ALTERNATIVES TO THE MANAGEMENT
OF HAZARDOUS WASTES AT
NATIONAL DISPOSAL SITES
report to
THE ENVIRONMENTAL PROTECTION AGENCY
under
Contract No. 68-01-0556
by
Arthur D. Little, Inc.
Cambridge, Massachusetts
C-74861
May 1973
Arthur DLittldnc
-------
ALTERNATIVES TO THE MANAGEMENT
OF HAZARDOUS WASTES AT
NATIONAL DISPOSAL SITES
report to
THE ENVIRONMENTAL PROTECTION AGENCY
under
Contract No. 68-01-0556
by
Arthur D. Little, Inc.
Cambridge, Massachusetts
C-74861
May 1973
Envinrrrental Protection
-,---'/-! "-r'iilnois 60606
-------
ENVIRONL'EXTAL PROTECTION AGSNCX
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ACKNOWLEDGEMENTS
A number of individuals in and out of the Federal Government made valuable
contributions to this effort. Within the Environmental Protection Agency, we wish to give
special acknowledgement to Mr. Sam Morekas, Mr. Thomas Gross and Mr. John Lehman of
the Resource Recovery Division, Office of Solid Waste Management Programs. Their
guidance, insights, and responsiveness did much to ensure the successful completion of the
project. In addition, Mr. Henry Johnson of the Solid Waste Research Laboratory, National
Environmental Research Center, Cincinnati, contributed many helpful thoughts and
suggestions during the course of this study.
Rollins Environmental Services, as a subcontractor, provided a valuable perspective as
well as much useful information on the nature of industrial hazardous wastes and the
processes that are applicable to their treatment.
Finally, a warm sense of appreciation is extended to Dr. Robert Ottinger and his
associates at TRW for their generous assistance throughout this program.
111
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TABLE OF CONTENTS
Page
List of Tables vi
List of Figures vii
I. SUMMARY
INTRODUCTION 1
OBJECTIVE, SCOPE, AND APPROACH 2
CONCLUSIONS 4
Need for Off-Site Processing Facility 4
Economics 5
Legal and Institutional Factors 6
Risk Factors 7
Need for Flexibility 8
II. METHODOLOGY
INTRODUCTION 9
WASTES, PROCESSES, AND FIELD DATA 10
DESCRIPTION OF ALTERNATIVES 14
COMPILATION OF THE DATABANK 18
Selection of Areas for Field Work 18
Assumptions and Cost Factors Used in the Process Economics 19
Risk Analysis 21
Legislative Framework for Controlling Hazardous Wastes 28
COMPARISON OF ALTERNATIVES 31
Development of the Economic Decision Maps 31
Modification by Risk and Legal Factors 32
III. DISCUSSION OF RESULTS
CHARACTERIZATION OF WASTE STREAMS 37
PROCESS DESCRIPTIONS 40
Treatment of Heavy Metal Wastes 44
Treatment of Cyanide Wastes 45
Disposal of Chlorinated Hydrocarbons 46
ECONOMICS OF WASTE TREATMENT 47
Treatment of Concentrated Heavy Metals (A) 47
Dilute Heavy Metals (B) 50
Organics with Heavy Metals (C) 50
Heavy Metal Sludge Disposal (D) 50
Concentrated Cyan ide Waste (E) 51
Dilute Cyanide Waste 51
IV
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TABLE OF CONTENTS (Continued)
Page
III. DISCUSSION OF RESULTS (Continued)
Liquid Chlorinated Hydrocarbons 51
Chlorinated Hydrocarbon Slurries and Solids 52
Mobile Incinerator for Chlorinated Hydrocarbons 52
Interhalogens 52
Mobile Waste Disposal Systems 52
ECONOMIC DECISION MAPS 54
On-site versus Off-site 54
Pretreatment of Wastes 67
Configuration of Regional Processors 70
LEGAL AND INSTITUTIONAL FACTORS 74
Introduction 74
Federal Approaches to Abating Pollution 75
Overview of State Pollution Control Measures 77
Legal Liability Issues 79
Legislative Needs 81
RISK CONSIDERATIONS 82
Introduction 82
Risk from Fire 82
Risk from Explosives 83
Risk from Toxic Gases 83
Risk from Polluting Wastes 83
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LIST OF TABLES
Table No. Page
2.1 Character of Hazardous Waste Streams 11
2.2 Waste Categories 12
2.3 Alternative Approaches for Treatment of Hazardous Wastes 15
2.4 Factors to be Considered in Treatment of Hazardous Wastes 17
3.1 Industries with Wastes Requiring Treatment 38
3.2 Minimum Estimate of Sources of Hazardous Wastes 39
3.3 Capital Investment and Operating Costs for Waste Treatment
Processes 48
3.4 Summary of Waste Stream Data 55
3.5 Optimal Processing Strategies 66
3.6 Regional Processor Configuration 73
3.7 Maximum Volume of Water that may be Polluted Annually
Due to Accidental Spills 84
VI
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LIST OF FIGURES
Figure No. Page
2.1 Hypothetical Plot of Breakeven Line for Two Strategies 33
2.2 Decision Map Concentrated Heavy Metals 34
3.1 Interrelationship Between Hazardous Wastes and Treatment
Processes 41
3.2 Decision Map Concentrated Heavy Metals 56
3.3 Dilute Heavy Metals 57
3.4 Dilute Metals with Organic Contamination 58
3.5a Asphalt Encapsulation of Hydroxide Sludges 59
3.5b Cement Encapsulation 60
3.6 Concentrated Cyanides 61
3.7 Liquid Chlorinated Hydrocarbons 62
3.8 Dilute Cyanides 63
3.9 Chlorinated Hydrocarbon and Heavy Metal Slurries 64
3.10 Effect of Distance to Off-Site Processing Facility on
Disposal Cost 68
3.11 Regional Processor Configuration Concentrated
Heavy Metals 72
vu
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INTRODUCTION
Certain wastes, because of their chemical, physical, or biological nature, are hazardous
to the environment and thus present special treatment and disposal problems. In 1970, the
Environmental Protection Agency was directed by Congress to study the technical and
economic feasibility of establishing a system of National Disposal Sites (NDS) for the
centralized treatment or storage of these hazardous wastes. Some of the tasks of that study
were: identify candidate hazardous materials; describe available methods for neutralization,
recovery, or final disposal; determine capital and operating costs; evaluate legislative needs;
specify candidate locations for such sites; and evaluate public attitudes toward them.
Because of the complexities of the problem and the potential impact the NDS System
might have on specific local environments, EPA authorized Arthur D. Little, Inc., to
evaluate alternatives to the initially proposed NDS System. National Disposal Sites were not
defined by the legislative history, but it was commonly assumed that the NDS System
would consist of 25 to 50 sites located in relatively isolated places, and would be required
by law to receive any and all hazardous wastes from a fairly wide surrounding area, treat
these wastes safely, and dispose of any residues in an environmentally safe manner.
During the study, it became evident that an NDS System might include any institu-
tional or technical arrangement that would be administratively acceptable and that would
fill the need for proper handling of hazardous wastes. The goal of the program discussed in
this report was to define and evaluate on technical, economic, risk, and legal grounds the
various alternatives for processing hazardous wastes.
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OBJECTIVE, SCOPE, AND APPROACH
In the initial definition of tasks, four potential alternatives to an NDS System were
outlined: (1) on-site disposal; (2) off-site disposal at a municipal facility; (3) on-site
recycling; and (4) a transportable disposal system. During this investigation, however, it was
found that these four could be incorporated into three, more general, categories: (1) on-site
processing; (2) off-site processing; and (3) on-site pretreatment with off-site treatment
and/or disposal.
The major emphasis of the program, therefore, was devoted to assessing differences
among these alternative approaches in:
the economics associated with waste treatment;
the immediate risk to human safety, as well as the eventual hazard to the
environment; and
the legal and institutional issues that would have an impact on a national
treatment system.
Most of the study effort was devoted to the wastes included in the toxic and
flammable classifications for so-called Category I wastes.* By mutual agreement, efforts on
radioactive wastes, DOD items and explosives were limited, so most of our program was
oriented primarily towards those Category I waste forms containing heavy metals, cyanides,
pesticides, chloro organic solvents, and some other miscellaneous toxic chemical species.
To help in the economic analysis, the wastes were grouped according to the processes
that should be applied for effective treatment. With this as a goal, all the wastes of
interest except for DOD items, explosives, and radioactive materials were grouped so
that four basic processes could be applied: precipitation of metals, followed by burial;
oxidation to destroy cyanides; reduction to destroy oxidants; and incineration of organics.
The economic analyses were based on decision maps developed for this study, and for
future programs requiring economic comparisons between alternative strategies. These
graphical decision maps permited a comparison of on-site and off-site treatment in terms of
the source (or sources) that generate the waste and can help frame the optimum approach
Category I wastes were established by TRW during their contract as candidates for treatment within a
National Disposal Site System.
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for establishing a system of regional processing facilities. The data for these decision maps
were derived from a series of field studies conducted to identify waste sources, including
types and amounts of Category I wastes.
Federal and state laws and legislative frameworks were studied to learn whether any
legal or institutional factors would militate against the conclusions made on economic
grounds. Finally, each alternative was evaluated to determine whether any factors of risk
would override the economic decision.
Although risk to people working with hazardous materials is, and should be, a major
concern to society, those persons employed to handle, treat or transport the wastes were
excluded on the assumption that they have freely chosen to accept the risk associated with
their employment. Our study focused only on those risks to society from hazardous wastes
which occur without its explicit consent.
Part 2 of this report describes the methods used to derive the data needed for the
analyses of potential alternatives. Part 3 describes the results of the analyses. The thrust of
the discussion is to describe the economic basis for suggesting a treatment site and then to
show the impact of legal and risk factors on the economic decision.
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CONCLUSIONS
Need for Off-Site Processing Facility
On economic grounds alone, off-site treatment facilities will be preferred by a majority
of producers ofjndustrial hazardous wastes, with the possible exception of those who han-
dle explosives and dilute aqueous wastes. Although the shape and form of the processing sys-
tem might vary, because of individual differences, this conclusion will be true for all regions
of the United States. On the basis of this study, existing risk, legal, or institutional con-
siderations will not alter this basic conclusion.
In addition to off-site processing (where the industrial source sends its waste, as
generated, to an off-site processor), two other basic options are possible alternatives to be
considered by a hazardous waste producer:
On-Site Processing. The industrial source, either on its own or via a con-
tractor, treats and disposes of its own waste. This option could include the
use of a mobile treatment van (owned by an outside company).
Combination of On-Site Pretreatment with Off-Site Treatment and/or
Disposal. On-site pretreatment could be performed by the industrial concern
that generates the waste or by a separate entity that operates a mobile
treatment facility. The pretreated (concentrated) but still hazardous waste
would then be shipped to an off-site processor.
Because of the economies of scale available to a central processing facility, these two
options will not be as attractive to most waste producers as off-site processing without
pretreatment. An exception to this occurs with aqueous waste streams containing low
concentrations (ppm level) of heavy metal salts.
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It is important to recognize that it is not necessary to decide whether all industrial
hazardous wastes will receive off-site treatment but rather whether any will need off-site
facilities. In fact, it is very likely that some industrial waste sources will choose to treat their
own wastes, because:
(1) their particular volumes are sufficiently large to make on-site treatment more
attractive;
(2) the nearest treatment center is too far away; or
(3) other factors - such as liability, fear of revealing trade secrets, image,
corporate policy, etc. override the decision made solely on economic
grounds.
Nevertheless, the basic conclusion would still be that off-site (regional) facilities
represent the most economically attractive option for a majority of hazardous waste
producers.
Note that this conclusion holds even though the evaluation was purposely biased
towards on-site processing. For example, it is recognized that satisfying environmental
needs, especially during the ultimate disposal step, will be difficult for many on-site
locations. However, this consideration was excluded in making the decision for off-site
treatment centers in order to ensure a bias towards on-site treatment.
Economics
The economics of on-site treatment and disposal of most hazardous wastes are high
because of high fixed costs or high labor costs. Off-site processing benefits from the
economies associated with a larger volume to be treated. In most cases, these economies
outweigh the transportation costs required to get the waste to the central processing facility.
Other factors, such as using one waste to treat another or using waste oil as fuel, were not
factored into the cost of off-site processing to help ensure a bias for on-site treatment.
Qn-Site Treatment. On-site treatment might be attractive for two situations.
Economics favor on-site disposal (burn or explode them) of industrial explosives that are
either off-standard or overaged. Moreover, much off-standard or overaged material is
considered too dangerous to transport; in fact, in several states it is against the law to
transport them.
In addition to shipping untreated wastes, waste sources may find that some waste
categories, such as dilute solutions that contain heavy metals, will be more economic to
concentrate on-site to reduce the cost of transporting the original very large volumes to the
off-site processor.
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Mobile Waste Treatment. Mobile treatment facilities are not expected to become a
major national treatment system, because the economies of scale derived from using a
mobile waste treatment van for even "average" volumes of waste do not offset the added
costs incurred for the extra storage facilities at the waste source.
Impact of Non-Hazardous Wastes. A central processing facility that only treats haz-
ardous wastes will not be able to compete economically with one that also treats non-
hazardous wastes. This conclusion rests largely on the economies of scale that are in-
herent when a facility treats all (therefore more volume) wastes. This problem area could
have a serious impact on hazardous waste management and deserves further study.
Economic Decision Maps. As an integral part of this program, a series of decision maps
was utilized to aid in making decisions about whether a waste source would choose on-site
versus off-site treatment. These maps were based on a general mathematical formula
describing the economies associated with the total waste handling, treatment and disposal
process. In addition to providing insight into the on-site versus off-site question, the maps
were extremely valuable in studying the impact of having nonhazardous wastes included in a
central treatment facility, and the overall area and/or waste volume that a central processor
could handle when confronted with competition from other processors. It is recommended
that this approach be expanded and further applied to the hazardous waste area.
Legal and Institutional Factors
Legal. The legal framework that applies to environmental problems generally, and to
waste specifically, is in a period of rapid growth and development. The emphasis of these
laws, with the notable exception of the Atomic Energy Act, has been on after-the-fact
recovery of damages, rather than on prevention. Few laws relate specifically to "hazardous
wastes." State statutes vary widely in this area. Federal laws apply through the establish-
ment of effluent standards or regulation of transportation in interstate commerce. State
laws are more directly applicable to the producer or processor of wastes via registration and
permit systems.
Under existing laws, liability for a waste can be shared with an off-site handling or
processing agent, but this liability is not likely to be removed entirely from the initial
producer of the waste. If off-site processing is to be encouraged, it might be desirable for
states to change their laws so that the responsibilities of the waste producer are minimal if
the waste is handled by an approved off-site processor. This step should encourage waste
sources to ship their wastes to "safe" locations and thus reduce the total number of ultimate
disposal sites located throughout the country.
Institutional. In Congress and in state legislatures, various committees are concerned
with environmental problems, but only a few have addressed "hazardous wastes" specifi-
cally - usually as a result of a spill or an incident of serious pollution. A similar pattern
exists among executive agencies.
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In setting up a system for dealing with hazardous wastes, attention should be paid to
existing systems that focus on similar problems. The atomic energy area is a prime example
of an approach that deserves attention. However, a more universal approach to the
regulation of radioactive wastes is needed than presently exists under the Atomic Energy
Act of 1954. This new approach should provide for control of all radiation and radio-
toxicity hazards, whether or not they are related to the national security mission of the
AEC.
Regulations. There is a strong need for regulations which ensure that hazardous wastes
are either properly treated, disposed of, or not created in the first place. Based on extensive
field work, ADL believes that much of the material which belongs in a hazardous waste
system is not receiving adequate attention - especially with regard to ultimate disposal.
Approach for Enforcement. EPA is concerned about hazardous materials primarily
because they have a potential for causing undesirable effects. Therefore, the overall objec-
tive of a hazardous waste management system is to minimize the chances that these
materials will create either short-term or long-term problems. Although there are a number
of institutional approaches to attaining this objective, effluent and area monitoring is the
only certain way of knowing whether hazardous materials reach the environment in an
unsafe condition. In-put or inventory control, as well as process control (waste production
or treatment), can be useful; but effluent monitoring will still be needed to ensure
compliance.
Risk Factors
With only one exception, considerations of risk never changed a decision based on
economic or legal factors.
Risk to the environment or to human health during transport is the principal difference
between "on-site" and "off-site" treatment. Risk will occur during all steps involved in a
hazardous waste treatment system storage, transfer, transport, processing, and ultimate
disposal. However, during processing, storage, or handling, operational steps are readily
available to ensure that hazardous materials do not reach the outside environs of the plant
site or at least to drastically reduce such a possibility.
Except for explosives, the risk during transportation was found to be well below levels
generally considered acceptable by the public. The explosives industry, as a standard
practice, does not ship explosives that are off-quality. ADL agrees with this practice,
believing that the apparent but undocumented risk, outweighs any economic grounds for
shipping.
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Need for Flexibility
Whatever approach is taken to establish a national system for treating hazardous
wastes, it should be set up with flexibility in mind. For instance, materials will be added
continually to the hazardous waste list as new effects are recognized and the selected system
should be capable of dealing with them. In addition, within the system, procedures need to
be applied so new wastes can be recognized and priorities assigned according to the degree
of hazard or the need for immediate or special handling. Similarly, at the present time, there
is very little good data on the composition, form, and quantities of hazardous materials
being generated as industrial waste. This information needs to be obtained and, as it is, the
data will likely help to reshape the overall waste processing system.
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INTRODUCTION
As noted, the objective of this program was to compare based on economic, legal,
and risk criteria alternative approaches for processing hazardous wastes. To attain this
objective:
Existing information was reviewed from the Literature, other EPA con-
tractors, and private sources.
The boundaries for the hazardous waste compounds, hazardous waste
streams, treatment processes, and the alternative strategies were established
and classified.
Detailed data were developed for:
Waste sources (type volume, frequency and location),
- Unit processes (technical feasibility and cost),
Transportation (types, costs, and distances),
Risks associated with handling, transportation processing, and disposal,
and
Legislative factors that impinge on the problem.
Means for evaluating data were developed.
Evaluations and conclusions were prepared.
Part 2 describes the methodology that was employed to accomplish these tasks. The
first section covers selection of wastes, processes and areas for field investigations. The next
section discusses the classification of alternative approaches and criteria for selection
between them. Next is discussed the manner in which the economic, technical, risk and legal
data were generated and, lastly, a decision map approach for choosing between alternatives
is described. Actual study results are presented in Part 3. More specific details for each
subject area are provided in a separate volume containing the Appendices.
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WASTES, PROCESSES, AND FIELD DATA
To compare the economics or risk associated with alternative treatment approaches for
hazardous wastes, it was necessary to identify specific waste streams containing a known
hazardous material. TRW (and later Battelle) developed a list of hazardous wastes, which it
refers to as Category I Wastes, that contains almost 200 specific chemicals.* Since it was
impossible, within the scope of this assignment, to develop information on the nature, form
and volume of every one of these hazardous wastes, the TRW's list (Appendix A, Table A-l)
was narrowed to a smaller, more manageable number.
Initially, the wastes were placed into 12 general categories according to their basic
composition or properties. Recognizing the differences within these groupings, however, the
12 categories were divided into 34 sub-categories which described all of the chemicals on the
TRW list as of September, 1972. These sub-classes are shown in Appendix A, Table A-2.
Later TRW and Battelle added more chemicals to the Category I list (see Table A-3,
Appendix A), but since these additions did not introduce new categories, and since this
program was already under way, it was decided not to purposely change the original list
(Table A-2, Appendix A). In this work, however, selected additional wastes (e.g., the
chlorinated aromatics) were included where such inclusion was convenient as well as
appropriate.
To aid the field work, as well as the process design for treatment facilities, it was next
determined which basic chemical or physical processes should be applied to properly treat
the wastes either at the site of the source of off-site at a waste treatment processing facility.
At the same time, it was important to recognize that the chemicals listed in Table A-l
actually show up as components in mixed streams - liquid, solid or gaseous. Therefore, it
also was necessary to consider treatment processes that are able to handle a given type of
waste stream, rather than a specific chemical. With this in mind, the waste categories were
regrouped according to the treatment processes that should be applied to similar waste
streams. Eight process categories cover all of the wastes except those noted below. These
eight, are shown in Table 2.1 and a matrix showing which processes apply to the original
waste categories is given in Table 2.2.
"Reference is made in this report to material developed by TRW, Battelle, and Booz-Allen. These com-
panies were also working on the processing of hazardous waste under contract to EPA as follows:
Battelle Memorial Institute, Pacific Northwest Laboratory, Richland, Washington
EPA Contract No. 68-01-0762
Booz-Allen Applied Research Inc., Washington, D.C.
EPA Contract No. 68-03-0032
TRW Systems Group, Redondo Beach, California
EPA Contract No. 68-03-0089
10
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To minimize duplication with the work of other contractors, only a minimal effort was
placed on the inter-halogen compounds (sub-category 15), DOD compounds (sub-category
25), explosives (sub-categories 26-31) and radioactive elements (sub-category 32-34). In each
case, it was felt that sufficient attention was being supplied by Battelle so that our limited
program could best be focused on other wastes. Therefore, these ten sub-categories were not
studied in the same manner as were the other wastes and thus are not included in the tables.
An understanding of the types, volumes, and frequency of industrial waste streams was
developed via several routes. First, information developed by other contractors (Booz-Allen,
TRW, Battelle) was used. Second, ADL professionals with expertise in a particular industry
were utilized to generate a description of the wastes from that industry through the use of
inhouse information, interviews, and plant visits. Finally, detailed information was obtained
on specific waste streams from a processor of industrial wastes.
The specific data obtained from the regional processor provided a picture of waste
streams that actually exist in the industrial world. Therefore, the field work by ADL was
designed to ensure that the specific data was not biased in a way that would lead to
erroneous conclusions concerning the need for off-site processing. (For more details, see
Part 3 and Appendix B.)
13
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DESCRIPTION OF ALTERNATIVES
In developing an overall strategy for collection and treatment of industrial hazardous
wastes, one can classify the available alternatives on the basis of operational, technical and
administrative options (Table 2.3). The operational options reflect overall concepts of
possible ways to approach the problem on-site processing, mobile van, local processor, or
regional processor. The technical options are what can actually be done with the wastes in a
chemical or physical sense. Administrative options describe alternative ways in which a
regulatory body can influence the shape of a hazardous waste disposal system. All three
types (operational, technical, and administrative) are important and will greatly influence
the final decision on how a particular hazardous waste should be processed.
This program focused primarily on the operational alternatives that might be available
to an industrial plant generating a hazardous waste. Thus the interest was mainly in
determining whether the waste source would, on economic grounds, choose to treat on-site,
off-site, or via a combination of the two. The technical and administrative options are
included in Table 2.3 for completeness only.
In deciding whether to select an alternative strategy or a National Disposal Site
Concept for selected wastes, one must consider environmental impact, economic costs,
health and safety factors, legal and regulatory restraints or incentives, and technical
soundness. Criteria are necessary for the unit that generates the waste as well as for the
company or agency that chooses to process the waste. Some of the factors that need to be
considered are shown in Table 2.4. These can be divided into a few objective criteria (all
economic), some very important but subjective criteria, boundary conditions that apply to
all the criteria, and some miscellaneous factors.
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TABLE 2.3
ALTERNATIVE APPROACHES
FOR TREATMENT OF HAZARDOUS WASTES
A. Operational
1. On-Site Processing
Recycle for internal or external use
Complete Treatment by Waste Generator including disposal, if necessary
Final Treatment via Mobile Facility using incineration or treatment and
discharge of effluent at plant site
2, Off-Site Processing either all in one place or combined among various off-site
recycling treatment and/or disposal facilities
Private
Public
3. Pretreatment On-Site and Final Treatment Off-Site
Pretreatment by
Waste generator
Mobile van
Final treatment by
Processor (public/private)
Disposal (public/private)
Reclaimer
B. Technical Options
1. Recycle or Re-use
2. Destruction of a Chemical Form i.e., oxidation, reduction, or incineration
3. Conversion to a Less Hazardous Form via precipitation, complexation, etc.
15
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TABLE 2.3 (Continued)
4. Dilution to Non-Hazardous Concentration Levels
5. Storage in Containers or Sites that are Designed for Long-Term Safety
6. Eliminate Source change product or process so that hazardous waste no
longer is formed
7. Some combination of the above
C. Administrative Options
1. Controls
On Wastes type or effluent concentration
On Generator of Waste process type or effluents
On Processor of Wastes processes and effluents
2. Incentives
Tax Incentives or Relief
Grants or subsidies
Price Incentives
3. Organization
Publicly-Owned and Operated
Public Authority
Privately-Owned and Certified
Privately-Owned and Operated
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TABLE 2.4
FACTORS TO BE CONSIDERED IN
TREATMENT OF HAZARDOUS WASTES
Treatment by
Waste Generator Off-Site Processor
OBJECTIVE CRITERIA
Investment Cost X X
Operating Cost X X
Transportation Cost X X
SUBJECTIVE CRITERIA
Risk - impact on environment X X
Public Relations company image X -
Complexity - will operation fit in X -
Operational Feasibility space,
utilities, etc. X X
Nuisance Factor willingness to cope X
BOUNDARY CONDITIONS
Legal Aspects regulations and
standards X X
Technical Factors will technology
meet current and future needs X X
Social Pressures - good neighbor, etc. X X
OTHER FACTORS
Competition X
Market Structure X
Input Control X
Storage Facilities X X
Waste Synergism X X
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COMPILATION OF THE DATA BANK
Selection of Areas for Field Work
To ensure that the study would be based on realistic information, data was collected
on hazardous waste streams in a number of different ways. Some data came from industrial
firms processing wastes. Other information was obtained from industrial companies that
generate hazardous wastes, while still other data was found in the literature. Throughout
this data generation phase, however, it was felt necessary to focus attention in some depth
on a particular geographical area rather than attempt to cover the total United States in a
superficial manner.
In selecting a particular region for the field studies, attempts were made to ensure that
the area:
Contained sources of the wastes that had been selected for study;
Had a variety of transportation forms available for carrying the wastes from
one place to another;
Did not have overly restrictive laws or regulations which seriously limit the
choice of alternative strategies;
Had several types of geography and population centers.
The New Jersey-Eastern Pennsylvania region was selected for most of the field studies
because:
Specific data on the nature of selected individual industrial waste streams -
waste form, volume, and concentration - are available.
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New Jersey and Pennsylvania have been active in developing programs
oriented towards dealing with hazardous waste problems.
Major segments of the chemical manufacturing industry, as well as users of
those chemicals considered as candidates for an NDS system, are located in
this region.
Assumptions and Cost Factors Used in the Process Economics
The economic comparisons of treating various waste streams on-site, versus some
alternative off-site treatment, were based on actual conceptual design and sizing of on-site
facilities for specific waste streams as indicated by the field survey (both as to volume of
waste produced per day, week or month, and concentration of this waste). This same
process was then assumed to be used in an alternative off-site facility. In each case, the
alternative selected was the least expensive on-site processing steps that would still meet the
estimates of future environmental standards or guidelines. If a cheaper off-site process exists
the methodology is still correct in that it biases the results in favor of on-site processing.
The on-site facility was conservatively assumed to buy all of its fuel and neutralization
chemicals for the specific waste being treated; that is, there would be no synergism of
mixing acid and basic wastes or any fuel value contained in any of the waste. This same
constraint (no synergisms, all fuel and neutralization chemicals purchased) was assumed for
the off-site facilities; to the extent that the off-site facilities could mix acid and basic wastes
and use waste oil for fuel, the methodology again prejudices any comparisons in favor of
on-site treatment.
To repeat, sizing and costing were done for the on-site system. The various processes
are described in Part 3 and detailed in Appendix C. For the alternative off-site waste
treatment facilities, capital investment was estimated to vary by the 0.6 power of the
throughput. For example, a plant 4 times larger would cost only 2.3 times more than the
base plant, 4° -6.
This short-cut method is well documented for the types of processes used in waste
treatment and is sufficiently accurate for the intended uses.* It was also assumed that labor
varied as the 0.6 power of the throughput but an allowance was made for incremental labor
(part-time assignment to waste processing) at the on-site facility of a production plant.
To the extent that an off-site facility will have more waste to handle and therefore
would operate two or three shifts per day instead of one (assumed in some cases for the
on-site facility and also assumed for the off-site facility) such savings at the off-site facility
would again prejudice the method in favor of on-site processing.
*Rase and Barrow, Project Engineering of Process Plants, p.51 John Wiley & Sons (1957).
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One exception to the 0.6 rule that may crop up and favor on-site processing would be
the invention of small preassembled packaged plants for a specific waste treatment process.
Such prepackaged plants built by the hundreds, with economies of mass production
would be cheaper than indicated by the 0.6 factor rule. These types of small plants may well
be designed, for example, to remove heavy metals or cyanides from plating baths (because
of the thousands of plating operations in the country), or to remove chromates and zinc
from cooling water, again because of the large number of cooling water installations on
commercial and industrial buildings. However, even though this would lead to a reduced
volume of the original waste form for treatment at a regional processor, there still would be
a need for ultimate disposal facilities for the concentrated wastes.
As the scale of process increases, especially in automatic processes, the labor does not
go up in accordance with the 0.6 factor except for sampling and analysis. However, again,
the assumption of the 0.6 rule puts the bias in favor of on-site processing.
Land cost was not entered as a factor in the cost of either on-site or off-site processing,
since, in many cases, land would be more expensive, and harder to come by at the on-site
installation. Once again, if a bias exists it would be in favor of on-site processing.
The overhead rate for on-site processing was taken to be the same as for off-site (50%
of direct labor). Other cost factors were selected on the bases of typical factors for the
United States as follows; *
Electricity 1 ^/kilowatt hour
Water 5411,000 gallons (1.3411000 liters)
Fuel 10tf/gallon(2.6tf/liter)
Neutralization chemicals Costed consistent with use rate
but again, no economies of scale
attributed to off-site processing
Depreciation 5 years
Maintenance 5% of capital investment
Insurance & local taxes 2% of capital investment
Labor rate $5.50/hour, including fringe
benefits
*Many literature sources provide data and discussion of these factors. An example is "Fundamentals of
Cost Engineering in the Chemical Industry" by H. C. Bauman (Reinhold 1969). In using these sources,
appropriate revisions were made to account for 1973 values.
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The cost of money was not included in the calculations for either the on-site or the
off-site waste treatment processing. Neither was there an allowance for profit in the case of
the off-site processing. Rather, the approach was to calculate the "cost «f society" by either
method.
For off-site processing, transportation costs were taken to be O.OStf per gallon (O.OOStf/
liter) per mile transported.
Risk Analysis
Introduction. Under normal operating conditions, the handling, storage and processing
of hazardous chemical wastes for the purpose of disposing of them should not present any
undue risks to society. Indeed, the disposal of chemical wastes is an operation which
inherently reduces risks to society. Only when abnormal events (accidents) occur during the
disposal operations may society become exposed to the hazards associated with the
particular waste that may be released as a result of the accident. Society may then become
exposed to such hazards as the thermal effects of a fire, the air blast of an explosion, the
release of a toxic gas into the atmosphere, the release of a polluting liquid into the drinking
water supply, or the release of harmful radioactivity.
Because these risks could affect the results of our economic comparisons of alterna-
tives, the risk level represented by the various categories of wastes included in the study was
calculated by:
(1) Arriving at methods for quantifying the various types of risks to which
society may be exposed from accidental releases during disposal of hazard-
ous chemical wastes.
(2) Utilizing these methods to compare the risks of alternative locations for
off-site disposal.
(3) Calculating absolute levels of risk for disposal operations and determining
whether these risks are acceptable by comparing them with levels that appear
to be acceptable to society.
This approach is still in its infancy. Although a good amount of accident data has been
collected, such data have been generated with other purposes in mind and are not directly
applicable to the approach listed above. Thus it was necessary to adopt the data to the
method used in this study.
For the purposes of this study, the hazards were divided into two categories. One
category consists of those hazards that can cause human fatality if people are within a certain
distance of the abnormal event: fire, explosion, release of radioactivity, and release of toxic
gases. The second category consists of those hazards that could be injurious to human health
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or the environment should an abnormal event occur the toxic liquid wastes. These toxic
liquids could result in human fatality when ingested. However, the probability of their being
ingested is very low. The waste liquids most likely would reach humans only by entering a
water supply. Given the time needed for this contamination to happen, measures could be
taken to prevent fatalities.
Techniques were developed for quantifying the risks presented by these hazards so the
risks of two disposal operations could be compared. Methods were also reviewed for
defining risk levels which appear to be acceptable to society. Such yardsticks were needed to
determine whether or not the accidental releases from a particular disposal operation expose
society to risks which are greater than those to which it is exposed from other sources.
Wherever possible, conditions were deliberately selected to bias the results in favor of on-site
disposal. Again, the reasoning was that if on-site disposal were not favored under these
conditions, it would not be favored at all.
In this analysis, several assumptions were made. First, employees at the site where the
hazardous waste is generated, handled, or disposed of were excluded. Also excluded were
persons involved in the transportation of these wastes. The rationale was that these people
have freely chosen to accept the risk associated with their employment. To them, either the
benefits are high or the perceived risk is comparable to that incurred in other employment.
Furthermore, the risk to these people is generally minimized by the various occupational
safety and health statutes and practices that have been promulgated on their behalf.
Second, several abnormal events that could not be treated quantitatively were
excluded:
(1) Accidental spills due to the extra number of transfer operations (hose
connections, filling drums, etc.) that would be entailed in off-site treatment.
(2) The careless attitude often associated with handling waste that is to be
transported to another site, for example:
The use of second-hand drums or slightly damaged drums for transport
of corrosive waste;
The tendency toward use of lower paid, and therefore less knowledge-
able, help in handling these materials;
The unwarranted assumption by employees that spent acid or waste
acid is less strong than "fresh" acid. In one instance such an assumption
led to an explosion because spent acid was put into used drums that
contained residual amounts of hydrocarbon.
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(3) The possible evolution of noxious gases due to pH changes during storage.
The risk factors are not amenable to mathematical treatment because of the paucity of
good data. More important, however, existing training programs and safety measures at
specific plant sites and transportation companies are expected to be strengthened and
become more widespread. This trend will reduce the number of such abnormal events, as
well as their consequences. However, it should be recognized that to the extent the above
factors apply, not taking them into account represents a bias in favor of off-site processing.
Finally for purposes of comparison, waste treatment and ultimate disposal techniques
at the on-site facility was assumed to be as safe as those at the off-site disposal facilities. Thus,
the risks entailed in storing, transferring, processing and actually disposing of the hazardous
waste on a given site could be eliminated from the calculations. These operations are
performed within the boundaries of a plant site and the risks involved are essentially the
same wherever the plant site is. This left the risk during transport as the principal difference
between on-site and off-site treatments, or between two off-site treatments.
In general, the approach to the quantitative determination of the degree of risk posed
by a hazardous waste was to calculate the probability of the threat's becoming a reality and
to compare this probability with other risks to which society is exposed in its everyday life.
The details of this method are presented in Appendix D and are summarized below.
Risks to Human Life. These risks stem from the possibility of a transportation
accident that may release a flammable, explosive,radioactive, or gaseous toxic waste.
Methods for calculating the probable number of fatalities per person-hour of exposure
were developed for each waste or hazard category. This unit of risk number of fatalities
per person-hour of exposure was suggested by Starr. (See references 1 and 2 in Appen-
dix D.) Starr also found that individuals appear to accept a risk equal to that of death by
disease or accident (10~6 fatality/person-hour exposure) for voluntary activities (smoking,
skiing, driving, etc.) and a risk about 1,000 times smaller (10"9) for activities to which the
individual is involuntarily exposed. This latter level of risk is approximately 10 times greater
than the risk to which society is exposed from natural disasters.
Starr's analysis suffers in two respects. It fails to recognize the fact that society
apparently is less willing to accept risks that may kill a large number of people, even though
the frequency of occurrence is very low, than those that are more frequent but kill fewer
people each time. His analysis also neglects injuries to people, which are 100 to 1000 times
more frequent than fatalities but which are difficult to normalize into a single unit and for
which data are unreliable and difficult to collect.
Nevertheless, Starr's unit of risk offers a number of advantages that justify its use.
First, time is something that is allocated fairly uniformly to all humanity, so it is a good
normalization factor for dealing with large segments of society. Second, this unit permits
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one to compare risk with risk, rather than risk with some other value such as dollars. Third,
it offers a useful yardstick for comparison purposes the probability that a healthy young
person will contract a fatal disease. Fourth, Starr's unit permits one to rationally compare
and combine many types of risks: disease, highway accidents, sports accidents, smoking, etc.
Finally, the numerical value of risk in Starr's unit corresponds well with the popular idea of
whether an activity is safe or dangerous. For example, it puts into proper perspectives the
comparative danger of trips to the moon and short walks to downtown shopping centers.
The exposure of individuals living along the route of travel to accidental releases of
hazardous chemical wastes during transportation is an involuntary activity. According to
Starr, these individuals would accept a risk equal to or less than 10"9 fatality per person-
hour of exposure. This level corresponds to the possible loss of 1.5-3 weeks from a normal
life expectancy of 60-80 years. (See Appendix D, Table D-2.)
We calculated risk levels for the flammable, explosive and radioactive wastes included
in this study by using the following equation:
P(a) x P(f/a) x nLF f . ,.,. , .
-^ 1-1*- = fatalities/person-exposure hour
HT
where:
P(a) = probability of an accident per vehicle mile
P(f/a) = probability of a fire (explosion or radioactive release)
given an accident
n = number of trips per year
L = length of trip (miles)
F = fatalities per fire (explosion or radioactive release) =
(7rR2p) P (p)
H = humans exposed per year = (2RLp)
T = exposure hours per person per year = 8760 P(p)
R = kill radius (miles)
(p) = population density per unit area
P(p) = probability of a person being within kill radius during
accident
The derivation of this equation is described in Appendix D.
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In making this calculation, an assumption was made that during the transportation of
the hazardous waste, people would be exposed to the risk 24 hours per day, even though
actual exposure would be only a few minutes, because one cannot predict precisely when
the waste will be transported. Moreover, this is the way the public perceives the risk, as
continuous rather than sporadic. A further assumption was made that every accident results
in a release of the threat associated with the hazardous material (i.e., P(f/a) = 1) and that the
probability a person living within the kill radius being there when the accident occurs is also
equal to unity (i.e., P(p) = 1).
Flammable Wastes. Many of the wastes identified in this study consisted of either
mixtures of combustible wastes or solutions of hazardous chemicals (e.g., DDT) in organic
solvents such as xylene or toluene. A transportation accident involving either type may
result in the release of combustible materials and a subsequent fire.
The method for calculating the kill radius of a fire is described in Appendix D. Briefly,
we assume the spill to be 0.5 inch (1.3 cm) deep. This gives a spill diameter of 142 feet
(43 meters) for a 5000-gallon (18,920 liters) truck. For typical organic fuels, a fire from this
spill gives a kill radius of 185 feet (56 meters) from the center of the spill. These values were
used in the general equation of risk to arrive at fatalities per person-hour exposure.
Explosions. Two types of explosions were considered: those that result from the
detonation of explosive waste materials (i.e., off-spec TNT) and those that occur when a
container of combustible liquid is heated by an exterior fire until the container ruptures
explosively due to pressure build-up. The consequences and risks of the latter event are
difficult to predict theoretically. However, descriptions of accidents in which such explo-
sions did occur show that usually there is ample time to evacuate residents and that the
casualties are limited to people within a radius of 100-200 feet (30-60 meters), usually fire
fighters or plant operators. This kill radius is within the "kill" radius of a fire resulting when
the entire contents of a 30,000-gallon (113,520 liter) tank car are spilled. Thus, this
explosion situation would be covered by the fire kill radius.
Explosive "waste" is generally very sensitive to detonation and therefore is shipped in
relatively small quantities. It can be handled "on-site" the point where it is discovered to
be bad or can be transported to a disposal site.
Transportation is a risk that should be found acceptable by society. If one looks at the
case of transporting a truckload of "off-spec" TNT along any route, the fatalities/expo-
sure-hour are found to be around 10"12 n where n is the number of trips per year. This
calculation assumes an explosion with every accident and a kill radius of 500 feet (152
meters). Thus even if explosives are transported 10 times a year and explosions occur 100
times more frequently than accidents due to bumps on road, crackpots shooting at
truck the risk is still in the acceptable range.
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Although risks to employees were not evaluated numerically, in this case a point
should be made. On-site disposal i.e., blowing up the explosive in the field must be
considered preferable to exposing society to unstable explosives. On-site disposal has only
one disadvantage air pollution but exploding the small amount of "waste" product is
insignificant compared to the large amount of "good" product that is used by society during
construction, mining, etc.
Radioactive Materials. In a study of the probability of transportation accidents involv-
ing radioactive materials, Brobst* classified radioactive package damage into six classes
ranging from "no break-no damage" to "large break-extreme damage." He estimated that
the probability of occurrence of an accident causing "severe" damage to the package and in
which radioactive material is released, i.e., P(a) x P(f/a), is 1.5 x 10"9 for barge transporta-
tion.
The risk from radioactive release was calculated using a "kill" radius of two miles (see
Appendix D) and truck transportation (the worst mode) as an example. A risk of 2.8 x
10"12n fatalities/person-hour exposure was calculated, where n is the number of trips per
year. It is obvious that this risk is very small and less than 10"9 as long as n is less than 357
trips per year.
Toxic Gases. A similar equation can be used to derive the risk of accidental release of
toxic gaseous wastes except that a different expression has to be used for the "kill" area.
The gaseous toxic wastes identified in this study consisted mainly of nerve gas, CS,
nitrogen, mustard and tear gas. These warfare gases can be shipped in various types of
containers ranging in size from aircraft spray tanks that have a capacity of 1356 pounds,
615 Kg to 750-pound (340 Kg) bombs that contain 220 pounds (100 Kg) of agent, to 8-inch
(20 cm) howitzer shells that contain 14.5 pounds (6.6 Kg), each and 155-mm howitzer
shells that contain 6,5 pounds (3 Kg). These gases could be released by an accident leading
to the rupture of the spray tank or the detonation of the ordnance. The latter event is prob-
ably of greater risk to society since the gases are dispersed over a wide area in aerosol form
and these aerosols are carried by the wind for many miles.
For the purposes of this study, the dimensions of the toxic vapor cloud were assumed
to be 40 miles (64 kilometers) long and 5 miles (8 kilometer) wide for a total "kill" area of
200 square miles (518 square kilometers). The risk to individuals is found to be 8 x 10M 2n
fatality per person-hour exposure for truck transportation, where n is again the number of
trips per year.
This risk appears to be acceptable as long as the number of trips per year does not
exceed 125. One should keep in mind that these gases would not be shipped in large tank car
"Brobst, W.A., "The Probability of Transportation Accidents," Paper presented at the 14th Annual
Explosives Safety Seminar, New Orleans, La., Nov. 10,1972.
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lots without many precautions that would lower the risk even further. As mentioned earlier,
however, incidents that kill large numbers of people at one time are not as acceptable to
society as those that do not. Most importantly, as in the case of radioactive materials,
psychological apprehension is associated with chemical warfare gases and this emotionalism
makes the public perceive a higher, less acceptable risk than is really present. (At least part
of this problem is being studied by HumRRO under EPA contract No. 68-03-0156.)
Risks to Human Health or the Environment. A large number of the wastes studied in
this project were toxic liquid wastes which, if spilled, could cause a major water pollution
problem. It is extremely unlikely, however, that heavy metal sludges or cyanide solutions
would kill outright via chemical toxicity (by ingestion or skin contact). One can envision a
transportation accident where one of these wastes spills directly on a person and kills him
but the fatality would be related more closely to the accident than to the toxicity of the
spilled chemical.
In calculating risks to human health and the environment from water pollution, some
simplifying assumptions similar to those used in the previous analysis were made. First,
although the risk of pollution from spills is inherently possible in any of the four basic waste
handling and treatment steps (i.e., storage, processing, transfer, and transport), transport
was considered the most important for the analysis. Risk during the other steps can be made
small by the use of secondary containment dikes, excess-flow valves, automatic control
devices, and leak detection systems. Furthermore, for comparison purposes, it is reasonable
to assume that processing risk generally will be the same regardless of where the waste is
processed.
Risks from transfer operations may vary by several orders of magnitude from one site
to another because of the differences in the location, structure, and operating characteristics
of the individual sites. For example, a spill at a site located in a desert area virtually
precludes the possibility of the waste's reaching water. At local sites, particularly those that
already exist, the probability of a spill's reaching a body of water may be anywhere from 0
to 1 (from geological considerations only). On the other hand, at any given site, the skill and
care of operators and the safety measures designed into the plant will profoundly affect
the probability that any spill will reach water. In one sense, therefore, it would be almost
impossible to estimate risk of pollution from transfer operations without specifying a
particular site. Furthermore, although this risk can be considerably higher than that posed
by transport, storage, or processing, prudent precautions will alter the situation and reduce
risk during transfer to a negligible level. Since such precautions are expected to be taken,
and perhaps to be mandatory, it was assumed that the risk of pollution during transfer
operations could be neglected.
Given the foregoing assumptions, the parameter of interest again is risk during trans-
port. In these calculations, transport in 5000-gallon (18,920 liter) trucks was assumed. This
mode of transport has the greatest frequency of accidents, involves the largest number of
trips, and is the mode most commonly used.
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To arrive at a measure of pollution risk, the unit chosen was the volume of water that
would be needed to dilute the spilled waste to the critical concentration (that is, the
minimum concentration that will produce some detrimental effect on human health or the
environment). This unit of risk was suggested by Dawson, et al;* values of the critical
concentration are given in the same report. In these calculations, Qs^, the number of
milligrams of hazardous chemical spilled during transport, was estimated from the annual
probability of an accident, the probability of a relase given an accident, the total volume of
a shipment and the concentration of the solution shipped. The minimum value for the
critical concentration Cc (in mg/liter) was chosen from Battelle's report.* The risk, mea-
sured in liters of water that could be potentially polluted per year, is thus equal to Qst/Cc.
This measure of risk can be used to compare the pollution risk of two off-site treatments.
Unlike the case of risk to human life, the literature suggested no yardstick that had
been used as an acceptable level of pollution a level that society is willing to live with.
However, such a yardstick may be derived from the total quantity of hazardous wastes that
society voids into its waters from manufactured consumer products. Such data should
become available very shortly from a study performed by Arthur D. Little, Inc., for the
Environmental Protection Agency .f This catalog can be used to calculate the total quantity
of waste e.g., cyanides and fluorides that reach water supplies through the normal use
of manufactured products. The quantity of water required to dilute these wastes to the
critical concentration level can then be used as a yardstick for comparing the risk of a
particular transport operation.
In any case, in making an evaluation of risk, it is important to remember that
hazardous materials are continually being transported in large quantities as "normal" articles
of commerce. Thus, each of the specific chemical species under study is already being
shipped in both large and small quantities and in many cases on a daily basis. Although the
form (pure vs waste stream) may have an impact on the risk value, it will not make a
radical difference. Therefore, on the basis of simple logic, one would not anticipate that
many of the items listed as hazardous wastes should be too dangerous to transport to an
off-site processing facility.
Legislative Framework for Controlling Hazardous Wastes
In addition to evaluating the impact of risk on the economic analysis of alternatives, it
is important that one also be able to ascertain the effects of legislation. For example: What
do the statutes permit or constrain? What might be needed to make an alternative viable?
*G. H. Dawson et al, "Control Spillage of Hazardous Substances," Battelle report to FWQA No. 15090
FOZ 10/70, GPO, 1970.
J. Berkowitz, "Catalog of Manufactured Products Having Water Pollution Potential," Final Report to EPA,
Contract 68-01-0102 in preparation (1973).
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How are the rules enforced? Thus, legislation pertaining to hazardous waste control at both
the Federal and state levels was reviewed.
Legislation at the Federal Level. Standard sources were searched to ensure that all
existing Federal statutes and regulations were identified, as well as major legislation
proposed and now pending before the Congress in late 1972, which seem to relate to one or
more hazardous wastes. These sources included:
* U-S. Code Annotated
Code of Federal Regulations
Federal Register
U.S. Congressional and Administrative News (for legislative history stating,
in some cases, the rationale underlying legal provisions)
Official reports, for example, Toxic Substances, published by the Council on
Environmental Quality in April 1971
Articles and commentaries in law journals and environmental magazines
Whereas the statutes and official documents show Federal policies as contained in laws
on the books, the articles and commentaries provide spotty but valuable information as to
how effectively these laws are operating in practice.
As one might expect, legal coverage of the hazardous wastes of concern to this study
varies. So do the strategies and techniques of controlling wastes. For example, neither the
Hazardous Substances Act of 1966, as amended, nor The Water Pollution Control Act of
1956, as amended, focuses upon the problem of disposal. The former focuses upon the
potential hazards in children's toys, such as flammability and sharp edges, while the latter
focuses upon discharge of pollutants into navigable waters. However, the enforcement
techniques of each are of interest: the first relies upon warning consumers by means of clear
labeling, rather than, for example, upon prior testing and certification; the second becomes
operative only after pollutants are dumped into waters, and provides for restrictions only
after the fact, by means of permits and fines.
This inventory and analysis resulted in three products. First, it led to the development
of a matrix to organize the information summary form. (See Appendix E, Table E-l). The
vertical axis of the matrix lists the applicable Federal statutes; its horizontal axis, the types
of information needed for this case. Each cell contains a few words or phrases describing an
important aspect of the law, for example, range of applicability, strategy of control,
technique of enforcement, and executing agency responsible. This matrix form of presenta-
tion does not, of course, pretend to be a lawyer's analysis of statutes, but merely an
efficient means for persons to grasp quickly the legal and administrative framework as it
now exists and to compare major provisions of the Acts.
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The second product is an organization chart of those Federal agencies concerned with
hazardous wastes (Appendix E, Figure E.I). Together with a brief description of the duties
of each concerning hazardous wastes, this chart enables one to grasp at a glance the
administrative means by which Federal laws are, presumably, applied. We also identified in
Congress those Committees and Subcommittees having interests in hazardous waste ques-
tions.
A third product is a discussion of federal and state approaches to disposal of hazardous
wastes and issues of importance in our consideration of each alternative. This discussion
appears in Part 3.
Legislation at the State Level. To gain some insight into the regulation of hazardous
wastes at the state level, state statutes, both existing and pending, were reviewed as
were other official state documents; and a few selected legislative and executive branch
officials in New Jersey and Pennsylvania were interviewed. These two states were selected
for field study not only because our technical field data came from that region, but also
because both states are active in developing programs to deal with problems of hazardous
wastes.
In New Jersey, the magnitude of the environmental control problem in general, and the
hazardous waste disposal problem in particular, is great. Northern New Jersey lying in the
midst of the New York City Philadelphia megalopolis, is densely populated with auto-
mobiles and with people. It contains a high concentration of industrial plants, especially
chemical facilities. Moreover, policy-making is complicated by other factors. For example.
relatively large undeveloped areas in the southern and coastal portions of the state are ripe
for exploitation. In addition, New Jersey has a tradition of strong home rule: the state has
more than 560 local governmental units each jealous of its prerogatives.
On the positive side, New Jersey was relatively quick to jump on the environmental-law
bandwagon. In 1954, for example, New Jersey passed legislation regulating smoke emissions
from industrial plants. It appears that this law was a first for a state, although the regulatory
bodies did not pursue vigorous enforcement programs.
Pennsylvania, another major industrial state, has been coping for years with waste
disposal problems that are made especially difficult by the geological and hydrological
character of the Appalachian Mountain region. The Commonwealth has therefore enacted
several comprehensive laws to control water, air, and solid waste contamination. A 1972
amendment to Pennsylvania Rules and Regulations, Chapter 75, Solid Waste Management,
addresses "Hazardous Wastes" specifically and in strict fashion. (See Appendix E,
Table E.6). It also has established a Department of Environmental Resources, with eight
regional offices and staffs, that appears to be well organized and well led in it's administra-
tion of these laws. The Department receives important policy support from the Environ-
mental Quality and Hearing Boards, Citizens Advisory Council, and the Joint Legislative Air
and Water Pollution Control and Conservation Committee.
30
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COMPARISON OF ALTERNATIVES
Development of the Economic Decision Maps
Because of the many variables involved in the analysis of alternatives, a series of
economic decision maps was developed for use as our analytical tool. To develop these maps
required the derivation of a mathematical equation that describes all the unit operating costs
associated with the treatment and disposal of hazardous wastes. (See Appendix F for
details.) The equation that does this is:
C = CHW + CTWMW + Cp + CHR + CTRMR + CF
where:
C = Total unit cost for processing a waste.
= Handling cost of waste (loading, unloading, etc.)
= Transport cost of waste per mile.
M^y = Miles waste is transported.
Cp = Processing cost.
= Handling cost of residue.
= Transport cost of residue per mile.
Mn = Miles residue is transported.
CF = Final disposal cost.
Many of these costs, however, are the same regardless of the site involved, assuming
that the waste in question and the disposal method are the same at each site. Under these
circumstances, one need consider only the net differences in cost between alternative
strategies for disposing of a hazard waste. These, as it turns out, are the differences in
transport cost and differences in processing cost. Therefore, the equation simplifies to:
C = CTW(M1 -M2) + (Cpl-Cp2)
where:
C = Difference in cost between two alternatives.
= Transport cost per mile for the waste in question.
= Miles from waste source to treatment site 1.
(For on-site disposal, Mj = 0.)
31
-------
M2 = Miles from waste source to treatment site 2.
Cp j = Processing cost for waste in question at treatment site 1.
Cp2 = Processing cost for waste in question at treatment site 2.
The difference in processing cost (for the same waste and treatment) is a function of
the relative capacities (or throughputs) of the treatment facilities involved. Thus, the
expression Cp j Cp2 in the above equation can be replaced by T! /T2, the ratio of the
throughputs at the treatment facilities being compared.
The difference in total unit cost, AC, can be set to zero for each processing cost ratio
(or each mileage difference) and the breakeven points between alternatives can be
determined by plotting M2 Mj versus T! /T2. The breakeven points delineate a line that
marks the boundary between conditions of transportation and processing costs that favor
one alternative or an other. (See Figure 2.1.)
This gave a method of comparing alternative strategies for specific types of wastes,
based on the number of waste sources within a given area and their distance from each
other. As noted earlier, however, further consideration of the list of wastes led to the
recognition that the important element in comparing strategies was not the waste, but the
treatment process. Thus it was not necessary to compare strategies for 100 or more
individual wastes or even for 35 classes of waste. Instead it was necessary only to compare
strategies (on-site versus off-site disposal) for the eight treatment processes that would
handle all of the hazardous wastes included in our study. This was the method adopted.
The information derived from the equation can be presented in a number of ways for
purposes of deciding among strategies. (See Appendix F.) However, the information can
best be displayed in the form of a decision map whose important parameters are:
the number of sources of waste,
the volume of waste generated by the sources, and
the distance separating these sources.
Figure 2.2 illustrates this type of decision map. It is this type of map that is used for
the discussion of the comparative economics between on-site and off-site disposal for the
waste treatment processes.
Modification by Risk and Legal Factors
Once the economic difference between on-site and off-site disposal for a given strategy
was calculated, the potential impact of the various risk and legal factors on that difference
32
-------
. Breakeven Line
Strategy 1 Favored
5
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Strategy 2 Favored
VT2
1.0
FIGURE 2.1 HYPOTHETICAL PLOT OF BREAKEVEN
LINE FOR TWO STRATEGIES
33
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34
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was determined. This could not be done directly, since the risk values were not calculated in
terms of unit costs and the legal impact could not be assigned any type of numerical value.
Thus, for each strategy it was ascertained whether or not the risks would be acceptable to
society and whether or not there seemed to be some legal restriction that would prevent or
add to the cost of a strategy.
Overall, neither the risk nor the legal factors were found to have any impact on the
economics of on-site or off-site disposal.
35
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CHARACTERIZATION OF WASTE STREAMS
The information and data that were obtained from the waste stream characterization
work are given in Appendix B. Part 1 of that appendix describes the industries that are
projected to have an important impact on a hazardous waste processing system:
chloro-organic solvents, pesticides, paints, tanneries, metal finishing, batteries, cooling
towers, chlor-alkali plants, and smelting or refining. These industries are important because
they will provide a large amount of the waste streams that contain the chemicals on the
hazardous waste list (Appendix A, Table A. 2). A brief summary of pertinent findings is
given in Table 3.1.
Looking at the specific region consisting of the two states of Pennsylvania and New
Jersey, evidence was found to support the need for off-site processing here as well as in
other areas in the country. Table 3.2 provides a preliminary estimate of the number of
establishments, both nationally and in the local region, for selected industries. This list is
not meant to represent the total number of industrial point sources in New Jersey and
Pennsylvania but rather an estimate of the minimum number in those two states.
37
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TABLE 3.1
INDUSTRIES WITH WASTES REQUIRING TREATMENT
Waste Category
Concentrated heavy
metals
Dilute heavy metal
Dilute heavy metals with
organics
Heavy metal sludges
Concentrated cyanides
Dilute Cyanides
Liquid organics
Organics with solids
Industry with
Applicable Wastes
Pesticides
Metal finishing
Metal finishing
Battery manufacture
Cooling towers
Chlorine production
Smelting and refining
Tanning
Tank cleaning
Metal finishing
Tanning
Metal finishing
Batteries
Cooling towers
Metal finishing
Metal finishing
Chemicals
Pesticides
Pesticides
Paints
Petroleum
Electronic
Description of Waste
Off spec or residue from formulation; tank
rinsings from applicators
Plating baths, etching solutions
Rinse tank water
Rinse from plate preparation
Blow down
Waste process water from chlor alkali plants
Process water
Chrome tanning of hides
Railroad or truck transport cars
Applying decorative coatings to metals
Waste point source precipitates metals and
then ships the sludge
Plating baths
Rinse water from plating baths
Dilute aqueous stream containing waste
solvents as well as water solvents
Liquid formulations
Unused or deteriorated formulations,
rinsings from applicator
Sludge residue, wastage from spray painting
Storage tank residue containing organo lead
compounds
Capacitors with PCB
38
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TABLE 3.2
MINIMUM ESTIMATE OF SOURCES OF HAZARDOUS WASTES*
Sources in
Industry Sources in U.S. IM. J. and Pa.
Chloro Organics Compounds 57 3
Pesticides 46 4
Paints 1700 266
Metal Plating 7000 298
Tanning 519 68
Cadmium Batteries 10 2
Chlor Alkali 29 1
Total 9361 642
"Only identified sources of wastes containing chemicals directly related to this study are included in
this tabulation.
39
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PROCESS DESCRIPTIONS
As discussed in Part 2, all of the hazardous waste materials listed in Table A.2 (except
radioactive material, DOD materials, interhalogens, and explosives) can be treated by
various combinations of the waste treatment processes summarized in Table 2.1.
In general, the hazardous wastes fall into three major groups: heavy metals, cyanides,
and chlorinated hydrocarbons. Often, a particular industrial hazardous waste will actually
fall into two of these groups and sometimes all three groups. This type of waste will require
treatment by several of the processes listed in Table 2.1.
The groups of hazardous wastes may be further subdivided into subgroups such as
arsenites and arsenates and soluble and insoluble anions which would be important in
treating a very specific waste (for example, incineration of copper cyanide to recover
copper). However, it has been found that most industrial hazardous waste streams contain
combinations of hazardous materials that require a more general treatment system. For
example, one industrial waste stream could contain arsenic, selenium, copper arid
hydrochloric acid. Thus, the processes illustrated in Figure 3.1 were selected on the basis of
their applicability to a variety of industrial hazardous wastes rather than the treatment of a
specific chemical compound.
The list of eight processes for treating hazardous wastes is not meant to be all-inclusive
of the processes that might be used "off-site" at a Central Processing Facility or even of all
the treatment methods that could be used "on-site" where the waste is generated. The main
purpose of selecting these waste treatment systems was to allow a comparison of the total
operating cost (including transportation cost) for "on-site" and "off-site" treatment systems
for industrial hazardous wastes.
Several processes discussed by TRW in its reports were included, such as chrome (heavy
metal) reduction and precipitation, ion exchange, activated carbon absorption, incineration
of chlorinated hydrocarbons, and cyanide destruction by alkaline chlorination. Also added
was sulfide precipitation of heavy metals, since the (stable) sulfides of the heavy metals are
less soluble than the hydroxide and thus can be removed more efficiently from the
wastewater. Other processes such as reverse osmosis and pyrolysis as described by TRW in
its report were not included, because it does not appear that they would be applied widely
for on-site (small-scale) processing, and these systems would involve the problem of
processing secondary wastes. For specific applications, ion exchange could be used to
recover many of the heavy metals, or newer methods of waste treatment - such as thermal
decomposition* or hydrogen peroxide oxidation', -are being developed for destruction of
cyanide. Again, however, these systems were not included in these estimates because they
are still in the development stage or would be applicable only to specific waste streams.
*Chemical Week, Dec. 20, 1972, p. 32
tChemical Week, Dec. 16, 1970, p. 54
40
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Treatment of Heavy Metal Wastes
Heavy metals may be removed from wastewater by precipitation as either the
hydroxide or the sulfide. The hydroxide (or sulfide) sludge is settled from the wastewater
and concentrated by filtration and centrifugation. To the extent that these sludges are being
landfilled directly, this approach could allow relatively easy reintroduction into the
environment through natural leaching. For adequate treatment these sludges should be
encapsulated before being landfilled to minimize their leaching back into the environment.
Therefore, encapsulation and landfill burial of these sludges have been included as part of
our waste treatment scheme.
Concentrated Heavy Metals. All of the heavy metals may be precipitated as the
sulfides, which in general are much less soluble than the hydroxides and, therefore, can be
removed more completely from the wastewater. (Insoluble heavy metal compounds could
be encapsulated in polymer or concrete, without further treatment, and be buried.)
Unfortunately, chromium sulfide hydrolyzes to the hydroxide when exposed to air, so
it was assumed that this heavy metal would be precipitated as the hydroxide in the waste
treatment processes. In addition, prior to precipitation, the hexavalent chromium must be
reduced to the trivalent chromium. This can be done by a number of reducing agents,
including ferrous sulfate or sulfur dioxide. In industry the most widely used reducing agent
for this purpose is sulfur dioxide. (The ferrous sulfate produces a more voluminous
precipitate when the chromium is precipitated as the hydroxide.) Following reduction to its
trivalent state, the chromium is precipitated as the hydroxide, generally using lime as the
precipitating agent. This hydroxide sludge would be encapsulated and buried in a manner
similar to that used for the sulfide sludges. If there were a market for the chromium
hydroxide, the hydroxide could be recycled as an alternative to encapsulation and landfill,
but presently it appears more economical to produce chrome from the ore than to try to
recover it from these sludges. Chrome wastewaters can be treated by this method in either a
batch or a continuous system. For small volumes it is usually batch treatment, whereas in
very large volumes it is continuous.
When the chromium is in a dilute solution (such as plating bath rinse) it is often
possible to recover the chromium by ion exchange as an alternative to disposing of the
chrome as a waste. In this situation both chromic acid and demineralized water are
recovered for reuse.
The possibility of recovering chromic acid from chromium plating wastewater using a
mobile ion-exchange unit was also examined. In this case deionized water would be available
on-site, but the chromic acid would not be.
Ion exchange is not generally used for recovery of concentrated chromic acid because
the resin would be quickly exhausted, large amounts of regenerant would be required, and
very little demineralized water would be recovered.
44
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Heavy Metal Wastes Containing Organics. When the heavy metal waste stream also
contains organics or hydrocarbons, it will be necessary to treat the stream for this material
after heavy metal precipitation but prior to discharge. These organics may be removed by
activated carbon treatment or simply by incinerating the waste stream. If, in addition to the
hydrocarbons, the waste stream contains halogens (such as chlorine) or salts such as sodium
sulfite it would be necessary to scrub the flue gas after incineration of the waste stream.
If activated carbon were used for final treatment to remove the organic material, the
activated carbon would have to be regenerated or disposed of. In the proposed process
scheme, "on-site" regeneration of this activated carbon was assumed.
Encapsulation and Burial of Heavy Metal Sludges. The hydroxide sludges are relatively
stable and could be encapsulated for burial by any of the techniques shown in Appendix C.
Some of the sulfides have a high enough vapor pressure (e.g., arsenic sulfide) so they would
have to be encapsulated by one of the cold encapsulation techniques (e.g., cement
encapsulation) rather than the hot melt technique using scrap polymer or asphalt.
In each of the encapsulation techniques the heavy metal sludge is mixed with the
binding agent (cement, molten asphalt or polymer, whenever binder is used by private
companies in this business) and then cast in waste drums for burial.
Treatment of Cyanide Wastes
Many techniques may be used to destroy cyanide wastes. Among these are
hypochlorite, alkaline chlorination and hydrogen peroxide oxidation or thermal oxidation.
The most widely used of these systems in U.S. industry for complete destruction of the
cyanide is alkaline chlorination, so this method has been used as a basis for our process
costing. As in the case of chrome wastewater, small volumes are treated in continuous
systems.
If the cyanide wastewater also contains heavy metals, heavy metal treatment would be
required after the cyanide destruction.
Treating a concentrated cyanide waste by alkaline chlorination requires large quantities
of the chlorine and caustic. Therefore the operating cost for an alternative cyanide
treatment method was estimated, where the concentration of cyanide would be
substantially reduced in the first step by acidification, the HCN gas then volatilized and
incinerated, and the residual cyanide destroyed by alkaline chlorination in the second step.
If heavy metals were present, they would be precipitated between these two steps to take
advantage of the reduced amount of alkali required in the alkaline chlorination second step.
(The wastewater would be alkaline after heavy metal precipitation.)
45
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Disposal of Chlorinated Hydrocarbons
The chlorinated hydrocarbon wastes occur as liquids, slurries, solids and aqueous
solutions.
The most resistant of these chlorinated hydrocarbons can be destroyed by incineration
at temperatures of 2500-2800 F. (1370-1536 C.) In order to reach these combustion
temperatures, auxiliary fuel (gas or oil) must be used. In the proposed treatment scheme
fuel oil is mixed with the liquid chlorinated hydrocarbons (containing no solids). This
mixture would be fed to the furnace just as would be the liquid chlorinated hydrocarbons,
but more fuel would be required to vaporize and heat the water in the solution. The flue gas
is cooled in a spray chamber, and the by-product hydrogen chloride is then scrubbed from
the flue gas in a scrubbing system using a Venturi first stage and a packed tower second stage
with lime hydrate as the absorbent. The dilute waste calcium chloride solution would be
discharged to an appropriate receiving body of water.
If the chlorinated hydrocarbon were in the form of a slurry, the solid and liquid phases
would be separated prior to incineration. The liquid phase would be mixed with fuel oil and
fed to a rotary kiln through an atomizing nozzle while the solid phase was charged directly
to the kiln. Solid chlorinated hydrocarbons would be fed directly to the sfemfcJ lr\,
46
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ECONOMICS OF WASTE TREATMENT
This chapter deals with the economics of waste treatment processes. Appendix C,
which provides additional details of the economics, also shows flow sheets of each of the
processes described above.
In estimating the cost for "on-site" treatment of hazardous wastes, these costs were
based on large individual sources. The rationale was that if it were not more economical for
a large individual source to treat the waste "on-site" than at a central processing facility, it
would be even less economical for "on-site" treatment for smaller sources of the hazardous
waste.
The estimates of capital investment and operating cost are calculated for specific waste
streams and treatment methods. A change in the size or composition of the waste stream or
the treatment method could greatly affect capital and treatment costs.
If it is assumed that the same treatment scheme is used both for "on-site" treatment
and treatment at the Central Processing Facility, the major cost factors affected will be
those related to scale: depreciation, maintenance, taxes (capital investment related), and
labor and administrative overhead (labor related). It was assumed in these estimates that
chemical and utility costs would be the same for both "on-site" and at a Central Processing
Facility, although the unit costs for chemicals and utilities would probably be less at the
Central Facility. Thus, these estimates were biased in favor of "on-site" treatment. Although
the capital investment and labor-related costs per unit of treated waste will be lower for the
Central Facility than for "on-site" treatment, transportation cost must be added. The
reduction in labor- and capital-related costs is traded off against transportation cost in the
Decision Map Analysis.
Table 3.3 summarizes capital investment and operating costs for the eight major
treatment processes (See Appendix C for details).
Treatment of Concentrated Heavy Metals (A)
Although the precipitation and removal of the heavy metals as hydroxides would be
less costly than their precipitation as the sulfide (18^ vs 20^/gallon [4.75.2
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49
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Dilute Heavy Metals (B)
In addition to heavy metal removal by precipitation, dilute heavy metals may be
removed (and recovered) by ion exchange. The cost for both of these methods is nearly the
same (Table 3.3). In the reduction-precipitation method, however, a chrome sludge must be
disposed of, whereas in the ion exchange system, sodium and calcium sulfate must be
disposed of.
Organics with Heavy Metals (C)
If the wastewater containing heavy metals also contains organics (chlorinated or
non-chlorinated hydrocarbons), these organics must be treated following heavy metals
removal. If the hydrocarbon were not halogenated (chlorinated), the aqueous organic stream
could merely be mixed with fuel (oil) and burned. The cost would be about 84 per gallon
(2^/liter) of wastewater as shown in Table 3.3. If a halogen is present, the flue gas from this
combustion must be scrubbed to remove the halogen before it is discharged to the atmos-
phere, which would increase the cost to 17|fc per gallon (4.5«i/liter). If waste fuel oil were
available at no cost, the incineration cost for both of these processes would be reduced by
about 2i per gallon (0.5<^/liter) of wastewater. The cost of incinerating dilute wastewaters
would be nearly independent of hydrocarbon concentration until concentrations reached
about 25% by weight, when the fuel value of the hydrocarbon would start to reduce the in-
cineration cost. (For chlorinated hydrocarbons, the cost would increase with increasing con-
centrations because of increased scrubber size and alkali requirements.)
Activated carbon absorption was also costed as a method for treating aqueous organic
wastes, but for the concentration of organics in the estimate (2% by weight) the amount of
activated carbon required makes this a very expensive process (39^/gal. [10<^/riter] waste-
water for carbon absorption vs 17
-------
cement mixer. The asphalt or polymer encapsulation, on the other hand, would reduce the
volume of sludge through evaporation of the water in the sludge. The lesser volume of
encapsulated sludge in asphalt encapsulation, when it can be used, results in a lower landfill
burial cost. The cost of labor and binding material would also be less for asphalt
encapsulation than for cement encapsulation (Table C.9).
Concentrated Cyanide Waste (E)
The cost of treating a concentrated cyanide waste in one step by alkaline-chlorination
was compared with a two-step process in which the cyanide solution is first acidified to
liberate HCN (which is incinerated) and then treated for residual cyanide by alkaline
chlorination. Despite the advantage of lower chemical consumption (and subsequent sodium
salts in the effluent), the cost for the two-stage treatment of the cyanide wastewater is
greater than that of the single-stage alkaline chlorination. This increase is due both to higher
capital investment and to higher labor requirements for conducting a two-stage reaction
compared with a single-stage reaction.
Often these cyanide wastes also contain heavy metals that require treatment. The cost
of heavy metal treatment is not included in this estimate, and would have to be added to
arrive at the total wastewater treatment cost.
Dilute Cyanide Waste
Dilute cyanide wastewater would be treated by alkaline chlorination. As before, the
treatment cost estimated in Table 3.3 does not include any additional heavy metal
treatment that would be required.
Liquid Chlorinated Hydrocarbons
The cost of treating liquid chlorinated hydrocarbons will depend on several factors, the
most important of which are chlorine content, heat value and, of course, system capacity.
More than half the capital investment for this system is for scrubbing the HC1 gas
by-product, and the size of the scrubbing system will be affected by the chlorine content of
the chlorinated hydrocarbon. About half the operating cost (including capital charges) is
related to the capital investment. Scrubbing alkali and fuel account for most of the
remainder. For chlorinated hydrocarbons with greater heat values, the requirement for
auxiliary fuel is reduced. Also, if a waste fuel (e.g., motor oil) could be used, this would also
reduce the operating cost considerably.
It has been assumed that the dilute calcium chloride solution (less than 1 percent
CaCl2) could safely be discharged to some body of water. If this were not possible, it might
be necessary to recycle the calcium chloride solution several times and then recover the
calcium chloride through spray drying. This would, of course, increase the cost of disposal.
51
-------
Chlorinated Hydrocarbon Slurries and Solids
The basic differences between this system and the other for handling liquid chlorinated
hydrocarbons are that a rotary kiln would replace the furnace for burning the waste and a
filtration system would be required for separating the liquid and solid phases. The solids
could be fed directly to the kiln while the liquid phase would be mixed with fuel oil and
fired into the kiln through an atomizing burner nozzle. The capital and operating costs for
this system are slightly higher than those for the liquid chlorinated hydrocarbons alone.
Because of the solids handling problem in addition to the liquid incineration, labor
requirements for this system would be greater than for the liquid alone.
Mobile Incinerator for Chlorinated Hydrocarbons
A cursory evaluation of using a portable incinerator to dispose of chlorinated
hydrocarbons indicates there would be no real economic advantage because additional
storage capacity would be required on-site, there would be a large periodic requirement for
utilities on-site (cooling water, fuel oil, power) and a very large utilization factor would be
required to offset the additional investment for transport equipment.
A mobile system for the disintegration and incineration of empty pesticide cans is
described in Appendix C.
Interhalogens
These compounds are expected to occur only in extremely small quantities either
on-site or at a regional off-site facility. They would be incinerated with off-gas scrubbing in
exactly the same manner as chlorinated hydrocarbons; a fuel rich system (oil or
propane/butane) would be used to provide a reducing atmosphere to permit scrubbing the,
resultant halogen acids with caustic.
Mobile Waste Disposal Systems
The biggest cost item with respect to on-site disposal is most often the high fixed
charges associated with the low throughput in expensive waste treatment equipment. Waste
treatment equipment on a mobile van could be, say, 4 times larger but use only one-fourth
the time at a given site to achieve economies of scale. (If the 0.6 exponent is used, this
example calculates to 4°-6 -f 4 = 57.5% of the original investment.) This approach was
considered for heavy metal wastes requiring ion exchange, chlorinated hydrocarbons
requiring incineration and scrubbing, and insecticide can destruction and decontamination.
With respect to ion exchange, it was found that the cost of the large waste retention
pond, to permit holding liquor for say one month for one week's treatment time at four
52
-------
times the normal rate, plus the extra fixed charges on tractor and trailer for the mobile unit
more than offset the savings that accrue from using the equipment only one week per
month. (Appendix C shows our cost estimates for such a system.)
A mobile unit for burning dilute chlorinated hydrocarbons is even less attractive than
the ion exchange unit because of the need for enclosed tanks to retain the waste (compared
to the cheaper ponds considered for ion exchange treatable waste).
A portable, insecticide-can, destruction and decontamination system could be
economic to the point of even paying for itself (zero destruction cost per can) depending on
initial cost of the unit and the net sales price of the scrap iron generated. A $300,000
portable unit operating at the rate of one can per minute could break even at $30/ton
($27/metric ton) net scrap value (Appendix C, summarizes the factors in this estimate.)
Unfortunately, the scrap iron market varies over a wide range, $10-40/ton ($936/metric
ton) and requires contracts for delivering large tonnages so it is difficult to draw any
economic conclusions from our cost estimates.
53
-------
ECONOMIC DECISION MAPS
On-site versus Off-site
The decision map provides the mechanism for comparing on-site to off-site alternatives
for each of the eight waste categories described earlier. The basic data on which the
comparison was based for each category are shown in Table 3.4. The scale-dependent
processing cost shown in column (4) includes only labor and capital related costs, which
depend on the scale of the processing operation. Chemical and utility costs are independent
of processing scale on the unit waste basis used here.
The decision maps for the eight waste categories are shown in Figures 3.2 through 3.9.
(Two decision maps are required under Category 4, Heavy Metal Sludges, to show the two
alternative processes, encapsulation by asphalt or cement.)
The decision map for concentrated heavy metals, Figure 3.2, is representative of the
others and will be discussed in detail. Point A on the map best represents the sample of
sources obtained in field work. This point is defined by the mean separation between
sources and the mean source size. The position of Point A on the map shows whether the
on-site or off-site processing alternative is economically preferable. Here Point A lies
comfortably within the OFF-SITE region of the map, and the off-site processing of
collected wastes is recommended.
The vertical lines corresponding to the smallest and largest sources in the sample are
also shown for perspective.
Two other points on the map are of interest. Point B defines the separation between
sources that would be required if on-site processing were to be feasible with sources the
same size as the sample mean. For concentrated heavy metals, this change-of-strategy
separation is 360 miles (579 kilometers), whereas the actual value is 81 miles (130
kilometers). Point C defines the source size at which on-site processing becomes feasible for
sources separated by the sample mean separation. For concentrated heavy metals, this size is
16 million gallons (60 million liters) per year (gpy), compared to a sample mean of 325,000
gpy (1,230,000 liters per year) and a sample maximum of 950,000 gpy (3,595,000 Ipy.)
Clearly, off-site processing is preferable for these wastes by a large margin.
With one exception, the decision maps for each waste category lead to the conclusion
that off-site processing is preferable. The exception, dilute heavy metals (Figure 3.3),
deserves special discussion. The sample data point falls in the ON-SITE region of the
decision map. The map also shows that for off-site processing to be feasible, the sources
would have to be 34 miles (55 kilometers) apart (instead of the 75 miles (121 kilometers)
shown by the sample) or have a mean size of 100,000 gpy (378,400 Ipy) (instead of the
760,000 gpy (2,876,000 Ipy) shown by the sample). The implications of these values are
discussed later.
54
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On the decision map for dilute heavy metals with organic contamination, Figure 3.4,
two waste groups are considered. The bulk of the sample consists of wastes from the metal
finishing industry and is shown in the usual manner. In addition, we identified two tanneries
in another geographical area. The waste volumes from these tanneries are one to two orders
of magnitude larger than the largest from the metal finishing industry and are shown
separately. For the plating wastes, off-site treatment is preferable. For the tanneries, on-site
treatment is preferred if the tanneries are more than 10 to 20 miles (16 to 32 kilometers)
apart.
The decision map results are summarized in Table 3.5, along with information which
provides a basis for evaluating the results. In all cases, except Category 3, off-site processing
is recommended based on the properties of the sample mean.
Would all sources, even the largest ones, actually make use of an off-site facility if it
were available? We cannot answer that question definitively, since the answer depends on
the location of the large source relative to the off-site facility. However, the numbers listed
in column (4) of Table 3.5 give some hint. This column shows the ratio of the source size at
which on-site processing becomes feasible to the size of the largest source in the sample. The
larger this ratio, the more likely that the large sources would find off-site processing
attractive.
In Categories 3 and 4a, these ratios are less than one and large waste sources within
these categories might well choose to process on-site. It is important to recognize that, even
if this occurs, off-site facilities are still required for the smaller sources. This conclusion can
be visualized on the decision map. Exclusion of large sources from the sample reduces the
mean size significantly. This forces the sample point to the left on the map and more deeply
into the OFF-SITE region.
For dilute heavy metals, Category 2, the recommended strategy is on-site processing.
The ratio (source size at which off-site processing becomes feasible to size of the largest
source in the sample) is 0.017, and the ratio to the mean source size is 0.13. These values
imply that only sources smaller than 13 percent of the mean size could afford to choose
off-site treatment if they are as much as 73 miles (118 kilometers) apart (the mean source
separation). There is little likelihood that an off-site facility geared strictly to the treatment
of these wastes would be feasible.
Column (2) of Table 3.5 shows the source separation at which the recommended
alternative changes (from off-site to on-site, or vice versa), compared to the mean source
separation derived from the source sample. It is important to recognize that additional
sampling for waste sources can result only in a decreased mean source separation as more
sources are located. In all cases except Category 2, the mean source separation is already less
than that at which the strategy changes, and the addition of sources to the sample cannot
change the recommended strategy unless the additional sources also cause the mean size to
increase dramatically.
65
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The sample separation for Category 2 is 73 miles (118 kilometers), and the
recommended strategy would change from on-site to off-site if the separation were reduced,
to 34 miles (55 kilometers) or less. It would take four times the number of sources in the
original sample to give the required 34-mile (55 kilometer) separation.
Pretreatment of Wastes
A processing strategy applicable to a wide variety of the aqueous wastes considered
under the eight categories analyzed in the preceding section is concentration of the waste by
an evaporation process prior to shipment to an off-site facility. The implications of this
strategy for the on-site/off-site decisions have been examined. There are two basic situtations
to consider. The first is on-site processing of dilute heavy metal wastes: is concentration of
the waste and shipment of the concentrate to an off-site facility less costly than on-site
treatment of the dilute waste? The second is the other waste categories in which off-site
treatment is advocated. Can savings be made by concentration prior to shipment? The
situations require separate consideration.
The cost of treating a dilute heavy metal waste on-site is simply the processing cost.
Concentration of the waste and shipment to an off-site facility incurs three major cost
elements: concentration, transportation, and off-site processing. Using a standard base
capacity of 10,000 gpd (37,840 Ipd), the total cost of on-site treatment of dilute heavy
metals via precipitation and burial was estimated to be 1.1 to 1.2^/gallon (0.38^/1). At the
same capacity, the evaporation cost was estimated to be $31.50 per thousand gallons
($8.30/1000 liters) evaporated. The evaporation cost alone, not including the transportation
and off-site processing cost accrued under the preconcentration strategy, is higher than the
on-site processing cost. Therefore, on-site treatment based on precipitation is preferable to
preconcentration and shipment.
In the second situation, where the waste would be shipped off-site even without
preconcentration, the question is somewhat more complex. The decision to preconcentrate
is an individual one which can be made at each waste source without influencing the same
decision at another source. However, all of the waste material winds up at the off-site
facility whether or not the waste is pretreated. Preconcentration reduces the individual's
transportation costs and also the off-site processing cost, since for the same amount of waste
chemical, a concentrated waste is less expensive to process than a dilute one. The question
is, under what conditions do these savings override the cost of preconcentration?
Figure 3.10 illustrates the situation. Total disposal cost (processing plus transportation)
is plotted against distance from the source to the off-site processing facility for three
alternative strategies:
(a) Shipment of dilute waste for processing off-site (Line A). This strategy has
the lowest processing cost (intercept at zero distance) and the largest rate of
increase of cost with distance. (A large volume of waste is shipped.)
67
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(b) Preconcentration of the dilute waste on-site and shipment of the concentrate
for off-site processing (Line B). Preconcentration raises the processing cost
above that of (a), but reduces transportation costs per mile shipped.
(c) On-site disposal of the dilute waste (Line C). This strategy has the highest
processing cost, but no transportation cost.
The intersection of these lines with each other defines the optimal processing strategy
as a function of distance from source to off-site processing facility.
Figure 3.10 shows that:
1. For M less than Mj, shipment of dilute wastes for off-site processing is least
expensive.
2. For M larger than Mj and less than M3, on-site preconcentration and off-site
processing of the concentrate is preferable.
3. For M larger than M3, on-site processing is least expensive.
Our previous analysis of on-site versus off-site alternatives considered the trade-offs
between Line A, shipment of dilute wastes, and Line C, on-site disposal.
The decision maps shown earlier are based on the breakeven distance between these
alternatives (M2 on Figure 3.10). Consideration of the evaporation alternative modifies the
results in two ways:
1. The cost can be reduced by preconcentration of the waste when the distance
from source to processing facility lies between Mt and M2.
2. The distance which the waste can be economically shipped for processing
increases from M2 to M3, although the magnitude of the cost difference
between on-site processing is not large in this distance range.
The values of Mt and M3 are difficult to compute for general classes of wastes. They
depend strongly on the degree of preconcentration carried out on-site. This in turn is limited
by the composition of the individual waste, which determines how far preconcentration can
be carried without severe technical difficulties arising. Difficulties to be expected in
preconcentration include decomposition of chemicals in the waste with off-gassing or
precipitation, and scaling or corrosion of concentration equipment.
Estimates were made of the values of Mj for dilute heavy metal solutions and dilute
cyanides. The breakeven distance, Mt, is given by:
69
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c
pp
Acp~
where:
a is the ratio of final to initial volume in the preconcentration process.
Cpp is the unit cost of concentrating the dilute waste on-site.
is the unit cost, per gallon of dilute waste, of treating dilute waste minus the
the unit cost, again per gallon of dilute waste, of treating the concentrated
waste.
is the transportation cost per gallon-mile.
If the actual distance to the off-site facility is larger than M! , preconcentration is
economic.
To illustrate the situation, the values of Mj for several examples were computed. Using
the processing costs discussed in Chapter JL2 and the equations given above, it was found
that values of M! for dilute heavy metals with organics range from about 80 miles (129
kilometers) for the largest sources found in the field survey to about 120 miles (193
kilometers) at the mean size source. For dilute cyanide solutions, comparable value s of Mt
are 50 miles (80 kilometers) and 300 miles (483 kilometers).
The conclusion is that large sources relatively far (50-80 miles) (80-129 kilometers)
from the off-site facility might find it economical to preconcentrate their wastes prior to
shipment. Small sources would find preconcentration economical only if they were located
several hundred miles from the off-site facility. (Specific distances are dependent on the
nature of the waste and thus the treatment required.)
Another way to view the selected process for dilute metals (precipitation and burial) is
that the precipitation step is actually preconcentration. However, for each gallon of waste
the cost of sludge disposal is less than one percent of the costs for precipitation; therefore,
the latter in reality is the effective processing cost. Thus, the decision map for dilute heavy
metals, is also a decision map for a preconcentration step based on precipitation.
Configuration of Regional Processors
The decision map analysis also provides some insight into the optimal configuration of
regional processors for those wastes best treated off-site. While a detailed analysis of this
configuration is beyond the scope of this work, this report includes the preliminary result of
an analysis to illustrate the power of the model.
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The decision map for concentrated heavy metals is shown in Figure 3.2. The region
denoted OFF-SITE PROCESSING includes varying degrees of collection; for example, one
processing facility might best serve only a few sources, while under other conditions it might
best serve a hundred sources dispersed over a wide area. In general, the farther into the
OFF-SITE PROCESSING region one moves from the line separating the two regions, the
greater the degree of collection called for.
This dependence can be shown by drawing contours of constant area served by each
processing site in the OFF-SITE PROCESSING region of the map. The location of the point
representing mean source size and separation relative to these contours shows the optimal
configuration for a regional processor treating these wastes. For example, Figure 3.11 shows
that the optimal processor configuration for serving the sample of concentrated heavy metal
sources uncovered in our field work is one processing site for each 70,000 square miles
(181,300 square kilometers).
This quantification of regional processor configuration is preliminary, and more
detailed analysis is required for actual design of a network of processing facilities. Two
important factors should be mentioned:
(1) A complete survey of sources within an area is required for network design.
Adding to the sources in our sample decreases the mean separation between
sources, and, as the contours show, reduces the size of the area best served
by a single processing facility. The mean source separation is universally
proportional to the square root of the number of sources, so doubling the
number of sources in an area reduces the separation by a factor of 1.4 and
therefore reduces the optimal area served by each processing facility by
about the same factor.
(2) When large geographic areas are inventoried, variations in source density
(mean source separation) within that area should be considered.
Table 3.6 summarizes the result of the preliminary analysis of regional processor
configuration for the eight waste categories considered. The area served by each processor is
listed as "maximum" since more detailed analyses would probably reduce the area for
reasons described in (1) above. The corresponding separation between processing facilities is
also shown.
The results vary significantly by waste category, but in each case the separation
between processing facilities is more than 100 miles (161 kilometers).
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1,000
Source Size (liters per year)
378'400 3,784,000 37,840,000
t-a*M%i:v>ra<*xv>xvXw>:-x
-------
Waste Category
1. Concentrated Heavy Metals
TABLE 3.6
REGIONAL PROCESSOR
CONFIGURATION
(Preliminary)
Approximate
Maximum Area Served
One Processing Facility
(sq. miles) (sq. kilometers)
Spacing Between Processing
Facilities (miles)
70,000
181,300
(miles)
260
(kilometers)
419
2. Dilute Heavy Metals
ON-SITE
ON-SITE
3. Dilute Heavy Metals
with Organics
20,000
51,800
140
225
4. Heavy Metal Sludges, When
Encapsulated in
a. Asphalt
b. Concrete
5. Concentrated Cyanides
6. Dilute Cyanides
20,000
100,000
100,000
50,000
51,800
259,000
259,000
129,500
140
320
320
220
225
515
515
354
7. Liquid Chlorinated
Hydrocarbons
500,000
1,295,000
710
1,143
8. Chlorinated Hydrocarbon
and Heavy Metal Slurries
500,000
1,295,000
710
1,143
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LEGAL AND INSTITUTIONAL FACTORS
Introduction
The purpose of this phase of the program was to determine whether existing statutes
and regulations hinder the handling, treatment, and disposal of hazardous wastes and, from
that basis of understanding, to identify what legal powers, if any, need to be enacted in
order to ensure proper processing. This section first surveys and evaluates the framework of
existing Federal laws which would influence the alternative strategies, and then surveys
pollution control measures by various states; next it discusses questions of legal liability
relating to injury or damage resulting from handling and disposal of hazardous wastes;
finally, it outlines the major legislative needs for creating an effective hazardous waste
management system.
The conclusion, in brief, is that present Federal and state laws do not hinder the proper
handling of wastes; but with the exception of radioactive wastes regulated by the Atomic
Energy Act, neither do they encourage or require proper treatment and disposal. Legislation
is therefore needed to confer the authority to regulate waste treatment, to structure the
Federal-state partnership in this field, to require reporting and inventory procedures, to
specify standards and controls, to authorize a system of permits, and to authorize inspection
of waste handling, treatment, and disposal sites.
One must keep in mind the general distinctions among: (1) statutes, (2) administrative
regulations, and (3) agency practices. While most administrative regulations take on the
force of law, an important distinction remains between legislatively-enacted statutes and
administrative regulations. Administrative rules and regulations must fall within the bounds
of a statutory standard set by the legislative body. Regulations can be changed with relative
ease and speed, whereas statutes must await the more deliberate acts of legislatures. Both
statutes and regulations are, of course, subject to judicial interpretation and the test of
constitutionality; however, any regulation must remain not only within constitutional
bounds, but also within a statutory standard, however broad. Administrative practice and
behavior may have the same practical force of law for an affected party who cannot afford
time and/or money to challenge it in court. In summary, describing the legal framework in
hierarchical terms, the descending order of importance of the elements is: constitutional
provisions, statutes, regulations, and administrative practice.
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Federal Approaches to Abating Pollution
The Federal Government traditionally has left to the states the role of establishing and
enforcing air and water quality standards. When it has taken action, it has done so in two
ways. One has been to detect and deal with pollution after it has occurred. Although this is
clearly not the most effective strategy to reduce pollution, it has attracted the broadest
political support.
In general, the most effective statute has been the Refuse Act of 1899. This law has
recently been applied, thanks to broad judicial interpretation, to waste discharges of many
kinds. Its strength lies in three areas:
(1) It authorizes immediate court action, instead of allowing the long delays
characteristic of procedures under later Acts;
(2) Violators can be convicted even if pollution complies with water quality
standards; and
(3) Applications for discharge permits have to include data on composition and
volume of wastes.
The alternative method, to regulate polluting substances before they enter the environ-
ment, has not been pursued vigorously until recently. Although the Federal Water Pollution
Control Act (FWPCA) of 1965 stated a policy of preventing water pollution, its enforce-
ment powers applied only after pollution occurred; it relied on the states to set water
quality standards, but allowed the Federal Government to step in and set standards if a state
failed to do so.
Congress improved Federal strategy considerably with the landmark Federal Water
Pollution Control Act Amendments of 1972 (P.L. 92-500; 33 U.S.C. 1251-1376). This
amended, reorganized, and expanded FWPCA attempts to close many of the loopholes in
the existing statute as well as tighten Federal controls. Its important aspects regarding
hazardous wastes include:
extending pollution control, liability and enforcement provisions to haz-
ardous substances as well as oil;
extending Federal control to all U.S. waters;
setting up a permit system to replace the Refuse Act of 1899 with strong
regulation of industrial waste; and
creating effluent limitations backed by strong standard-setting and enforce-
ment provisions.
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Similarly, the proposed "Toxic Substances Control Act" would regulate substances
before allowing them to be marketed. This legislation was submitted by the President in
1972 and passed by the Senate, but died upon expiration of the 92nd Congress; it was
reintroduced after the 93rd Congress convened in 1973.
Several existing statutes confer powers to act before pollution occurs, for example, the
Clean Air Act (auto emissions regulations and testing), National Environmental Policy Act
(requiring an impact statement before beginning a project), Federal Insecticide, Fungicide,
Rodenticide Act (requiring registration and labeling before use), Food, Drug, and Cosmetic
Act (registration and labeling before use), Hazardous Substances Act (requiring labeling),
and Atomic Energy Act (total control of radioactive substances). The enforcement powers
of most of these acts, with the notable exception of the Atomic Energy Act, are weak or
non-existent Nevertheless, they do show Congress's concern for threats to the environment
and the general health. Another statute which proclaims an overall policy and authorizes
financial aid but confers no enforcement powers is the Solid Waste Disposal Act.
Federal authority is stronger in the field of transportation. Acts regulating carriage of
explosives and hazardous substances such as flammable liquids reflect both accidents and
public apprehensiveness about catastrophes on land, for example, from explosions of trains
carrying munitions or poison gas, and on water, for example, from oil spills. The Depart-
ment of Transportation administers five laws, for instance, the Hazardous Cargo Act, that
require proper packaging, labeling, reporting, and handling.
These laws and resulting regulations have provided models for similar requirements by
a number of states seeking to cope with at least the dramatic incidents which can occur with
hazardous substances. They reflect the psychological observation, reported in the discussion
of risks, that public consternation, and political support for regulatory action by govern-
ment, is aroused less easily by a series of minor accidents than by a major disaster. A court
test might lead to a ruling of Federal preemption in this field of law where both Federal and
state governments have interests.
These laws provide both a legal framework and a data base of administrative experience
in one important aspect of the handling of hazardous wastes. They both hinder unregulated
transportation of hazardous wastes in interstate commerce and facilitate orderly transpor-
tation by providing uniform national controls.
Turning to the less-than-dramatic aspects of handling hazardous wastes, several prob-
lems seem important. Some are common to intergovernmental relations in many fields. The
major one, of course, is whether Federal or state governments are more capable of ensuring
proper handling or, if neither is clearly best, what system of sharing responsibilities will
achieve the desired results. At one extreme is the radioactive substance model, in which
Federal Government, through the Atomic Energy Commission, exercises total control and
enjoys strong enforcement powers. At the other is the traditional model by which questions
of health and environmental quality were, before the 1960s, left largely to the states, which
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in turn often delegated them to local governments. But administrative necessity tends to
render these extreme models more theoretical than real: even the Atomic Energy Com-
mission, although it retains authority to set standards and monitor performance, delegates
operating responsibility to those states which qualify and desire it.
Some problems relate specifically to the technical characteristics of hazardous wastes.
Which of the several tools of control are most effective for dealing with them? The Federal
Insecticide, Fungicide and Rodenticide Act, the Hazardous Substances Act, and the Food,
Drug, and Cosmetic Act use labels to warn consumers of the dangerous nature of what they
are buying and using; but this warning protects neither the user from himself nor innocent
companions such as children. The issuing of permits, as in the Refuse Act, places the burden
of decision on the issuer and the holder of the permit rather than on downstream users of
water. Where in the "life cycle" of an individual waste, given its chemical characteristics, can
it be controlled most effectively? It may be impossible to prescribe a general rule other than
to control the substance, especially if it is a mixture of several chemical pollutants, before it
does any harm.
In the past, environmental protection efforts have been focused, for good reasons, on
only one medium at a time. But now, because of the variety of substances that may be
considered hazardous wastes, all three media water, air, and soil - must be protected. In
addition, the existence of hazardous wastes in all media must be inventoried: even though
the amounts in each medium may not be damaging when evaluated separately, their
cumulative and total effect may well be dangerous. What is the best standard or measure for
each substance, in each medium? The Clean Air Act provides that each substance be
assigned its individual standard within overall ambient air quality standards. Because of the
complexity of substances, this may be the best way, even if unwieldy, for other media.
Of the three media, standards and control methods for air are already being vigorously
developed under the Clean Air Act, and the water quality control will be substantially
upgraded by the FWPCA Amendment of 1972. But land, the ultimate sink for many
polluting wastes, including those discharged initially into air and water, remains unprotected
by comprehensive Federal or state laws. The next legislative frontier is to create authority to
regulate the use of land as the ultimate disposal medium for hazardous wastes.
Overview of State Pollution Control Measures
The Federal Government has traditionally relied upon the states to control air and
water pollution. In recent years, however, Congress has specifically directed the states to
establish air and water quality standards. Currently, all states have basic air and water
pollution control legislation; they have also developed or are in the process of developing
program strategies and plans.
While the specific provisions vary greatly from state to state, their laws have several
elements in common. Several states have specifically granted to individual citizens the right
to initiate lawsuits for the protection of the environment. Delaware, Maine and Vermont
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have developed statewide land-use controls, reflecting a definite trend of increased regu-
lation over use and development of land.
State laws and regulations may be classified broadly into a few categories. Water
quality laws have the longest history. Air quality laws, of recent origin, generally parallel
water laws in strategy. Solid wastes have received attention most recently from states,
although municipal governments have traditionally exercised jurisdiction over dumps and
sewers.
Water effluent standards, as required by the Federal Water Pollution Control Act, have
been promulgated by all states. Federal approval by the EPA has been granted for all but a
few states. States have approached the control of water pollution in various ways. One
common technique is to establish a permit system: 46 states, Pennsylvania and New Jersey
among them, have wastewater discharge regulations which require registration and the
issuance of a permit. Maryland has established a state-wide, state-level sanitary district
empowered to take over waste treatment functions which have been traditionally handled
by municipalities. Thirty-two states now provide tax incentives to private industry to
construct waste treatment facilities. The FWPCA Amendments of 1972, enacted over
President Nixon's veto in the closing days of the 92nd Congress, accelerates the drive to
improve water quality.
States have often lacked adequate powers to manage proper disposal of solid wastes.
Their traditional authority, based on general health and/or nuisance laws, controlled the
dumping of refuse on public and private property. But recent recognition of the magnitude
of the problem has made planning more acceptable. Many states have, with Federal financial
assistance, conducted statewide studies to develop recommendations for solid waste manage-
ment. Maryland, New Hampshire, and Pennsylvania have enacted legislation requiring local
governmental units to prepare comprehensive management plans. New York has carried out
a state-financed sewerage study covering the entire state on a region or county basis.
Concerning hazardous substances, almost all states have some regulations. Often, as in
Texas and California, they are modelled on provisions in the Code of Federal Regulations
and focus on the transportation of hazardous substances. In New Jersey and Pennsylvania,
large industrial states which have experienced dramatic spills and accidents, regulations
emphasize control of industrial wastes. California passed in 1972 a strong bill specifically
controlling hazardous wastes; the new law confers regulatory powers on the California
Department of Public Health, requires a listing of wastes, provides for supervision of their
handling and disposal, and provides civil enforcement procedures.
California's Water Quality Council adopted July 6, 1972, regulations to implement the
"State Policy for Water Quality Control." The Council strongly states (1) that treatment of
hazardous substances is part of efficient wastewater management, and (2) that treatment
must provide sufficient removal of hazardous substances to guard against adverse effects on
the water for beneficial and community use.
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New York's legislature recently passed a comprehensive act dealing with all aspects of
handling and management of "substances hazardous to the environment."
Some states have recently passed constitutional amendments establishing an "environ-
mental bill or rights," or comprehensive policy statements. These states have thus establish-
ed broad legal authority for dealing with all aspects of pollution, and the threat of pollution,
in any medium of the environment.
An important administrative trend is to reorganize those departments or agencies
which have had jurisdiction over pieces of the environment into "superagencies." These seek
to exercise comprehensive control over many aspects of pollution. Thirteen states already
have working environmental departments; two, New Jersey and Pennsylvania, are discussed
in Appendix E. There seem to be several reasons for these consolidations:
to create a strong regulatory agency which is visible and accountable, both to
other government agencies and to the general public;
to coordinate programs of previously separate, and sometimes competing,
agencies;
to improve both the efficiency and professional standards of environmental
programs;
to parallel consolidation of Federal agencies.
Despite these encouraging signs of progress, however, state governments still face basic
and persistent problems. A familiar one is severe shortages of appropriations to implement
environmental protection laws. The states generally still rank far behind the Federal
Government in matters of technical and administrative manpower, often because of un-
attractive pay scales. Officials are too often reluctant or unable to impose regulation on
politically-powerful polluters and land developers.
Legal Liability Issues
The major issues are two:
To what extent have statutory developments altered common law principles
relating to liability for abnormally dangerous activities?
Is the law in this area principally Federal, state or municipal?
Two areas of the law apply to disposal of hazardous wastes: torts and criminal law. The
only distinctions to be made for this purpose between tort liability and criminal liability
relate to the generality of interests affected and the remedies afforded by the law.
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The issue of tort liability is resolved in a civil action brought by a private plantii'f
representing his personal interest, whereas criminal liability is determined in an action
brought by a public official representing broad societal interests. The remedy in a tort
action is money damages that compensate actual harm done or an injunction to stop the
activity, while criminal liability results in a fine and/or imprisonment, often regardless of
whether any harm was done.
While there are some common-law crimes, the dumping of hazardous wastes is not one
of them. In the absence of statute, such dumping would not constitute a crime. This is true
whether the question is dumping per se or any harm that may result to property or person
as a consequence of such dumping.
A tort action could be brought by a private party basing the case on a number of
different common-law theories, or by a government agency pursuant to statutory authority
where such authority exists. A variety of Federal statutes, such as the Rivers and Harbors
Act of 1899, empower Federal officials to bring criminal actions against polluters. However,
it is probably fair to say that the basic law relating to collection and disposal activities, as
opposed to violations by industrial firms, is primarily a matter of state and local jurisdiction.
As a general rule the supervision of the removal and disposal of all types of refuse and waste
is an affirmative duty that is imposed and delegated by the state upon municipalities
pursuant to state statute. Primarily for reasons of governmental economy, local governments
have usually limited their collection and disposal activities to non-industrial wastes. How-
ever, basic jurisdiction over all waste collection and disposal usually remains at the local
level. There are likely to be a variety of state and local statutes assessing fines for dumping
violations; however, private harm is compensated through the particular jurisdiction's law of
torts.
When an industrial firm hires contractors to dispose of its waste, as is usually the
situation, the firm still must comply with local codes and regulations. In addition, some
states, such as New Jersey, regulate collection and disposal activities at the state level
through public utility commissions. There may be specific statutes setting standards for the
disposal of hazardous materials in some states, but that is probably not the rule. Where such
statute or local code has been violated during the collection and disposal process and
damage to life or property results, not only may fines be imposed but suit may be brought
by injured plaintiffs on a variety of tort theories. The suit may be based on a theory of
absolute liability, or negligence, or even nuisance. Most states would adhere to the rule of
law that one who by statute or by administrative regulation is under a duty to provide
specified safeguards or precautions for the safety of others is subject to liability to the
others for whose protection the duty is imposed for harm caused by the failure of a
contractor employed by him to provide such safeguards or precautions. Thus, an industrial
firm would be liable for harm done by his collector and disposer of hazardous wastes in the
event the contractor violates some statute or code during his operations. Where code
violation is involved, tort liability of the industrial firm is absolute.
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Even when no statute exists or has been violated, tort liability may be imposed on the
industrial firm in the event that his contractor has been negligent or creates a nuisance in the
process of collecting and disposing of the firm's refuse. This liability for the industrial firm
is present even when the industrial firm has specifically instructed the contractor to take the
necessary precautions.
If the collecting and disposing organization is a governmental organization, an added
complication is present. Under the common law doctrine of sovereign immunity, govern-
ments are exempt from suits except where they specifically waive such exemptions. At the
Federal level, the Federal Tort Claims Act would provide a mechanism for injured parties to
sue a Federal instrumentality that caused damage in the course of its disposal activities.
Similarly, a specific statute could provide such a right of action.
Statutes similar to the Federal Tort Claims Act have been enacted in certain states, but
courts must still often be creative in finding a theory which will allow private suits. The
theory often used is that a governmental agency which is engaged in an essentially business
activity, such as waste collection and disposal, has waived its immunity.
Perhaps the most pressing concern in the area of hazardous waste disposal liability
relates to insurance. Presumably, certain ultra-hazardous wastes could cause such extensive
damage that a private concern would be unable to compensate the victims. Some form of
pooled risk coverage or Federally underwritten coverage similar to flood and riot insurance
seems desirable.
Legislative Needs
The foregoing discussions of Federal laws, state laws, and liability issues lead to the
conclusion that no major statutory obstacles would hinder development of a hazardous
waste management system which includes central processing facilities. Some adjustments
would be required, of course, for example, in present laws regulating transportation of
hazardous substances; but these would not present insurmountable problems.
The need, instead, is to legislate the authority for creating, administering and enforcing
a waste management system. Whether the system consists of on-site treatment and disposal
by waste generators or shipment to off-site central processing facilities, the legal and
administrative needs are the same: Federal and state agencies must be authorized to regulate
hazardous wastes; they must develop and maintain lists to identify and classify wastes; they
must specify standards for controlling effluents if not the waste-generating processes
themselves; they must be able to require adequate record-keeping by waste generators and
to inspect treatment and disposal sites to ensure proper observance of standards; and
adequate judicial powers must exist to back the efforts of these agencies. States can and
should follow the example of California in enacting their own laws to address the hazardous
waste problem. But a Federal role is also required. The immediate need, therefore, is
Congressional action to demonstrate the Federal interest, especially in land disposal, to
establish the basic Federal approach, and to structure the Federal-state cooperative relation-
ship.
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RISK CONSIDERATIONS
Introduction
It is important to reiterate at the outset that in analyzing risks to society in the manner
described in Part 2 new ground is being broken. Thus, even though this work represents only
a preliminary study of the problem, the conclusions are useful in setting some estimates on
the magnitude of the problem. However it is recognized that such an approach for
quantifying risks could be improved upon, and could possibly become a powerful tool for
determining the acceptability of all types of risks that technology presents to society.
Part 2 and Appendix D treat the general methodology for arriving at the risks to which
society may be exposed during the transportation of hazardous chemical wastes and the
levels that appear to be acceptable for those risks that can result in human fatality. Within
the time limitations of this work, an acceptable level of water pollution was not derived,
although one approach that appears promising is suggested.
This section discusses the results and conclusions reached in assessing the risks of
transporting the various categories of wastes.
Risk from Fire
To evaluate the magnitude of the risk from fire to individuals along the route of travel,
the waste identified in Appendix B, Table B.2.H as H-l 1 which is essentially gasoline, was
used as an example. One million gallons are produced every year and trucked in 5000-gallon
(18,920-liter) trucks to a disposal site. This example was chosen because it provides the
worst condition.
Inspection of the risk equation shows that the length of the trip is immaterial. The risk
depends only on the probability of a spill for this mode of transportation, the probability of
a fire for a given spill, the number of trips per year, and the kill radius.
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For this example:
P(a) = 36 x 10"8 accident/vehicle mile
(22 x 10"8 accident/vehicle kilometer)
P(f/a) = 1 fire/accident (conservatively assuming that every
accident results in a fire)
R =185 feet (56 meters)
n = 200 trips/year
(1,000,000 gallons per year/5,000 gallons per trip*)
The calculated risk of transportation for this example is 4.5 x 10'M fatality/person-
hour exposure. This is lower by two orders of magnitude than Starr's suggested acceptable
level of 10"9 fatality/person-hour exposure and lower than the risk of dying in a flood (see
Table D. 1 in Appendix D).
Risk from Explosives
As indicated in Part 2, "off-spec" explosives are generally shipped in small quantities.
Although no explosive wastes were identified in the geographic region of concern, the risk
for an explosive shipment by truck was calculated. A kill radius of 500 feet (152.4 meters)
was used and this led to a calculated risk of about 10"1 2 n fatality/person-hour exposure,
where n is the number of trips per year along a certain route. Even if the explosions occur
100 times more frequently than accidents, this risk level is lower than the acceptable risk of
10"9 as long as the number of trips, n, is less than 1000 per year.
Risk from Toxic Gases
The risk of shipping CW agents was shown to be 8 x 10"12 n fatality/person-hour
exposure. This level would also be acceptable as long as n is less than 125 trips per year.
Risk from Polluting Wastes
The maximum volume of water that could be polluted annually from spills of typical
wastes containing heavy metals, cyanides or chloro organics (e.g., DDT) has been calculated.
The calculation was made using truck transportation and 5000-gallon (18,920-liter) ship-
ments. The results are shown in Table 33.
*3.9 million liters per year/18,920 liters per trip.
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TABLE 3.7
MAXIMUM VOLUME OF WATER THAT MAY BE
POLLUTED ANNUALLY DUE TO ACCIDENTAL SPILLS
Code Hazardous Waste
A-3 2-3% Sodium Arsenite
and Arsenate, 1-2%
Aniline in 10% NaCI
A-6 8.5% Chromic Acid
20% H2SO4 with traces
of Iron and Lead
A-9 14% Chromic Acid in
10-30%H2S04
B-8 5000 ppm Chromium,
IBOOppm Nickel
300 ppm Copper in
15% HCI-HF-HN03-H2SO4
E-1 7% Sodium Cyanide
2% Sodium Hydroxide
F-1 50 ppm Sodium Cyanide
1% Sodium Cyanate
F-6 7000 ppm Copper
Cyanide
G-1 30% DDT
Gallons/Year
6,000,000
66,000
520,000
3,600,000
300,000
120,000
200,000
20,000
Liter/Year
(xlO6)
22.7
0.25
1.9
13.6
1.14
0.45
0.76
0.08
Liters of Water
Polluted/Year
3.8 x 106
2.4 x 107
2x 10s
3.5 x 106
4x 10
1.5 x 106
1.5 x 106
1.2 x 10s
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In the absence of an "acceptable" level of risk for water pollution, these numbers will
have to be used to compare the relative risk between alternative sites or alternative
transportation schemes. Eventually, when a more realistic acceptable level of pollution is
determined a more meaningful description of an acceptable level for water pollution can be
derived. It is felt that this area is worthy of further study.
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4".':! P^^a'jtiori Agency
LIL:-.-.. . , -;i:-:i
1 l
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