the facility?  What are  our options for procuring  a  system?   What are
our financial options?  and How much will it  cost?

To answer these questions,  the Phase II program  includes the  following
tasks:

      Market Development

      A more specific development of local energy and materials market
      including discussion  of costs, revenues, and commitments. We anti-
      cipate that letters of commitment will  be  the output  of this task
      from each market.
                                 -422-

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      Waste Ownership

      With private collectors doing a majority of  the refuse collection
      in our neighboring counties,  it is vital  that we know how to  assure
      that the refuse will be delivered to our regional  resource recovery
      facility.  A review of ordinances and our collection  system will
      result in changes that may be necessary.

      Institutional Arrangements

      Who owns and operates our regional facility  will be the outcome of
      this task.

      System Procurement

      A variety of procurement methods has become  available in recent
      years for municipalities looking toward implementing  a resource re-
      covery system.  We will investigate our jurisdictional and regional
      flexibility in procuring these systems and,  if justified, consider
      changes to our procurement procedures.

      System Development

      Additional technical evaluation will be required to understand the
      options available to the region.  Also, further evaluation of the
      modular and conventional approaches to energy recovery will be done.
      Field visits to operating systems will be made to further evaluate
      operating concepts before a decision is made.

      RFP

      A request for proposal will be prepared and  sent to qualified bidders
      to supply an energy recovery  system to serve the Richmond Metropolitan
      Area and the energy markets identified.

The Phase II program will be more concerned with those aspects of implemen-
tation that involve decision-makers.  For that reason, a subcommittee approach
is now being used.  Each major task has a subcommittee made up of task
Group Members with specific interest or background for that study task.
The consultant will work directly with each subcommittee.  This will fa-
cilitate the transfer of information and involve the Task Groups a  little
more deeply in the decision-making  process.

The decision-making process will function continuously throughout the
study program.  As outputs are generated, they will be presented to the
Task Group which will evaluate,  comment and direct legislative and
administrative thinking toward implementation needs.  When  these steps
                                 -423-

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have been completed,  the decision-making process  can  be  finalized,
and a plan of action  can be established.  Final coordination of
political subdivisions will be required to obtain concurrence.   The
consultant will  present this information as an executive summary, a
report, which will  be used to obtain jurisdictional approval to  begin  the
Request for Proposal  stage, establish the implementing agency/procedures,
and initiate jurisdictional agreements.

As a final effort  for this phase of the project,  a brief request for pro-
posal will be prepared by the consultant:   this will  outline the program
and its objectives  and invite qualified bidders to respond  with  their  pro-
posal for facilities, services, and costs.

When the request for the proposal is completed, estimated to be  in June
1977, it is hoped  that most questions relating  to implementing a system
will have been resolved.  Then it will  be possible to begin construction
and thereby provide an essential Weston management solution for  the  Solid
Waste Management needs of the Richmond  Metropolitan Area.
                                  -424-

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                                                Department of Public Works
                                                Richmond,  Virginia
                                                September 24, 1976
                        QUESTIONNAIRE
        CONSIDERATIONS FOR IMPLEMENTING RESOURCE RECOVERY

I.  Materials Supply -
   A.  Annual Tonnage - 400,000
   B.  Who controls collection of wastes:
     1.  City of Richmond
     2.  County of Henrico
     3.  County of Chesterfield
     4.  Private collectors

   C.  How to assure delivery of wastes -
     1.  Legislation must be developed and/or contracts prepared.
     2.  It is likely competitive dump charges would be considered.

   D.  Wastes have no special characteristics.

II.  Facility Funding -
   A.  Capital Funding Options
     1.  Revenue bonds
     2.  In dustrial authority bonds
     3.  Private capital
   B.  Yes - We had a legal bonded indebtedness limit.

m.
   A.  Present  Operating and amortization costs -
     1.  Landfilling - $4.00/ton dumping fee
     2.  Incineration - none

   B.  No, since landfill space is being rapidly depleted.
   C.  Remaining landfill life -
     Chesterfield County:
        Chester -  5-7 Years
        Bon Air     1.25  Years
     County of Henrico:
         Springfield Road     12 years
         Nine Mile Road      1.5 Years

     City of Richmond
         East Richmond Road   -  8 Years
         Fells  Street     -        1.5 Years
         Maury Street -          2 Years
   D.  New landfill sites in Richmond are non-existent and zoning is very restrictive in
            the counties.
                                      425-

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IV. Resource Recovery Systems Choices:
   A.   (1) Feasibility studies indicate our best choices to be steam generation in
                 two locations with'ferrous recovery from residue.
       (2) None existing

   B.   Refuse derived solid fuel preparation was determined not feasible due to no
                  existing markets in region.

V.  Energy and Materials Markets:
   A.   Do you have readily - available markets for the following:
      1.  Steam - yes
      2.  Refuse - derived fuel - No.
      3.  Natural gas - Yes
      4.  Fuel Oils - Yes
      5.  Electricity - Yes
      6.  Other - No.
   B.   Do you have available markets for the following:
      1.  Light ferrous metals - Yes
      2.  Heavy ferrous metals - Yes
      3.  Aluminum - Yes
      4.  Other non-ferrous metals - Yes
      5.  Flint glass cullet -  No.
      6.  Color sorted glass cullet - No
      7.  Color-mixed glass fines - No
      8.  Glass - aggregate -  No
      9.  Recovered paper fibers - Yes
      10. Inert Residue - No.
      11.  Other - no.

VI. Other Institutional legal concerns:
   A.   No decision has been made on the type institution to operate the facilities.
       The transporting of refuse across governmental boundaries and ownership
       must also be resolved.

   B.   Long term contracts would be contingent on the eventual form of institution.

   C.   The system must meet state rules and regulations for design and air and
       water pollution.  A permit must be issued and inspections will be made by State.
                                       -426-

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                                  APPENDIX
NSWMA Institute of Waste Technology

   The National Solid Wastes Management Association's Institute of Waste
Technology  (IWT) was established  in  June  of  1974  to  assist government and
industry by offering technical  and planning  expertise in all aspects of
waste management.  Representatives of private waste  service firms, resource
recovery companies, landfill operators and engineers, public officials, and
researchers serve on the Institute's major committees:

   • Chemical Waste Committee
   • Industry Resource Recovery Committee
   • National Sanitary Landfill Committee
NSWMA Waste Equipment Manufacturers'  Institute

   The NSWMA Waste Equipment Manufacturers'  Institute (WEMI)  formed in 1972,
is comprised of 73 leading U.S. manufacturers of wastes handling equipment.
Five major equipment committees of WEMI  are:

     Incineration and Thermal Energy  Systems Committee
     Landfill Equipment Committee
     Mobile Equipment Committee
     Processing Equipment Committee
     Stationary Compaction Equipment  Committee
SW-22p
                                     -427-
                                 all.S. GOVERNMENT PRINTING OFFICE. 1977 720-115/9849 1-3

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