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cost of capital, the resulting offset would be only a small percentage of
total annualized costs. One problem in dealing with this offset should
be noted however. If real interest rates are significantly below those
used to calculate fund size, the government may need to retain all of
the fund or even ask for additions to it in order to insure that adequate
funding remained for expenditures other than insurance.
G. Ownership Requirements
RCRA §3004(6) calls for the issuance of such regulations of
ownership requirements as may be necessary or desirable. It is
a commonplace response of individuals and organizations , exposed to
high risks of potential liability, to attempt to shield some or all of
their assets from potential claimants. So, for example, it is a widely
held belief that police officers regularly transfer all their assets to
other members of their families to defeat attachment process arising out
of claims of false arrest or official misconduct. Suspicion of a plan
to accomplish a similar result underlay the unsuccessful Federal criminal
prosecution of Allied Chemical Corporation for alleged conspiracy to
avoid liability in setting up Life Sciences Corporation of Hopewell,
Virginia, to manufacture the pesticide, Kepone. At least one of the
major hazardous waste disposers currently in operation utilizes an
extremely complex set of interrelated subsidiaries in operating an
essentially unitary integrated business. Different sites are owned by
different subsidiaries. A special subsidiary owns and operates most of
the vehicles. Another subsidiary, with no significant assets of its
own, conducts the actual operations. There is no implication of inten-
tional misconduct. The organization exercises a high degree of care and
advanced technologies in its operations and has an excellent reputation
with EPA. Nevertheless, there is at least ground to infer that the organi-
zation seeks to partition its assets in such a way as to give some protection
in the event of catastrophic loss.
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The possibility of such a structure being adopted as part of an
intentional pattern of misconduct was also raised in the course of
several interviews. Two insurance industry representatives from New
Jersey reported that in that State, the waste management industry generally,
and the hazardous waste management industry in particular, included firms
affiliated with organized criminal activities. Whether these reports
were reliable or not, the possibility still exists that individuals
entering the hazardous waste disposal business might meet permit require-
ments for closure and post-closure planning without intending to carry
out the required plans. Such permit holders might contrive to harvest
the profits from active stie operation while making preparations to
transfer these profits and to abandon the site, as soon as the site was
filled to capacity.
A second problem associated with ownership is the possibility
that a waste disposer might utilize a rented site over which he would
have no authority after termination of his lease.
For the foregoing reasons, it would appear that requirements
preventing the insulation of corporate assets from claimants and ensuring
the government the opportunity to gain access to a non-complying site,
may be necessary or desirable. The most straightforward regulation to
achieve that end would be a requirement that the organization obtaining
the permit own all of the land used for waste disposal outright, as in
"fee simple" as well as the assets in cash, buildings, vehicles and
facilities used in the operation for which the permit is issued. In the
alternative, where a permit holder chooses to lease equipment or buildings
or otherwise to make use of assets not the property of the permit holder,
it would be required to file proof of financial status showing current
net assets in excess of the value of the rented utilized equipment or real
estate, or a guarantee in a like amount of an affiliated corporation able
to make such proof of financial status. Under such circumstances it
should also be required to show that its authority to control and have
access to the land will extend beyond the biologically active life of the
wastes to be disposed of on the land.
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"Fee Simple" is a term denoting unqualified ownership of land;
unlimited as to duration. It distinguishes land held outright by a
single owner and subject to disposition by at his sole discretion from
land that is held under lesser forms of ownership or possessory right such
as a lease, ownership by a trustee in trust for another, occupation by a
life-tenant of property in which the remainder interest passes to another
at the life tenant's death, or tenancy-in-common or joint tenancy with
others.
In general, the requirement that a permit holder own land in
"fee", "fee simple" or "fee simple absolute" does not mean that it cannot
be mortgaged in most states. Originally, under its common-law interpreta-
tion, a mortgage required a conveyance of legal title in the land to be
mortgaged to the lender. The borrower, or original owner, retained only
an equitable right to compel a re-conveyance of legal title back to him
when he paid off the debt. Today, in most jurisdictions, positions are
reversed. The borrower keeps legal title to his land when he mortgages
it, but the lender gets a security interest or lien upon the land that
can be legally enforceable.
The possible requirement that permit holders own land in fee sim-
ple is not intended to prevent permit holders from mortgaging their land
but to ensure that the permit holder has absolute control over disposition
of the land and so can place enforceable restrictions on the potential
buyer of his closed'site.
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Chapter III
CONTINGENCY PLAN STANDARDS
A. Introduction
Section 3004 (5) of RCRA requires owners of hazardous waste
management facilities to develop contingency plans for effective action
to minimize unanticipated damage from the treatment, storage or disposal
of hazardous wastes.
This chapter sets forth possible contingency plan standards,
the associated relative costs that would be incurred by owners and oper-
ators of hazardous waste facilities, and various strategy options for the
implementation of these standards.
Contingency plans are formulated in advance of emergency situ-
ations that could occur at a hazardous waste management facility. The
standards against which proposed contingency plans are to be measured
are presented in Part "C" of this chapter. The approach used to develop
them is explained in Parts "B" and "C". Although there is a general lack
of literature on contingency plan standards, the Nuclear Regulatory
Commission (NRC) has addressed the problem in developing such standards
for use in handling nuclear wastes and has set forth comprehensive
contingency plan standards. The contingency plan standards presented
here have been grouped into the same general categories used by NRC:
organization, communication, assessment and response/recovery.
The proposed standards and associated costs are based on
scientific and engineering judgement and employ best estimates of present
day costs incurred in the establishment of such standards.
Before the standards could be written, an evaluation and inte-
gration of all facility, event and waste types had to be made. Part
B summarizes this procedure. Once all possible facility-event-waste
groupings had been developed, appropriate contingency plan standards were
written. Associating the various standards with the facility-event-waste
groupings highlighted certain conclusions. Specifically, all standards were
found to be virtually independent of hazardous waste type. Standards
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are directly related to the environment (i.e., atmosphere, subsurface
water, etc.) into which a given release occurs. Although some standards
relate more to specific events such as fires and explosions, the majority
of standards apply "universally" to all facility-event-waste groupings.
After the contingency plan standards were completed, relative
costs for implementation of the standards were developed. These are
costs incurred by the owner for necessary measures or actions required
in the event of hazardous waste release. The relative costs incurred
are dependent on facility type, size and annual production. The two
general facility types addressed are incinerators and landfills.
Four sets of strategy issues to be resolved before implementing
contingency plan standards were examined to determine the advantages and
disadvantages inherent in each strategy.
Finally, three sets of contingency plan standards were selected
and an overall evaluation of each set was made with regard to its advan-
tages and disadvantages. The three sets were intentionally chosen to
present a wide range of possible alternative standards.
B. Evaluation and Integration of Facilities, Events, and Waste Types
The procedure employed in the development of contingency plan
standards was a detailed review of all pertinent literature and avail-
able data concerning hazardous waste management facilities, an identifi-
cation of the conceivable events (including natural disasters) that
could occur at such facilities, and an examination of the various hazardous
waste types that have been or are being treated, disposed of, or stored
at such facilities. An effort was made to identify by this procedure all
possible combinations of facility, event and waste types.
Appendices 3, 4, and 5,'on facilities, events and wastes,
respectively document the results 'of these investigations and elaborate
on the procedures used in arriving at the results. Summaries of these
findings are presented here.
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1. Facilities
Available information on hazardous waste management techniques
and present technology indicates that only certain disposal facilities
or final treatment methods can provide effective treatment, storage or
disposal of hazardous wastes, without having adverse effects on the
environment. Thus, only those disposal facilities or final treatment
methods likely to be deemed suitable for the treatment, storage
and disposal of hazardous wastes were evaluated. Disposal
facilities include landfills, incinerators, deep well injection, waste
lagoons or ponds, land burial at depth, near-surface land burial and
above surface storage. Final treatment processes include oxidation/
reduction, neutralization, chemical degradation, detoxification, open
burning, detonation, hydrolysis, biological degradation, and resource
recovery.
Landfills
Landfills that may potentially hold hazardous wastes are termed
secure landfills. These must isolate their contents from the environment,
without compromising air and water quality. Other types are approved
landfills, in which inert solid wastes and decomposable organic materials
must be separated from underlying or adjacent usable water; and general
landfills that can contain water along with the wastes. Sites fully
meeting the specifications for secure landfills will be extremely limited
under certain geologic and hydrologic conditions.
Incineration
Incineration is a controlled process that utilizes some type of
combustion/burning process to convert a waste to less bulky, less toxic,
or innocuous gas, liquid and/or solid. Incinerators can be used to
dispose of combustible solids, semi-solids and concentrated liquid wastes.
In general, carbon dioxide, water and ash (of various compositions) are
the major constituents of incinerator products. When the combustion
141
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product contains undesirable compounds such as toxic hazardous waste
gases (i.e., hydrogen cyanide), additional treatment such as after-
burning, scrubbing, or filtration is necessary. Subsequently, the solid
and liquid effluents, for example toxic inorganic oxides, are either
treated further or disposed of at a hazardous waste facility, such as a
secure landfill. In some instances, by-products, such as hydrogen
chloride or lead slag, are recovered during the incineration process
and recycled.
Deep Well Injection
Subsurface disposal of liquid wastes (deep well injection) has been
practiced for many years. The mining and oil industries have used deep wells
for the disposal of oil field and chemical brines. The major industries that
dispose of hazardous wastes by deep well injection today include the chemical,
petrochemical and pharmaceutical industries. These industries inject solvents,
corrosives, heavy metals, pesticides and other hazardous wastes as liquids,
which usually are pretreated prior to disposal. Injection wells in the United
States generally range in depth from 1,000 to over 12,000 feet (Warner 1973).
Treated wastes are injected by gravity flow or under pressure into subsurface
strata that contain non-potable brackish or briny waters. Receiving strata
must be bounded above and below by confining strata, such as clays and shales,
to preclude any migration to and eventual contamination of potable water supplies,
The composition of the hazardous waste is usually altered by pretreatment
processes to insure that the wastes are compatible with the existing waters and
subsurface environment, thus minimizing the possibility of clogging the in-
jection zone. Inasmuch as earlier laws focused on the potential pollution of
surface waters and only indirectly addressed the problem of ground-water pol-
lution, disposal by deep well injection has gained in popularity among waste
generators. However, deep well injection is likely to be deemphasized in favor
of incineration and secure landfills under the new EPA RCRA standards.
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Haste Lagoons and Ponds
Waste lagoons and ponds can consist of small concrete tanks or large
excavated basins several acres in area. If a natural impervious material is
absent at the base of the excavation, the larger facilities must be lined with
relatively impermeable natural or synthetic liners such as clay, asphalt,
concrete, or plastic to preclude the migration of hazardous wastes to the sub-
surface environment. Also, routine monitoring and detection systems such as
wells, usually need to be installed along with diversion structures (trenches,
berms, etc.) to intercept surface water runoff from surrounding areas.
Ideally, lagoons and ponds are located in geographical areas
where favorable climatic conditions prevail. Such areas include those where
evaporation rates are high and precipitation is low. The organic chemicals,
pesticides and tannery industries are some of the major industries that dispose
of hazardous wastes in various sizes and types of lagoons and ponds
(EPA, 1976f; 1976k).ftt
Near-Surface Land Burial
In near-surface burial, the hazardous waste is placed directly into
the ground or is deposited in a variety of stainless steel tanks, concrete
lined pits or a combination of these devices beneath the ground (Powers,1976).
Although the hazardous wastes can be in a liquid or solid form, generally
prior to burial, the wastes are converted to a solid form (i.e. by cementation,
solidification, etc.) to reduce the mobility of the hazardous wastes in the
subsurface environment.
Presently, near-surface burial of various hazardous wastes from the
chemical industry is being conducted at several sites.
Various types of monitoring devices are installed, depending on the
type of hazardous waste, to detect any leaking or leaching to the subsurface
environment. Trenches are usually equipped with drains and pumps to capture
potential leakage.
T References for Chapter III are listed at the end of the Chapter.
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Land Burial at Depth
Burial in deep subsurface openings is not widely practiced.
Serious consideration is being given to this method, especially for radio-
active wastes.
Above-Surface Storage
Small quantities of hazardous wastes might be stored in tanks,
vaults or other containment devices, on or above land surface, until the
wastes are collected and transported to another type of hazardous waste
disposal facility. These wastes might include highly toxic organic
chemicals and pesticides or lethal gases that may eventually be disposed
of at other hazardous waste facilities, such as deep injection wells or
incinerators.
Final Treatment Processes
In this report, a "final treatment" process is defined as one
which alters or destroys hazardous wastes completely, leaving only innocuous
substances whose by-products do not adversely affect the environment. The
wide variety of treatment processes provides a broad range of treatment
capabilities for the numerous hazardous waste types generated by industry.
For the most part, these processes are performed by hazardous waste genera-
tors and often are incorporated directly into the processing plant system.
2. Events
The purpose of this section is to describe a classification of
accidents or events whose occurrence at hazardous waste treatment, storage
or disposal facilities might require emergency response measures. In this
report, the words "accidents" and "events" are synonymous. Only events
which relate directly to confirmed releases are considered. Natural disaster
warnings, (e.g., for tornados and hurricanes, etc.) will be covered under
RCRA §3004 operating plan regulations, not under contingency planning. A
more detailed discussion of the events classification is presented in Appendix
4.
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Non-routine Liquid Release
Liquid releases are divided according to cause of release
(i.e., event subcategories): seepage, failure, or personnel error.
These three groups are then further broken down into surface and subsurface
groups since detection and response for these two types of release will
differ significantly.
Non-routine Solid Release
Non-routine solid releases can occur at any hazardous waste
facility that treats, stores or disposes of wastes in a solid phase,
such as "dried" chemicals, explosives, sludges, etc. Typically, these
releases would result from improper handling or breakage of containers
used in the transport of these waste types within facility boundaries.
Additionally, wind erosion is a mode of solid release.
Non-routine Gas Emission
This class of events includes ncn-rcutine emissions from
incinerators, reaction products from the improper mixing of reactive
wastes, failure of gas storage vessels and other accidental gas releases.
Non-routine gar, emissions can occur in both the surface and subsurface
environments depending on the facility type.
Fire
Fires can best be classified along the guidelines established
by the National Fire Protection Association Standard Number 10, described
in Appendix 4.
Explosion
Explosions can occur in both the surface and subsurface environ-
ments according to facility type.
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Dike Failure
While the class of events described by the term dike failure
could be included in the category of non-routine liquid releases, dike
failures represent a common and specific type of accident of potentially
serious magnitude and, therefore, merit separate consideration. Dike
failures can result from either natural causes, or from improper design
and construction.
Direct Human and Animal Contact
These exposures can occur as the result of non-routine liquid
and gas releases, and also in the course of routine operations. For
example, a worker might accidentally step or fall into a disposal trench
containing highly corrosive wastes. The potential for contact with
hazardous wastes exists at every type of facility.
3. Hazardous Wastes
This section defines the hazardous waste category system developed
for this study. The classification system has been devised so as to address
comprehensive all conceivable waste types, i.e., it is capable of
representing any type of existing or future hazardous waste stream. In
addition, the classification presents the waste categories in a way which will
relate meaningfully to contingency plan standards after incorporation with .
facility/event pairings.
In general, existing waste classification schemes fall into one of
four general categories:
1) classification of wastes by source
2) classification of wastes by disposal method
3) classification of wastes by chemical properties
4) classification of wastes by associated hazard.
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For the purposes of developing standards for contingency plans,
the following waste classification scheme was adopted. A complete dis-
cussion of the logic and rationale behind the development of the hazardous
waste categories is presented in Appendix 5.
Flammable/Explosive Vapor
This category is reserved for gases and vapors which are
flammable and/or explosive. In addition, it is applicable to liquids
(or solids) which are extremely volatile and give off flammable/explosive
vapors.
Flammable Solids/Liquids
This category is reserved for liquids, solids, sludges, slurries,
etc. which are flammable.
Explosive Solids/Liquids
This category is reserved for solids, liquids, sludges, slurries,
encapsulated or contained gases, liquids, etc. which may present an
explosion hazard.
Bioconcentratives
This category is reserved for substances which may concentrate
in a single species or through a series of species (plant or animal) in
the human food chain to a level, above the ambient level, which are
toxic or injurious to humans.
Corrosives
This category is reserved for substances which are corrosive
to equipment, structure, containers, etc. which are likely to be found
in hazardous waste facilities or which may be used at such facilities
during emergencies.
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Reactives
This category is reserved for substances which tend to react
spontaneously in a hazardous way with common materials. Included in
this category are substances which may undergo synergistic interactions.
In this definition the term "hazardous way" means that the substance may
react so as to produce any of the following effects:
a. violent reaction (spewing reactants)
b. rapid heat generation
c. generation of hazardous products
The term "common material" would include:
a. air
b. water
c. structural metals
d. other construction materials
Radiological
This category is reserved for materials which spontaneously emit
ionizing radiation to the environment. This includes radionuclides and
materials contaminated with radionuclides. It does not include materials
covered by NRC regulations.
Environmental Hazard
This category is reserved for substances which pose a threat
to the environment. . This would not include the hazards of fire, explosion
or radiological materials, nor would substances producing adverse effects
on humans alone can be classified as environmental hazards. The emphasis
of this definitional category is on materials with special effects on
plants, crops, fish, shellfish, livestock, etc. and on those at higher
levels in the food chain.
In addition, materials which might effect the structure, function,
etc., of non-living objects in such a way that it may cause harm to plants,
animals, or humans would be classified as an environmental hazard.
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Airborne Health Hazard
This category is reserved for substances which may be transported
via the air and which pose a health hazard to humans. This health hazard
would not include the normal hazards associated with fires, explosion or
radioactive materials. Hazards which would be included are:
a. inhalation toxic
b. dermal penetration toxic
c. irritating
d. sensitizing
e. etiologic
f. carcinogenic
g. mutagenic, teratogenic, etc.
h. ingestion toxic (applies to materials which might settle
on the surface of plants which are subsequently eaten).
Waterborne Health Hazard
This category is reserved for substances which may be transported
via water, in solution, suspension, or by flotation, and which pose a
health hazard to humans. This health hazard would not include the normal
hazards associated with fires, explosions or radiological materials.
Hazards which would be included are:
a. ingestion toxic
b. dermal penetration toxic
c. irritating
d. sensitizing
e. etiologic
f. carcinogenic
g. mutagenic, teratogenic, etc.
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Contact Health Hazard
This category is reserved for substances which may be transported
via direct contact and which pose a hazard to human health. The direct
contact might be via fallout from an explosion, splash from or contact
with a spill, or mishandling of materials. The normal hazardous effect
associated with fires, explosions, or radiological materials are not
considered under this category. Hazards which would be included are:
a. dermal penetration toxic
b. irritating
c. sensitizing
d. etiologic
e. carcinogenic
f. mutagenic, teratogenic, etc.
Unknown
This category is reserved for materials whose compositions or
properties are unknown. An example of an UNKNOWN hazard would be an
unlabeled (perhaps due to corrosion or negligence on the part of an
operator) drum of material which is in close proximity to a fire at
a hazardous waste disposal facility.
As previously mentioned, at the time of this study EPA had not
promulgated regulations defining what its hazard categories will be or
what degree of danger will be necessary before a substance would be defined
as "hazardous" Until threshold values are specified by regulation, it will
be necessary to define waste categories in qualitative terms only.
4. Integration of Facilities and Events
In carrying out this study, a matrix (Integrate I shown in
Figure 4) was used to correlate all possible facility types with all
conceivable events to assess the applicability or non-applicability ("NA")
of each facility/event pairing. All pairings considered possible were
150
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examined in the subsequent analysis. Furthermore, by inspection, certain
subcategories of events and facilities (e.g., classes of fires) were
grouped and have been represented below as general categories.
Examples of the approach used in forming general categories
and in eliminating from consideration the non-applicable pairings are
discussed below:
Non-routine Liquid and Solid Releases
Surface failures and seepages onto the surface of liquid
hazardous wastes are by definition unlikely in underground hazardous
waste facilities (i.e., land burial facilities) and are indicated accord-
ingly as being non-applicable. However, some surface facility types
such as lagoons and landfills, etc., can experience liquid releases
induced by either structural failures or natural geohydrologic conditions
which might affect both the surface and subsurface environment. Similarly,
both environments could be affected by leaks or breaks in tanks, vaults
or pipe lines used in final treatment processes and in above-surface
storage facilities.
Also, Integrate I shows similar conclusions in the subcategories
of landfills and incinerators listed regardless of the event type. These
two groups are further considered in Integrate II (Figure 4), which
will correlate specific event/facility types with hazardous waste types.
Non-routine Gas Emissions
Non-routine gaseous emissions can occur both above ground and
in ,the subsurface environment depending on the facility type utilized
for the disposal of hazardous wastes. Generally, hazardous wastes in
a gaseous form are treated, stored or disposed of at a facility as a
primary hazardous waste (i.e., chlorine gas, etc.) or are created as
a secondary product of a particular facility treatment process or chemical
reaction. A non-routine gaseous emission from hazardous wastes buried
152
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at depth or in a near-surface land burial facility is considered highly
unlikely because of the types of hazardous wastes that are usually stored
or disposed of in these facilities (i.e., liquid and solid wastes).
Gaseous emissions normally occur at or above land surface.
All facility types have the capability of releasing hazardous wastes in
the gaseous state, depending on the hazardous waste type being
processed.
•
Fire
Fire would appear to be one of the most common events likely
to occur at hazardous waste facilities. Figure 3 indicates that the
applicability of the N.F.P.A. classes of fires is similar for each
facility type, suggesting the grouping of all fires under a single
event category would be adequate for future comparisons.
Explosion
In general, serious consequences due to explosions will
apply to surface facilities, threatening the lives of employees and
creating fires which could spread to other areas in the vicinity of
the explosion. In addition, the possibility of subsurface explosion
exists in the inadvertent mixture of reactive hazardous wastes in man-
made subsurface storage structures such as silos, tanks and vaults and
in natural cavities in geological formations. The proper design of
facilities and hazardous waste identification should greatly reduce the
possibility for this type of accident.
Dike Failure
The most commonplace events cited and documented for particular
facilities, whether due to natural disasters, improper design or human
error, include dike failure, surface-seepage and subsurface leakage,
usually resulting in non-routine rel'eases of liquids to the surface or
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subsurface environment. Figure 4 indicates that these particular
events are directly related to certain facility types. For example, the
possibility of dike failure exists at a hazardous waste landfill. A
dike failure is not applicable at all facilities listed, but would
commonly be associated with landfills, lagoons and ponds. However, in
certain cases, similar backup systems (i.e., dikes or berms) are employed
at other facility types. The release of hazardous liquid wastes after
a dike failure is defined as a "non-routine release." A dike failure
not associated with a release would be repaired in accordance with
operational procedures. Only when the dike failure is associated with
a release event would control and repair of the dike be covered by
contingency plan standards.
Direct Human and Animal Contact
The matrix in Figure 4 indicates that direct contact by
wildlife or humans is conceivable in nearly all cases. Obviously,
mechanized hazardous waste disposal operations (i.e., deep burial) or
enclosed facilities would limit the possibilities of direct contact by
wildlife or humans. Access to certain types of facilities such as
incinerators, and deep burial sites could also be minimized by proper design
specifications. However, facilities such as lagoons, ponds and landfills
could be vulnerable to intrusion from contiguous populated areas. Wild-
life, especially from adjacent wilderness areas, would often have access
and therefore a risk of exposure to these areas.
Causes of Events
Some causes of the aforementioned events are notable. For
instance, any major natural disaster, such as an earthquake, tornado,
hurricane or flood, will always have some type of adverse effect(s) on
those facilities which operate at land surface (i.e., incinerators,
landfills, etc.). Any natural disaster could conceivably damage a
facility, resulting in the release of hazardous wastes. Actions taken
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in response to warnings of natural disasters are covered by operational
plan standards. Releases resulting from natural disasters would fall
into one or more of the categories described above and responses to such
releases would be dealt with under contingency plans.
5. Integration of Hazardous Wastes with Facilities/Events
All applicable facility/event pairings were correlated with the
various hazardous waste types to assess the applicability or non-applicability
of each facility/event/waste grouping (Figure 5). As in the case of
the integration of facilities and events, groupings became evident. This,
together with the non-applicability of some pairings, reduced the number
of possible facility/event/waste combinations. The contingency plan
standards were developed using this integration.
Examples of the approach used in the elimination and grouping
of the combinations follow.
Events Applicable to All Facilities
First, those events which are independent of the facility type
were considered and related to all hazardous waste types; special cases
where events and facilities are dependent on one another were then
examined.
Figure 5 shows some general trends in comparing facility/event
types with hazardous waste types. It is conceivable that any of the
hazardous waste types, with the exception of those classified as
flammable/explosive vapors and airborne health hazards,could reach the
environment in the form of non-routine liquid or solid surface release.
Similarly, there is no apparent correlation between waterborne health
hazards, liquid or solid explosives or liquid or solid flammable wastes
with an event such as non-routine gas generation at the surface. All
other waste types, however, could conceivably be related to or occur
in the form of a non-routine gas generation (i.e., corrosives, reactives,
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contact hazards, etc.). If a non-routine gas generation did occur at
a facility, it would be characterized by one of the other hazardous waste
types listed.
Figure 5 indicates that there are inherent differences between
the events of fire and explosion even though these events often occur
concurrently at hazardous waste facilities. In the event of an explosion,
corrective measures would obviously have to be taken regardless of the
facility or hazardous waste type. Any of the various types of wastes
could enter the atmosphere, surface and/or subsurface water environments
depending on the severity or magnitude of the explosion. On the other
hand, in the event of a fire, the applicability of hazardous wastes such
as bioconcentratives, corrosives, reactives, radiological and waterborne
health hazards is not directly apparent. Normally, these types of
wastes would not enter the environment as gaseous emissions which would
be released during a fire. However, the remaining hazardous wastes
(i.e., flammable vapor, contact hazards etc.) could very likely reach
the environment if a fire were to occur.
Direct human contact with hazardous wastes at any facility is
always applicable (see Figure 5 ) regardless of the hazardous waste type.
Existing definitions of the term "hazardous waste" imply that pre-
cautions and measures must be taken to minimize the possibility of direct
human contact with any hazardous waste. Also, responses would vary
greatly in the event of direct human contact, depending on the hazardous
waste type contacted.
Events Dependent on Facility Type
Deep-Well Injection
At certain facilities, events could occur in ways directly
related to the facility type. One of these events, not addressed in
the previous sections, is non-routine subsurface liquid relearse. • In
the specific case of a deep injection well, the non-applicability of
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introducing hazardous wastes in the vapor state is apparent. Another
event type that could occur at a deep well injection facility is an
equipment malfunction. For the most part, the applicability of equip-
ment malfunction is related to all hazardous wastes, excluding flammable/
explosive vapors, and airborne health hazards, whose inapplicability was
discussed above. It is conceivable that a contact hazard, as defined,
could have adverse effects if an equipment malfunction occurred at or
near land surface. Furthermore, any equipment malfunction including a
well blowout, casing failure, pressure loss or pipe failure, could
result in a non-routine surface liquid release. Therefore, appropriate
corrective actions should be included in that event category. These
actions will be discussed in later sections.
Landfills, Lagoons, Near-Surface Burial and Burial at Depth
Figure 5 indicates that the non-applicability relationships
between waste types and non-routine subsurface liquid releases at other
hazardous waste facilities, including landfills, lagoons, near-surface
burial and burial at depth, is similar to that discussed above for a
deep injection well facility. An exception, however, might be radio-
logical wastes; pertinent literature indicate that it is a common practice
to store or dispose of radioactive wastes at burial facilities located
near the surface and at depth. Also, it is conceivable that in the
event of a non-routine subsurface liquid release, airborne gaseous emis-
sions could be created indirectly because of a change of state in the
waste as it reached the land surface. Because it would be very difficult
to detect a subsurface gaseous emission before it migrated to the surface,
examination of remedial actions will focus on the primary event, a non-
routine subsurface liquid release.
Equipment malfunctions are a common occurrence at landfills,
lagoons, ponds and burial sites and must be addressed. Figure 5
indicates that an equipment malfunction at that facility type is
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applicable to all hazardous waste types. A wide variety of equipment
is utilized depending on the facility types. More importantly, these
facilities are used to treat, store and dispose of a wide variety of
hazardous waste types. Many types of hazardous wastes may be present
in a particular landfill facility. For this reason, an equipment
malfunction at any of these facilities theoretically could cause the
release of virtually any hazardous waste type to the environment and
specific measures would have to be undertaken to mitigate potential
adverse effects depending on the hazardous waste type.
Incinerators
Some hazardous waste facilities, especially incinerators and
other process-intensive final waste treatment techniques, rely extensively
on equipment, mechanical or electrical, to store, transmit or process
the wastes. Because of the numerous operations and functions at these
hazardous waste facilities, the occurrence of an equipment malfunction
is more probable as compared to facilities such as landfills and lagoons.
Several types of incinerators are used to dispose of hazardous
wastes in a liquid, solid or gaseous form. The equipment needed to handle
these wastes will vary. Presently, incineration is a major technique
used for hazardous waste disposal. Theoreticially, most hazardous waste
types can be reduced in volume or disposed of by this method; however,
in practice, high costs of fuel, power and air quality standards prevent
the use of incinerators for many wastes. Most hazardous waste types are
disposed of in a more cost-effective manner at other types of facilities.
Figure 5 shows that almost all of the hazardous waste types
could be released to the environment in the event of an equipment
malfunction.
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Final Treatment Process
Some industries that generate hazardous wastes dispose of or
contract out for disposal by means of various final treatment processes.
These processes effectively degrade, alter, destroy, or completely
recover hazardous wastes. Detoxification, detonation and chlorination
are a few examples of final treatment processes that effectively elimi-
nate some wastes so that they will not detrimentally affect the environ-
ment. Usually, chemical industries incorporate final treatment processes
directly into the production system to treat hazardous wastes, thereby
reducing the wastes to innocuous by-products which can be disposed of
by conventional methods (i.e., sanitary landfill, etc.).
Figure 5 indicates that all hazardous waste types with the
exception of radiological wastes, can be treated at least partially by
some final treatment process. The complicated mechanical and electrical
systems and equipment used to convey, alter and finally produce chemical
substances increase the opportunity or probability of an equipment mal-
function. Because of the large variety of equipment, plant location and
possible paths to the environment, each final treatment process and
hazardous waste type must be evaluated separately to determine appropriate
measures that must be taken to correct a possible release of the waste
to the environment.
The analysis of the facilities, accident events, and hazardous
wastes that characterize the hazardous waste industry is reported here
in considerable detail to demonstrate the wide variation on a site-by-
site basis that can be expected in the contingency plan needs of the
industry. In recognition of this, contingency plan standards were put
forward that are basically applicable to all sites," while flexible
enough to permit major site variations to be incorporated into the
implementation of the standards at each site. Contingency plan standards
are discussed in the following section.
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C. Contingency Plan Standards
Introduction
The material in Sections A and B describes the reasoning used to
develop the facility/event/waste matrix. This matrix is displayed in
Figure 5. Once the applicability or nonapplicability of each facility/
event/waste intersection was determined, contingency plan standards were
developed which could be applied to one or more of the applicable matrix
intersections.
Several approaches were used to develop the contingency plan
standards. First, a thorough literature search of federal agency guidelines
and industrial guidelines in the private sector was undertaken. Only the
Nuclear Regulatory Commission (NRC) guidelines presented detailed contin-
gency plan standards. Other general standards were identified. In this
manner independent sources of standards were used to adopt contingency
plan standards where applicable. These standards were helpful in develop-
ing organizational and communication standards, as well as some assessment
standards.
Secondly, random groupings of potential contingency plan stan-
dards were found in literature for certain industries which more or less
applied to specific accidents (events) such as fires, oil spills and
releases of noxious gas. Wherever an association between these varied
standards and the matrix could be seen, specific standards were incor-
porated or modified to fit the given situation. For example, it is very
likely that a standard regarding actions in case of fire at an industrial
plant may apply in the event of a fire created by release of a specific
hazardous waste at a particular facility. Standards of this type found
through the literature search were very helpful in determining assessment
and response/recovery standards.
The third approach used in developing contingency plan standards
was directly dependent on and related to specific matrix intersections.
Individual intersections or similar groups of intersections were chosen
that might be associated with certain general contingency plan standards.
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Separately a listing of general contingency plan standards was developed
which encompassed several of the more obvious events and hazardous waste
types. For example, when dealing with flammable or explosive wastes
certain standards would apply regardless of the facility type. In addi-
tion, the more unusual types of events or hazardous waste types found at
certain facilities were addressed on an individual basis. The standards
in these cases were written keeping in mind a specific intersection being
evaluated. For example, the accidental release of bioconcentratives while
buried at depth might necessitate separate contingency actions which do
not apply to any surface releases. These specific standards were generally
associated with the assessment and response/recovery standards.
Finally, the three approaches were combined, thereby producing
a comprehensive set of standards that could be used in any facility/
event/waste situation. Furthermore, subsets of standards could be derived
from these contingency plan standards that could apply to any specific
intersection.
Assumptions Made in Writing Contingency Plan Standards
In devising standards for contingency plans, certain assumptions
have been made based primarily upon discussions with EPA project monitoring
staff. It is assumed that contingency plans go into effect when the
release of hazardous materials has occurred, may be imminent, or is sus-
pected to have occurred. Presumptive evidence that one or more of these
conditions are present include: fires in the vicinity of hazardous waste
containers; explosive gas conditions which could disperse hazardous
particles, gases, or aerosols if denotation should occur; and, any employee
illness or incapacitation displaying toxicological characteristics.
It is further assumed that operating standards, which are
presently being developed by EPA, will require certain items to be on-site,
or actions to be taken, which would provide the basis for some of the
contingency plan standards that follow. For instance, protective clothing,
evaluation of environmental baseline conditions, communications equipment,
to name a few, are expected to be required under operational standards.
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Contingency actions, then, go one or more steps beyond those required
under operating standards. The costs of contingency plans have been calcu-
lated accordingly.
Precautionary measures to be taken in the event of warnings of
natural hazards are expected to be covered by operational standards.
Thus, it is assumed that responses to hurricane, tornado or flood alerts,
such as protective shut-down of the facility, would be applied under
operating rules established for the facility. Actions relating to any
releases caused by these natural events would be covered by the contingency
plan standards.
Divisions of Contingency Plan Standards
The standards are written in four main groups. The first two
groups (Organization and Communication) essentially involve actions that
must precede any emergency. The remaining groups (Assessment and Response/
Recovery) would be put into effect at the time of the emergency.
Response Times and Distances
In a number of the standards that follow, numerical values
are used to define distances and periods of time in which certain require-
ments must be met or response action undertaken. The numerical values
assigned reflect the generalized distance or time periods judged responsible,
prudent and safe with respect to a particular standard.
ORGANIZATIONAL STANDARDS
Organizational standards are aimed at insuring a well-defined,
effective and coordinated emergency effort, and deal primarily with
authority and responsibility in maintaining, implementing and activating
a contingency plan.
1. Standard for Requiring an Approved Contingency Plan:
Every operator of a facility engeged in, or permitted to
engage in, treatment or storage for a period of more than 90 days,
or disposal of any materials defined as hazardous wastes under
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the provisions of the Act shall be required to formulate a
contingency plan to minimize unanticipated damage in the event
of discharge of aforesaid hazardous materials to the surrounding
air, surface and subsurface environment. This plan must be
submitted to and approved by the permitting agency.
2. Filing the Contingency Plan:
The contingency plan must be filed with the responsible
permitting authority and EPA and all local public and private
entities which may be called upon to provide services in the
event of emergency. All revisions to the plan must be promptly
reported, in writing, to all parties in possession of copies of
the contingency plan.
Note: The requirement that the contingency plan be filed with EPA
could be modified to require the plan to be submitted to the state
administrator of solid waste planning. However, until the roles of
federal* and state agencies in regulating hazardous waste management
facilities is resolved the appropriate agency cannot be determined.
3. Defining Civil Authority:
The contingency plan must define the extent of interaction
between facility personnel and local public and private organiza-
tions in the event an accidental release threatens the general
public and/or the local environment.
Note: The authority of an operator of a waste facility to make emergency
declarations would end at his property boundary. Beyond that boundary,
he has a responsibility to communicate emergency declarations to civil
authority. No part of the Act changes the authority or responsibility
of local -civil authorities to act initially within this basic charter -
the protection and preservation of life and property. The lines of
authority include police (control of persons and securing of areas),
fire, and medical authorities. Because emergency situations are related
to dispersion of hazardous materials, multiple geonraphic jurisdictions
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of each type of authority may be involved. Furthermore, authorities in
some areas may be limited in the responsibilities delegated to them, or
which they are willing to accept: fire departments would be expected to
deal with smokes, gases, and flammable materials, but some fire departments
also provide all first-aid and ambulance medical services. Some localities
provide for coordinated emergency functions; others do not.
4. Defining Internal Authority:
The contingency plan must include the names of the persons
given primary responsibility for coordinating emergency response
measures at all times. The names of alternate emergency response
coordinators must also be listed.
Note: For contingency purposes, it is assumed that a responsible owner/
operator is defined for each hazardous waste facility, and an operator,
directly responsible as the agent of the owner, is on the site at all
times during the operating life of the facility, unless a variance is
granted by EPA.
5. Response to Emergency Inquiry:
Every operator of a hazardous waste facility shall be capable
of providing information at all times in the event of emergency
inquiry. The name and phone number of a person qualified and
authorized to act as responsible agent shall be maintained on file
with all local authorities, to include, but not be limited to:
a. the nearest police agency with round the clock personnal and
preferably with the policy agency of every jurisdiction within
three miles of the facility
b. the nearest fire agency with round the clock personnel and
preferably with the fire gaency of every jurisdiction within
three miles of the facility
c. the medical doctor, clinic or hospital named by the operator
as providing services to employees of the facility.
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The responsible agent shall be thoroughly familiar with the
substances handled at the facility, the location of the manifests
within the facility, and the locations and characteristics of the
different wastes stored on-site.
6. Facility Contingency Equipment Standards:
The contingency plan will list and describe all equipment to
be utilized in emergency situations for worker safety, emergency
communications, alarms, and spill recovery (equipment, chemicals,
foam, water, etc.).
7. Information on Exposure Symptoms and Treatment:
The operator will maintain information regarding the symptoms
and required treatment for exposure to all hazardous materials
handled at the facility, as well as their expectable by-products.
Such information will be provided to appropriate medical agencies
in the event of employee exposure, or a large scale release.
8. Inactive Sites:
Any administrator (person), upon nomination as the custodian
of an inactive waste disposal facility shall, before assuming those
duties formulate a contingency plan to minimize unanticipated
damage in the event of discharge of hazardous waste materials
to the surrounding air, surface, or subsurface environment.
Note: After the capacity of a landfill/burial site has been exhausted,
the site will become inactive. Attendant receiving, treatment, handling,
etc., will cease (although treatment of hazardous materials unrelated to
disposal at the site might not be precluded). Under Section 3004 (6),
which outlines requirements for maintenance of operation of the facility,
it is assumed that a custodian, either a private or public entity, will
maintain surveillance and control of the site for a period determined
pertinent by regulatory agencies and consistent with the nature of the
hazardous materials disposed.
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9. Training and Drills:
The contingency plan shall include specification of operator
training requirements and the type, number, and frequency of drills
required to maintain a state of awareness and preparedness.
COMMUNICATION STANDARDS
Communication standards are intended to insure positive and
pre-planned notification to emergency authorities in the event of
accidents or hazardous discharges. In preparing the standards, it has
been considered that: all fires, including short-lived ignition of
unexplained free gases; any detonation except one controlled entirely
within the operating limits of an incinerator chamber; any situation
requiring employee evacuation; any employee injury due to spontaneous
rupture of a container; or any release of hazardous gases, fumes, or
dusts, outside the regulated area of the facility may require automatic
alert to a detached fire department. With a direct fire alarm signal
available, it has been estimated that ordinary telephone service should
be adequate for emergency communications for ambulance service, requests
for police assistance, etc.
1. Pre-Contingency Notification of Nature of Hazards:
The operator of any hazardous waste management facility engaged in
treatment storage, or disposal of materials specified under this
Act shall communicate the following to all local agencies which may
provide emergency services to the facility:
a. the nature of the materials
b. maximum amounts received during an
operating cycle
c. known deleterious effects of the material(s)
d. modes by which this material might be released
to the environment
e. areas which could reasonably be expected to suffer
exposure during any accidental release.
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2. Emergency Communication Equipment:
Any facility engaged in the treatment, storage, or disposal of
hazardous waste materials specified under the Act shall be equipped
at a minimum with:
a. regular single-party telephone service
b. an alarm system capable of summoning emergency assistance
external to the facility, and/or simultaneously notifying
civil authorities responsible for emergency services
c. an internal communications system capable of providing
immediate instruction to all employees.
Note: Two way radios should be considered at least for waste facilities
because there may be some damage to telephone wires due to fire or
explosion.
3. Internal Alarms:
The operator should insure that when hazardous wastes are being
poured, mixed, spread or otherwise handled, at least one employee
involved in the operation has immediate access to an alarm device,
which can be activated by a single motion, capable of summoning aid
or warning of unsafe or unknown conditions. The employee with
immediate access to the alarm should be in clear visual and aural
contact with all other employees involved in the operation who do
not themselves have access to alarms or who are not in contact with
another employee who has access to an alarm. If at any time during
operation of the facility, there shall be a sole employee on the
premises, the alarm should be capable of directly summoning aid and
providing emergency warning to an emergency response authority
external to the facility.
4. Notification of Required Agencies:
A contingency plan shall list the EPA office and other agencies
and local authorities responsible for environmental quality or public
health and safety to be notified in the event of an accidental
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release at the facility. The plan shall list such agencies separately
for each of these major classifications;
a. suspected hazardous airborne release;
b. confirmed hazardous airborne release;
c. surface liquid release escaping the facility
confinement;
d. detection of materials in leachate exceeding
the established acceptable limits for the facility;
e. structural damage to the facility caused by
any accidental event;
f. discharge of hazardous materials into navigable
water as defined by Public Law 92-500.
ASSESSMENT STANDARDS
Assessment standards are aimed at 1) providing prompt
appraisa-1 of the extent and severity of dispersion and contamination
from the accidental release of hazardous wastes to the environment,and 2)
assisting in selecting an appropriate response to mitigate potential
adverse effects from the release of any contaminants.
Assessment standards are distinguished here from response
standards in that the former are aimed primarily at providing immediate
guidance on the nature, concentration, volume, extent of dispersion,
and areas threatened or affected by contaminants. Often the area affected
must be delineated by a physical or mathematical model.
1. Airborne Dispersion Model:
The operator of any facility that may be deemed capable of
generating an airborne contaminant shall prepare an atmospheric
dispersion model for the site, using meteorological records, and
maintain at all times current data on ambient meteorological con-
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ditions. The results must be detailed enough to provide precise (acceptable)
plume boundary and concentration information. The model should consider
variables including: meteorological conditions, temperature of the
airborne release, density of the released material, diffusivity of the
released material, concentration of the released material, duration of
the release, elapsed time since release ended, features of the local v
terrain, and teh degree of hazard associated with the material. In addi-
tion, the following requirement must also be met:
a. the model should be capable of completing its output
within a reasonable period of time depending on the
type of facility, hazard, etc.
b. the model must be approved by the EPA, or other governing
authority under a state implementation plan;
c. airborne hazard maps (or overlays showing anticipated
affected areas) must be prepared in advance and be
accessible for use within 5 minutes (X minutes) by a
trained person.
d. the maps or overlays shall be prepared using an appropriate
model (see, for example, those detailed in the Nuclear
Regulatory Commission (NRC) regulatory guide):
e. a copy of the maps or overlays shall be on file with
local emergency authorities within the radius of possible
effect,
2. Waterborne Dispersion Model:
The facility operator shall determine, where practicable,
the concentrations, directions and rates of movement of the hazardous
waste by use of site-specific hydrologic and water quality models
designed to predict the area, in either the surface or subsurface
environments, affected by the release. The models should be approved
by EPA or other governing authorities, and should consider such
factors as runoff rates, local topography, permeability, porosity,
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infiltration rates, local ground water velocities, chemical characteris-
tics, viscosity and density of wastes, and the background chemical
characteristics of water environments affected.
3. Identification of Material:
The facility operator shall identify to these public and
private bodies which may provide emergency services to the facility the
character and concentration of the spilled or released material. This could
be accomplished by review of facility manifests and/or chemical analysis.
4. Source and Extent of Release:
The facility operator shall determine, where possible, or
estimate the exact source, volume and extent of the spill or release
and report this to the predetermined public and private agencies who will
be providing emergency services to the facility. This shall be done in a
timely manner.
5. Atmospheric Release Assessment:
In the event of a gas leakage, fire, explosion or liquid
release, which produces or releases gases, vapors, dusts, or mists,
an operator should be prepared to predict the dispersion patterns of
a hazardous material which is released into the atmosphere by
applying pertinent meteorological data to the approved model; and
the degree of hazard associated with the dispersing material.
6. Waterborne Release Assessment:
The facility operator should apply all pertinent geohydrologic,
water quality and climatological data, including the most recent
data obtained from monitoring systems, to the available site-
specific model, as noted above, to assess the potential effects of
releases of contaminants to the surface and subsurface environments.
Where practical, the model should be used in advance to prepare
approximating maps (or overlays) which may be quickly accessible
during an emergency.
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7. Fire Assessment:
An operator must be prepared to assess the degree of hazard
associated with a fire or threatened fire at a facility and determine
the actions which should be taken to mitigate damage or injury.
The determination should indicate whether:
a. evacuation should be initiated because of certain imminent
dangers such as toxic combustion products, flammable or
explosive vapors, threatened explosion caused by fire,
etc.; or
b. members of the local community may be exposed to
hazardous substance.
The assessment of the degree of hazard should consider
indirect effects such as toxic, irritating, or asphyxiating combustion
products; hazardous surface runoff due to water or other chemical
agents used to control fire; and heat induced explosions. Obviously
any actual evacuation notice and/or the actual task of evacuation
will have to be initiated and executed by the proper local*authorities.
RESPONSE AND RECOVERY STANDARDS
Response to an emergency situation must follow immediately
after assessment. The line between response and assessment is of its
nature indistinct, but for organizational purposes it will be assumed
that once the assessment phase indicates the magnitude of the event
(e.g. concentration of contaminant, area affected etc.) all following
actions are a response to it. The response phase culminates in recovery
from the effects of the event.
The contingency standards for response to emergencies apply
whether air, water or the ground surface is contaminated. They, furthermore,
apply to all the facilities, events, and waste types as described in
other sections of this report. Consequently, response and recovery standards
will be addressed under the following subcategories: notification;
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shut-down of facility; evacuation; delineation of affected area (including
monitoring and modeling); collection and/or containment of released
wastes; the continuing assessment of affected areas; personnel availability;
medical treatment; alternate water supply; and fire fighting and prevention.
Notification of Release
1. The facility operator shall activiate on-site alarm
systems to notify all personnel that a release is imminent or has
occurred.
2. The facility operator shall notify appropriate agencies with designated
response roles immediately if said release threatens contiguous
populated areas or the local environment.
3. The facility operator shall record the time, date, quantity and
nature of the release, and convey a preliminary report with this and
any other pertinent information on the incident to the appropriate
regional office of the EPA within 24 hours.
4. The facility operator shall, at*a later time not to exceed 15 days,
submit a final report of the incident to the EPA including information
regarding damage, personal injury, corrective actions taken and
plans for preventing recurrence.
Sh-ut-Down
5. The facility operator shall provide adequate switching mechanisms
for cessation of processes; and for the shielding or containment of
unprocessed hazardous materials.
6. The facility operator shall designate those personnel who will
control any shut-down procedures and shall insure that said personnel
are available within a specified period of time after a release.
7. The facility operator shall monitor for the possibility of releases
subsequent to shutdown including leaks, pressure buildup, gas
generation or ruptures in valves, pipes or other devices or equipment.
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Evacuation
8. The facility operator shall notify the appropriate responsible
agencies as soon as his assessment has indicated that public evalu-
ation is necessary.
9. The facility operator shall begin evacuation of all personnel on
the site immediately if the release poses an immediate threat to
the health and safety of the personnel by virtue of either the
amount, concentration or unusual characteristics (i.e. combustion,
toxicity, etc.) of the release.
10. The facility operator shall assist, as advised by responsible
agencies or parties, in any evacuation procedures deemed appropriate
by those agencies.
Monitor and Delimit Affected Area
11. The facility operator shall secure against entry of unauthorized
personnel those areas which are under his jurisdiction, (i.e.,
within the facility boundaries). He shall also notify appropriate
agencies or parties regarding those areas which should be secured
which are outside of his jurisdiction when such actions are necessary
to prevent public exposure.
12. The facility operator shall continue the modeling and monitoring
of air, surface or subsurface waters initiated in the
assessment phase to determine the concentration, direction, rate of
movement and extent of contamination.
13. The facility operator shall have all water and air samples analyzed
for those chemical, physical and biological parameters deemed
appropriate by the authorized regulatory agencies. The analysis will
be by a laboratory approved by the responsible agency.
Collection and/or Containment of Waste
14. The facility operator shall secure the immediate area where a
release has occurred with impermeable cover materials, dikes,
channels or trenches so as to contain the wastes and preclude
precipitation and runoff water from contacting the wastes.
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15. The facility operator shall immediately initiate containment
and/or collection of wastes where said material poses an imminent
threat to human health and safety. Plans for cleanup shall be
developed as part of the contingency plan.
16. The facility operator shall provide for placement of recovered
wastes and contaminated soils in a designated emergency storage
area. Furthermore, he must provide a means for ultimate treatment,
storage or disposal of such materials.
17. The facility operator shall continue to assist in the collection
and containment of any material which has escaped from the boundaries
of his facility until such time as the affected area is declared safe by
the EPA or other regulatory authority.
18. The facility operator shall avoid the receiving or handling of any
wastes which may be reactive or incompatible with the released
material or which may result in the possible generation of secondary
contaminants such as dusts, mists, vapors or liquids until clean-up
procedures are completed.
19. The facility operator shall clean up and restore all emergency
equipment including vehicles, sumps, temporary storage containers,
etc. to pre-release conditions in a timely manner.
20. The facility operator shall determine, or contract for the determination
of, any failures or loss of integrity of containment equipment to
insure that the structures, devices or barriers have not been damaged
or altered and meet all permit requirements under Section 3004 (4)
of the Act.
Continued Assessment of Affected Areas
21. The facility operator shall continue to monitor and assess any
damage to the environment from the release of the contaminants
until such time that the affected areas are restored and normal
operations have resumed.
22. The facility operator shall file with the appropriate authorities
monthly reports that record additional environmental, health and
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other pertinent information until the affected areas are restored
and normal operations have resumed.
Personnel Availability
23. The facility operator shall insure that sufficient qualified personnel
are available on site, or have been notified and can reach the site
within a specified period of time to initiate appropriate emergency
response measures and/or assessment operations.
24. The facility operator shall insure that qualified personnel assigned
to utilize appropriate-models are available, or on call, and can
begin to incorporate any new data, adjust programs and update
parameters input in modeling the release.
Medical Assistance and Treatment
25. The facility operator shall provide that a physician and medical
equipment including ambulances and emergency treatment be available
from nearby hospitals or clinics for the emergency first aid of
injured personnel that have been exposed to hazardous waste materials.
26. The facility operator shall provide emergency assistance, as directed
by appropriate authorities, which will aid in treatment of any
persons in contiguous population areas who have been exposed to
or adversely affected by the release.
27. The facility operator shall furnish information to appropriate
medical agencies regarding the symptoms and necessary treatments
for exposure to all hazardous materials which are handled and any
by-products of the materials.
28. The facility operator shall make available, or have access to,
adequate decontamination equipment including showers, chemical agents
and disinfectants, etc., to safeguard the health of all employed
personnel.
29. The facility operator shall, in the event of fire, activate all
necessary alarm systems including required on-site direct communication
systems to local fire authorities.
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30. The facility operator shall issue fire fighting equipment to designated
emergency response personnel as a initial response measure to
contain or reduce any local fire.
31. The facility operator shall, in the event of fire, ascertain the
location of any explosive materials in the immediate vicinity and
employ appropriate measures, including removing containers, cooling
to reduce pressure buildup, or isolating containers either physically
or with chemical substances, to minimize the risk of subsequent
explosion.
D. STRATEGY ISSUES FOR THE IMPLEMENTATION OF CONTINGENCY PLAN STANDARDS
This section addresses the issues inherent in five different
strategies in terms of the advantages and disadvantages of the regulatory
options offered by each strategy, as well as the degree of human health
and environmental protection afforded. Each strategy issue can be
discussed in general terms of its effect on all standards.
STRATEGY ISSUE I - STANDARDS BY FACILITY TYPE VERSUS UNIFORM STANDARDS
FOR ALL FACILITIES
With respect to facility type, two options are available for
writing contingency plan standards. Either a single set of standards
may be written which applied uniformly to all types of facilities, or
separate sets of standards may be written for each major facility type.
The appeal of separate sets of standards is based on the premise that
the various facility types are clearly distinct in character. This
premise is not entirely correct, however. While it is true that there
are unique features which distinguish various facilities, it is also
true that a great deal of commonality exists. Most facilities handle
wastes with the same basic accident potentials. The primary differences
between facilities are physical design and methods of operation. Design
and operation are not within the scope of contingency standards-. Though
the specific response to an accident will vary according to the peculiari-
ties of a site, facility specific standards will not take this into account
unless they are coupled with site specific, case by case regulations. If
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site specific regulations were promulgated, the myriad of location and
environmental conditions which might be encountered would make the
standards unduly complex and lengthy. Because of the length and complexity,
the cost of developing such standards would be much greater than uniform
standards.
The motivation for uniform standards applied to all facilities
is based on the opposite premise from facility-specific standards, i.e.,
it is based on the commonality of various facilities. The major advantages
are lower cost for development, implementation, and uniformity of adminis-
tration. Since there is much in common between facility types with respect
to accident potential, uniform standards have the same options for being
specific as facility-specific standards. The major disadvantage of uniform
standards is that they could in some cases discriminate against certain
waste handlers by setting requirements which may not be warranted because
of physical circumstances, volume of waste handled, and the like. A
system of waivers could be used to mitigate such cases.
STRATEGY ISSUE II - FEDERAL REGULATION VS. STATE REGULATION
Contingency plan requirements can be promulgated under three
regulatory strategies: federal regulations only, state regulations
only, or combined federal/state regulations. These three options will
be discussed with the relative advantages and disadvantages inherent in
each.
- Federal contingency plan requirements would presumably take
the form of guidelines issued by EPA for the preparation of contingency
plans, including a number of mandatory requirements to be contained in
such plans. The advantages of national standards include uniformity of
administration and enforcement of regulations, elimination of certain
states as "havens" for facilities because of their inadequate regulations,
relieving states of the burden of regulating specialized, and often
sophisticated, operations (particularly the states with only a small
number of facilities), and elimination of the duplication of effort in
the research behind preparation of the regulations. Furthermore, federal
regulation could make it administratively more feasible for participation
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by a federal "response team" in assessment of, response and recovery from,
hazardous waste releases. The concept of a response team in terms of
assessment and cleanup has been successfully demonstrated on a regional
basis. To a lesser degree, such teams have also been established in
some states. Major disadvantages of this regulatory strategy include
the costs and administrative burdens of federal monitoring and enforce-
ment, and the negative incentive for innovative state programs for dealing
with hazardous management programs.
Under a state-only regulatory strategy, the federal government
would provide guidelines for state regulatory programs, and technical
support to those states requesting it. The program suggested would then
be modified in response to local needs or interest groups. The major
advantages of this option include the ability of states to adopt regula-
tory schemes to review proposed contingency plans on a case-by-case basis,
enabling consideration of local characteristics at each site (i.e.,
proximity of population centers, local fire fighting capabilities,
hydrology, geology and climate of the area) and the low overall cost to
the federal government. The major disadvantage is the burden placed on
each state to acquire additional personnel having the necessary technical
expertise to judge the adequacy of plans submitted.
The most attractive regulatory option with regard to federal
vs. state regulation of contingency plan requirements may be the combi-
nation of federal and state controls contemplated by RCRA. The federal
EPA, using the technical resources available to it, may publish guide-
lines for state regulatory programs. In addition, minimum contingency
plan requirements would be promulgated as federal regulations. Authority
to grant permits would be delegated to the states, enabling adequate
consideration of site-specifics. This approach would eliminate most of
the disadvantages and provide most of the advantages for the alternative
listed above.
STRATEGY ISSUE III - EXACT AND SPECIFIC REQUIREMENTS VS. AD HOC FLEXIBLE
REQUIREMENTS
The issue to be addressed here concerns the level of detail to
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be contained in the uniform contingency plan standards. The greatest
degree of public safety and environmental protection would be provided
with specific requirements. However, due to the wide variety in facility
designs and sizes, site characteristics, and local emergency services
available at each location, a very extensive and cumbersome administrative
program would be involved. Additionally, considering the relatively
brief experience of the hazardous waste management industry, many innova-
tions in techniques of treatment, storage and disposal, as well as
emergency response are expected. These developments would require
constant revision of specific standards governing contingency plans.
Flexible, or ad hoc, requirements could state the objective of
the standard without specifying the technique to be employed. These
requirements enable the tailoring of contingency plans to individual
facilities and encourage innovation. However, evaluation of the adequacy
of contingency plans becomes quite difficult, requiring extensive review
by qualified regulatory authorities.
On balance, the exact and specific requirements appear to be
preferable because regulation would tend to be more uniform and objective.
STRATEGY ISSUE IV - ENFORCEMENT OF CONTINGENCY PLAN REQUIREMENTS BY
SELF MONITORING OR PERMIT AGENCY INSPECTION
There are usually two regulatory strategies related to enforce-
ment of contingency plan requirements. In both approaches, it is assumed
that the contingency plan would be reviewed by the permit granting authority
to determine if it adequately addressed the regulations in affect. Under
the first strategy, the EPA and the permitting agency would rely on the
permittee to monitor and provide information to them concerning the
adequacy of the plan. The second approach would require periodic inspection
of the facilities by EPA and/or the permitting agency to confirm that the
measures described in. the plan were in force.
The determination of the feasibility of inspection for contin-
gency plan compliance is dependent on the decision whether or not to
require an inspection program to determine compliance with design and
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operating standards. If such an inspection program is instituted, the
additional annual costs associated with determining compliance with con-
tingency plan standards would be minimal. If such a program for design
and operating standards is not instituted the costs of instituting an
inspection program solely for contingency plans would be very expensive.
Flexible, or ad hoc, requirements could state the objective of
the standard without specifying the technique to be employed. These
requirements enable the tailoring of contingency plans to individual
facilities and encourage innovation. However, evaluation of the adequacy
of contingency plans becomes quite difficult, requiring extensive review
by qualified regulatory authorities.
On balance, the exact and specific requirements appear to be
preferable because regulation would tend to be more uniform and objective.
STRATEGY ISSUE V - HANDLING VOLUME LIMITATION
By establishing limits on the handling capacity of individual
facilities, the overall threat to human safety and the environment might
be reduced for two reasons. By limiting the amount of hazardous wastes
in temporary storage at a given facility, the magnitude of the maximum
possible accidental release would be reduced-, and handling limitations
would force an increase in the number of facilities, possibly resulting
in an overall reduction in transport of the wastes, and therefore the
number of transportation-related accidental releases. A disadvantage
of such action would be the increased risk of accidental releases
resulting from the greater number of facilities. A policy of requiring
small facilities would also increase the problem of finding enough suitable
sites. Geological and hydrological constraints will limit the potential
number of suitable sites. Popular opinion may be a factor also in that
it may be more difficult, in terms of citizen resistance, to establish
many small sites than a few large ones.
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E. COMPATIBILITY OF CONTINGENCY PLAN STANDARDS WITH EXISTING FEDERAL
LAWS AND REGULATIONS
INTRODUCTION
Section 1006 of the Resource Conservation and Recovery Act of 1976
requires that the provisions of the Act be integrated with the appropriate
provisions of the Clean Air Act, the Federal Water Pollution Control Act,
the Federal Insecticide, Fungicide and Rodenticide Act, the Safe Drinking
Water Act, the Marine Protection Research and Sanctuaries Act of 1972 and
other such acts which grant authority to the EPA administrator, to avoid
duplication among the acts and enable their efficient administration and
enforcement. The purpose of this section is to review the provisions of the
above laws which deal with areas related to emergency response requirements
or plans in order to establish the extent of existing laws with regard to
contingency plan requirements.
CLEAN AIR ACT
Section 112 of the Clean Air Act authorizes the Administrator of
EPA to set standards for hazardous air pollutants at any level "which in his
judgment provide an ample margin of safety to protect the public health".
Specifically, asbestos, beryllium and mercury are three hazardous pollutants
for which emission limits have been promulgated. However, emergency response
requirements for the accidental release of hazardous pollutants above these
levels are not addressed in the act. Hazardous waste facilities which handle
substances for which emission standards have been set under this act must
meet these emission standards. However, any contingency plan standards pro-
mulgated under RCRA would be outside the scope of the Clean Air Act, and
would thus be compatible.
THE FEDERAL WATER POLLUTION CONTROL ACT
In response to the President's request for the Council on Environ-
mental Quality to carry out subsection (c) (2) of section 311 of the Federal
Water Pollution Control Act, as amended, (33 U.S.C.1251,et seq.), the Council
developed the National Oil and Hazardous Substances Pollution Contingency
Plan. The objectives of the Plan are "to provide for efficient, coordinated
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and effective action to minimize damage from oil and hazardous substance dis-
charges, including containment, dispersal and removal." The Plan is effective
"for the navigable waters of the United States and adjoining shorelines and
for the contiguous zone and the high seas where a threat to the United States
waters, shoreface, or shelfbottom exists."
The most significant provision put forth under the Plan potentially
related to hazardous waste management facilities is the requirement that any
person in charge of an onshore facility shall, as soon as he has knowledge of
any discharge of oil or a hazardous substance into navigable waters, immediate-
ly notify the nearest EPA or United States Coast Guard office of such dis-
charge. In the event the responsible party is unable to eliminate the threat
to the U. S. waters, shoreface, or shelfbottom,the federal government is
assigned the task of undertaking response activities to minimize damages from
such discharge. The federal government is then authorized to bring suit
against the party responsible for the discharge for costs incurred in the
response effort.
In summary, the National Oil and Hazardous Substances Pollution
Contingency Plan imposes two requirements on hazardous waste facilities if
an accidental release from such facilities threatens navigable waters:
notification of EPA or the Coast Guard, and recovery of the release. Since
both these requirements are included in the contingency plan standards
discussed earlier, there would be no incompatibility between the contingency
plan standards promulgated under RCRA and the National Oil and Hazardous
Substances Pollution Contingency Plan. Moreover, most hazardous waste
management facilities will probably be located far from navigable
waters.
Through the Federal Water Pollution Control Act Amendments of 1972,
the federal government was granted some authority over deep well injection,
since the legislation requires state regulation of the disposal of pollutants
in wells as a prerequisite for qualification for federal funding of area-wide
waste-treatment management. Using this authority, the EPA Administrator,
through the Administrator's Decision Statement No. 5, has recommended the
requirement that contingency plans that will aid in preventing any environ-
mental degradation must be prepared to cope with all well shut-ins or any
well failures prior to issuance of permits by state authorities. Therefore,
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the only requirement issued under this authority for facilities employing deep
well injection is that a contingency plan be prepared which concurs with the
requirement which could be promulgated under RCRA.
THE FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT
Under the authority of the Federal Insecticide, Fungicide and
Rodenticide Act, as amended by the Federal Environmental Pesticide Control
Act of 1972, the EPA promulgated "Regulations for the Acceptance of Certain
Pesticides and Recommended Procedures for the Disposal and Storage of Pesti-
cides and Pesticide Containers" (40 C.F.R. 165). The following guidelines
pertinent to accidents at hazardous waste management facilities were
published:
1. "All accidents are incidents involving the storage or disposal
of pesticides, pesticide containers or pesticide related wastes should be
reported to the appropriate Regional Administrator."
2. "Containers should be checked regularly for corrosion and
leaks. If such is found, the container should be transferred to a sound,
suitable, larger container and properly labeled. Materials such as
adsorptive clay, hydrated lime and sodium hypochlorite should be kept
on hand for use as appropriate for the emergency treatment or detoxification
of spills or leaks."
3. A number of accident prevention measures are suggested.
4. The use of protective clothing and respirators is recommended
for all employees handling pesticides.
5. "Where large quantities of pesticides are stored, or where
conditions may otherwise warrant, the owner of stored pesticides should inform
the local fire department, hospitals, public health officials and police
department in writing of the hazards that such pesticides may present in the
event of a fire."
In all likelihood, most pesticide-s related wastes will fall into
the category of "hazardous wastes"in the classification to be promulgated
under RCRA. However, all of the above requirements are included in the
contingency plan standards discussed earlier. Therefore, no conflictir._
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requirements would be introduced through adoption of the contingency plan
standards proposed in this report.
THE OCCUPATIONAL SAFETY AND HEALTH ACT OF 1970
This Act authorizes the Secretary of Labor to set mandatory stand-
ards to protect the occupational safety and health of all employers and
employees of businesses engaged in interstate commerce. Section 6 (b) (5)
deals specifically with toxic materials and other harmful agents requiring
the Secretary to "set the standard which most adequately assures that no em-
ployee will suffer material impairment of health or financial capacity" from
regular exposure to such hazards.
Specific requirements issued under this Act pertinent to contin-
gency plan standards include:
1. Emergency response requirements have been issued for any
facility which handles, processes, releases, or stores 4-nitrobiphenyl, alpa-
Naphthylamine, 4,4'Methylene bis(2-chloroaniline), Methyl chloromethyl ether,
3,3'-Dichlorobenzidine (and its salts), bis-Chloromethyl ether, beta-Naph-
thylamine, Benzidine, 4-Aminodiphenyl, Ethyleneimine, beta-Propiolactone,
2-Acetylaminofluorene, 4-Dimethylaminoazobenzene, or N-Nitrosodimethylamine.
In the event of an accidental release which may result in exposure to or con-
tact with any of the above substances:
a. The potentially affected area shall be evacuated as soon as the
emergency has been determined.
b. Hazardous conditions created by the emergency shall be .-limin-
ated and the potentially affected area shall be decontaminated
prior to the resumption of normal operations.
c. Special medical surveillance by a physician shall be instituted
within 24 hours for employees present in the potentially affect-
ed area at the time of the emergency.
d. An incident report on the emergency shall be made within 24
hours to the nearest OSHA Area Director.
e. A written report shall be filed with the nearest OSHA Area
Director within 15 calendar days of the event and shall include:
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i. A specification of the amount of material released,
the amount of time involved and an explanation of the
procedure used in determining this figure;
ii. A description of the area involved and the extent of
known and possible employee exposure and area contamina-
tion;
iii. A report of any medical treatment of affected employees
and any medical surveillance program implemented; and
iv. An analysis of the circumstances of the incident and
measures taken or to be taken, with specific completion
dates, to avoid further similar release.
2. Similar emergency response requirements have been issued for
facilities handling vinyl chloride.
The contingency requirements issued by OSHA for facilities handling
the aforementioned carcinogens concur with those presented earlier for all
hazardous waste facilities, with the additional requirement of filing reports
with the OSHA Area Director. There are no incompatible provisions between
the existing OSHA regulations and those proposed under RCRA.
OTHER REGULATIONS
In addition to the laws described above, the following acts which
deal either directly or indirectly with hazardous wastes were reviewed to
determine if they contained provisions related to contingency plans for
hazardous waste management facilities:
-Safe Drinking Water Act (P.L. 93-523)
-Marine Protection, Research and Sanctuaries Act of 1972 (P.L. 92-
532)
-Atomic Energy Act of 1954 (42 USC 2011)
-Toxic Substances Control Act (P.L. 94-469)
-Transportation of Explosives Act (18 USC 39)
-Hazardous Materials Transportation Act of 1970 (P.L. 91-458)
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None of the preceeding acts were found to have applicability
regarding contingency plan standards for the hazardous waste facilities to
be regulated by EPA under the Resource Conservation and Recovery Act.
Specifically, RCRA does not mandate regulations concerning transportation
related accidents (as do the Transport of Explosives Act, the Hazardous
Materials Transportation Act of 1970 and the Marine Protection, Research
and Sanctuaries Act of 1972) or accidents involving the release of radio-
active wastes regulated under the authority of the Atomic Energy Act of 1954.
Neither the Safe Drinking Water Act nor the Toxic Substances Control Act
grant authority to EPA to promulgate regulations concerning contingency plan
standards.
CONCLUSION
In conclusion, none of the contingency plan standards proposed
for implementation under RCRA were found to be incompatible with existing
regulations, or in conflict with the authorities granted under other acts.
However, facility operators may find that contingency plans must meet
supplementary requirements of other governmental regulations, such as
OSHA safety standards requiring supplementary fire equipment other than
mentioned in the Contingency Plan Standards.
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F. RELATIVE COSTS OF CONTINGENCY PLAN STANDARDS
Under the Section 3004 specifications, the design of the facility
must include the goal of reducing the possibility of material dispersion to
the environment. This reduces potential contingency plan costs, in that
protective structures such as dikes, sumps, paving to minimize or eliminate
inflow of spills into ground water, etc., must be considered regular
facility costs, rather than "emergency devices". The facility costs to
implement contingency plan standards are then for (the group of standards to
which each type of cost is related is indicated in parenthesis):
1. Fire control and suppression systems (Response).
2. Employee protective equipment donned during emergency periods
(as contrasted to protective equipment worn during material
loading or handling) ( Assessment and Response).
3. Emergency communication equipment (Communication).
4. Assessment model costs ( Assessment).
5. Neutralizing, sorbing, or barrier materials used after or
during spills (Response).
6. Contingency response costs (Response).
7. Facility diseconomies resulting from contingency
considerations, such as inventory limitations (An indirect cost
not related to specific groups of standards).
8. Governmental emergency services for fire, medical, and police
actions (An indirect cost).
The subdivisions listed above are used as the basis for the contin-
gency item costs given in the following section, under "Contingency Plan
Costs."
Disposal costs at landfill sites in the 100 ton per day (tpd)
range were estimated at $10+ per ton based on 1969-1972 costs. Because
of escalating land values and construction costs, these disposal costs on
at 1977 basis would be estimated at $20 per ton for new sites, and about
$15 ton for existing fills.
1 QQ
I CO
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Using an economist's rule of thumb that capital investment in
landfill operations should be able to return 15 to 20 percent per year
return towards profit and amortization in addition to covering operating
expenses, a TOO tpd operation, 250 days per year, would need to charge $1
per ton for each $100,000 of investment in safety or environmental protection
equipment.
Incinerators in the one-half to one tpd range (100 Ibs/hour) were
estimated to incur disposal costs of about $6.50 per ton based on 1969-1972
data. Current costs for low BTU content materials requiring pyrolysis and
stack scrubber protection would be estimated at about $15-20 per ton, decreas-
ing to about $10 per ton as the fuel quality of the material improves.
Scrubber safety systems have to be tested frequently if they are to provide
reliable service, and consequently, are likely to incur high labor costs.
CONTINGENCY PLAN COSTS
Relative cost estimates for the contingency items listed are given
relative to 100 tpd landfills and/or a 1 tpd pyrolyzer:
1. Fire control and suppression systems, type A. As supplied by
a municipal system, 10,000 gallons per minute (gpm) capacity,
no annual usage, $150 to 600 per month, higher if exclusive main
is installed:
7 to 30<£/ton, landfill
1500 gpm capacity, $30/mo. U/ton, landfill
7<£/cwt, incinerator
Type B, pressurized or small portable systems,
$800 to $30,000 (several cylinders, to truck mounted
pumper: 3
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$20,000 to 35,000
$ 8,000
$ 25,000
Emergency communication:
Telephone -- zero allocated to contingency
Internal Alarms, $100 per year
Direct signal alarms: $1500 per year
higher for remote locations 6<£/ton, or 32<£/cwt
Assessment model costs
Computer model assembly
Meteorological
Surface Water Hydrology
Ground Water Hydrology
Computer standby and data update
(update user monitoring results,
but lab costs not allocated on
routine readings)
Met. data input, standby service
(costs assumes data prepared
routinely for other uses,
charged at margin for standby)
Cost Recovery:
$63,000 X 20% --$13,600
plus mo. 300 X 12% -- $3,600
$17,200
$ 200 per month
$ 100 per month
over 25,000 tons gives 69<£/
ton, landfill
over 5,000 cwt gives $3.44/
cwt, incinerators
Non-computer model
Meteorological $1200
Surface water $1800
(no contour survey)
Ground water $1200
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5.
Cost recovery:
$200 X 20% --$840
Meteorologist standby $250 per mo.
Surface hydro!ogist $150 per mo.
Ground water model update $300 per mo.
$9240 gives 37i/ton
$1.85/cwt.
Computer service response
aimed at 10 min. max. Non-
computer service aimed at
30 min. maximum.
Consumable supplies:.
Sorbents, neutralizers, etc.
estimated at $400 to 3000 per
annum:
2* to 12
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Facility diseconomies:
A landfill of 100 tpd should have no scale loss for inventory
limitations of one day capacity or greater. For one-half day, 10
percent can be estimated, although it could be lower. For one-
quarter day limit, at least 10 percent diseconomy should be expected.
For a batch incinerator, no facility diseconomy can be charged
for inventory limitation as no operating time is lost waiting for
batch handling. However, the operating costs of a separate storage
facility may be incurred, plus transportation inefficiency losses.
Governmental emergency/services costs:
Local governmental costs vary widely and depend on the extra
costs incurred by government because of the facility- Fire costs
decrease per hour with increased usage on the department. Using
a rule of thumb of $120,000 actual costs per service person, fire
costs for a 25 man crew with 15 percent on-line duty per year
would be $2300 per hour, or $8-10,000 per usual fire. Police costs,
at 90 percent on-line duty, would be figured at one-sixth of fireman
cost. Equipment charges can be estimated as an additional 25 per-
cent of manpower.
Administrative and regulatory services of government can be
estimated at $40,000 per man year. The allocation of that time to
a particular hazardous waste facility would be expected to be a
small fraction of the man-year. However, startup costs for all
types of governmental administrative services could be high if
new facilities and equipment would be required at close proximity
to the disposal facility.
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Total Costs of Contingency Items
This estimate excludes items 7 and 8, but includes all other
contingency cost items as relevant to the type of facility. The low
estimate of costs uses the lowest cost options under any relevant cost
item, and the high estimate uses the highest cost option under any rele-
vant cost item.
Incinerators: $15,600 to $55,600 per year; $3.00 to $11.00
per cwt. As a percentage of costs for a 1 ton per day operation, contin-
gency items for a low of triple current disposal costs to a high which
would represent a major multiple of such costs. For a 100 ton per day
facility, such as might be used in a medium sized contract hazardous
waste disposal facility, these items would represent from 6 percent to
22 percent of current disposal costs.
Landfills: $21,400 to $84,160 per year; $.85 to $3.40 per
ton. These costs represent from 4.2 to 23 percent of the costs per ton
of disposal for a 100 ton per day land fill, with the variation in the
percentage depending upon both the range in the costs of contingency
items and upon the range in costs of disposal for different types of
facilities.
CONTINGENCY COSTS AT DETACHED WASTE FACILITIES
The waste treatment facility which is detached from the ultimate
disposal point often fulfills a processing function, particularly by-product
recovery, which is additional to the waste aspects of operation. Allocating
contingency standards costs to such a facility is difficult because, ideally,
the capital investment and operating costs committed to the waste stream may
be small. As a general approach, it can be assumed that, however, a
detached facility will have the same contingency costs per site as any
other.
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G. CONTINGENCY PLAN STANDARD SETS
In this section, three "sets" of contingency plan standards are
presented. Each set lists a different group of standards that could be
used to promulgate rules and regulations. These sample groupings are
three of an infinite number of groupings that might be developed from
the lists of standards in Part C. It should also be remembered that
different strategies may also be applied to the listed standards in a
group.
The purpose of developing the following three sets is to
present three logical and rational lists of standards from which the
EPA may choose for implementation. Realistically, these three sets
may be supplemented and/or modified by the EPA in their developing the
"best" or final set of standards.
CONTINGENCY PLAN STANDARD - SET NUMBER 1
This set of standards applies the strategy of uniform contingency
plan requirements for all facilities. In the most general terms, this
set reflects a lenient regulatory stance, providing much latitude in
the preparation of the contingency plans by the individual facility
operator. The regulatory agency would presumably provide additional
guidelines to these standards for the preparation of contingency plans
for specific facility types. These guidelines would serve solely as
suggestions to assist the facility operator in meeting requirements at
his site and dealing with particular hazardous waste(s).
Organization Standards
These standards are concerned with formalizing lines of
responsibility for contingency actions. The major costs arising in
organizational standards are those from any safety-related equipment,
such as fire protection, breathing equipment etc., specified in
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CONTINGENCY PLAN STANDARD
SET #1
ORGANIZATIONAL STANDARDS
1. Standard for Requiring a Contingency Plan
3. Defining Civil Authority
4. Defining Internal Authority
6. Facility Contingency Equipment Standards
9. Training and Drills
COMMUNICATION STANDARDS
2. Emergency Communication Equipment
ASSESSMENT STANDARDS
3. Identification of Material
4. Source and Extent of Release
7. Fire Assessment
RESPONSE AND RECOVERY
Notification of Release
1. (Activate Alarms)
2. (Notify Agencies immediately)
8. (Notify Agencies)
15. (Initiate Containment)
28. (Decontamination Equipment)
29. (Fire Alarm)
30. (Initial Response)
31. (Explosive Materials)
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organizational standards. Since such specifications could as well
be set under competing standards - facility design, NIOSH regulations,
and local permitting, it is felt that no significant costs are generated
which would be a disadvantage.
Several questions, however, covering overlaping and competing
authorities arise in the organizational standards. These questions are
central to the functioning and permitting of waste facilities under the
Act. These conflicts between local regulation on the use of land, and
regional regulation based on the authority to control water and air quality
extend to the contingency planning activities as well.
The suggested format in the planning standard used the words
"file with", without saying "approved by". Thus approval of the
contingency plan has been left to implicit approval through the issuance
of a permit. On the one hand, for a bu-ilding, construction or land-use
permit granted by local authority, there would seldom, if ever, be a
procedural, review of the contingency plan complete with comment or
endorsement by the concerned local emergency entities. On the other
hand, a state or regional permit granted under authority of the Act
could certainly embody such review. The permit process may, therefore,
provide for comment and agreement by the local authorities.
The standard for an inactive site or for post closure of a
site has been touched upon in this section. The subject of post closure
contingency plans is tied very closely to the contingency plan at a
facility used when the facility was in an operating mode. It is assumed
and logical that closure plans for a facility which are part of the operating
plans, would include provisions to identify the level of effort required
to be maintained after the operation mode has ceased. It is apparent that
post closure contingency plans will vary dramatically with such variance
dependent on (1) hazardous waste type at the facility, (2) the mode of
storage, (3) the exposure of the facility to the environment and the site
location/characteristics. Although post closure contingency plans would
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be developed as part of closure plans (Operations), the Standard in this
report may be utilized to develop the necessary plan. Implicit in the
standards given are assumptions about the nature of hazards, especially
the limited nature of hazards, that may arise from a properly sited and
operated facility. In this report, guideline longevity for the hazards
was assumed to be 50 years (range 1-100 years) for most organic residues,
200 years (range 100-500 years) for certain persistent organics, and
5000 years (range 500-10,000 years) for metal element hazards. The
ultimate fate of the organics is considered to be microbial breakdown
and oxidations while metal elements are considered to disperse during
ground water migration at tolerable concentration, even in impermeable
sites (based upon a defined impermeability of 10~ cm/sec). Concentrated
radiologicals, however, are not considered in the longevity. Small
amounts of them would be assumed to disperse to below background levels
of activity in the same manner as metal elements, even if their radio-
activity had a much greater longevity.
For help in preparing a list of appropriate standards for
post closure, a list similiar to this Set Number 1 should be utilized
with the realization that costs for equipment and manpower monitoring
would need to be borne solely by the plan. Although the organizational
standards, the communication standards, the assessment standards as
well as the response and recovery standards would easily carry over
from active operations, general post closure costs could run from $1,000
per year to $10,000 per year at a disposal facility. It is not envisioned
that security costs would be extensive at a closed facility if adequate
and effective closure techniques are utilized at a site. If security
guards are required, such costs could be as high as $40,000 to $60,000.
The advantages of defining the organization standards allow
for execution of response and recovery in an orderly fashion. Such
establishment is imperative to protecting public health minimizing harmful
exposure of hazardous waste releases on the environment.
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Communication Standards
The standards considered for communication require that facility
operators be able to summon external aid and that employees be able to
summon aid internally. The standards require that the knowledge of complete
inventory and storage be available and that notifications required under
the Act be formally established and identified in the contingency plans.
These standards seem to be minimumly different from those that a prudent
operator would not ordinarily undertake on his own. The list is adequate
but not exhaustive.
Additional standards, such as predetermination of language
communication between all employees and supervision, or between operators
of the facility and persons transiently engaged in transportation activites
at the facility, may also be formulated if potential problems in this area
might occur. Precedent for such standards can be found in oil spill
contingency plan standards, and in the Port Safety Act. However, it was
concluded that the international nature of the oil spill problems and
Port traffic would not be expected at a hazardous waste facility. Any
certification training requirements, internal alarms, and the proper
supervision or transient personnel, would more than likely provide adequate
safeguards in preventing communication problems.
Automatic warning system requirements have been generally concluded
to be of little application in waste facilities, Nevertheless, incinerators
generally incorporate high and low temperature control sensors. And in
this case, safety equipment has been both required and important.
The question has also been raised that a central agency, such as
a state or regional alarm center should receive instant automatic alerts
when an accident occurs at a particular facility. The advantage of
such an alert would be quick response of the state or regional facility
to the accident. However, with the basic premise of facility operator
preliminary assessment is considered to be most important to protection of
health and the environment, little advantage would be associated with the
instant alert alarm. With little advantage, any communication costs in this
regard are not justifiable.
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The advantages of reliable and effective communication in the
event of an accident at a facility is most important in minimizing the
impact of a hazardous waste accident. Costs for implementation of
communication standards would be on the order of only several thousand
dollars at a facility.
Assessment Standards
The costs imposed on a small facility by assessment standards
are considerable. Assessment standards, are linked to siting studies,
requiring provision of a considerable exploration of the natural dispersive
qualities of a site before a facility is permitted to be established.
Particularly important are airborne and waterborne dispersion vectors.
Dispersion profile capabilities need to be established at the facility
and the precedent for providing such assessments is well established with
nuclear power plant facilities. The value of such information is also
clearly pointed out by looking at the recent contamination problems in
storm arid sewage discharges from kepone wastes and the dioxine waste
releases at Seveso, Italy.
Several policy considerations arise in conjunction with
assessment of a non-routine release at a facility and the facility siting
criteria. The problems involve transport of hazardous materials, and the
treatment location of industrial hazards, in general. For example, if
the standards for siting hazardous waste facilities should follow the U.S
nuclear regulations example of partial isolation of risk, i.e., limiting
siting to zones of low population exposure potential, then the hazard
exposures in transport to such isolated sites may well be increased. The
sites would also become a concentration focus for such hazards. The
exposure is acceptable for organic materials to be pyrolyzed, but may be
counter-productive for metal elements. In the latter case, dispersion
of metal elements into the natural environment may be the preferable
ultimate fate of the disposal, instead of perpetual concentrated storage.
Policy decisions need to be made on whether isolated distant sites are
preferable to closer more exposable locations.
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The alternative approach of allocating the risk to small incin-
erators, smaller disposal sites, and limitation of inventory could reduce
total risk of public exposure and risk at any one time. However, off-
setting the risk reduction at a specific site is the fact that populations
are exposed. Contingency plans for small local areas also might not
require sophisticated atmospheric models since the exposures could be too
rapid for them to be useful. More important would be informing the local
population of preset evacuation plans and providing them with quick
knowledge of wind conditions at the time of an accident. It is assumed
that the policy questions raised in this area will be resolved under the
permit granting process. The effect of the decision will certainly impact
dramatically on event assessment costs associated with and required at the
facilities. The closer a potential hazardous waste contaminant is to
human population centers, the greater the committment must be to monitoring
equipment and assessment standards.
In general, the question of cost effectiveness of sophisticated
assessment models is closely linked to siting considerations, and
contingency planning will have to reflect the siting policy. Assessment
model costs on facilities including the basic data collection at a site
may be on the order of $50,000 to $100,000 which emphasizes the importance
of size to distribute such costs. The disadvantages of not having an
adequate assessment procedure would be a serious compromise to protecting
the environment and public health.
Response and Recovery
The area of greatest advantage for response standards will
probably lie in providing a firm, prescriptive methodology for cleanup
of spills, leaks, which are internal to the facility. Such expenditures
will result in expeditious cost effective cleanup operations. Without
good responses, i.e., very careful attention to housekeeping, the potential
is great for the later damages of reactive residues in the surface layers
of soil around handling points in the facility. Improper response could
also lead to fugitive dusts, puddles of corrosive and reactive materials,
and difficult control of contaminated runoff.
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Training and maintenance of training in hazardous waste handling
may be instrumental in improving the lack of attention of personal safety
often demonstrated by the workers themselves.
The external response standards in this section are likely to
be the least effective in promoting contingency actions. The standards
recognize this implicitly in requiring the operator to cooperate with
emergency authorities and to assist in emergency response. The open
ended nature of an operator's liability with regard to external exposures,
and also the need for objectivity in assessments, such as in water quality
analysis, have a predictably inhibiting effect on external action. The
phenomenon of inhibited reaction is a well known result of legal
liability proceedings. Such reluctance has led some states to pass
"good Samaritan" laws in order to compensate for any reluctance of action
in this area. Thus, those standards for external action which are expected
to be more effective are those where the ability of the operator to assist
external actions (provide extra breathing equipment, pump and collect
leachate, etc.) can be enhanced by pre-planning.
External response standards for facilities may in several cases
be effectively combined with those for transportation, although this
combination has not been considered in the standards. An operator has
no requirement to mitigate spill of materials carried by an independent
transporter, even though the incident might be outside his gate - thirty
feet away. Nevertheless, the advantage in mutual agreements for
assistance between operators is apparent. Agreements in the petroleum
industry are common and have been executed to avoid just such a problem.
By enabling those providing assistance to have expectation of financial
recovery, and to be held harmless from liability for situations for
which another operator is legally responsible, make mutual external
response agreements viable. This pattern should also be workable in
the hazardous waste disposal industry as it has been in the petroleum
industry.
Contingency plan actions resulting in facility shutdown raise
some concern for public hazard exposure at the generator site. At present,
a generator may not be covered by the provisions of the Act, if his normal
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storage inventory of waste does not exceed the limits to be specified.
If the generator's waste disposer is shut-in, there is no mechanism to
prevent build-up of the inventory to abnormal or dangerous levels.
Widespread exposure in the event of accident at the generator's facility
may certainly be possible.
The costs from the Response and Recovery standards are the
most variable of any of the four groups. The primary reason for such
variance is the magnitude and type of non-routine spill will control
the overall magnitude of control/cleanup costs. Spills into the
subsurface, for example, will be both more costly and time consuming
as compared to surface spills. The advantages of a quick and organized
response to an event will be measured primarily in terms of basic
protection to public health and environment. Costs for the most basic
response and recovery contingency plan will be greater than $0.25/ton
Evaluation
This first set of contingency plan standards contains a minimal
number of standard requirements. As such, it closely resembles regula-
tions in effect or under consideration in several states. The effectiveness
of this type of regulatory approach relies primarily on the competence
of permit granting authority in evaluating the effectiveness of proposed
plans. The most important advantage in the set of standards would be
the ability of the standards to cover a wide range of facility types and
sizes. In addition, administrative and other costs are kept at a minimum.
The major disadvantage of the approach may be the lack of guidance provided
to the facility operators in preparing specific contingency plans for
their facility.
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CONTINGENCY SET #2
The 2nd set of standards is addressed primarily to facilities with
incinerators. It specifically includes requirements for airborne dispersion
modeling. Specific requirements in all four standards areas (organization,
communication, assessment, and response and recovery) have been detailed to
a greater degree. This approach reflects a facility oriented regulatory
strategy, and addresses a number of specific contingency plan operational
requirements.
The advantages and disadvantages for the areas of organization,
communication, assessment and response/recovery have been discussed in Set #1
along with general costs. Costs outlined in Set #1 would be applicable in
addition to costs incurred by supplemental standards. The greatest number of
these standards are in the area of response and recovery. A 10% increase in
overall costs for this area is expected which may be on the order of $0.30 to
$0.50/ton. A listing of Standards follows on the next page and includes
applicable strategies.
Evaluation
The standards in this set are markedly more specific and stringent
that those presented in Set #1. The additional standards may increase the
effectiveness of public health protection and environmental protection. An
additional advantage of the specific contingency plan standard requirements
is the relative ease of determining compliance of submitted plans based on
the regulation standards. The major disadvantage of this regulatory approach
is a lack of flexibility. Unless provisions were made to enable the granting
of variances to certain facilities from full compliance with the regulations,
the requirements might prove to be excessive for many facilities, particularly
the smaller operations. Such possible over-regulation presents the threat
of suits claiming that the regulations may be "arbitrary and capricious".
In summary, the more detailed regulations presented in Set #2 result in
minimal cost increases but may provide a greater protection potential for
public health and the environment.
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CONTINGENCY PLAN STANDARDS
SET #2
ORGANIZATIONAL STANDARDS
1. Standard for Requiring a Contingency Plan
2. Filing the Contingency Plan
3. Defining Civil Authority
4. Defining Internal Authority
5. Response to Emergency Inquiry
6. Facility Contingency Equipment Standards
7. Information on Exposure Symptoms and Treatment
9. Training and Drills
COMMUNICATION STANDARDS
1. Pre-Contingency Notification of Nature of Hazards
2. Emergency Communication Equipment
3. Internal Alarms
4. Notification of Required Agencies
ASSESSMENT STANDARDS
1. Airborne Dispersion Model
3. Identification of Material
4. Source and Extent of Release
5. Atmospheric Release Assessment
7. Fire Assessment
RESPONSE AND RECOVERY
Notification of Release
1. (Activate Alarms)
2. (Notify Agencies immediately)
3. (Initial Report)
4. (Final Report)
Shut-Down
5. (Switching Mechanisms)
6. (Personnel Designated)
7. (Monitor Releases)
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Evacuation
8, (Notify Agencies)
9. (Begin Evacuation)
10. (Evacuation Procedures)
Monitor and Delimit Affected Area
11. (Secure Entry)
12. (Monitoring Program)
13. (Sample Analysis)
Collection and/or Containment of Waste
14. (Secure Area)
15. (Initiate Containment)
16. (Emergency Storage Area)
17. (Collection and Containment)
18. (Handling of Wastes)
19. (Clean-up Emergency Equipment)
20. (Integrity of Containment Equipment)
Continued Assessment of Affected Area
21. (Monitoring)
22. (Monthly Reports)
Personnel Availability
23. (Qualified Personnel on Site)
24. (Qualified Personnel Availability)
Medical Assistance and Treatment
25. (Physician and Medical Equipment)
26. (Emergency Assistance)
27. (Treatments for Exposure)
28. (Decontamination Equipment)
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Fire-Fighting and Prevention
29. (Fire Alarm)
30. (Initial Response)
31. (Explosive Materials)
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CONTINGENCY SET #3
This 3rd set of standards is directed toward contingency plan
standards for facilities which primarily utilize land burial and/or
lagooning. The set resembles Set #2 with respect to the level of stringency
associated with the standards. While the response and recovery standards
are for the most part flexible, a modeling requirement for assessing water-
born movement of accidentally released wastes is addressed. Again, a
facility-type regulatory strategy is employed; both specific and flexible
standards are included in the Set on the following page.
Costs for Set #3 would be very similar to those associated with
Set #2 and, therefore, about 10% greater than Set #1. Advantages of this
set also mirror the advantages of Set #2.
Evaluation
This set represents a thorough treatment of standards to ensure
greater protection of human safety and the environment from accidents
occurring at facilities employing land burial*or lagooning. Most hazardous
waste facilities will likely be of this type. A combination of specific
and flexible requirements are included in the Set. As with the standards
presented in Set #2, some provision must be made to enable granting of
variances to certain facilities deemed exempt from certain requirements,
particularly small facilities. Nevertheless, the inclusion of specific
standards enables an easier measure of compliance during review of
contingency plans by the permit granting authority.
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CONTINGENCY PLAN STANDARDS
SET #3
ORGANIZATIONAL STANDARDS
1. Standard for Requiring a Contingency Plan
2. Filing the Contingency Plan
3. Defining Civil Authority
4. Defining Internal Authority
5. Response to Emergency Inquiry
6. Facility Contingency Equipment Standards
7. Information on Exposure Symptoms and Treatment
8. Inactive Sites
9. Training and Drills
COMMUNICATION STANDARDS
1. Pre-Contingency Notification of Nature of Hazards
2. Emergency Communication Equipment
3. Internal Alarms
4. Notification "of Required Agencies
ASSESSMENT STANDARDS
2. Waterborne Dispersion Model
3. Identification of Material
4. Source and Extent of Release
6. Waterborne Release Assessment
7. Fire Assessment
RESPONSE AND RECOVERY
Notification of Release
1. (Activate Alarms)
2. (Notify Agencies immediately)
3. (Initial Report)
4. (Final Report)
Evacuation
8. (Notify Agencies)
9. (Begin Evacuation)
10. (Evacuation Procedures)
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Monitor and Delimit Affected Area
11. (Secure Entry)
12. (Monitoring Program)
13. (Sample Analysis)
Collection and/or Containment of Waste
14. (Secure Area)
15. (Initiate Containment)
16. (Emergency Storage Area)
17. (Collection and Containment)
18. (Handling of Wastes)
19. (Clean-up Emergency Equipment)
20. (Integrity of Containment Equipment)
Continued Assessment of Affected Areas
21. (Monitoring)
22. (Monthly Reports)
Personnel Availability
23. (Qualified Personnel on Site)
24. (Qualified Personnel Availability)
Medical Assistance and Treatment
25. (Physician and Medical Equipment)
26. (Emergency Assistance)
27. (Treatments for Exposure)
28. (Decontamination Equipment)
Fire-Fighting and Prevention
29. ( Fire Alarm)
30. ( Initial Response)
31. ( Explosive Materials)
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Ohio Environmental Protection Agency, 1974,
Emergency Response Annual Report. OEPA.
Ottinger, R. S., and others, 1973, Recommended
Methods of Reduction, Neutralization, Recovery,
or Disposal of Hazardous Waste, 16 volumes.
U. S. Environmental Protection Agency,
EPA-670/2-73-053C.
Perry, Robert H.(ed), 1973, Chemical Engineers
Handbook. McGraw-Hill Book Company, 5th ed.
Peters, Gerald 0., Levin, James, and Thomas, Peter,
1977, Assessment of Industrial Hazardous Waste
Practices - Electronic Components Manufacturing
Industry. United States Environmental Protection
Agency, SW-140c.
Pilie, R. J., and others, 1975, Methods to Treat, Control
and Monitor Spilled Hazardous Materials. U. S.
Environmental Protection Agency, EPA-670/2-75-042.
Powers, P. W., 1976, How to Dispose of Toxic Substance
and Industrial Wastes. Noyes Data Corporation,
Park Ridge, New Jersey.
213
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Resources Research, Incorporated, 1972, Accident Episode
Manual. U. S. Environmental Protection Agency,
APTD-1114.
Rosenberg, D. G., and others, 1976, Assessment of
Hazardous Waste Practices. In the Petroleum
Refining INdustry. United States Environmental
Protection Agency, SW-129c.
Shuster, Kenneth A., 1976a, Case Study of the Sayville
Solid Waste Disposal Site in Islip (Long Island),
New York. United States Environmental Protection
Agency, SW-509.
, 1976b, Case Study of the Fox
Valley Solid Waste Disposal Site in Aurora, Illinois.
United States Environmental Protection Agency,
SW-514.
, 1976c, Case Study of the Peoples
Avenue Solid Waste Disposal Site in Rockford,
Illinois. United States Environmental Protection
Agency, SW-517.
Straus, M. A., 1977, Hazardous Waste Management Facilities
in the United States - 1977. U. S. Environmental
Protection Agency, SW-146.3.
U. S. Environmental Protection Agency, 1973, Ground
Water Pollution From Subsurface Excavations.
USEPA, EPA-430/9-73-012.
, 1974
Report to Congress - Disposal of Hazardous Wastes.
USEPA.
, 1975a,
Hazardous Wastes Damage Inventory. USEPA, open-file report,
, 1975b,
Hazardous Waste Disposal Damage Reports, Document No. 2.
USEPA, SW-151.2, p.5-8.
, 1975c, Hazardous
Waste Disposal Damage Report. USEPA, SW-151.
, 1975d, Examples
of Damage Incidents from Improper Disposal of
Industrial Wastes in Washington. USEPA, open file report,
, 1975e, Examples
of Damage Incidents from Improper Disposal of
Industrial Wastes in New Jersey. USEPA, open file report.
214
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U. S. Environmental Protection Agency, 1975f, State
Program Implementation Guide - Hazardous Waste
Surveys. USEPA.
, 1975g,
Assessment of Industrial Hazardous Waste
Practice - Inorganic Chemicals Industry.
USEPA, SW-104C.
_, 1975h,
Assessment of Industrial Hazardous Waste
Practices - Storage and Primary Batteries
Industries. USEPA, SW-102c.
, 1975j,
Third Report to Congress - Resource Recovery
and Waste Reduction, USEPA, SW-161.
, 1976a,
Hazardous Waste Disposal Damage Report,
Document No. 3. USEPA, SW-15.3, p.10-12.
, 1976b, Examples
of Damage Incidents from Improper Disposal of
Industrial Wastes in Wisconsin. USEPA, open file report.
, 1976c,
Pharmaceutical Industry-Hazardous Waste Generation,
Treatment, and Disposal. USEPA, SW-508.
, 1976d,
Solid Waste Management Available Information
Materials. USEPA.
, 1976e,
Assessment of Industrial Hazardous Waste Practices -
Paint and Allied Products Industry Control Solvent
Reclaiming Operations and Factory Application of
Coatings. USEPA, SW-119c.
, 1976f,
Assessment of Hazardous Waste Practices -
Organic Chemicals, Pesticides and Explosives
Industries. USEPA, SW-118c.
, 1976g,
Solid Waste Management Available Information
Materials. USEPA, SW-58.J6.
, 1976h,
Proceedings of the Fourth National Congress -
Waste Management Technology and Resource &
Energy Recovery. USEPA, SW-8p.
215
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U. S. Environmental Protection Agency, 1976i, Hazardous
Waste Disposal Damage Reports, Document No. 3.
USEPA, SW-151.3.
, 1976j, A Manual
of Laws, Regulations, and Institutions for Control
of Ground Water Pollution. USEPA.
, 1977a,Draft of
OHM-TADS System Classificiations. Private
Communication with Jan Rogers, Atlanta Office
of the Environmental Protection Agency, Office of
Oil and Hazardous Materials, July 1977.
U. S. Nuclear Regulatory Commission, 1977, Regulatory
Guide 1.101 - Emergency Planning for Nuclear
Power Plants. U.S.NRC.
Waldrop, P., 1976, State Hazardous Waste Regulations
and Legislation: A Synopsis of Information on
Seven Selected States. U. S. Environmental
Protection Agency, SW-530.
Wapora, Inc., 1976, Analysis of the Variation in the
Charges for Treatment and Disposal of Hazardous
Wastes. U. S. Environmental Protection Agency.
Williams, R., and others, 1976, Economic Assessment
of Potential Hazardous Waste Control - Guidelines
for the Inorganic Chemicals Industry. United States
Environmental Protection Agency, SW-134c.
216
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Chapter IV
TRAINING AND CERTIFICATION
This chapter deals with the separate but related issues of
training and certification of hazardous waste management site operators
or employees. Training is designed to assure that the appropriate
personnel will possess the specific skills and knowledge required to
carry out their responsibilities effectively and safely, including
contingency plan implementation and record keeping. Certification
provides the authorities with assurance that the requisite skill and
knowledge levels are held by the employees on a continuing basis. A
key issue, if both the training and certification functions are to be
included in the EPA Resource Conservation and Recovery Act regulatory
program, is the degree to which the certification program should be
linked to the training program. An independent certification program
will have, for example, an examination schedule of its own. Certification
linked to a training program might require only that a certificate be
filed with the regulatory authority attesting that an employee successfully
completed the training course.
A second key issue is whether all hazardous waste management
operators will have to undergo training and be certified, or whether
experienced operators will be exempted from either or both requirements
through "grandfather clause" provisions. This is a stipulation that
personnel who have been carrying out the responsibilities for a specified
number of years may continue to do so without having to meet the new
formal training and certification requirements which are to apply to new
entrants to the field.
The first section of this chapter summarizes the background
of the problem. Unlike the other questions examined in this study,
recommendations are made in this chapter, in the second section for
training and in the third for certification. The fourth section examines
the costs of the training and certification schemes recommended. The
fifth section discusses alternative certification agencies.
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A. Statement of the Problem
Section 3004(6) of the Resource Conservation and Recovery Act
of 1976 requires that standards be implemented regarding training for
hazardous waste facility personnel, as may be necessary or desirable to
protect human health and the environment. Personnel in the hazardous
waste mana cement industry must perform their tasks in a consistently
competent manner in order to assure public health and safety and to pro-
tect the environment. Many of the jobs associated with hazardous waste
management require high skill levels. Clearly, training in these jobs
is essential, whether it is acquired on the job and through experience,
or through a formal course of instruction.
Certification is a common method used to document the amount
and type of training that individuals have received and the skills they
possess, and can be used in a regulatory program to ensure that individuals
charged with specific responsibilities have this requisite training and
competence. Because certification requires an assessment of the training
acquired and skills possessed by an individual, it is easy to link
certification to training where training is provided through formal, channels,
scuh as a classroom, or a training workshop. But where training has been
informal, gained on-the-job, or through experience, or where training
will provide only some of the required skills, certification linked to
training course completion may be quite inadequate.
Where formal training requirements are implemented certification
is effectively a concommitant requirement, if the training is to be
verified and enforced. Course-work and training certification may be
included in a larger certification program, also requiring separate
examination and periodic updates, for example.
A motivated, knowledgeable work force is needed to meet
hazardous waste management permit conditions. This is especially true
at a landfill site where hazardous materials are disposed of under a
covering of earth. The performance of such facilities is difficult to
judge. There may be no product stream as in a liquid waste treatment
218
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plant or incineration facility by which performance can be measured.
Thus, the personnel at such facilities must perform their jobs with
certain minimum levels of competence, knowing that their actions can
affect their own personal health and the welfare of the community for
decades.
The subject of certification has elicited many responses from
the hazardous waste management industry. The proposal that facility
operators would be obliged to qualify under a mandatory certification
program received overwhelmingly negative comments. The recurring theme of
these comments was that meeting the performance standards to be established
by EPA was an adequate measure of training, obviating the need for a
certification program. An additional objection centered on the feasibility
of a certification program given the many types of wastes involved, the
variations in methods and systems of disposal, and the greater role of pri-
vate enterprise in hazardous waste management as contrasted with waste water
treatment (this last factor making proposed certification much different
than the situation facing the PL 92-500 Grant Program). It seems clear
that a mandatory certification program for facility operators would have
to overcome strong objections from the hazardous waste management industry.
A major question concerning the usefulness of a certification
program is the extent to which it brings additional assurance of safety
to the hazardous waste management programs other mechanisms in the
program work toward the same goal: 1) training programs are designed
to provide a competent, knowledgeable work force; 2) performance standards
are designed to provide environmentally sound operation; 3) operator's
permit conditions provide an overall framework; and 4) contingency plans
provide for proper response to emergencies and/or accidents. It can be
argued that requirements in these areas may eliminate the need for
certification.
Competition for reduced insurance premiums provides another
incentive for accomplishing the same goals as certification, .-the inter-
action between the hazardous waste manager trying to demonstrate competent
operation in order to lower its premium rate and an insurer attempting to
219
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evaluate the risks of an operation, could lead.to a review framework
similar to a certification program.
The main arguments for a training and independent certification
program focus on the inherent hazardousness of the material being handled
and on the current status of the industry. Though an independent certifi-
cation program may only present a minor incremental margin of safety,
given the operational requirements, inspections, monitoring, and
contingency plans that will also be required, it is one that may orove
cost-effective given the possible damage that an unintended release could
cause. The industry is in an embryonic form: its personnel are often new
to the business and new requirements are being made of the operators in
the areas that they may have no experience in. The current range of
capabilities found in the industry vary widely, from well managed,
sophisticated, responsible companies to antiquated land fills, to fly-by-
night illegal dumpers. A strong training and certification program will
help raise and unify standards and help eliminate the incompetent from
what is likely to prove an increasingly demanding and sophisticated
industry.
The RCRA regulations will result in better planning, design,
and operation of hazardous waste facilities. This should go a long way
toward reducing risk and raising the level of owner and operator competence.
Nevertheless, a well planned and designed facility, which will be required
by strict permit requirements, does not insure the facility will be
operated and maintained to function in the manner for which it was planned
and designed. It is important to build in the same safeguards and level
of competence in the operators of the facility as in the basic physical
facility itself.
A training and an independent certification program is recommended
for the hazardous waste management industry. The costs of the program are
likely to prove small compared to the increase in safety and industry
responsibility that should result from the program. A grandfather clause
should be included for the training program, but all operators should have
to meet the same certification requirements.
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B. A Training Program for the Hazardous Waste Industry
The industry is new and lacks established procedures and
practices which could provide an effective means to provide formal
training for new personnel. It lacks industrial structure, i.e., relation-
ships between generators of raw materials, equipment suppliers, management,
workers, professional organizations, regulators, etc., which would
provide a context for new personnel training. Because of this, it is
necessary to have a more deliberate approach in developing training
programs.
While the newness of the industry is a handicap in one sense,
it is an opportunity in another. Effective training programs can be
implemented more readily at this beginning stage than at later stages
when routines and behavior patterns are established.
Factors Relevant to Training Program Development
Because of the opportunity for development of a completely
new hazardous waste training program, special attention is warranted
toward factors usually given less consideration. Some of these factors
are enumerated below. They include:
(1) Program Development. A program is an organized effort to
promote some end. It is not a single act. Training is a long-term commit-
ment and must be developed and carried forth as a program. It cannot be
successful if it is only a limited effort. As a program becomes insti-
tutionalized, it acquires its own momentum. In the beginning stages,
however, considerable effort will be required to keep it going.
(2) Institutionalization. For a training program, the process
of institutionalization includes: the development of organizational entities
to manage the training activity; the assurance of continuing financial
support; the continuing support of management; the emergence of a body of
peers, and official sanctioning bodies; the emergence of ceremonies for
the receipt of certificates and awards and the regular occurrence of commen-
surate social functions, etc. This process may require several years or
221
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even decades to develop. While proper nurturing may let it happen at a
faster pace, it cannot be forced, and must be given time to occur.
(3) Support. The training program must be supported fully by
management and by all personnel involved (i.e., those persons who interact
on the job with the trainee, those supervising and teaching, and those
who are the trainees).
(4) Logistics. A training program requires deliberate management
with attention given to such items as budget, instructors, facilities, and
time allotment for trainee participation.
(5) Substantive Content. The specific training should be
designed carefully to relate to the tasks of the job in both curriculum
and specific course content. Further, the relationships between the
learning and job tasks should be evident to the trainee.
(6) Modes of Training and Media. Training can take place in
the classroom, on the job, by correspondence, by video tapes, etc. An
attempt should be made to match budget, training mode, and effectiveness.
This may require more attention in the hazardous wastes area since there
may exist only limited precedents for the mode of training selected.
For example, the video tape self-teaching exams mode, discussed below, may
appear to be appropriate for a hazardous wastes training program. But
the video tape technology for such use is new and so there are not many
existing situations to confirm this assessment.
The success of any training program will depend upon how well
these factors are considered. It is important not to expect too much too
fast. The institutionalization must be given a chance to develop.
Training Program
A training program may not be successful on a national basis unless
it can be implemented easily by the hazardous wastes industry. Since the
industry is new and there is no structure to support it, federal involvement
to develop the training materials would be advisable. To determine the
feasibility of the development and implementation of a training program on
222
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a national basis, a model training program was designed; the complete
design outline is presented in Appendix 7 while an overview of the overall
program is seen in Table 26.
The model training program consists of seven modules. The
modules are developed along the lines of a "need to know" theme, advocated
by the Association of Boards of Certification (ABC) group (which is
active in water and wastewater treatment training standardization, as
described below). The seven modules are intended to fit together as an
integrated, comprehensive, and complete training program.
Module 1 starts with a basic orientation about the problem of
hazardous wastes and the relevant legislation which controls their disposal.
The module has both "basic" and "in-depth" phases. The basic phase provides
essential information necessary for all personnel. The in-depth phase is
intended for the supervisory level and requires reading of the relevant
laws, regulations and other pertinent reference material.
Module 2 provides training on good practices for hazardous wastes
handling. Again, it has both basic and in-depth phases.
Module 3 has three options: treatment, storage, and disposal.
It reviews the specific procedures for handling hazardous wastes which are
unique to the respective type of facility discussed. Only the option or
options associated with the facility of employment would be required.
Module 4 is site-specific training and would be taught by the
superintendent of the facility or his assistant. It relates to specific
procedures in dealing with hazardous wastes which are unique to the
particular site.
Modules 5 provides an applied review of the relevant scientific
principles which are pertinent to the facility operation. This module
should be available to supplement other levels of training where necessary,
but would not necessarily be required for any individual.
223
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Module 6 reviews some of the topics which most personnel would
be expected to know prior to working at a hazardous wastes facility. It
is a package designed to provide the necessary information for remedial
work.
Module 7 is the continuing training module. The specific content
of this module would be determined by the superintendent of the faciUty.
It could include a variety of topics. Also, the training mode for each
topic could be designed to fit the circumstances. Contingency plan drills,
attendance at short courses, on the job instruction, etc., are examples
of training activities appropriate for this module. A minimum number of
hours of training in this module would be expected annually.
To circumvent the problem of insufficient institutionalization
to carry out a program, as proposed in Table 26 and Appendix 7, the use
of video tapes is advocated for those modules where the nature of the
training is not site-specific. There are many advantages to such a system.
The equipment involved is cheap and easy to use. Also, the tapes can be
viewed at the convenience of the trainee, obviating the need for a more
formal setting. They can be viewed as many times as desired. The self-
teaching examinations would complement the tapes and would be taken as many
times as is necessary to develop the trainee's knowledge to an adequate
level. Further, a formal classroom format could be used occasionally to
complement the video tape and self-teaching exams format. The video tape
scheme also concentrates the "front end" costs in an initial effort to
produce the tapes. Further, there can be some assurance that minimal
training standards are promulgated throughout the country.
The major conclusions of this investigation is that a training
program for hazardous wastes handling is feasible if done along the lines
outlined in Table 26 and Appendix 7. The program must be relatively
easy to implement and administer and be capable of implementation by the
industry as it develops. The module concept of training which uses the
video tape media has these characteristics.
225
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C. A Certification Program for the Hazardous Waste Management Industry
Two alternative programs of certification are presented: one
comprehensive, and one limited. The comprehensive program provides for
training and certification for all hazardous waste management employees
appropriate to the level of technical knowledge and the degree of
responsibility required of the candidate. The limited program is a
mandatory certification scheme, which applies only at the management
level.
As noted above, an independent certification program is
recommended for the hazardous waste management industry. Two program
alternatives are considered here: a comprehensive certification
program, and a limited one.
There are two existing certification programs that are analogous
to the proposed hazardous waste management, certification program. They
are the pesticide certification program and the waste water treatment
program that operates under the Association of Boards of Certification
(ABC) Program. Pesticide certification is an example of a federally
administered program. The Association of Boards of Certification is an
example of a collection of state administered programs aided by the EPA.
The following discussion explains the workings of these two programs.
The Association of Boards of Certification (ABC)
EPA involvement in certification of waste water operators stemmed
from the need to assure competent operation of waste water facilities for
the protection of public health and environment. In 1972, EPA went to
appropriate trade associations and together they developed the ABC. This
board was to certify municipal waste water treatment plant operators only.
Twenty thousand dollars was provided by EPA for a "start up" fund. The
general objectives of the ABC were: 1) improvements in operator certifi-
cation laws; 2) promotion of operator certification as a means to
accomplish #1; 3) standardization of state regulations so operators could
transfer state to state; 4) development of a uniform examination; 5)
assistance to new boards. The federal agency that was designated the
226
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focal point for operator certification functions was the Municipal Permits
and Operations Division, Office of Water Program Operations. In general
terms, this office provided technical assistance and project grant support
funds. The central theme of EPA involvement was contained in a 1975 state-
ment made at an ABC/Tri-Regional Certification Meeting in New York City:
"Through cooperative efforts with ABC, EPA goes on record in support of a
nationally recognized authority for assisting state certification programs
in program upgrade and development and for the adoption of mandatory
certification programs by individual states."
In 1977, the ABC program is in 47 states, the Department of
Defense, and the Park Service and has affiliations with several foreign
countries. Two states have mandatory programs while the others have a
voluntary program. ABC outputs include: 1) design of a model law;
2) classification of facilities and operators; 3} creation of a program
guide and training manual; 4) establishment of examination criteria. While
the program is still focused on municipal operators, there is a trend to-
ward certification of industrial operators as well. Formerly, many indus-
trial operations cooperated with the ABC particularly in the area of
exchange of professional information. Now many states are involved in
certifying industrial operators. The State of Michigan is the most
advanced in this. Their proposed legislation requiring industrial cer-
tification is designed to license and regulate persons engaged in removing
and disposing of liquid waste; to provide for the inspection and licensing
of equipment; and to provide for the control over the disposal of liquid
waste. As such, it is very similar to the procedure for certifying muni-
cipal operators.
Three major problems have inhibited the effectiveness of the ABC:
1) inability or unwillingness of many states to revise or enact new legis-
lation or requirements to conform to ABC guidance; 2) inability or unwilling-
ness of many states to effectively administer and enforce current certi-
fication programs; 3) inability or unwillingness of state certification
227
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examinations to meet legal questions of job relevance and validity,
predicated on criteria established by the Equal Employment Opportunity
Commission and the Department of Justice, Division of Civil Rights.
The ABC is an example of a certification program funded but
not administered by EPA. At the inception, EPA did not want to administer
a national exam or a certification program, but wanted rather to endorse
an independent entity to manage mandatory programs.
Cooperation with trade associations in the establishment of
the ABC has largely accomplished these goals. EPA has presented recommen-
dations and relied upon the tool of persuasion, resulting in voluntary
cooperation in dealing with the ABC. A key reason for the success of
the program has been the continuity of EPA personnel who have dealt with
the ABC. This has allowed a growth in confidence and mutual respect
between EPA and the ABC. An additional advantage occurred because the
ABC certification approach has resulted in the avoidance of criticism
and opposition which might have occurred if EPA had directly administered
the program. However, since EPA only provided a service, the certifica-
tion process may have taken longer to develop than otherwise might have
been the case.
Certification of Pesticide Applicators
Applicator certification is required by the Federal Insecticide,
Fungicide and Rodenticide Act of 1947 as amended in 1972. Section 4a of
this law describes the certification procedure: "the Administrator
shall prescribe standards for the certification of applicators of
pesticides. Such standards shall provide that to be certified, an
individual must be determined to be competent with respect to the use
and handling of pesticides, provided that the certification standard for
a private applicator shall, under a State plan submitted for approval,
be deemed fulfilled by his completing a certification form." Since 1976,
most pesticides classified for restricted use may be applied only by or
under the direct supervision of certified applicators.
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Within the 1974 amended law two types of applicators were
designated, commercial and private. Ten occupational categories for
commercial applicators were established. In developing their plans,
states may adopt, delete or alter these categories as needed. States
may also request the EPA administrator's approval to add major categories
to meet local conditions. Written examinations and, as appropriate,
performance testing is used to determine the competence of commercial
applicators. Testing is based on examples of problems and situations
pertaining to the particular category of the applicator's certification
and includes the following areas: 1) label and labeling comprehension;
2) safety; 3) environmental factors and the consequence of use and
misuse of pesticides; 4) knowledge of pests; 5) knowledge of pesticides
and types of formulation including hazards associated with residues;
6) equipment use; 7) application techniques; 8) applicable State and
Federal laws and regulations.
The certification requirements for private applicators have a
different emphasis. A private applicator must show that he possesses a
practical knowledge of pest problems associated with his agricultural
operation, plus the proper storage, use, handling and disposal procedures.
This practical knowledge includes the ability to: 1) recognize common
pests and pest damage; 2) read and understand labels and labeling infor-
mation; 3) apply pesticides in accordance with label instructions;
4) recognize local environmental situations; 5) recognize poisoning
situations and know what to do in case of an accident. Competence of
private applicators is verified by the responsible state agency using
a system to ensure that such persons are qualified to use restricted
pesticide products.
Although EPA was given the responsibility for developing and
publishing standards of competence, the amended law reflects Congressional
intent that States assume primary responsibility for certification of
applicators. State certification plans must be reviewed and approved by
EPA.
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The Pesticide Applicators Certification Program is an example
of a Congressionally mandated EPA administered program. EPA works in
cooperation with the trade associations, primarily the National Pesticide
Control Association. Difficulties have arisen in convincing states
that trade associations can make valuable contributions to the certifica-
tion procedure. Another problem has involved establishing reciprocity
among the state certification programs. Intragovernmental cooperation
exists in that the U.S. Department of Agriculture is given EPA funds to
run training programs. The regulatory officers involved with certification
have received moderate cooperation from the private and commercial sector.
Most of the opposition to the program has focused on the enforcement
agencies.
Hazardous Haste Certification Needs and the Pesticide and Waste Water
Certification Programs
The preceeding discussion of existing certification programs
presented some variables that differ from the hazardous waste management
«
program proposed below, and some that are similar. The hazardous waste
management law does not specifically require certification; the pesticide
law does. As in the hazardous waste area, a classification scheme was
necessary to distinguish types of operators in pesticide application. The
ten class system for commercial applicators was based on different types
of application needs (e.g. forest pest control crop pest control). A
hazardous waste certification program would need an analogous classifica-
tion scheme based on facility types (e.g. incineration, landfill). The
problems of reciprocity among states, differences in state laws and
enforcement procedures and opposition from the private sector can be
expected to occur in any certification procedure.
The ABC had to deal with a wide variety of facility types and
is thus analogous in this respect to hazardous waste certification. But
waste water engineering practices are much older than hazardous waste
230
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practices and thus certification procedures had a much deeper experience
base to draw on. Another dissimilarity is the contribution to the success
of the ABC made by the continuity of EPA personnel associated with the
ABC Program. This fortunate circumstance cannot be planned on in designing
a hazardous waste certification program.
Comprehensive Certification Program
The proposed comprehensive program for certification has four
basic elements: education, training, examination, and experience.
Further, the program requires certification at all levels, from laborer
to superintendent. The certification requirements covering these four
basic areas and each of the levels of personnel working in the facility
are summarized in Table 27. The training and examination elements of
the Comprehensive Program utilize the modular training program outlined in
Table 26 and Appendix 7. Table 28 defines the tasks associated with
each of the positions referenced in Table 27.
The education requirements shown in Table 27 are suggested
entry level requirements. Personnel could be expected to upgrade from
one certification class to a higher class without attaining the entry
level education requirements for that class. Also, experience could be
substituted for education.
Laborers would be required to become certified at the Class D
level soon after they are hired. The certificate would be valid only for
a specific facility. If the place of employment were changed, recerti-
fication would be required. As is illustrated in Table 28, Class C and
D certification does not entail an examination upon completion of training.
The required training could be administered by any Class A operator,
either on site or in a formal classroom situation.
Personnel certified at Classes A, and B would be required to
pass an examination appropriate to that level. Candidates for these
classes would be eligible for certification after they had worked six
months in a position requiring such a certification level. Certification
would be required within eighteen months of assuming that position. Class
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Table 28
Tasks Associated With Various Positions
or a Hazardous Wastes Processing Facility
Job Title
Tasks
Responsible Person
in Charge
Superintendent
Supervisor/Foreman
Has legal responsibility for operation of facility.
Qualified to start up, manage, and supervise the
operation of a facility
Qualified to supervise a particular unit of opera-
tion of set of unit operations of a facility.
Operator
Laborer
Qualified to operate machinery, equipment, and
processes of a facility.
Qualified to perform tasks as directed but not to
operate.
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A, B, and C certificates should be renewed periodically, e.g. every three
or five years. The requirement for certificate renewal could be satisfied
by a specified number of hours of training in Module 7.
One unique feature of this certification scheme is that those
in the professional levels of planning and design be required to take
certain familiarization training to make them fully aware of the hazardous
waste industry and its facilities. This is advantageous because of the
diversity of backgrounds of various professional engineers, who, while
they may possess the basic knowledge required, may lack specific instruc-
tion in the design and operation of hazardous waste facilities. This
instruction is important because of possible risk to public health and
welfare. The training specified in Modules 1 through 4 would be
particularly appropriate for site designers and engineers. While there
would not be an examination requirement for those professionals, a training
program should be strongly encouraged. Of course, professional engineers
would have to continue to be licensed in their engineering specialties
as they now are.
The certification scheme of the Comprehensive Program is
designed for flexibility in fitting the present variety of treatment and
disposal site management practices. It is intended that job titles and
appropriate certification requirements be stated in the site permit
application and approved by the permitting authority. There should be at
least one Class B certified person on each site, even if it is a one
person operation. Certification of at least one on-site person at the
Class A level should be encouraged.
The position of responsible person in charge (RFC) has been
adopted from similar designations in the water and wastewater industry.
The RFC would have legal responsibility for the operation and maintenance
of the site. This person should be designated in the facility permit.
The RPC may serve as Superintendent when the position exists, or may be
the manager or owner to whom the Superintendent would report.
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The advantages of this comprehensive scheme are:
1. Competent operation of a facility by personnel who possess
the necessary qualifications, (i.e. education, training,
and experience,) would ensure the consistently effective
performance of the facility.
2. A career pattern for operating personnel is formalized,
which helps to foster a professional attitude and reduce
personnel turnover.
3. Documentation of training and experience levels commensurate
with insurance requirements is simplified.
4. The existence of uniform standards for personnel qualifica-
tions greatly simplifies enforcement.
The disadvantages, relative to the Limited Program, outlined
below, are:
1. The program wo*uld be administratively more cumbersome.
2. The costs would be greater.
3. The program would be large for the relatively small number
of facilities and personnel involved in the industry
nationwide.
Limited Certification Program
The Limited Certification Program is intended to be a minimum
recommended certification scheme. Under this scheme an RPC would be
designated, who would be required to complete all the requirements for a
Class A certification under the Comprehensive Program. While certifica-
tion would be limited, the training program should be developed for
general distribution as outlined in Table 26 and Appendix A. Voluntary
participation in the training program should be encouraged and a program of
voluntary certification at other levels below Class A could be established.
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The advantages of this program are:
1. It assures ease of implementation due to reduced training and
administrative efforts and logistic requirements.
2. The program would be less costly to implement.
3. It provides the possibility for the implementation of a more
comprehensive program which could follow at a later date.
The disadvantages are:
1. A career pattern is not established, which may result in
rather high turnover rates of personnel.
2. There would be less assurance of consistent facility
performance at a level which meets the requirements estab-
lished by regulatory agencies, for the protection of public
health and welfare.
Grandfather Clause Certification
Grandfather clauses have been part of many state water and
wastewater certification programs in order to make them more palatable
to the work force which would be regulated. For the same reason, there
is a strong temptation to include the recommendation of such blanket
clauses in this permit program. To do so, however, may sacrifice public
health and safety and could impair the effectiveness of the certification
program for as long as any "grandfathered" certificate holders remain in
the work force. As a compromise, it is suggested that employees already
in the industry be required to complete the above referenced formal
examination requirements, but that training modules appropriate to the
level of certification could be waived.
Summary
To ascertain the feasibility of training and certification of
personnel in the hazardous wastes management industry model, programs for
accomplishing these purposes were conceived. The model training program
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design was based upon the "need to know" theme advocated for water and
wastewater treatment operators.
The model training program designed has the following elements:
(1) The training program would be administered by the industry.
(2) The training consists of seven modules. Each module has
a special function. Together, the modules comprise a
comprehensive training program.
(3) The use of video tape cassettes, together with self
teaching examinations, is advocated as the medium for
instruction for five of the seven modules.
Two alternative certification programs were outlined. They
were: (1) a comprehensive program, and (2) a limited program. A
comprehensive certification program is prepared with a limited program
presented as a recommended absolute minimum certification. The latter
would require certification of the responsible person in charge of the
facility only. Some of the special features of the comprehensive certi-
fication program include:
(1) As a working premise, certification has four elements.
They are: education, experience, training, and examination,
(2) All personnel associated with management and operation of
hazardous wastes processing facilities would be certified.
Certification would have five levels which would correspond
to respective job requirements.
(3) The training requirements for the different levels of
certification are integrated with the training program
proposed.
(4) Certifying authority for some of the training modules may
be conferred by the state to the "responsible person in
charge" of the facility.
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Special note should be given to the fact that the form of any
training and certification programs must have an appropriate fit with the
present zero-based institutional context of the industry. A strict copy
of the present water and wastewater operators training and certification
programs probably would not work for this reason, i.e., these programs
have a well developed base of institutionalization. The video tape self-
teaching examination and strong industry role and responsibility in
training and certification is felt to be a form appropriate to the
hazardous waste monitoring industry.
D. Costs of Training and Certification Programs
Costs of Training
Any estimates of the costs of training personnel are dependent
upon the assumptions made about the nature of the training program, its
extent, and the plan for its implementation. Estimates may be based
upon comparisons with existing similar programs, or they may consist of
hypothetical budgets. The manner of implementation of the program is
another consideration, e.g. whether the training is held annually in
classrooms with outside instructors, in-house sessions, on-the-job, etc.
Further, a system of uniform accounting rules must be devised if costs
of alternative plans are assessed, e.g. if the training is in-house the
real costs of the training may be difficult to break out from other
activities.
The estimate of training costs made below is based upon the
video tape program outlined in Appendix 7. The estimate is limited to
the cost of production and delivery of the tapes for this program.
Administration of the instructional system at each facility and the
investment of employee time are on-going operating costs and are not
included.
An estimate of the costs associated with the production of a
taped lesson may be determined from identification of the tasks required,
an assignment of time in manhours for completion of the task, and the
hourly rate. Table 29 is a preliminary identification of tasks.
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Table 29
Phases and Tasks of Video Tape Lesson Production
Design of the Instruction:
Conceptualization
Detailed Lesson Plan
Graphics Design
Preparation:
Drawing, Lettering, etc.
Site Visits
Script Writing
Tape Production:
Narration
Taping
Editing
Distribution:
Tape Reproduction
Use of Tapes:
Purchase of Equipment
Self-Teaching Examination Package
Preparation of Examinations
Editing, Typing, Printing, etc.
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Table 30 provides an estimate of the studio costs of producing
a tape; the amount is $1,800. These are the "taping" and "editing" lines
in Table 29. It is probably the only cost that is constant for each
lesson. The costs associated with the complete set of tasks of Table
29 are summarized in Table 31. The total cost for a tape is $152,000,
including content design and execution and production. Using th'is cost
per tape, the total cost for 30 tapes in Modules 1, 2, 3, 5, and 6 would
amount to $4,560,000, or nearly $5 million in round numbers.
If a series of tapes are envisaged, a pilot tape should be
developed. The pilot tape not only provides a feedback but it could give
a better, i.e., more empirical, idea of costs. Some economies of scale
could also be achieved by a series of tapes.
It should be noted too that "adequate" tapes could be produced
probably for about $30,000 to $50,000 each. The $150,000 tapes would
be for "highly effective" tapes. The argument for the more expensive
effort is rather compelling if one examines the costs of not being
effective. This would be in terms of trainee manhours which may not be
utilized effectively and in terms of operation problems which would occur.
So the more expensive version would probably be more "cost-effective."
The cost per facility for the video tape approach would depend
upon the number of facilities. If 1,000 facilities existed in five years,
the cost for the tapes per installation would be $5,000. The video tape
equipment might run $2,000, giving an investment cost of $7,000. This
is not a great amount in terms of costs of other capital equipment for
these facilities. Also in terms of equivalent instructor tine and
associated efforts, the $7,000 is a rather modest investment.
Costs of Certification
A recently completed ABC staff report provides sorre basis for
estimate of the costs of administering a water ard wastewater plant
operator certification program (ABC, 1977). According ID the report,
which was based on a recent survey of existing certification programs,
the number of equivalent full time staff ranged from 0.2 to 1.5 per 1,000
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Table 30
Costs and Use of Video Tape Production Facilities
Studio Time:
Master Tape Cost:
Cost of Production of a 30
Minute Master Tape:
Cost of Duplicate Tapes:
$200/hour which includes studio and staff;
about six hours are required to produce a
30 minute tape which includes two hours
for editing.
$150/hour
Six hours @ $200/hour plus four hours @
$150/hour, or $1,800.
About $50 per cassette.
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Table 31
Cost to Produce a Typical 30 Minute Video Taped Lesson
Design of the Instruction: $ 25,000
500 hours @ $50/hour
Preparation: 100,000
2,000 hours @ $50/hour
Self-Teaching Examination Package: '
500 hours @ $50/hour
Tape Production:
$1,800 + $200 for Narration 2.000
TOTAL $152,000
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certified operators or active certificates whichever was higher. The
mean and median response was 0.7 personnel/1,000 operators. There was
a trend toward greater manpower requirements as the size of the certifi-
cation program decreased. There were 0.9 equivalent personnel/1,000
operators currently employed in programs which certify up to 1,000
operators. Only 0.6 personnel/1,000 operators were employed in programs
certifying over 3,000 operators.
There was almost universal agreement as to the need for more
staff, on the order of approximately 2-1/2 times the current level. On
the average, those responding suggested at least one full time staff per
1,000 operators for the largest programs, up to two or three per 1,000
for the smaller programs.
Because of the relatively small size of the proposed hazardous
waste certification programs, it can be assumed from the above that
approximately three full time staff personnel per 1,000 certificates
would be required to effectively administer the program. At an approximate
cost of $25,000/staff person, the total cost for the program would be
$75,000/1,000 certificates. This estimate includes costs for salary,
fringe benefits aad overhead, and assumes a mix of clerical and
professional personnel.
The above estimate is applicable to the comprehensive certi-
fication program previously proposed. Costs could be reduced
if the limited certification program were instituted. Costs per
1,000 certificates, however, would probably be greater.
E. Alternative Certifying Agencies
The foregoing discussion examines two existing certification
programs currently being used to enhance the effectiveness of environ-
mental protection legislation. This study has considered a variety of
other alternatives, most of which have characteristics that might benefit
a hazardous waste operators certification program.
In reviewing certification alternatives it has been necessary to
distinguish two separate functions that are present in most such programs:
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training and verification of competence. In some programs these are
carried out by a single organization, in some by separate organizations.
The study considered the following categories of organizations for per-
formance of one or the other, or both, of these functions:
1. The Federal Government
2. State or local government agencies
3. A trade organization or professional society
4. Academic or vocational schools
5. Employers
6. Trade unions.
The earlier discussion covered examples of two of these alter-
natives. The pesticide program is carried out directly by the Federal
Government. The ABC waste water treatment program is an affiliation of
trade organizations acting as professional societies.
The remaining categories are discussed below. In most cases
the functions described are carried out by separate organizations. For
this reason, groupings of these organizations are discussed.
State Governments/Academic and Vocational Schools
Teacher certification is an example of a widely accepted
practice in which the two functions are often separate. A typical
state certification program is based on a set of basic course require-
ments coupled with opportunities to use continuing education to establish
eligibility for higher pay status. Most states accept transcripts of
specified academic course work as proof of accomplishment. In them,
the certification process is carried out by a state agency and consists
of verifying that the course content and academic standards in the
training institution relied upon were appropriate to provide the desired
skills. Some local governments conduct examinations to establish,
independently, that the required standards have been achieved.
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Trade Unions/Local Government/Federal Government/Employer
Apprentices in craft unions take part in a variety of training
programs provided in large part by the unions under supervision of the
Federal Department of Labor Bureau of Apprenticeship Training (BAT).
Training consists of a combination of on-the-job experience that might
be considered as supplied by the employer, and formal training provided
by the union. For some skills, such as typesetters, proof of competence
is established through examinations administered by the unions under BAT
supervision and establishes the apprentice's right to the status and pay
of a journeyman. For others, particularly such building trades as plumbing
and electrical work, proof of competence also requires examination by
state or local governmental agencies to determine not only that the worker
has the requisite manual skills, but also that he is familiar with appli-
cable requirements of the building code.
Because of the uniqueness of the hazardous waste management
industry, the analysis of certification alternatives did not concentrate
on assessing the comparative success of one or another existing certifi-
cation program or the degree of similarity between waste management
certifications and existing certification programs. Instead, the eval-
uation effort sought to develop a combination of elements from existing
programs that would take into account the selective merits of uniform
interpretation of standards, the importance of ensuring interchange
between current practitioners and the certification process, and the avail-
ability and location of existing facilities and personnel for administering
the certification program.
The staff analysis resulted in the construction of a composite
of the alternatives described above. The composite certification
process would utilize course credits as partial proof of accomplishment.
The course requirements would be set by the Federal EPA or, in states
that had opted to carry out their own hazardous waste control program,
by the state agency filling a comparable regulatory role. Once the
course content had been adequately defined by the regulatory body, state
university extension services would be enlisted to undertake the proposed
series of courses. Such extension services may utilize either instructors
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drawn from state academic institutions, or may contract for the service
of individuals or organizations not connected with such institutions.
In an appropriate case, the instructor might be the director of opera-
tions for one or another of the hazardous waste management firms, and those
courses could be given on the premises.
The individual seeking certification would be required to enroll
in, attend, and pass examinations for the assigned course. The cogni-
zant regulatory agency would verify the applicant's accomplishment both
by reviewing the course content and by obtaining satisfactory documentary
proof of satisfactory course work.
The procedure outlined would give a partial national standard
to allow some mobility of workers, but be subject to the equal standard
option for individual states. It would use existing facilities and
provide an opportunity, if not a requirement, for current practitioners
to play a leading role in course formulation and instruction.
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APPENDIX 1
EXAMPLES OF INSTITUTIONS THAT PROVIDE FINANCIAL RESPONSIBILITY
AND CONTINUITY OF OPERATIONS
In examining the alternatives for the maintenance of financial
responsibility and continuity of operations by hazardous waste disposers,
we investigated potentially analogous mechanisms employed by a variety
of institutions and several pieces of federal legislation. The results
of the research were reviewed with attention focused on the basic struc-
ture rather than on the operational details. The following are:
(1) The Oil Pollution Liability and Compensation Act: An
Example of a Group Liability Fund.
(2) The Federal Deposit Insurance Corporation: An Example
of a Group Insurance Group.
(3) The Federal Savings and Loan Insurance Corporation: An
Example of a Group Insurance Fund.
(4) The Maryland Savings Share Insurance Corporation: An
Example of a Group Insurance Fund.
(5) The Mutual Central Savings Fund: An Example of a Group
Insurance Fund.
(6) The Ohio Workmen's Compensation Program: An Example of
a State Insurance Fund.
(7) The Nuclear Energy Liability - Property Insurance
Association: An Example of an Insurance Pool.
(8) The Swine Flu Program: An Example of a Type of Federal
Insurance.
(9) Federal and State Strip Mine Legislation: An Example
of Provisions for Continuity of Operations.
(10) Cemetery A: An Example of Provisions for Continuity of
Operations.
(11) Cemetery B: An Examole of Provisions for Continuity of
Operations.
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1. The Oil Pollution Liability and Compensation Act: An Example of a Group
Liability Fund
The potential for enormous damage and cleanup expenses in the
event of an oil spill from either a vessel or an on-shore facility has
prompted the search for liability protection. The Oil Pollution Liability
and Compensation Act contains elaborate provisions for establishing a fund
as well as defining the limits of liability. The proposed House Act
mandates the Secretary of Transportation and the Secretary of the Treasury
to form and administer a $200 million Comprehensive Oil Spill Liability
Fund. This fund will be made up of fees from refineries and terminals,
monies from liable parties and all monies from civil or criminal penalties
and fines. The fund is designed to pay damages and claimants in four
areas: 1) removal costs; 2) injury of property; 3) injury of natural
resources; and 4) loss of profits or impairment of earning capacity.
In addition to this funds the Secretary shall establish limits
of liability. These limits take two forms, a maximum figure for
certain facilities and a sliding scale based on type and size of vessels.
Fifty million dollars is the top figure for on shore facilities in the
former case. An example of the latter arrangement occurs with small,
inland barges where liability is set at $150 per ton of vessel.
The owner or operator of a vessel or facility must demonstrate
evidence of financial responsibility sufficient to sa'tisfy the maximum
amount of liability. Such evidence is insurance, a guarantee surety bond
or qualifications as a self-insurer.
In the event of a spill, the owner or operator of the vessel or
facility is made,in the words of the act," strictly liable for all claims
up to reasonable limits, while the owner of the oil carries the burden for
claims exceeding those limits, contributing his share through his con-
tribution to the fund."
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2. The Federal Deposit Insurance Corporation: An Example of a Group Insurance
Fund
The Federal Deposit Insurance Corporation (F.D.I.C.) was created
under the Banking Act of 1933. The deposit insurance program was intended
to restore confidence in the banking system, eliminate "runs" on banks and
protect individual depositors as well as the nation's money supply.
The Deposit Insurance Fund is supported by annual assessments
of member banks. Banks are required to file condition reports four times
per year from which F.D.I.C. averages out total yearly deposits. The
banks must pay 1/12 of 1% of these averaged total deposits. This is es-
timated for the 15,000 F.D.I.C. member banks and from this sum is deducted
administrative costs and reserves set aside for bank failures. One-third
of the remaining sum is credited to the Deposit Insurance Fund and the
other two-thirds goes to the banks as credit against next years assessment
(on a pro rata basis). The total cost of Federal Deposit Insurance, then,
to a member bank is 1/27 of 1% per year's averaged deposits.
In the event that the Fund reserves are inadequate to meet its
obligations, F.D.I.C. has a three billion dollar drawing authority from
the U.S. Treasury. In order to reimburse the fund, F.D.I.C. may liquidate
some assets or reduce (or eliminate) the amount of credit going to the
banks. F.D.I.C. does not provide minimum or maximum amount requirements
for the Fund, however studies made several years ago (when F.D.I.C. in-
creased its insurance maximum) reported that the Fund, through the years,
was "adequate" because it had kept pace with bank failures and other ex-
penses. In 1934, when F.D.I.C. was established, the ratio of insurance
fund to insured deposits was 1.61 -- today the ratio is 1.18.
If a bank fails, it is closed by the chartering agency (e.g. the
state bank agency) which names the F.D.I.C. as receiver. The F.D.I.C.
then either arranges for the purchase of the deposit liabilities (by
another bank), or arranges to pay off the depositors. This is determined
by which costs F.D.I.C. less.
249
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The greatest loss sustained by the F.D.I.C. deposit insurance
fund was upon the collapse of the U.S. National Bank in San Diego in
1974. After liquidation of all the assets (which the Crocker National
Bank did not want), F.D.I.C. lost 150 million dollars. The F.D.I.C. net
losses from all the bank failures from 1934 to 1974 totalled less than
150 million dollars.
The F.D.I.C. has six factors which they use in determining the
suitability of an applying bank. They are the following: 1) financial
history of the bank; 2) adequacy of the capital structure; 3) future
earning prospects; 4) character of the management; 5) convenience and
needs of the community to be served; and 6) consistency of the corporate
powers with the powers of the bank — i.e., it must be a corporation and
it must be a bank of deposit. The banks which have been refused member-
ship were refused largely due to management character and/or lack of
capital. The F.D.I.C. has little control over changes in management,
although there has been a bill on the Hill for several months, which
would allow the F.D.I.C. a voice in management changes.
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3. The Federal Savings and Loan Insurance Corporation: An Example of a Grr ,
Insurance Fund
The Federal Savings and Loan Insurance Corporation is the
insurance arm of the Federal Home Loan Bank Board. It was created as part
of the New Deal Legislation in 1934, under the National Housing Act,
Section 402A. F.S.L.I.C. is a government agency (all civil service),
however, it is self-supporting and receives no government appropriations.
The F.S.L.I.C. Insurance Reserve Fund (I.R.F.) now total approximately
4-1/2 billion dollars. When the corporation was established, there was
a stock issue to set up the corporation, and a percentage of that was
used to create the fund. F.S.L.I.C. requires an entrance fee of 3/10 of
1% of all insurable assets of an entering savings and loan association.
There is a yearly assessment of 1/12 of 1% of averaged deposits per
association. Neither the initial fee nor the yearly assessemnt is refund-
able. The Act creating F.S.L.I.C. specified no_ minimum or maximum for
the fund. F.S.L.I.C. has a line of credit with the U.S. Treasury if
their reserves are not enough to meet their obligations.
In the 1960's, the Secondary Reserve Fund (S.R.F.) was established
as a result of an unusually large number of "pay-outs", thus stimulating
concern about the adequacy of the I.R.F. The member S&L associations
were charged a second yearly assessment which went into this fund.
Recently, it was decided that the S.R.F. was no longer necessary. It is
being "phased out" and the member S&L's are being refunded their money
from the S.R.F. The S.R.F. could be reopened if the F.S.L.I.C. board of
directors felt that the additional funds were needed.
Each member S&L must establish a Federal Insurance Reserve
Account and F.S.L.I.C. may assess members to draw on this special account.
The balance must represent a certain percentage of the total savings held
by the association:
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After 4 years the balance must be 1% of savings.
After 10 years the balance must be 2.5% of savings.
After 16 years the balance must be 4% of savings.
After 20 years the balance must be 5% of savings.
The maximum balance required is 5% of the total savings.
The Federal Home Loan Bank Board requires that all member S&L's
undergo a detailed examination once a year.
The pay-out is, of course, only made if nothing else works.
F.S.L.I.C. is permitted to do any number of things to maintain the stability
and safety of a member S&L, including: making loans, contributions, pur-
chasing assets, setting up mergers and drawing up "rehabilitation agreements"
in which F.S.L.I.C. temporarily assumes management of the troubled
association. When an association does go into default, F.S.L.I.C. pays
off the savers in cash up to the limit (e.g., $40,000 on an individual
account). The last pay-out was in 1971 to a S&L in Seattle. The largest
pay-out ever made was approximately 90 million dollars on the closure of a
Chicago S&L in the 1960's.
The general factors determining membership qualifications are
similar to those of the F D.I.C., including: the financial stability of
the S&L, the competence of the management, and the needs of the community
to be served. A S&L eligible for charter, will be granted it conditional
to acceptance into F.S.L.I.C.
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4. The Maryland Savings Share Insurance Corporation: An Example of a
Group Insurance Fund
The Maryland Savings Share Insurance Corporation (M.S.S.I.C.)
was created by statute June 1, 1962 (Article 23, Chapter 131, Sections
161 MM-161XX of the Maryland Code). It is a non-stock, non-profit
corporation owned by 136 member savings and loan associations. Since
Maryland requires that all S&L's be fully insured, M.S.S.I.C. serves to
cover those S&L's which: 1) are too small to fulfill the F.S.L.I.C.
regulations ; or 2) prefer the flexibility permitted by M.S.S.I.C.
When M.S.S.I.C. was established, the Governor appointed a
Blue Ribbon Commission which reviewed the assessment procedures of such
similar organizations as F.D.I.C., F.S.L.I.C., the Massachusetts Central
Savings Fund, and the Ohio Guarantee Fund. They decided that 2% was a
sound percentage. This means of assesseent is unusual. Upon becoming a
member of M.S.S.I.C. each S&L association must post 2% of its free share
accounts. One-half of this capital deposit must be paid upon acceptance,
one-quarter is paid six months after, and the final quarter is paid twelve
months after acceptance.
The capital deposit is semi-annually adjusted according to the
increase or decrease of a member association's total savings. If they
increase, the S&L must pay the difference and if they decrease, the S&L
receives a cash refund. There is no annual premium. The capital deposits
are refundable to a member upon withdrawal fom M.S.S.I.C. M.S.S.I.C. is
required, by law, to retain all net earnings.
The Deposit Insurance Fund totals 32 million dollars. When
M.S.S.I.C. was created, it was required to have at least 25 member
S&L's with an aggregate total of free share accounts of at least 25
million dollars. The initial capital deposits and the semi-annual adjust-
ments support this Fund. M.S.S.I.C. has lines of credit (45 million
dollars) with commercial banks. Their investments are in hign-grade
corporate and government obligations, with no more than 10% in common stock,
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The Central Reserve Fund (CRF) was set up to provide for
emergency lending to member S&L's. As of September 30, 1977, the CRF will
have approximately $12,500,000 in assets. The capital derives from the
sale of "capital notes" of $100.00 each. The assessment per association
varies: 1) 1/2 of 1% of member's assets of S&L's with less than 75
million dollars in assets; and 2) 1-1/2 of 1% of member's assets of S&L's
with 75 million or more in assets. Payments for the capital notes are
due quarterly. In the event that the CRF is liquidated, members will be
refunded their shore.
M.S.S.I.C. must accept all applicants providing they meet the
requirements set forth in the Maryland Code and in M.S.S.I.C.'s rules and
regulations. These include certification by the state commissioner of
the applicant's fiscal affairs, solvency and management. Each member must
maintain a liquidity fund equal to 6% of its total free share accounts.
They must all enter with a "Reserve for Losses" of 6%, which may go only
as low as 3%. The largest pay-out ever made by M.S.S.I.C. was $300,000
in 1963. It was fully recovered upon liquidation of assets.
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5. The Mutual Central Savings Fund: An Example of A Group Insurance Fund
The Mutual Central Savings Fund (F.C.S.F.) is a tax-exempt, non-
profit deposit insurance corporation for mutual savings banks in
Massachusetts. It was established in 1932 by Chapter 44 of the Massachusetts
Code. Savings banks are required by Massachusetts law to be mutual -- they
have no shareholders and their main objective is to accept deposits with a
greater part of their business involved in home mortgages.
The M.C.S.F. insures deposits in full up to the legal limit which
varies according to the type of account. There are four types of accounts:
1) individual accounts - $45,000; 2) term or contracted accounts - $100,000;
3) corporation accounts - $150,000; and 4) non-profit, tax-exempt organiza-
tion accounts - are insured in full to an unlimited amount. The insurance
also covers any interest which might accumulate.
Each year the member bank is charged an assessment of l/16th of
1% based on the deposits of the last fiscal year. This percentage was
established by statute, although there is a provision in it that the Board
of Directors may ask the Commissioner of Banks for a reduction in the
percentage.
The decision to change the assessment is usually determined by
the ratio of the insurance fund to insured deposits and also by comparison
of this ratio to similar institutions. For example, in the last fiscal
year, the M.C.S.F. ratio was 1.419 which comapres favorably to the F.D.I.C.
ratio of 1.18. There are no other fines or charges.
In Massachusetts, mutual savings banks, by law, must be a member
of either the M.C.S.F. or F.D.I.C. If they are a member of both, F.D.I.C.
insures the first $40,000 (their limit) and the M.C.S.F. insures anything
above that to $45,000 (their limit). There have been no new applicants
since the late 1940's. Since new applications are so rare, the M.C.S.F.
has no established format for charter applicants (all mutual savings banks
must be state chartered).
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The Deposit Insurance Fund (DIP) was established by statute in
1934 and as of October 31, 1976, totalled approximately 180 million dollars.
Although there have been no failures in the history of the Fund, they do
have lines of credit with commercial banks and the assets of the failed
bank as reserves in case the fund is not adequate. The M.C.S.F. is
empowered to do "anything necessary" to prevent bank failure, e.g. extend
loans, arrange mergers, etc. As of the last fiscal year, the DIF has $1.44
of deposit insurance for every $100.00 of insured deposits.
While the DIF is to protect the depositors, the Liquidity Fund
(established in 1932) generates extra money for emergencies (e.g. unusual
deposit withdrawals) and totals 11 million dollars. This fund is stable
and takes in no assessment money. In the event that the Liquidity Fund
needs more money, the M.C.S.F. may charge a second assessment to the
members. M.C.S.F. may also sell commercial paper on the open market to
generate more funds. This commercial paper would normally mature in 60-
90 days. The investments for both the DIF and the Liquidity Fund are
restricted to "highly liquid short-term" U.S. government securities.
In the event of a merger, the full assets and liabilities of
the merging bank are determined. There should be a surplus, normally
between 8-9%, as a reserve which is still available to the depositors.
If the surplus is not adequate, the M.C.S.F. will cover the balance.
If a bank is in serious trouble and is considered unsafe and
unsound by the Commissioner, she may certify it to the M.C.S.F., and they
must do whatever necessary in order to insure the safety of the depositors.
This has only occurred 4-5 times in the history of the M.C.S.F. The
most recent one occurred in 1971 as a result of mismanagement. When the
M.C.S.F. steps in to prevent closure or facilitate a merger, etc., the
yearly assessment fee is not refundable.
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6. Workmen's Compensation: An Example of a State Insurance Fund
The state of Ohio requires that any employer with one or more
employees have worker's compensation insurance. This includes domestic
help who earn more than $160/quarter. Ohio has an exclusive state
insurance fund. Employers may self-insure if they meet the prescribed
standards.
Insurance by this fund is not effective until both an applica-
tion and a premium have been submitted. An advance deposit is required
based on 8 months estimated payroll at a rate based on the employer's
classification. There is a $10.00 minimum deposit for new coverage. The
premium changes with each biannual reporting period according to payroll
changes. There is a fee charged each reporting period to cover administra-
tive costs -- 9.5 cents for every $100.00 of payroll with a minimum of
$3.00.
The rates change every July 1 according to the classifications
and claims for that year. In the past several years, the rates have
steadily risen with an increase of 30% last year. The increase is due
primarily to the increase in the cost of disability benefits. A rate
change is decided upon by the Acturial Agency, with approval coming from
a three member Industrial Commission.
Another fee, created by the Ohio legislature is the Disabled
Worker's Relief Fund Excise Tax which is $.05 per $100.00 of payroll.
The fund has 1-1/2 billion dollars in reserves, with their investments
restricted to Blue Chip stocks. No speculation is permitted.
The State Fund insures approximately 250,000 employers.
Each reporting period between 25-30,000 accounts are allowed
to lapse. During this time, the accounts are not covered. In the event
that a company goes bankrupt, the Fund obtains the final payroll as of
the last operating day. They apply the advance deposit towards what is
due. If there is a credit, then the comapny receives a refund; if money
is due, the Fund turns the case over to the Attorney General's Office who
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deals with it through the bankruptcy courts.
The advantages of an exclusive state worker's compensation fund,
as listed by a fund administrator are: 1) The rates of the state fund,
though high, are "significantly less" than those of private insurers;
2) There are definite advantages for the employees, especially ff their
employer has not complied with the regulations. They may either bring
a civil suit against the employer or they may file a claim with the state.
In the latter case, the Fund will service the claim and then bill the
employer for all costs; 3) Since a state-administered fund is not a profit
making organization, it is more likely to look out for its clients interests.
The operating expenses are substantially lower as well; 4) More and more
private insurers are giving up worker's compensation insurance.
In order to qualify as a self-insurer, a company must fulfill
ten requirements: 1) have a minimum of 500 employees; 2) have a minimum
annual premium of $50,000; 3) have been in operation in Ohio for a minimum
of 2 years; 4) be able to prove financial solvency; 5) have a separate
Ohio bank account for worker's compensation insurance, or if it is an out-of
state comapny, it must be sponsored by an Ohio bank; 6) give a thorough
description of its safety provisions; 7) outline how it would execute claims;
8) post a performance bond based on the state fund premium; 9) provide the
same benefits as the state fund; 10) have a minimum of $100,000 and a
maximum of 1 million dollars in the insurance account.
The bond required is either in a surety bond or is with the
treasurer of the state. Self-insurer's financial statements are required
once a year and all lost time claims are filed with the Bureau of Worker's
Compensation. Special examinations are only performed when a complaint is
filed against an employer.
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7. The Nuclear Energy Liability-Property Insurance Association: An Example
of an Insurance Pool
There are three insurance pools which provide insurance for the
nuclear industry. The Nuclear Energy Liability - Property Insurance
Association (NEL-PIA) is one of these. It provides two types of insurance,
liability and property insurance coverage. The operators of nuclear
facilities and their suppliers are covered for any liability they may incur
as a result of bodily injury or property damage resulting from a nuclear
accident. This coverage provides financial protection for the public.
The property insurance covers damage to the property of nuclear facility
owners.
Since nuclear liability insurance's inception in 1957, the total
insurance available has steadily risen, totaling $140 million in January
of 1977. This total is reached by the combination of NEL-PIA's pool and
the other pools through reinsurance agreements. Property insurance in
1977 totaled $220 million.
Beginning in August of 1977, $30 million of contingent liability
capacity will become available. This 'Retrospective Premium Plan1
incorporates the most recent legislation renewing the Price-Anderson Act.
It provides that power reactor operators be assessed a retrospective
premium up to a maximum of $5 million per reactor by the pools, should a
nuclear incident result in liability losses which exceed the pool's
primary $140 million protection. Thus, a buffer is formed should any
operator be unable to meet this assessment at the time of loss. At a
later date the pools would seek repayment of any such defalut from these
operators.
By the end of 1975, the accumulation of the premium income
earmarked for losses amounted to $54 million. Should losses exceed this
sum, the pools wuld make up the difference based on their degree of
participation in the pool up to the $140 million limit of the liability
policy.
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The liability insurance rates charged by the pools are established
by the Insurance Services Office. Among the factors involved in liability
ratings are the size, type and location of the facility. An average
nuclear power plant would pay about $262,000 annually for liability pro-
tection with the lowest rated reactor paying $197,000 and the highest rated
paying $c"4,000.
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8. The Swine Flu Program: An Example of a Type of Federal Insurance
The "National Swine Flu Immunization Program" of 1976 contained
a provision that provided insurance in case of an injury or death
death that resulted from the program. The pertinent text reads:
"The Attorney General shall defend any civil action
or proceeding brought in any court against any employee
of the government or program participant (or any
liability insurer thereof)."
Furthermore, the government would cover the expense of both in and out of
court settlements. If however, a participant in the program was clearly
negligent and their negligence resulted in damages, then the government
can try to recover costs from that participant. In effect, this approach
represents insurance for the public and any participant in the program
who faces liability not caused by his own negligence.
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9. Federal and State Strip Mine Legislation: An Example of Provision for
Continuity of Operations
The Mineral Leasing Act of 1920, and its subsequent amendments,
specifies the reclamation requirements of Federal strip mined lands.
The operator's liability shall extend for at least five years after the
first planting of new vegetation. The maximum liability shall not exceed
ten years after the first planting. Bonds shall be furnished in sufficient
amounts to ensure reclamation in accordance with reclamation standards, and
the terms and conditions of the lease.
The mining plan shall be enforced by a combination of a per-
formance bond, reports and inspects for compliance. The performance
bond shall be at least $2000, and shall be an amount determined by the cost
of reclamation.
State regulations tend to require either a bond based on a dollar
figure per acre or a bond based on the total cost of reclamation. There-
fore, amounts of these bonds vary considerably. At the low end of
the scale are the states of Virginia, Missouri, Kansas and Arkansas which
require between $500 and $1000 per acre. Oklahoma, Maryland, Illinois,
Indiana, West Virginia and Kentucky require higher levels of bonding ranging
from $600-%5000 per acre. Often they specify either a fixed sum or a
charge per acre whichever is higher. A number of states set bond levels
at the cost of total reclamation. Frequently these states establish a
board to establish the bond to insure performance of duties. Such states
include Ohio, New Mexico, Colorado, Texas, Washington, Wyoming, Iowa and
Montana.
Alabama requires that the amount of the bond shall be $1200 per acre
but not less than $10,000 per permit. Sixty percent of the bond shall be
released when the first stages of reclamation are completed. Tennessee
has a similar conditional release clause. The amount of the bond shall
not be less than $1000 per acre. After initial planting of vegetation
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cover in accordance with the approved revegetation plan, the bond may be
reduced to $500 per acre. This amount shall remain in force until
safisfactory revegetation survival has been accomplished.
P
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10. Cemetery A: An Example of Provisions for Continuity- of Ooerations
Cemetery A was established within the last year, when the
cemetery bought out a neighboring one. The burial plots range in price
from $250 - $700, depending on location.
In creating a perpetual endowment fund, the state of Virginia
requires that the cemetery corporation start with a minimum initial
deposit of $25,000. With the sale of each lot, a minimum of 10% of the
sale must go into this trust fund. The principle is never touched, and
the interest provides for maintenance, security, and perpetual monitoring.
The trust fund is managed by a trustee. In the case of one of the
cemeteries (before the merger), the trustee was the National Bank of
Fairfax.
Regulations concerning use of the cemetery land are set out in
the cemetery's charter. This charter states that the land may only be
used as a cemetery. Purchasers of burial plots are buying only the burial
rights, not the land; therefore, they are not required to pay any taxes.
The cemetery corporation pays taxes on the land to Fairfax County. The
burial rights may be sold to anyone, at any time, for any amount of
money; or they may be donated to a church or a charity.
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11. Cemetery B: An Example of Provisions for Continuity of Operations
Cemetery B is a profit-making organization established in 1917.
It occupies 40 acres (the size of the original site), and has not been
completely developed. The price of the plots vary according to size and
are only raised on the basis of the tax structure in Arlington County.
According to the law of Virginia, an initial deposit is required
in order to establish a perpetual care trust fund. The cemetery
corporation uses a percentage of the cost of the grave site ( the percentage
varies according to the cost of the site) to establish a trust account.
The trust accounts are pooled, and this pool is administered by the chair-
man of the corporation, acting as trustee. In the event that the chairman
cannot act as trustee, the trusteeship is assumed by the board of
directors. Six to seven years ago, Virginia passed a law establishing the
conditions for payment into this fund. It may only be on a percentage
basis, no annual payments may be required. The state is the only regula-
tory agency.
In purchasing a burial plot, the customer is buying the land,
not just the burial rights to that land. The deed given to the buyer of
a site states only that the corporation conforms with the covenants
specified in the company charter.
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APPENDIX 2
STATE HAZARDOUS WASTE REGULATIONS
Research into state hazardous waste programs was performed in order
to gather data concerning state positions on the options involved in pro-
viding for financial responsibility and continuity of operations for hazardous
waste disposal firms. These alternatives are summarized in fact sheets on
the follwoing states: California, Idaho, Kansas, Maryland, Ohio, Oklahoma,
Oregon, Texas, Washington, and Wisconsin.
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FACT SHEET: California
1. State of the Legislation: California's present hazardous waste
management law and regulations represent a pioneer effort in the area of
hazardous waste identification. The proposed regulations (due for public
hearing August 16, 1977) primarily concern changes in permitting proce-
dures and in the fee structure.
2. Insurance: no requirements
3. Bonds: no requirements
4. Fees: The proposed regulations require that off-site and on-site
operators pay a fee to the state of $1.00/ton. There is a $2500 maximum
per facility. The fees cover Department of Health Administrative costs
since California is the only state with mandatory cost recovery for a
state-administered program.
5. Land Deeding: no requirements
6. Land Covenants: no requirements
7. Access/Easements: no requirements
8. Other: The California Department of Health is working with disposers
and manufacturers on long term care plans. Nothing has been resolved at
this time, however, they expect something within the year.
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FACT SHEET: Idaho
1. State of the Legislation: The Idaho Solid Waste Management Regulations
and Standards were adopted by the Board of Environemntal and Community
Services and termed effective on June 28, 1973. In Idaho, hazardous waste
management is regulated through the Conditional Use Permit provisions of
the regulations and is worked out on a case-by-case basis.
2. Insurance: no requirements
3. Bonds: At present, only one hazardous waste site exists in Idaho,
it is privately owned and operated and is located in an abandoned Titan
missle silo complex. Due to the unusual site qualities, a bond was not
required upon initial permit approval. Recently it was decided to
require a surety bond (amount undecided) to cover and provide for
permanent closure of an artesian well on the site.
4. Fees: no requirements
5. Land Deeding: There is a possibility of establishing deeding provi-
sions, however nothing has been resolved.
6. Land Covenants: no requirements
7. Access/Easements: no requirements
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FACT SHEET: Kansas
1. State of the Legislation: The Kansas Solid Waste Act was amended in
1977 to provide for complete control of hazardous wastes. The Department
of Health and Environment is in the process of promulgating rules and
regulations.
2- Insurance: The Amended Act requires "the permittee to provide
surety bond, cash bond or liability insurance, including coverage against
non-sudden occurrences-, or any combination thereof." The liability
insurance for disposers will be determined by the state and will vary
depending on the site. Only 1 site has been permitted so far and they
were required to have $300,000 liability insurance.
3. Bonds: "Within 30 days following the effective date of the permit,
the permittee shall establish an escrow account with a bank with conditions
and instructions suitable to the Department. At this time, the permittee
shall place a $50,000 surety bond in such account. In lieu of a surety bond,
the permittee may post cash or eligible securities deemed equivalent to cash..
The permittee shall have the options, at anytime, of replacing a surety
*
bond with cash or eligible securities deemed equivalent to cash."
"Until the initial $50,000 escrow account plus annual cash pay-
ments equals $100,000...the permittee shall make an annual payment of
$5,000 to the escrow account within 30 days after the anniversary of the
effective permit date."
The amount is determined per site and should be adequate to
provide for maintenance, monitoring and closure fees in the event that
the state is forced to close the site.
"Five years following the certification date that proper closure
is complete the $50,000 bond or equivalent case established in the escrow
account shall be returned to the permittee. After ten years has expired,
all remaining monies in this account shall then be returned to the permittee."
*
All quotes from: State of Kansas, Special Conditions to Permit, Department
of Health and Environment, Topeka, Kansas.
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(Kansas cont'd)
4. Other Accounts: "The permittee shall also establish a separate escrow
account...which shall provide the Department with monitoring funds for
perpeutuity or until the account is terminated at which time all remaining
monies shall be deposited in the state of Kansas general fund. Annual
payments of $1,000 shall be made to this account...until total cash pay-
ments total $10,000 at which time this annual payment shall be cancelled."
5. Fees: No requirements.
6. Land Deeding: No specific requirements, although after site closure
the state retains the right to approve all future uses of the land.
7. Land Covenants: A restrictive covenant must be issued by the
permittee which specified post-closure use of the site.
8. Easements: An easement must be executed by the permittee which
authorizes Department representatives to: 1) complete unfinished work
on site closure plan; 2) perform work for which surety is provided;
3) sample, repair or reconstruct monitoring facilities; 4) require operator
to preserve and protect monitoring facilities.
*•
All quotes from: State of Kansas, Special Conditions to Permit, Department
of Health and Environment, Topeka, Kansas.
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FACT SHEET: Maryland
1. State of the Legislation: The Maryland Safe Disposal of Hazardous
Substances Act was passed in 1976 and the regulations are expected to be
promulgated soon.
2. Insurance: The permit requires that a facility maintain "adequate
liability insurance." No further information was available.
3. Bonds: The state requires that an applicant either: 1) prove
financial ability to operate and maintain a facility or; 2) provide a
surety bond; or 3-) a transfer ownership or operation to the State. The
bond should be a minimum of $10,000. It provides for monitoring, maintain-
ing, closing the facility, and for security after the closure.
4. Funds: The state established a Hazardous Substance Control Fund to
provide for monitoring and controlling the "proper disposal of designated
*
hazardous substances." All permit fees, renewal fees and other charges
are credited to this fund.
5. Fees: There is an initial application fee of $50.00. The permit fee
is scaled, must be renewed yearly and is determined by: 1) the threat to
the environment; 2) the cost of monitoring and regulating the site;
3) the cost of removing and disposing of hazardous substances which escape
from the site; and 4) the amount of acreage of the site.
6. Land Deeding: no requirements
7. Land Covenants: no requirements
8. Access/Easement: no requirements
State of Maryland, Senate Bill No. 977, The Maryland Safe Disposal
of Hazardous Substances Act, Section 1; Baltimore, Md., 1976.
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FACT SHEET: New York
1. State of the Legislation: New York has no law which specifically
addresses hazardous waste management. At this time it is incorporated
into their Solid Waste Management Law and their regulations concerning
waste haulers. The Solid Waste Management Division is aware that the
existing laws are far too broad and a bill addressing Hazardous Waste
Management is "in the works". It is unclear when it will be passed.
2. Insurance: no requirements
3. Bonds: Bonds are only required upon receipt of a court order, and
this is infrequent.
4. Fees: There is only a nominal registration fee.
5. Land Deeding: no requirements
6. Land Covenants: no requirements
7. Access/Easements: no requirements
An amendment to New York's Insurance Law prohibits issuance of non-
accidental insurance to cover liability arising from pollution or contam-
ination. (McKinney's Consolidated Laws of New York, Title 27 Insurance
Law, §46.)
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FACT SHEET: Ohio
1. State of Legislation: At this time, all hazardous waste management
problems are regulated through the state's current Solid Waste Law and Reg-
ulations, enacted in 1976. The Ohio EPA has specific hazardous waste
legislation due to be presented to the State Assembly in the 1977-78 session,
2. Insurance: no requirements
3. Bonds: Ohio EPA's proposed legislation requires a surety bond, the
amount of which is determined per site. In considering the amount Ohio
EPA considers: 1) size and type of facility; 2) quantity and composition
of wastes to be stored or disposed of; and 3) "Assurances of continuity of
operation consistent with the degree and duration of risk associated with
*
the type of wastes received."
4. Other Accounts: All fees associated with hazardous wastes, including
penalties, permit, license and disposer fees, go into a rotary fund called
the Hazardous Waste Collection Account. The account is administered by
the Director of Ohio EPA and covers the cost of enforcing and administering
the Act. It does not cover post-closure operations.
5. Fees: no information available other than the above.
6. Land Deeding: no requirements
7. Land Covenants: no requirements
8. Access/Easement: no requirements
*
State of Ohio, Propose Legislation, Section 3734.03, Ohio Environmental
Protection Agency, Columbus, Ohio, 1977.
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FACT SHEET: Oklahoma
1. StatP of the Legislation: The Oklahoma controlled Industrial Waste
Disposal Act was enacted in 1976. The state Department of Health was
designated as the administering agency.
2. Insurance: The state requires that the disposer have liability
coverage equal to two times the value of all real property within one mile
of the site (excluding the site property). This should be not less than
$100,000 and not more than $500,000. Additional coverage may be required
for damage to underground resources.
3. Bonds: A bond is required guaranteeing the performance of maintenance,
and monitoring, and proper closure. The amount has not yet been set.
4. Fees: no requirements
5. Land Deeding: no requirements
6. Land Covenants: no requirements
7. Access/Easements: no requirements
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FACT SHEET: Oregon
1. State of the Legislation: A bill concerned with hazardous waste
disposal practices was passed in 1971 and revised in 1973.
2. Insurance: The Oregon law requires "adequate" liability insurance.
They now require a $1 million minimum.
3. Bonds: A bond is required upon receiving a license. It begins as
a surety bond of $75,000 and is gradually transformed into a cash bond
by means of annual cash payments of $18,750 for the first year and
$5,625/year for the next ten years. Interest credited to licensees,
except for inflation deductions. The non-refundable principal and the
interest covers closure, post-closure monitoring and maintenance.
4- Fee: The annual license fee of $4,324 is to cover pre-closure
monitoring costs.
5. Land Deeding: All land used in hazardous waste disposal is deeded
to Oregon State within 30 days of licensing.
6. Land Covenants: no requirements
7. Access/Easements: no requirements
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FACT SHEET: Texas
1. State of the Legislation: The Texas Solid Waste Act of 1969 was
amended in 1971 and again in 1977 to "bring it in line with Public Law
94-580."
2. Insurance: no requirements
3. Bonds: The regulations authorize the Texas Water Quality Board
(the hazardous waste administering agency) to set a closure bond for a
permitted site. In determining the amount, the Board receives a site's
closure plans and cost estimates, and sets the bond accordingly.
4. Fees: no requirements
5. Land Deeding: no requirements
6. Land Covenants: no requirements
7. Access/Easements: no requirements
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FACT SHEET: Washington
1. State of the Legislation: Washington's Hazardous Waste Disposal Law
was passed in 1976, however the regulations are still in draft form.
2. Insurance: The proposed regulations require a minimum of $1,200,000
in liability insurance.
3. Bond: The proposed regulations further require that the operator post
a performance bond of at least $50,000, which is refundable upon contract
expiration.
4. Fees: The fee schedules will be established by the operator, subject
to approval by the department. "The department shall use the following
criteria to review such disposal fees: a) their relationship to other fees
charged for similar services; b) reasonable return on investment and
profit for the operator; and c) the cost of administration, development,
operation, maintenance, and perpetual management of the disposal site."
5. Land Deeding: The state is purchasing the land which will contain
the only extremely hazardous waste facility in Washington. The operation
of the site will then go out to private bid. Upon proper closure by the
operator, the state immediately assumes responsibility for all subsequent
monitoring and maintenance.
6. Land Covenenats: no requirements
7. Access/Easements: no requirements
te
State of Washington, Draft Regulations, July, 1977, Olympia, Washington,
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FACT SHEET: Wisconsin
1. State of the Legislation: The legislation specifically concerned
with hazardous waste management is still in draft form. The proposed
Act is in compliance with RCRA and is expected to be enacted by next
spring's session of the Assembly.
2. Insurance: no requirements
3. Bonds: no requirements
4. Funds: A Waste Management Fund will be administered by the Depart-
ment of Natural Resources and supported by user fees. The general pur-
pose of the fund is to provide for long term care. More specifically,
it will provide funds for costs and expenses not anticipated in the
approved plans of operation; and for the "acquisition and maintenance
of facilities which the public is forced to acquire because the owner
or operator either does not wish to continue being responsible for the
facility, or voluntarily or involuntarily abandons the facility.' The
fund will also be used to provide monies to repair facilities, to repair
environmental damage caused by facilities, and to pay damages to persons
or properties harmed by a facility.
5. Limit on Liability: The total amount of awards for any one occur-
rence shall not exceed $500,000.
6. Fees: The fees which represent the Fund's income will be collected
quarterly on all wastes entering disposal facilities. The fees will be
scaled according to the relative degree of hazard represented by each
waste.
7. Land Deeding: The site operator must monitor and care for the site
up to ten years after closure. At this time the state reviews the site,
if "nothing is left" the state may terminate the site. If further long
]State of Wisconsin, Assembly Bill 880, Prefatory Note, July 13, 1977,
Madison, Wisconsin.
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term care is required the site operator has two options: 1) he/she may
continue to provide the necessary care and monitoring; or 2) he/she may
sell the site to the state, which will then assume responsibility. In
the event that the site is sold to the state, each party obtains an
appraisal for the "fair market value".
8. Land Covenants: no requirements
9. Access/Easements: no requirements
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APPENDIX 3
HAZARDOUS WASTE FACILITIES
INTRODUCTION
In order to assure consideration of possible contingencies which
could occur in the management of hazardous wastes, a detailed review of the
pertinent literature was undertaken to identify all types of hazardous waste
treatment storage, and disposal facility types, all conceivable events
that could occur at such facilities, and all hazardous waste types likely
to be handled. After lists of facility, event, and waste types were
developed, they were combined through the use of matrices to obtain all
applicable facility/event/waste (FEW's) to be considered in the development
of contingency plan standards. A complete discussion of the facility
classification used for this analysis is presented in this Appendix.
A wide variety of facility types and disposal methods are
employed by a broad spectrum of industries in the United States for the
treatment, storage and disposal of waste products that are generated.
Many of these wastes are considered to be "hazardous", and large quantities
are generated each year.
Hazardous wastes have been defined under federal and state
legislation, including the Federal Water Pollution Control Act Amendments
of 1972 (Public Law 92-500); Florida Resource Recovery and Management
Regulations; State of California Water Resources'Control Board, (subchapter
15); Illinois Pollution Control Board Rules and Regulations, (chapter
7); New York State Environmental Conservation Law (Part 360); and several
other state policies, regulations or laws. An all-inclusive, comprehensive
definition and classification of the term "hazardous waste" is presently
being formulated and will be adopted in 1977 by EPA under RCRA (Public
Law 94-580). For the preparation of this report, a general working
definition of "hazardous wastes" has been defined as follows: "hazardous
wastes" are wastes that are believed to potentially affect individual
health or safety over the near- or long-term. Appendix 5 of this report
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(Wastes) presents in detail the classification scheme adopted for this study
A general listing of major industries which generate hazardous
wastes and treat, store or dispose of these wastes on-site or through
private waste management contractors includes, but is not limited to:
- organic chemicals and pesticides industries
- textiles industry
- inorganic chemicals industry
- pharmaceutical industry
- special machinery manufacturing industry
- paint and allied products industry
- leather tanning and finishing industry
- storage and primary batteries industries
- metal smelting and refining industry
- electronic components manufacturing industry
- electroplating and metal finishing industries
- petroleum refining industry
- food industry
- nuclear industry
- ordnance industry
- rubber and plastics industries
A compendium of waste management facilities owned and operated
by waste generators and by private contractors was gathered through a
literature search of available publications and pertinent reports and
information from cognizant state and federal agencies. Several of
these hazardous waste facilities have the capability of providing for
effective treatment, storage or disposal of hazardous wastes, without
having adverse or detrimental effects on either the natural or human
environment. Only those facilities or treatment methods which would
most likely be deemed suitable for the treatment, storage and disposal of
hazardous wastes, as adopted pursuant to Public Law 94-580, are discussed
in this report. Present disposal facilities, treatment methods, or
combinations which show the most promise include but are not necessarily
nmited to:
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Facilities:
1) landfills
2) incinerators
3) waste lagoons or ponds
4) land burial at depth
5) deep well injection
6) near-surface land burial
Final Treatment Processes:
1) oxidation/reduction
2) neutralization
3) chemical degradation
4) detoxification
5) open burning/detonation
6) hydrolysis
7) biological degradation
8) resource recovery
Preparatory Treatment Processes:
1) flocculation-sedimentation and filtration
2) precipitation
3) ammonia stripping
4) evaporation
5) centrifugation
6) carbon sorption
7) solidification/fixation
8) solvent extraction
9) vacuum distillation
Some of the aforementioned methods of treatment, particularly
the preparatory treatment processes, require additional treatment and/or
eventual disposal. In general, these preparatory treatment processes
are utilized to reduce waste volumes or remove particular hazardous wastes
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(i.e., heavy metals, etc.) from the waste stream generated, and should
not be considered as viable alternatives for final disposal. Therefore,
only the disposal facilities and the "final" treatment processes previously
listed will be discussed in detail. Alternate methods of treatment,
storage or disposal will have to be evaluated on an individual basis in
complying with the hazardous waste management standards to be adopted under
Section 3004 of Public Law 94-580.
LANDFILLS
Standard definitions of three major types of landfills were
developed by Shaver et. al. (1975), under contract by EPA which cover
the types of landfill sites suitable for the disposal of hazardous
wastes. The definitions of general, approved and secured landfills are
as follows:
General Landfill: A site which is limited to disposal of inert
solid wastes which should not pose a threat to water quality.
The site may contain water (for example, marshy areas, gravel
pits, or periodically flooded areas) with no threat to water
quality from the wastes.
Approved Landfill: A site which is suitable for the disposal of
inert solid wastes and decomposable organic materials. The site
must provide separation of the wastes from underlying or adjacent
usable water because of leachate possibilities.
Secured Landfill: A site suitable for the disposal of all wastes,
including liquid and/or solid hazardous wastes. The site must
allow no discharge of these materials or their by-products to
usable ground or surface waters by leaching, percolation or any
other means. Another feature which may be included is inventory
control on the wastes buried in the secured landfill. The prime
requisite for such disposal is that the hazardous contents of the
landfill be isolated from the surrounding environment. Water
quality of surface and ground water must not be compromised. Air
quality must also be maintained.
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Typically, general landfills are not adequate for the disposal
of hazardous wastes and afford no protection against leachate generation
and the potential contamination of usable water resources. In addition,
the potential for the generation of hazardous gases and vapors exists,
which could result in fires or explosions. Although, in some instances,
good site selection, design and operation could minimize these adverse
effects, a general landfill should not be considered a proper facility
for the disposal of hazardous wastes.
An approved landfill, where specific site conditions prevail,
may be adequate for the disposal of certain hazardous waste types. In
many cases, hazardous wastes could be disposed of without any additional
precautions, such as steel tanks or containers. Approved landfills
should have to meet the following criteria (Powers, 1976):
1) the type and quantity of each hazardous waste is known and
approved for disposal by pertinent regulatory agencies;
2) the site should be environmentally suitable for hazardous
wastes; and
3) provision is made for monitoring wells and leachate
control and treatment if required. The necessary design
standards for the disposal of hazardous wastes, which will
determine if the above criteria are sufficient for the disposal
of hazardous wastes, are being adopted concurrently under
Public Law 94-580.
Placement in secured landfills would be the safest and most
effective method for the disposal of hazardous wastes. Usually, small
volumes of highly toxic inorganic and organic chemicals and other extremely
hazardous wastes are disposed of in this manner. Because of the hazard
potential of these wastes, additional criteria to those required for an
approved landfill are necessary to safeguard the environment. Examples
of these criteria include: accurate recording of burial coordinates to
avoid any interactions between incompatible chemicals; a water table at
least 10 feet below the lowest level of the landfill; adequate provisions
for the diversion and control of surface water; a vertical permeability
of the natural or synthetic liner (plastic, rubber, concrete, etc.) not
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to exceed 10~7 cm/sec; and registration of the landfill site for a
permanent record of its location once filled.
Although criteria for the disposal of hazardous wastes in an
approved and secured landfill will vary, depending on the existing
hydrologic and geologic environment, the possibilities of any damage to
the environment due to toxic gas generation, leachate generation, or
interactions between hazardous wastes should be minimized. Furthermore,
the most environmentally favorable landfill sites should be selected for
any particular hazardous waste to mitigate any possibility of adverse
effects to the environment.
INCINERATORS
Incineration is a controlled process that utilizes some type
of combustion/burning process to convert a waste to less bulky, less
toxic, or innocuous gases, liquids and solids. Incinerators can be used
to dispose of combustible solids, semi-solids and concentrated liquid
wastes. In general, carbon dioxide, water and ash (of various compositions)
are the major by-products of incinerator processes. When the combustion
product contains undesirable compounds such as toxic hazardous waste
gases (i.e. hydrogen cyanide), additional treatment such as afterburning,
scrubbing, or filtration is necessary. Subsequently, the solid and
liquid effluents, for example toxic inorganic oxides, if hazardous, are
either treated further or disposed of at a hazardous waste facility,
such as a secured landfill. In some instances, by-products, such as
hydrogen chloride or lead slag, are recovered during the incineration
process and recycled.
Several types of incinerators handle wastes in a more efficient
manner, depending on whether the waste is in the liquid, solid or gaseous
form. Some incinerators are capable of handling all three types of
wastes. Examples of these incinerators, given by Powers (1976), include
the fluidized bed and rotary kiln incinerators. Other incinerators that
are more effective with solids and liquids are the open pit multiple
chamber and multiple hearth incinerators. Liquid combustors specifically
handle liquid wastes, whereas catalytic combustors, gas combustors,
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flares and afterburners are more suited for gaseous waste disposal. In
certain cases, where the hazardous wastes themselves are not adequate as
fuels to maintain combustion, additional fuels must be fed into the
incinerator to support combustion.
All incineration processes create some type of secondary
waste, which may be hazardous. These wastes may contain toxic gases,
heavy metal sludges or organic residues. If these wastes are hazardous
they must be treated, stored or disposed of at a hazardous waste facility
or recycled. In general, solid and semi-solid hazardous wastes are
disposed of in landfills certified to accept hazardous wastes or they
are buried, sometimes in containers or tanks,by the generator in properly
designed trenches or pits or transported to other hazardous waste facilities.
The major source of pollution from incinerators is the release
of gaseous emmissions to the atmosphere. Depending on the type of
pollutant, whether particulates or airborne gases from wastes containing
halogens, sulfur or phosphorous compounds, various devices can be effectively
used for pollution abatement, including cyclones, bag filters, electrostatic
precipitators and scrubbers. The release of toxic gases from incinerators
must be controlled by these devices to safeguard the environment.
DEEP WELL INJECTION
Several states, including Alabama, Colorado, Illinois, Indiana
Kansas, Michigan, Missouri, New York, Ohio, Texas and West Virginia,
have developed specific laws, regulations or policies concerning the
subsurface disposal of industrial wastes. Deep well injection of hazardous
wastes has become more attractive to the various process industries
because of the recent enactment of federal legislation, such as the
Federal Water Pollution Control Act Amendment of 1972 and the Marine
Protection, Research and Sanctuaries Act of 1972, regarding the discharge
of pollutants into the waters of the United States. In general, these
laws focus on the potential pollution of surface waters and only -indirectly
address the problem of ground-water pollution. Therefore, because of the
limited legal constraints presently imposed on industry, more and more
hazardous wastes are being disposed of by deep well injection. Warner
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and Orcutt (1973) show that the number of deep injection wells in the
United States has increased by a rate of 30 wells per year since 1967.
In the past, many operators minimized costs from surface
discharge permits and treatment by injection of hazardous wastes into
subsurface aquifers. Recent policy statements, specifically the EPA
policy on subsurface emplacement of fluids by well injection, Decision
Statement No. 5, are aimed at discouraging the disposal of various
wastes, including hazardous wastes, to the subsurface for the purpose of
avoiding discharge permits. Decision Statement No. 5 addresses, in
detail, the policy requirements and guidelines that should be adhered to
in order to insure protection of the subsurface environment from the
emplacement of fluid wastes. EPA recognizes that deep well injection is
a viable waste disposal technique provided adequate regulations and
controlled conditions exist.
Subsurface disposal of liquid wastes has been practiced for
many years. The mining and oil industries have used deep wells for the
disposal of oil field and chemical brines. Today the major industries
that dispose of hazardous wastes by deep well injection include the
chemical, petrochemical and pharmeceutical industries. These industries
inject solvents, corrosives, heavy metals, pesticides and other hazardous
wastes, usually pretreated prior to disposal, into subsurface formations.
Injection wells in the United States generally range in depth from 1,000
to over 12,000 feet (Warner 1973). Treated liquid wastes are injected
by gravity flow or under pressure into subsurface strata that contain
non-potable brackish or briny waters. Receiving strata must be bounded
above and below by confining strata, such as clays and shales, to preclude
any migration to and eventual contamination of potable water supplies.
The composition of the hazardous waste is usually altered by pretreatment
processes to insure that the wastes are compatible with the existing
waters and subsurface environment. This process also minimizes the
possibility of clogging the injection zone.
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WASTE LAGOON AND PONDS
Waste lagoons and ponds have been utilized by industry for the
containment and disposal of liquid wastes. The organic chemical, pesticide
and tannery industries are some of the major industries that dispose of
hazardous wastes in various sizes and types of lagoons and ponds (EPA,
1976f; 1976k). Depending on the volume of hazardous wastes, lagoons and
ponds can consist of small concrete tanks or large excavated basins
several acres in area. Typical pond sizes in the textile industry vary
from one to two acres (EPA, 1976). If a natural impervious material is
absent at the base of the excavation, the larger facilities must be
lined with relatively impermeable natural or synthetic liners such as
clay, asphalt, concrete, or plastic to prevent migration of hazardous
wastes to the subsurface environment. Also, routine monitoring and
detection systems usually need to be installed along with diversion
structures (trenches, berms, etc.) which intercept surface water runoff
from surrounding areas.
The hazardous wastes stored or disposed of in lagoons and
ponds may be treated in-situ as a final disposal process and discharged;
may be treated partially and disposed of at another hazardous waste
disposal facility; or may be accumulated by evaporation until the volume
warrants disposal at a hazardous waste disposal facility. Any combination
of these methods may be employed. Some typical treatment processes
include sedimentation, biochemical oxidation, and precipitation. Many
times, mechanical surface aerators or sprayers are used to increase the
rate of evaporation.
Ideally, lagoons and ponds should be located in geographical
areas where favorable climatic conditions prevail. Such areas include
those where evaporation rates are high and precipitation is minimal.
Because of overflow or flooding problems in wet climates, lagoons or
ponds are usually feasible only in the Western United States. In some
instances, off-site disposal contractors that handle various types of
hazardous wastes may find it necessary to segregate incompatible waste
types or may require appropriate pret^eatment by the waste generator.
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Lagoons and ponds that are utilized for the temporary storage
or permanent disposal of hazardous wastes should be designed and constructed
to minimize any adverse environmental effects. These effects might
include ground-water contamination from leachates or air pollution from
the generation of toxic gases such as hydrogen cyanide.
NEAR-SURFACE LAND BURIAL
Another facility or form of hazardous waste disposal is near-
surface land burial. In near-surface burial, the hazardous waste is
placed directly into the ground or is deposited in stainless steel
tanks, concrete lined pits or a combination of these devices (Powers,
1976). Although the hazardous wastes can be in a liquid or solid form prior
to burial, the wastes are usually converted to a solid form (i.e.
by cementation, solidification, etc.) to reduce the mobility of the
hazardous wastes in the subsurface environment in the event of an accidental
release.
Presently, near surface burial of radioactive wastes from the
nuclear industry is being regulated by the Nuclear Regulatory Commission
(NRC) at several sites. Hazardous chemical wastes are similarly buried
in unlined trenches, up to 20 feet in depth. Morton (1968) indicates
that some of these trenches are from 25 to 60 feet in width and vary
from 300 to 700 feet in length. After emplacement of the hazardous
wastes is completed, the trenches are backfilled to the surface with
materials, such as asphalt, to reduce infiltration and leaching. Radioactive
wastes are typically stored as solids or liquids in steel tanks or bins
enclosed in concrete. The capacity of these tanks can exceed one million
gallons.
Various types of monitoring devices are installed to detect
any leaks or leaching to the subsurface environment, depending on the
type of hazardous waste. Trenches are usually equipped with drains and
sumps to capture any potential leakage. More stringent precautions must
be taken for radioactive wastes, including instrumentation for measuring
temperatures, liquid levels and possible leaks from the tanks or bins.
Because of the long half-lives of several radioactive wastes, these
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tanks can only be considered as interim storage facilities and must be
replaced or repaired if accidental releases to the subsurface environment
occur.
LAND BURIAL AT DEPTH
Only limited studies have been conducted to determine the
feasibility of burial of hazardous wastes, especially radioactive wastes,
at depth. Bradshaw et. al. (1969) and Dunn et. al. (1971) have discussed
active waste disposal in impervious salt formations. Hazardous wastes
would be buried/stored at depths up to 1500 feet in unlined tunnels.
After the waste disposal operation is complete, the area is sealed from
the surface environment by backfilling with salt. Studies have also
been performed to determine the feasibility of radioactive waste disposal
in vaults excavated in deep-seated crystalline rock. These vaults can
be designed to accept both liquid and solid wastes. After the vault is
filled it is completely sealed off from the surface environment. Necessarily,
comprehensive waste retrieval plans and monitoring systems must be
devised to insure protection of the subsurface environment.
No technically acceptable concept for the ultimate disposal of
radioactive wastes exists to date. Additional studies will have to be
made to assess more fully the benefits and possible long-term adverse
environmental effects that might result from the disposal of hazardous
radioactive waste at depth. Nevertheless, non-radioactive hazardous
wastes could conceivably be handled in this fashion with proper pre-
cautions.
ABOVE-SURFACE STORAGE
In some instances, hazardous waste generators might find it
convenient to store extremely hazardous wastes in tanks, vaults or other
containment devices on or above land surface until the wastes are collected
by off-site contractors and transported to another type of hazardous
waste disposal facility. Generally, the types of hazardous wastes
stored in this manner are produced in small quantities. These wastes
might include radioactive wastes, highly toxic organic chemicals and
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pesticides, or lethal gases, which may eventually be disposed of at
other hazardous waste facilities, such as landfills or incinerators.
Certain industries, such as the pesticides-formulating industries, use
activated carbon adsorption for the removal of hazardous organic materials.
The spent carbon is then stored in above surface containers until sufficient
quantities are accumulated for disposal, although in some cases the carbon
is regenerated by thermal methods (EPA, 1976f). Interim storage facilities
of this type should provide adequate safeguards, including monitoring or
leak detection systems, to prevent any accidental release of hazardous
wastes to the surrounding environment. In addition, the hazardous waste
storage containers should be placed in an isolated area to minimize
possible detrimental effects on industrial workers.
FINAL TREATMENT PROCESSES
In this report, a "final treatment" process is defined as one
which alters or destroys hazardous wastes completely, leaving only
innocuous substances as by-products. Several hazardous waste generators
and private contractors that dispose of hazardous wastes employ various
physical and/or chemical treatment processes, in addition to storage
at the aforementioned hazardous waste facilities, to effectively alter
or destroy hazardous wastes. The innocuous substances that result from
these processes do not, in general, have adverse effects on the environment.
The wide variety of treatment processes provides a broad range of treatment
capabilities for the numerous hazardous waste types generated by industry.
For the most part, these processes are performed by the hazardous waste
generator and often are incorporated directly into the processing plant
system.
Several of the major "final treatment" processes which
eliminate hazardous wastes include oxidation, reduction, neutralization,
detoxification, open burning, detonation, chemical/biological degradation,
hydrolysis, dechlorination, chlorination and resource recovery. Specifically,
certain types of hazardous wastes (e.g., hexavalent chromium, DDT,
cyanide, etc.) can be effectively destroyed or altered to a harmless
state by one or more of these treatment processes.
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Because hazardous wastes are generated by virtually all
industries, it is advisable that the generator facilities be designed in
accordance with hazardous waste disposal standards to mitigate the
potential for a release to the environment. Portions of these processing
areas can be considered as temporary treatment and/or storage facilities
and should conform to standards promulgated under Public Law 94-580.
Usually, these facilities isolate the hazardous wastes from the environment
by virtue of the physical or chemical processes involved, thereby
minimizing the possibility of contamination. Therefore, it is unlikely
that these hazardous wastes could enter the surrounding environment,
except under unusual circumstances (i.e. explosion, pipe rupture, etc.).
PREPARATORY TREATMENT PROCESSES
The preparatory treatment processes (e.g., sedimentation,
flocculation, etc.) should not be construed as adequate processes for
the treatment, storage or disposal of hazardous wastes. Although these
processes do partially alter, accumulate or concentrate hazardous wastes,
they do not, in themselves, constitute a viable means of hazardous waste
treatment, storage or disposal in accordance with Public Law 94-580.
In each of these processes, additional treatment, storage or
disposal at a hazardous waste facility is necessary. Therefore, these
preparatory treatment processes, as well as similar processes, are not
being considered as hazardous waste disposal facilities in this report.
Note: References cited in this Appendix are listed at the end of
Chapter III.
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APPENDIX 4
HAZARDOUS WASTE RELEASE EVENTS
The purpose of this section is to describe a classification of
accidents or events whose occurrence at hazardous waste treatment, storage or
disposal facilities might require emergency response measures to be undertaken.
In this report, the words "accidents" and "events" are considered
synonymous. Only events which relate directly to confirmed releases are
considered. We have confirmed with EPA that natural disaster warnings,(e.g.
for tornados and hurricanes, etc.)will be covered under operating plan
requirements, to be discussed in another report.
Table 32 shows the general classes of events considered in this report.
The procedure for classifying events relied primarily on a review of past
incidents or releases involving hazardous wastes. In addition, a number of
hypothetical events were considered to have the potential of creating
emergency situations at various types of hazardous waste facilities. The
In reviewing EPA files on accidents involving hazardous wastes
(EPA, 1975a; and open file materials), it is evident that in the past the
majority of hazardous waste related incidents or releases resulted from the
improper burial of the wastes, very often simply from depositing the wastes
tnto open dumps, abandoned mines and pits. These improper disposal practices
often resulted in ground water and surface water contamination and other
serious environmental consequences (Shuster, 1976a, 19765, 1976c). While it is
assumed that the regulations to be promulgated under the provisions of RCRA
will greatly reduce the incidence of improper disposal of hazardous wastes,
it is felt the occurrence of any of the following events (see Table 1) at
hazardous waste facilities may pose the threat of serious environmental damages
unless responded to promptly and effectively:
1) Non-routine Liquid Release: Although this class covers a wide
variety of situations when identified with specific facility types, rather
well defined events can be related to certain facilities. At first an attempt
was made to break down this class into categories according to the quantity of
wastes released. However, due to the wide range of toxicity, flammability,
and other characteristics among the various hazardous wastes, no such breakdown
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TABLE 32
CLASSIFICATION OF EVENTS
1. Non-routine Liquid Release: seepage - surface
subsurface
failure - surface
subsurface
personnel error - surface
subsurface
2. Non-routine Solid Release: wind erosion
personnel error
3. Non-routine Gas Emission: surface
subsurface
4. Fire (N.F.P.A. Standard No. 10)1: Class A
Class B
Class C
Class D
5. Explosion: surface
subsurface
6. Dike Failure
7. Direct Human Contact
Direct Animal Contact
N.F.P.A. Standard No. 10 is described in Table 2.
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can easily be obtained. Therefore, the releases were divided according to
cause of release (i.e., event subcategories): seepage, failure, or personnel
error. These three groups were then further broken down into surface and sub-
surface groups since detection and response for these two types of release
will differ significantly. Documented cases of non-routine liquid releases
include:
a) Contamination of ground water beneath the Rocky Mountain Arsenal
and surrounding area (EPA, 1975b): This accident involved the contamination
of a shallow water table aquifer. A complex mixture of chemical by-products
was stored in a holding pond. Eventually, leachates from the pond reached
the aquifer and forced the abandonment of 64 domestic, stock and irrigational
wells. This event would thus be classed as a non-routine surface release as
seepage.
b) Emergency Incident Involving Hazardous Wastes, Anniston,
Alabama (Ghassemi, 1977): In this case, industrial wastes containing high
concentrations of sulfuric acid were being stored in steel drums prior to
treatment and disposal. A large number of the drums corroded during storage,
and the spillage eventually contaminated both ground water and surface water.
Here, the release was due to a failure at the surface.
In addition to the examples of non-routine liquid releases cited
above, a large number of other non-routine liquid releases are possible at
hazardous waste facilities (e.g., seepage through retention dikes, etc.).
Subsurface releases can result from failure or improper installation of
injection well casing, landfill liners or subsurface storage containers.
2) Non-routine Solid Release: Non-routine solid releases can occur
at any hazardous waste facility that treats, stores or disposes of wastes
in a solid phase, such as "dried" chemicals, explosives, sludges, etc.
Typically, these releases would result from improper handling or breakage of
containers used in the transport of these waste types within facility bound-
aries. These types of personnel errors occur frequently at hazardous waste
facilities; however, the effects are generally minimized because solid wastes,
unless directly introduced in surface or ground waters, tend to remain in
place and do not migrate rapidly like liquid and gaseous releases. On the
other hand, solid hazardous wastes can be spread over extensive areas by wind
295
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erosion unless the waste is properly covered.
3) Non-routine Gas Emission: This class of events includes non-
routine emissions from incinerators, reaction products from the improper mixing
of reactive wastes (EPA, 1976a), failure of gas storage vessels, and other
accidental gas releases. Non-routine gas emissions can occur in both the sur-
face and subsurface environments depending on the facility type.
4) Fire: Fires can best be classified along the guidelines estab-
lished by the National Fire Protection Association Standard Number 10
(N.F.P.A., 1976), described in Table 33 . The Standard classifies fire accord-
ing to type of material burning (Class A: "ordinary combustibles"; Class B:
flammable liquids; Class C: electrical equipment; and Class D: combustible
metals). This classification scheme enables the immediate determination of
the type of fire fighting agent to be used. An attempt was made to find a
standard classification by magnitude of fire, but a review of National Fire
Protection Association publication (N.F.P.A., 1976; Bahme, 1976; N.F.P.A., 1975)
and interviews with local fire protection officials (Hortzell, 1977) suggest
that no such classification exists.
5) Explosion: A number of explosions have been reported at hazard-
ous waste disposal facilities, generally the result of the improper handling of
wastes (EPA 1975c; 1976b; 1975d). Due to the explosive characteristics of
certain wastes handled at hazardous waste facilities, there are numerous ways
in which explosions can be accidentally triggered. The most convenient
distinction among explosion events appears to be between surface and subsur-
face explosions, since the response to each type of explosion would differ
significantly.
6) Dike Failure: While the class of events described by the term
dike failure can likely be included in the category of non-routine liquid
releases, dike failures represent a common accident of potentially serious
magnitude and, therefore, merit separate consideration. Dike failure can
result from either natural causes (EPA, 1975e), or improper design and con-
struction practices (EPA, 19755).
7) Direct Human & Animal Contact: Reports of accidental direct
human and animal contact with hazardous wastes have been documented for a
number of hazardous waste facilities (EPA, 1975a; 1975b; 1975c). Such
296
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TABLE 33
N.F.P.A. STANDARD NO. 10
Class A: Fires involving ordinary combustible materials (such as wood, cloth,
paper, rubber, and many plastics) requiring the heat-absorbing (cooling)
effects of water, water solutions, or the coating effects of certain dry
chemicals which retard combustion.
Class B: Fires involving flammable or combustible liquids, flammable gases,
greases, and similar materials where extinquishment is most readily secured
by excluding air (oxygen), inhibiting the release of combustible vapors, or
interrupting the combustion chain reaction.
Class C: Fires involving live electrical equipment where safety to the opera-
tor requires the use of electrically nonconductive extinquishing agents.
(Note: when electrical equipment is deenergized, the use of Class A or B
extinquishers may be indicated).
Class D: Fires involving certain combustible metals (such as magnesium,
titanium, zirconium, sodium, potassium, etc.) requiring a heat-absorbing
extinquishing medium not reactive with the burning metals.
Note: References cited in this Appendix are listed at the end of Chapter III.
Z97
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exposures can occur as the result of non-routine liquid and gas releases,
and also in the course of routine operations. For example, a worker might
accidentally step or fall into a disposal trench containing highly corrosive
wastes (EPA, 1975c). The potential for contact with hazardous wastes exists
at every type of facility.
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APPENDIX 5
HAZARDOUS WASTES
INTRODUCTION
This section defines the hazardous waste category system
developed for this study. The classification system has been devised so
as to comprehensively address all conceivable waste types, i.e., it is
capable of representing any type of existing or future hazardous waste
stream. In addition, the classification presents the waste categories
in a way which will relate meaningfully to contingency plan standards
after incorporation with facility/event pairings. In the paragraphs
which follow, the logic and rationale behind the development of the
hazardous waste categories is outlined.
The task of defining a hazardous waste classification system
is a complex one. Ideally, the results of the current EPA waste classification
study would have been utilized in this investigation. Unfortunately,
only preliminary thinking and effort in the classification system was
available at the time required for early input in this investigation.
Detailed discussions were, however, held with the Sec. 3001 Desk Officer
so that the latest input would be available for this study. Nevertheless,
the importance of a classification system in our study was apparent and
an "interim" definition was developed.
DEFINITION
For the purposes of this report the most relevant
definition of a hazardous waste is provided by the Resource Conservation
and Recovery Act of 1976 (P.L. 94-580). It defines a "hazardous waste"
as:
"...a solid waste, or combination of solid wastes, which because of
its quantity, concentration, or physical, chemical or infectious
characteristics may--
"(A) cause, or significantly contribute to an increase in mortality
or an increase in serious irreversible or incapacitating reversible,
illness; or
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"(B) pose a substantial present or potential hazard to human health
or the environment when improperly treated,stored, transported, or
disposed of, or otherwise managed."
The term "solid waste" is defined in the Act as:
".... any garbage, refuse, sludge from a waste treatment plant,
water supply treatment plant, or air pollution control facility and
other discarded material, including solid, liquid, semisolid, or
contained gaseous material resulting from industrial, commercial,
mining and agricultural operations and from community activities,
but does not include solid or dissolved material in domestic sewage,
or solid or dissolved materials in irrigation return flows or
industrial discharges which are point sources subject to permits
under section 402 of the Federal Water Pollution Control Act, as
amended (86 Stat. 880), or source, special nuclear, or by-product
material as defined by the Atomic Energy Act of 1954, as amended
(68 Stat. 923)."
Four hazardous waste classification systems were considered
and are shown in Table 34. After comparison, the "best" system was
selected on the basis of relative advantages and disadvantages. Table 35
summarizes the merits of each system. From Table 35 it was decided that
the fourth classification system is the most preferable system. As a
result, the categories used for this report were based on the classification
by associated hazards.
300
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TABLE 34
POSSIBLE CLASSIFICATION SYSTEM BASES
I CLASSIFICATION OF WASTES BY SOURCE:
Group wastes according to the type of manufacturing process of
which they were by-products. This might possibly utilize Standard
Industrial Classification (SIC) codes.
II CLASSIFICATION OF WASTES BY DISPOSAL METHOD:
Group wastes according to the specific type of process used to
dispose of or treat the waste.
Ill CLASSIFICATION OF WASTES BY CHEMICAL PROPERTIES:
Group wastes according to their specific physical or chemical
properties. Under this system some typical categories would be
ACID, ALKALINE, OXIDIZER, SOLUBLE, etc.
IV CLASSIFICATION OF WASTE BY ASSOCIATED HAZARD:
Group wastes according to the type of hazard the waste posed.
Typical categories in such a system would be FLAMMABLE, EXPLOSIVE,
CORROSIVE, etc.
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TABLE 35
ADVANTAGES AND DISADVANTAGES OF CLASSIFICATION SYSTEMS
I CLASSIFICATION BY SOURCE:
ADVANTAGES:
1. SIC codes exist for a wide range of industries
which are potential hazardous waste producers.
DISADVANTAGES:
1. There are a large number of waste sources. This
would lead to a large number of categories.
2. It would be very difficult to consolidate categories. If one
did consolidate, so many generalities would be introduced into
the classification that they would not be useful.
3. Some categories are not necessarily consistent with respect to
chemical, physical or hazard properties. In other words, it
is not possible to characterize uniquely a source. Therefore,
it would not be possible to specify standards for contingency
plans which would apply to it.
4. More specific SIC categories which relate to waste types are
not available.
II CLASSIFICATION BY DISPOSAL METHOD
ADVANTAGES:
1. These type classes relate directly with facility type (by
definition). Thus a large number of facility/event pairings
will be not-applicable. A smaller number of pairings will be
less complex when related to contingency plan standards. The
result will be easier to comprehend.
DISADVANTAGES:
1. The classifications for the most part do not relate to the
types of hazards associated with a waste. As such, it is
difficult to relate contingency plan standards to them.
302
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TABLE 35 (cont'd)
III CLASSFICATION BY CHEMICAL PROPERTIES:
ADVANTAGES:
1. A large amount of physical and chemical property data exists
for pure materials.
2. Some chemical properties relate to the hazards associated with
a substance. Thus, for these categories a relationship to
contingency standards can be made.
DISADVANTAGES:
1. Most wastes are not pure compounds. Although much
data exists on the complex wastes, it is not necessarily
applicable to waste streams.
2. Many properties do not relate to hazard categories. Therefore
even if the properties were defined for a waste, the properties
could in many cases not be related to specific contingency
plan standards.
3. Chemical properties for the most part do not relate to "events",
or "facilities".
IV CLASSIFICATION BY ASSOCIATED HAZARD:
ADVANTAGES:
1. Hazard categories, by definition, relate to the hazards associated
with a waste. Therefore, these categories relate very well to
contingency plan standards. This relationship is a primary
objective of the classification process.
2. Hazard categories correlate well with event types.
DISADVANTAGES:
1. Hazard categories do not correlate to facilities.
2. A large number of properties fall into several areas associated
with hazards. All of these must be considered simultaneously,
requiring a large number of categories.
In order to be useful, they will therefore have to be consolidated,
which may introduce some undesired generalization.
303
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CLASSIFICATION OF WASTE BY ASSOCIATED HAZARD
The hazards associated with a waste fall into five areas. For
the purpose of identification these areas are denoted as; "origin of
hazard", "mode of transmission", "environment of hazard", "mode of
attack" and "type of hazard". Each of these areas are examined in the
following paragraphs.
Origin of Hazard
The "origin of hazard" associated with a waste relates to how
it becomes hazardous. For example, certain materials release or produce
hydrogen cyanide gas upon combustion. The origin of hazard for such a
material would be combustion. This method does not result in an exclusive
classification, however. A material might also have other "origins of
hazard" associated with it since there are many ways in which a material
may become hazardous. The following list describes those ways which are
most important.
INTRINSIC: A material may be intrinsically hazardous
at standard temperature and pressure, i.e., it may not
require any transformation to become hazardous. This
would include a consideration of auto-degradation with
time or ageing. Some materials become more dangerous
with age.
REACTION WITH AIR: A material may react with air to
become hazardous. For example, a substance may give off
toxic fumes when it comes in contact with air. Another
example is a flammable gas. When it comes into contact
with air it may form a potentially explosive mixture.
REACTION WITH WATER: A material may react with water to become
hazardous. For example, water reacts with calcium
carbide to form flammable acetylene gas.
OTHER REACTIONS: A substance may react with other common materials
to form hazards.
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SYNERGISM: A substance's toxicity or other harmful effect may be
activated or magnified by association with another
substance. This is not a reaction but a synergistic
effect.
HIGH TEMPERATURE DEGRADATION: A substance may degrade when subjected
to temperatures substantially above ambient. The products
of degradation may be hazardous.
EVAPORATION: A substance may volitalize or evaporate into the air.
If the air mixture which results is hazardous, this
category would apply.
COMBUSTION BY-PRODUCTS: The by-products of combustion may be
hazardous. Commonly there may be suffocating carbon
monoxide gas or cyanide gas released.
EXPLOSION BY-PRODUCTS: The by-products of an explosion may be
hazardous. This situation might be due to the de-
composition reaction of a chemical explosion. It could,
however, also be due to an intrinsic property of a sub-
stance which was released by a rupture type of explosion.
BIO-DEGRADATION: A substance may be acted on by biological organisms.
The products of this interaction may be more hazardous
than the original substance.
AQUEOUS SOLUTION: A substance may be activated by going into
solution in water.
Mode of Transmission
The "mode of transmission" relates to how a hazard is conveyed
from its initial or safe position under controlled (preaccident) conditions
to where it inflicts injury or damage. There are five modes which are
important. These are explained below:
STATIONARY: A material may be hazardous in-situ. It may not
require any vehicle of transmission to be hazardous. An
example of such a situation is a solid high explosive.
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WATERBORNE: A material may be carried via water as a
solution, suspension, flotation, etc., to a distant location
where it may pose a hazard. This mode implies that the
material is not rendered harmless by exposure to water.
PROPELLED: A material may be carried, propelled, ejected, etc.
from its "safe" location to a distant location where it
might pose a hazard. An example of such a situation
would be the ejection of contaminated soils or liquids
from the vicinity of an explosion. Another example would
be contaminated material carried from a landfill into a
surrounding community by birds, rodents, etc.
SURFACE: A material may move via natural or man-made devices to
a distant location where it might pose a hazard. An
example would be the movement of a flammable liquid
through a dry storm drain into a community.
Environment of Hazard
The "environment of hazard" is the condition under which a material
is hazardous. For example, beryllium dust is toxic at very low concentrations
in air, but when it is dissolved in water it poses no ingestive threat
when the concentration is not too great (Battelle, 1973). Thus, an
environment of hazard (with respect to toxicity) for beryllium dust
would be air, but not water. The following environments are the most
important ones to consider:
AIR EXPOSURE
WATER EXPOSURE
INDEPENDENT
SURFACE CONTAMINATION
Mode of Attack
The "mode of attack" refers to how a hazard affects humans. The
toxic mode of attack for beryllium dust, for example, would be inhalation.
The modes of attack considered in this report are:
306
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INHALATION: A material may be hazardous if inhaled.
INGESTION: A material may be hazardous if ingested.
DERMAL PENETRATION/CONTACT: A material may be hazardous to the
touch. For example, some pesticides can penetrate through
the skin and produce toxic effects. Another example is
a strong acid. If such a corrosive agent contacts the
skin, it may produce tissue damage.
PROXIMITY: Some types of material are hazardous to humans by virtue
of proximity. An explosive is a good example. If an
explosion occurs it will effect humans who are near it.
There is no requirement that direct contact be made with
the explosive. Radioactive materials, of course, would
fall into the same category.
INDIRECT: A material may be indirectly hazardous to humans by
virtue of its damage potential to plants, crops, livestock,
fish, etc. In addition effects on non-living objects can
be considered as indirect threats to humans.
Type of Hazard
The "type of hazard" refers to the commonly recognized classes
of hazard which may be presented by a material. Included in this classification
are such categories as toxicity, flammability, genetic change potential,
etc. It is the basic attribute system for representing a hazardous
characteristic. Most of the studies which have been done in the past to
define hazardous substances have used criteria which fall into this type
of hazard category. Several of these studies are represented in Table 36
(EPA 1975f). It shows the criteria which were evaluated in determining
what materials would be classified as hazardous. Most of these systems
were developed to define hazardous substances in general; however five
are concerned directly with hazardous wastes. These include Ocean
Dumping - Title 40, CFR, Part 227; State of California List; Booz-Allen
Applied Research, Inc.; Battelle Memorial Institute; and TRW Systems
Group.
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TABLE 36
SUMMARY OF CRITERIA FOR
HAZARDOUS SUBSTANCE CLASSIFICATION SYSTEMS
Criteria
System
Department of the Army
Department of the Navy
FDA - Title 21, CFR, Part 191
Drinking Water Standards
FWPCA - Sec. 307 (a)
FWPCA - Sec. 311
Clean Air Act - Sec. 112
Ocean Dumping - Title 40, CFR, Part 227
DOT - Title 49, CFR, Parts 100-199
State of California List
National Academy of Sciences
Booz-Allen Applied Research, Inc.
Battelle Memorial Institute
TRW Systems Group
NIOSH - Toxic Substances List
Pesticides - Title 40, CFR, Part 162
Source: State Program Implementation Guide - Hazardous Waste
Surveys, USEPA, 1975.
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308
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The system which seems to have gained the most widespread use
and acceptance is the 1973 Battelle Memorial Institute report Program
for the Management of Hazardous Wastes, prepared for the EPA. The
report developed a Hazardous Waste Decision Model which can be used to
determine whether or not a given waste stream should be considered
hazardous. This model is shown schematically in Figure 5-1. It provides
screening criteria for hazard categories, and may serve as a working,
quantitative definition of hazardous wastes.
The following abbreviated definitions are for the terms used
in the model and are taken from the Environmental Protection Agency
Report to Congress (EPA, 1974).
Maximum permissible radioactive concentration (MPC) levels: Levels
of radioisotopes in waste streams which if continuously maintained
would result in maximum permissible doses to occupationally exposed
workers and which may be regarded as indices of the radiotoxicity
of the different radionuclides.
Bioconcentration (bioaccumulation, biomagnification): The process
by which living organisms concentrate an element or compound to
levels in excess of those in the surrounding environment.
National Fire Protection Association (NFPA) category 4 flammable
materials: Materials including very flammable gases, very volatile
flammable liquids, and materials that in the form of dusts or mists
readily form explosive mixtures when dispersed in air.
NFPA category 4 reactive materials: Materials which in themselves
are readily capable of detonation or of explosive decomposition or
reaction at normal temperatures and pressures.
Lethal dose fifty (LD5Q): A calculated dose of a chemical substance
which is expected to kill 50 percent of a population of experimental
animals exposed through a route other than respiration. Dose
concentration is expressed in milligrams per kilogram of body
weight.
309
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WASTE
STREAM
DOES WASTE CONTAIN
RADIOACTIVE CONSTITUENTS
> MPC LEVELS?
"
,r NO
IS WASTE SUBJECT TO
8IOCONCENTRATION?
Y NO
IS WASTE FLAMMABILITY
IN NFPA CATEGORY 4?
| NO
IS WASTE REACTIVITY
IN NFPA CATEGORY 4?
v NO
DOES WASTE HAVE AN ORAL
LD,a < 50 mg/kg?
v NO
IS
WASTE INHALATION TOXICITY
200 ppm AS GAS OR MIST?
LC,. < 2 mg/liter AS DUST?
v NO
IS
WASTE DERMAL PENETRATION
TOXICITY LOS 0 < 200 mg/kg?
V NO
IS WASTE DERMAL IRRITATION
REACTION < GRADE 8?
1 NO
DOES WASTE HAVE AQUATIC
96-hr TLm < 1.000 mg/liter?
NO
IS WASTE PHYTOTOXICITY
IL,0 < 1.000 mg/liter?
y NO
DOES WASTE CAUSE
GENETIC CHANGES?
NO
OTHER WASTES
YES
YES
YES
YES
w
YES
YES
YES
YES
YES
YES
YES
•w
HAZARDOUS WASTES
Figure 5
DECISION MODEL FOR
SCREENING AND SELECTING HAZARDOUS COMPOUNDS
SOURCE'REPORT TO CONGRESS-DISPOSAL OF HAZARDOUS WASTES'.' USEPA.1974
-------
Lethal concentration fifty (LC5Q): A calculated concentration which
when administered by the respiratory route is expected to kill 50
percent of a population of experimental animals during an exposure
of 4 hours. Ambient concentration is expressed in milligrams per
liter.
Grade 8 dermal irritation: An indication of necrosis resulting from
skin irritation caused by application of a 1-percent chemical
solution.
Median threshold limit [96 hour TLm): That concentration of a
material at which it is lethal to 50. percent of the test population
over a 96-hour exposure period. Ambient concentration is expressed
in milligrams per liter.
Phytotoxicity: Ability to cause poisonous or toxic reactions in
plants.
Median inhibitory limit (Il_m): That concentration at which a 50-
percent reduction in the biomass, cell count, or photosynthetic
activity of the test culture occurs compared to a control culture
over a 14-day period. Ambient concentration is expressed in milligrams
per liter.
Genetic changes: Molecular alterations of the deoxyribonucleic or
ribonucleic acids of mitotic or meiotic cells resulting from chemicals
or electro-magnetic or particulate radiation.
Screening criteria in addition to those of the Battelle model
are necessary because the hazard categories used do not address all the
areas which are of concern. Other sources suggesting more possibilities
follow:
The office of Oil and Hazardous Materials (OHM) Of EPA is
responsible for handling spills and other accidents which involve oil
and other hazardous substances. Their response is based on a case by
case analysis of all the circumstances surrounding a particular incident.
Assisting them in this capacity are a team of experts and an array of
other resources. One of these important resources is a chemical information
computer data base system called the Oil and Hazardous Material - Technical
311
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Assistance Data System (OHM-TADS). The data base contains information
on many aspects of hazard (EPA, 1977a). Many of the concerns are with
basic physical or chemical properties of a material. A considerable
number of catergories are concerned with specific, quantifiable, hazardous
properties. The hazardous properties which are addressed by the system
are summarized below:
CORROSIVENESS: Corrosive action to materials commonly used for
packaging or equipment that might be required at a spill
site.
FLAMMABILITY: Concerns the potential for flammability at a spill
site. The NFPA 704 ranking system is utilized.
EXPLOSIVENESS: Concerns the potential for violent rupture or
vigorous reaction at a spill site.
BIOCHEMICAL OXYGEN DEMAND: Concerns the potential to lower oxygen
level in a body of water either by direction reaction with
oxygen or biological oxidation. BOD is given as Ib/lb or
percent of theoretical demand basis.
FOOD CHAIN POTENTIAL: Indicates the potential for a material to
concentrate to toxic levels while it is passed up the
food chain to humans. This potential is often called
bioconcentration, bioaccumulation, or biomultiplication.
ETIOLOGICAL POTENTIAL: Concerns the potential of a material to
initiate or accelerate diseases ar ailments by exposure.
CARCINOGENICITY: Concerns the potential of a material to produce
cancer in humans.
MUTAGENICITY: Concerns the potential of a material to produce
biological alterations in humans.
TERATOGENICITY: Concerns the potential of a material to produce
birth defects or abnormal formations.
FRESHWATER TOXICITY: Concerns the concentration levels at which
toxic effects will occur in freshwater.
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CHRONIC AQUATIC TOXICITY: Concerns the chronic long-term exposure
limits of fish for a substance.
SALT WATER TOXICITY: Concerns the toxicity levels of estuarine
or marine animals for a substance.
ANIMAL TOXICITY: Concerns the toxicity levels of various test
animals for a substance.
CHRONIC ANIMAL TOXICITY: Concerns the chronic or long-term
toxicity levels of animals for a substance.
LIVESTOCK TOXICITY: Concerns the toxicity level of a substance
toward livestock.
HAZARD TO WATERFOWL: Concerns the effects of a substance on
waterfowl. Relates to the acute exposure limits.
CHRONIC HAZARD TO WATERFOWL: Concerns the chronic or long-term
effects of a substance on waterfowl.
AQUATIC PLANT TOXICITY: Concerns the potential of a substance to
injure aquatic flora.
IRRIGABLE PLANT TOXIC: Concerns the potential of a substance to
be injurious to crops.
CHRONIC PLANT TOXIC: Concerns the potential for injury to crops
which are exposed chronically or on a long-term basis
to irrigation water contaminated with a substance.
TASTE IMPARTING CHARACTERISTICS: Concerns the potential for a
substance to impart an undesirable taste to the flesh
of fish living in affected waters.
INHALATION LIMIT: Concerns the inhalation toxicitylevels of a
substance.
IRRITATION LIMIT: Concerns the concentration levels required for
a material to cause irritation to the skin and mucous
membranes of the body.
DIRECT CONTACT: Concerns the potential of a material to be
irritating or corrosive on direct contact with the skin,
eyes or mucous membranes.
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DIRECT HUMAN INGESTION: Concerns the potential of a sub$tance
to be toxic if ingested directly.
DRINKING WATER LIMITS: Concerns the levels which are recommended
as being safe in drinking water.
BODY CONTACT EXPOSURE: Concerns itself with the acute contact
hazard of a substance in water.
PROLONGED HUMAN CONTACT: Concerns itself with the safe levels in
water which is used for prolonged bathing and swimming
activities.
INDUSTRIAL FOULING POTENTIAL: Concerns the potential for water
contaminated with the substance in question to cause
problems when used by industry. This relates to scale
forming agents as well as materials with potential rupture
hazards when included in boiler feed or cooling water.
EFFECT OF WATER TREATMENT PROCESSES: Concerns the potential
interactions with typical water and waste water treatment
facilities. This includes the effect of chlorination
an aesthetic properties of contaminated water, as well
as the effect of high concentration on sewage organisms.
The above categories can be divided into two areas of emphasis;
short-term, immediate, acute effects; and long-term, future, chronic
effects. Each category has a difference in the degree of concern which
is associated with it. In relation to accidents, the factor of environmental
persistance (non-biodegradability) plays a vital role in deciding what
should be considered as important. If a substance is chronically
toxic to fish, but is not persistent in the environment, then it
would not be an important hazard to consider. Using this rationale,
the distinction between chronic and acute in the OHM-TADS-classification
may be disregarded and categories lumped together. This procedure was
adopted in integrating and converting the OHM-TADS concern categories
into the general type of hazard categories used in thts report. The
categories which result from this summarizing are listed below:
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TOXIC
IRRITATING
SENSITIZING
CARCINOGENIC
TERATOGENIC
ETIOLOGIC
INFECTIOUS
RADIOLOGICAL
EXPLOSIVE
FLAMMABLE
BIOCONCENTRATING
BIOCHEMICAL OXYGEN DEMANDING
AQUATIC TOXIC
PHYTOTOXIC
IRRIGABLE PLANT TOXIC
AQUATIC PLANT TOXIC
ANIMAL TOXIC
CORROSIVE TO EQUIPMENT, ETC.
INDUSTRIAL FOULING
WATER TREATMENT FOULING
All five of the major areas which have been discussed must be
considered simultaneously to completely describe a hazardous waste in
relation to an accident situation; however, it is awkward to do this
inasmuch as a total of 25,200 possible combinations result. Obviously,
the categories need to be combined and grouped into a more workable
number. To accomplish this a systematic approach was taken. Each of the
areas; "type of hazard", "mode of attack", "mode of transmission" and
"environment of hazard" but not "origin of hazard" were integrated with
one another in successive steps. The integrations were done to show
which attributes in each area were not compatable. For example, consider
the ingetration of the "type of hazard" with the "mode of attack":
The "type of hazard" category called EXPLOSIVE is not applicable to
the "mode of attack" category INHALATION. This is because inhalation
is not a a mode of attack for an explosive material. On the other
hand the "mode of attack" categories of PROXIMITY and INDIRECT are
applicable to an explosive substance.
315
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Once the applicability between the categories was established,
some of them were combined into hybrid groups. For this reason the
integration processes were denoted as "hybrid integrations". The hybrid
categories which resulted from the first integrations were included in
the next integration and so on until a final set of hybrid categories
evolved.
The "origin of hazard" categories were combined with the final
hybrid categories in a different way than above. The "origin of hazard"
categories were first clustered into "event" related groups, as described
below. The reason for this will be made apparent later. The resulting
"event" groups were then integrated with the final hybrid categories to
produce the final waste categories. This integration and clustering
process is shown schematically in Figure 5-2.
A first step in this direction is taken by integrating the
"type of hazard" with the "mode of attack" categories. This integration
is shown schematically in Figure 5-3. Coning out of the process are nine
groups which are numbered one through nine in the table. For identification
purposes these groups are denoted as follows:
GROUP 1 - INHALATION HEALTH HAZARD
GROUP 2 - INGESTION HEALTH HAZARD
GROUP 3 - CONTACT HEALTH HAZARD
GROUP 4 - RADIOLOGICAL
GROUP 5 - EXPLOSIVE
GROUP 6 - FLAMMABLE
GROUP 7 - BIOCONCENTRATIVE
GROUP 8 - ENVIRONMENTAL HAZARD
GROUP 9 - CORROSIVE/FOULING
The second step toward consolidation of categories involves
integration of the "type of hazard" - "mode of attack" hybrid categories
with the "mode of transmission" category. This is shown in Figure 5-4.
There are ten groupings which result. They are numbered in the table
and identified below:
GROUP 1 - AIRBORNE HEALTH HAZARD
GROUP 2 - WATERBORNE HEALTH HAZARD
316
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317
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Figure 8
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318
-------
Figure 9
SECOND HYBRID INTEGRATION
MODE OF TRANSMISSION
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319
-------
GROUP 3 - CONTACT HEALTH HAZARD
GROUP 4 - RADIOLOGICAL
GROUP 5 - FLAMMABLE/EXPLOSIVE VAPOR
GROUP 6 - EXPLOSIVE SOLID/LIQUID/SOLUTION
GROUP 7 - FLAMMABLE SOLID/LIQUID/SOLUTION
GROUP 8 - BIOCONCENTRATIVE
GROUP 9 - ENVIRONMENTAL HAZARD
GROUP 10 - CORROSIVE/FOULING
To combine the categories still further a third hybrid
integration is performed. This one involves the categories from the
previous step and the "environment of hazard" classification. Figure 5-5
shows the results. Notice that no vertical consolidation has taken
place. Therefore, the original classification names (above) are retained
for each of the groups which are numbered one through ten in the table.
There remains one further integration which must be performed to arrive
at the final set of classification which will be used to characterize a
waste hazard. This is integration with the "origin of hazard". Examination
of the "origins of hazards" list suggests a possible way of grouping
which will relate to events. The advantage of this is that it will
eliminate a great deal of redundancy in classification. Consider the
following example: Suppose that a material had toxic combustion products.
An origin of hazard for this material's toxicity would be combustion.
Suppose also that the material were not intrinsically toxic. If the
material were classified in a fully expanded system (i.e. one which, for
example, included categories such as INTRINSICALLY TOXIC, TOXIC WHEN
COMBUSTED, TOXIC IN WATER, etc.) there would be an unnecessary redundancy
of notation. When facility/event/waste groupings are correlated the
waste column called TOXIC WHEN COMBUSTED would be non-applicable in all
those cases where the event FIRE were not present.
Several categories are listed below. Each category is composed
of one or more of the original"origin of hazard classes. Where possible,
the groups relate to facility/event types.
I. SURFACE LIQUID RELEASE
A. INTRINSIC
320
-------
Figure 10
THIRD HYBRID INTEGRATION
ENVIRONMENT OF HAZARD
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CONTACT
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FLAMMABLE /EXPLOSIVE
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EXPLOSIVE SOLID
OR LIQUID
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B. REACTION WITH AIR
C. REACTION WITH WATER
D. AQUEOUS SOLUTION
E. BIODEGRADATION
F. EVAPORATION
II. SURFACE SOLID RELEASE
A. INTRINSIC
B. REACTION WITH AIR
C. EVAPORATION
III. FIRE
A. INTRINSIC
B. HIGH TEMPERATURE DEGRADATION
C. EVAPORATION
D. COMBUSTION BY-PRODUCTS
E. REACTION WITH WATER
F. AQUEOUS SOLUTION
G. BIODEGRADATION
IV. EXPLOSION
A. INTRINSIC
B. EXPLOSION BY-PRODUCTS
V. DIRECT CONTACT
A. INTRINSIC
VI. GASEOUS SURFACE RELEASE
A. INTRINSIC
B. REACTION WITH AIR
VII. GASEOUS/LIQUID SUBSURFACE RELEASE
A. INTRINSIC
B. REACTION WITH WATER
C. AQUEOUS SOLUTION
D. BIODEGRADATION
VIII. REACTIVITY
A. REACTION WITH WATER
B. REACTION WITH AIR
322
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C. OTHER REACTION
D. SYNERGISM
Special attention is given to the last category; REACTIVITY.
It is the only one which does not relate to specific event types. Therefore,
this category was added to the hybrid "type of hazard" - "mode of attack" -
"mode of transmission" categories. Note that it contains the"origin of
hazara" class SYNERGISM. Synergism is the joint action of two or more
agents which act together to produce an effect which is more pronounced
than the effect of any of the agents acting alone. A synergistic
interaction involving two chemicals is not a reaction per se. It is
however, consistent with the definition of Reactivity. For this reason, it
was included in the REACTIVITY grouping. One final grouping is added to
deal with the case where a material's identity or properties are not
known. This category is called UNKNOWN.
The final waste hazard categories are therefore as follows:
I. AIRBORNE HEALTH HAZARD
II. WATERBORNE HEALTH HAZARD
III. CONTACT HEALTH HAZARD
IV. RADIOLOGICAL
V. FLAMMABLE/EXPLOSIVE VAPOR
VI. EXPLOSIVE SOLID/LIQUID/SOLUTION
VII. FLAMMABLE SOLID/LIQUID/SOLUTION
VIII. BIOCONCENTRATIVE
IX. ENVIRONMENTAL HAZARD
X. CORROSIVE/FOULING
XI. REACTIVE
XII. UNKNOWN
These may be summarized as follows:
FLAMMABLE/EXPLOSIVE VAPOR:
This category is reserved for gases and vapors which are flammable
and/or explosive. In addition, it is applicable to liquids (or
solids) which are extremely volatile and give off flammable/explosive
vapors.
323
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FLAMMABLE SOLIDS/LIQUIDS:
This category is reserved for liquids, solids, sludges, slurries,
etc. which are flammable.
EXPLOSIVE SOLIDS/LIQUIDS:
This category is reserved for solids, liquids, sludges, slurries,
encapsuled or contained gases, liquids, etc. which may present an
explosion hazard.
BIOCONCENTRATIVES:
This category is reserved for substances which may concentrate in
a single species or through a series of species (plant or
animal) in the human food chain to a level, above the ambient
level, which are toxic or injurious to humans.
CORROSIVES:
This category is reserved for substances which are corrosive to
equipment, structure, containers, etc. which are likley to be
found in hazardous waste facilities or which may be used at such
facilities during emergencies.
REACTIVES:
This category is reserved for substances which tend to react
spontaneously in a hazardous way with common materials. Included
in this category are substances which may undergo synergistic
interactions. In this definition the term "hazardous way" means
that the substance may react so as to produce any of the following
effects:
a. violent reaction (spewing reactants)
b. rapid heat generation
c. generation of hazardous products
The term "common material" would include:
a. air
b. water
c. structural metals
d. other construction materials
324
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RADIOLOGICAL:
This category is reserved for materials which spontaneously
emit ionizing radiation to the environment. This includes
radionuclides and materials contaminated with radionuclides.
It does not include materials covered by NRC regulations.
ENVIRONMENTAL HAZARD:
This category is reserved for substances which pose a threat
to the environment. This would not include the hazards of
fire, explosion or radiological materials, nor would substances
producing adverse effects on humans alone be classified as
ENVIRONMENTAL hazards. The emphasis is on effects on plants,
crops, fish, shellfish, livestock, etc.
In addition, materials which might effect the structure, function,
etc., of non-living objects in such a way that it may cause harm
to plants, animals, or humans would be classified as an ENVIRONMENTAL
hazard.
AIRBORNE HEALTH HAZARD:
This category is reserved for substances which may be transported
via the air and which pose a health hazard to humans. This health
hazard would not include the normal hazards associated with fires,
explosion or radioactive materials. Hazards that would be included
are:
a. inhalation toxic
b. dermal penetration toxic
c. irritating
d. sensitizing
e. etiologic
f. carcinogenic
g. mutagenic, teratogenic, etc.
h. ingestion toxic (applies to material which might settle
on the surface of plants which are subsequently eaten).
325
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WATERBORNE HEALTH HAZARD:
This category is reserved for substances which may be transported
via water as a solution, suspension, or flotation and which
pose a health hazard to humans. This health hazard would not
include the normal hazards associated with fires, explosions or
radiological materials. Hazards which would be included are:
a. ingestion toxic
b. dermal penetration toxic
c. irritating
d. sensitizing
e. etiologic
f. carcinogenic
g. mutagenic, teratogenic, etc.
CONTACT HEALTH HAZARD:
This category is reserved for substances which may be transported
via direct contact and which pose a hazard to human health. The
direct contact might be via fallout from an explosion, splash from
or contact with a spill, or mishandling of materials. The normal
hazardous effect associated with fires, explosions, or radiological
materials are not considered under this category.
Hazards which would be included are:
a. dermal penetration toxic
b. irritating
c. sensitizing
d. etiologic
e. carcinogenic
f. mutagenic, teratogenic, etc.
UNKNOWN:
This category is reserved for materials whose compositions
or properties are unknown. An example of an UNKNOWN
hazard would be an unlabeled (perhaps due to corrosion
or negligence on the part of an operator) drum of
material which is in close proximity to a fire at some
type of facility.
326
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As previously mentioned, the EPA has not promulgated regulations
defining what the hazard categories are or what degree of danger is
necessary before a substance can be called hazardous. This contract study
is currently in progress and when it is finished, it should provide the
best basis for threshold values. Until threshold values are finalized
in that study, it is best to speak in qualitative terms only.
Note: References cited in this Appendix are listed at the end of Chapter III,
327
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APPENDIX 6
DAMAGE SCENARIOS; INTRODUCTION
These damage scenarios were designed as a conceptual aid to focus
attention on liability limits that may result from hazardous waste damage
events. To date, there is not a compilation of damages that resulted from
events at hazardous waste management facilities. Documented cases are
largely limited to accounts of accidents, spills and leaks from various
industries other than the disposal industry. Furthermore, these accounts
do not cover the full range of potential damages.
Hazardous waste incidents on the scale of the mercury poisoning
cases in Japan or the dioxin disaster in Italy have not occurred in the
United States. Thus, to accurately reflect the true nature of the problem,
these damage scenarios were designed. They are based on actual incidents
that have occurred or are extensions of such incidents. While in a few
technical areas, they may prove to be inaccurate, such inaccuracy will not
detract from their overall utility in highlighting both potential damages
and the consequences of these damages.
328
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Incinerator Malfunctions
•Operating Characteristics
-An incinerator used to dispose of hazardous wastes has the following
operating characteristics:
10 GPM Waste Tar
13,000 FT3/MIN Combustion Air
20,000 FT3/MIN TEMPERING AIR
300 GPM Fresh Water
2,300 GPM Recycled Water
•Failure Mode
-One hour undetected interruption in recycled water flow permitting
flue gas exit with insufficient scrubbing - 2:30-3:30 PM .
At that time, one-third of tar content is:
0
« M
MSMA: CH. - As - ONa
j i
OH
This compound is broken down during combustion to:
0
CH3 - AS - ONa + 302 As203 + 2C02 + 3H20 + 2NaOH
OH
Based on air flow and full release of As^O-,, the concentration at the stack
is 1,118 PPM
•Dispersion
-Assume westerly winds at 5 MPG during period of release. The area of
exposure is 2,356 SQ. MI.
329
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• Receptor Interaction
-Small town of 500 families located 40 MI. down wind. 20 families
located at closer distances 2,000 head of cattle located within
10 miles
•Ecological Impact
-In town: Skin Effects - Hyperkeratosis of palms and soles;
Edema of Eyelids - 20 people - duration 2 months
-Closer families: Central Nervous System-Mental Confusion, Defective
Control of Muscles-10 People; Skin Effects-20 People- Duration
6 Months
-Cattle: Nausea, Vomiting, Contaminated Milk-10 Cattle Die-Duration
3 Months
•Financial Impact
-Action for damages suits result in the following rewards:
Skin Effects - $50,000
Nervous System - $1,200,000
Cattle - $10,000
Total - $1,260,000
330
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Secure Landfill
Class I Secure Landfill Disposing Petroleum Refinery Hazardous
Materials On Site
•Operating Characteristics
-Segregation of Wastes
-Neutralization of Acids and Caustics
-Reduced Fluid Mobility Through Suitable Soil Mixture
-Daily Earth Covering of 6" Soil
•Failure Mode
-Explosion and Subsequent Fire Caused by Unknown, Unanticipated
Chemical Reaction
-Toxic Cloud Includes Oily Wastes, Phenols and Some Tetraethyl Lead
Vapors Toxic At .075 - .15 MG/M3
•Dispersion
-Explosion Radius 115' /. Contained Within Site 10 MPH Wind
-Fire Lasts 2 Hours But Evacuation Successful After 1 Hour
Area of Exposure 10 Sq. Mi.
•Receptor Interaction
-Urban Area of 500 People/Sq. Mi. ,*• Total Exposed Population = approximately
5000 People.
•Ecological Impact
-Approximately 1000 people experience irritation including skin and
lung problems. 45 people receive superficial skin burns from exposure
to airborne toxics, 17 people experience nausea and vomiting, 5
experience recurring headache and dizziness over 3 month period. One
elderly man is killed by a stroke during the evacuation procedures.
331
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• Financial Impact
-Since many of the exposed people are employing in the local petrochemical
industry only a small number file actions for damages against the refinery.
Eight of the 62 people who recovered within 36 hours sued for a total of
$100,000. Three of the recurring cases sue for $200,000 each and the widow
of the stroke victim sues for 2 million dollars. To avoid negative publi-
city and although they are self-insured and deny liability, the refinery
makes a guick out of court settlement for $150,000.
332
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Explosion at Secure Landfill
•Operating Characteristics
-Segregation of Hastes
-Neutralization of Acids and Caustics
-Reduced Fluid Mobility through Suitable Soil Mixture
-Daily Earth Covering of 6" Soil
•Failure Mode
-During the compacting process a small explosion occurs that ruptures a
nearby large pesticide temporary storage tank. A cloud of dioxin is
released.
•Dispersion
-Hind velocity is 3 MPH. The site is located in a bowl shaped valley
and there the cloud hovers over the valley for 36 hours.
•Receptor Interaction
-Alert to the experience in Italy evacuation procedures are triggered
immediately. 8000 people are evacuated. Livestock herds totalling
2,500 animals are left behind.
•Ecological Impact
-Dioxin is one of the most toxic chemicals known. Based on animal
studies, both the oral and dermal lethal doses are in the range of
micrograms per kilogram body weight.
•Liability Assessment
-5000 people are allowed to return to their homes. The other 3000 are
unable to return until the contamination level is reduced. The
National Guard seals off the contaminated areas. All drinking water
in the valley is contaminated and thus bottled water must be provided.
All livestock is condemned and destroyed. Because of the prompt
evacuation procedures, only 75 people in the immediate area of the site
333
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are exposed. Law suits totalling 200 million dollars are filed
against the facility by the 3000 dispossessed , the 75 people directly
affected, the owners of the livestock, and the city government. The
breakdown of this sum is as follows:
75 injured total $120 million
2000 dispossessed total 70 million
livestock total 8 million
city government 2 million
The courts award settlements totalling $38 million.
334
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Earthquake at Secure Landfill
•Operating Characteristics
-Segregation of Wastes
-Neutralization of Acids and Caustics
-Reduced Fluid Mobility Through Suitable Soil Mixture
-Daily Earth Covering of 6" Soil
•Failure Mode
-Mild earth tremor cracks liner at bottom of landfill allowing contact
with groundwater. Tremor occurs at night and is not noted by site
operators.
•Dispersion
-The slow leak of heavy metals including mercury and chromium into an
adjacent aquifer continues for fifteen years before it is detected.
58 private wells draw upon this aquifer for water supply as well as
one poultry processing plant.
•Receptor Interaction
-250 individuals are effected having consummed contaminated water for
an estimated 5-7 years. No pass on of heavy metals is thought to
have occured in the poultry plant.
•Ecological Impact
-10 individuals are found to have mild nose and throat problems, six
more severe liver damage and one severe central nervous system damage
attributed to mercury poisoning.
335
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'Financial Impact
-A recovery of costs damage suit for $10,000 is filed by the poultry
plant for installation of filter equipment. The 10 least affected
individuals file suit for $100,000 each, the six more severe cases,
$100,000 each, and the most severe case sues for 1 million dollars.
The municipality sues for $500,000 for cost of supplying an alternative
water supply to the area. The court awards a total of 1.1 million
dollars.
336
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Slow Leak at Secure Landfill
•Operating Characteristics
-Segregation of Wastes
-Neutralization of Acids and Caustics
-Reduced Fluid Mobility Through Suitable Soil Mixture
- Daily Earth Covering of 6" Soil
•Failure Mode
-The landfill is located above a dry aquifer. It is determined the
aquifer has been dry since a nearby large river naturally changed its
course 200 years ago. Development activities in the area including
the construction of a dam and canal, the blacktopping of natural
recharge sites,and large scale irrigation alters ground water channels
and refills the aquifer. Slow erosion underneath the landfill allows
infiltration of chemicals including potassium cyanide.
•Dispersion
-The potassium cyanide infiltrates the regional reservoir that provides
the drinking water for 120,000 people as well as into 200 private
drinking wells.
•Receptor Interaction
-Although monitors at the reservoir detect the potassium cyanide before
the water is utilized by the public, numerous private well users are
poisoned.
•Ecological Impact
-Potassium Cyanide is a very toxic chemical. 170 families are poisoned
by drinking from their private wells. 18 deaths result (primarily very
young and very old people) and 60 people are hospitalized for severe
poisoning. 27 of these patients develop permanent damage.
337
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•Liability Assessment
-17 of the 18 deaths result in law suits as do all 27 of the
permanently impaired and 120 people who were seriously exposed. Suits
totalling $134 million are filed. They include:
17 deaths total $ 34 million
27 permanently impaired 75million
120 seriously exposed 25 million
total
The courts award settlements totalling $40 million.
338
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Tornado at Solvent Reclaiming Plant
•Operating Characteristics
-A small solvent reclaiming plant operates batch reclaiming operations.
The toxic residue from the reclaiming process is stored in barrels in
an on-site warehouse until sufficient quantities are accumulated to
justify contracting an independent disposer to haul the barrels to a
secure landfill. The independent disposer arrives about twice yearly.
•Failure Mode
-A tornado sweeps through the reclaiming site destroying 70% of the
reclaiming plant and the entire storage warehouse.
•Dispersion
-Two types of hazardous wastes are dispersed into the environment;
solvents prepared for the reclaiming process such as carbon tetra
chloride and methyl chloroform, and toxic residue resulting from the
reclaiming process. Within 300 yards of the site, 186 barrels are
scattered along the path of the tornado. Most are ruptured and
leaking. Located over a 2 sq. mile path are additional barrels in
indeterminate numbers.
•Receptor Interaction
-On 3 private properties near the plant leaking barrels are located.
The occupants are evacuated. Over a weeks time, the barrels scattered
over the 2 sq. mile area are located and returned. However, 10 days
after the storm, 5 small children are playing in a wooded area and
discover one of the barrels. Attempting to role the barrel downhill
the barrel leaks and fumes overcome one of the children and temporarily
blind two others. Another individual finds one of the barrels, takes
it home and tries to fabricate a home fireplace. The fumes send this
individual to the hospital.
339
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•Ecological Impact
-The duration of the exposure is brief and then only the short range
effects of cramps, vomiting and temporary coma are experienced.
•Financial Impact
-The four individuals bring actions for damages totalling $80,000 and
receive a settlement of $5,000 each.
340
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Concrete Encapsulation of PCB Residue
•Operating Characteristics
-A chemical treatment facility disposes of large quantities of PCB
residue by encapsulating the PCB in concrete and storing the concrete
on site. These blocks are confused with a recent shipment of concrete
to be used for an on-site construction project. The on-site construction
is cancelled and the concrete sold. A highway construction firm
purchases the concrete to use as road base for a new 15 mile section of
superhighway without knowing about the PCB content. After one year
of grading and laying the highway base, the project meets local
opposition as citizens attempt to have the highway built elsewhere.
After two years of court proceedings, the project is abandoned after
sealing the road base with asphalt.
•Failure Mode
-Ten years later, a housing development is built amidst the abandoned
highway. The broken up road bed rubble is hauled 3/4 of a mile away and
used to fill a wetland area and flood plain. Over a fifteen year period
the PCB's slowly leach into a tidal river.
•Dispersion
-The PCB percipitates into the bottom silt over a 7 mile length of
river.
•Receptor Interaction
-No humans are directly affected but fish in the area start showing
large quantities Qf PCB's in their tissue forcing the shutdown of a
small, thriving fishing industry.
•Ecological Impact
-Fish and benthic organisms absorb the PCB's and pass them along the food
chain.
341
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'Financial Impact
-The original disposer, a large and financially secure organization,
is still in business. They are sued for damages resulting in loss of
revenue by the local fisherman for 8 million dollars and in an out of
court settlement pay 1.5 million dollars.
342
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Land Spreading on Contract Basis
of Industrial Wastes
•Operating Characteristics
-small land spreading and landfill company operating 4 trucks on
contract basis servicing industries in 50 mile area
-oily wastes are land spread on cropland and sprayed on roads as dust
control agent
-included in customer list is a chemical company that also produces
insecticides and weed killers
•Failure Mode
-barrels containing arsenic residue (A$203) from the insecticide plant
are accidently included with the oily waste barrels and instead of
landfilled are used for landspreading
•Dispersion
-the arsenic is sprayed as a dust control agent at a local fairground's
horse arena
•Receptor Interaction
-15 people, including seven children and four fairground employees,
are adversely affected by exposure to the dust
•Ecological Impact
-severe skin, central nervous system and gastro-intestinal effects of
3 days to 9 months duration
•Financial Impact
-various actions for damages totalling 1.5 million dollars are filed
against to disposer who is unab.le to pay the damage suits and is
forced to sell its assets and declare bankruptcy.
343
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APPENDIX 7
CONTENTS OF TRAINING MODULES
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TRAINING MODULE 1
Title:
The Problem of Hazardous Wastes and Their Control
Objective: To provide a general orientation and understanding of the
world of hazardous wastes.
Theme:
Time:
Format:
Hazardous wastes are a new problem area. If not controlled
they are a threat to the public health and welfare. Their
control must be by the mechanism of regulation (which inter-
nalizes the problem to the producing industry).
5-20 minutes per subject
Video tape with self teaching exams. In-depth supplement
for Professional and Class A certifications require reading
of selected references, including PL 94-580; self teaching
examinations are included. Completion of self teaching
examinations may satisfy Module 1 certification requirement.
Subject
Definition of Hazardous Wastes
Legal Mandates
Extent of the Hazardous
Waste Problem
Importance of Proper Handling
and Disposal
References
Content
EPA definition hazardous wastes
Categories of hazardous wastes
PL 94-580, objectives and key
provisions
Permit Program
EPA Guidelines
Other related federal legislation
State legislation
Sources
Current transport and disposal
Practices
Incidents
Consequences of lack of proper
control
Worker health and safety
OSHA requirements
Community health and safety
Environmental hazards
PL 94-580
Other laws
Regulations
Reports and manuals
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TRAINING MODULE 2
Title:
Objective:
Theme:
Time:
Format:
Practices Required in Processing Hazardous Wastes
To provide an understanding of the elements of practice
for a hazardous waste processing facility.
Hazardous wastes may be explosive, flammable, toxic, etc.
Handling these substances requires special procedures and
caution, to insure both the health and safety of the workers
and the community and to minimize potential harm to the
environment.
15-40 minutes per subject
Video tape with self teaching exams. In-depth supplements
for Professional and Class A certifications require reading
of selected references on subjects of this module; self
teaching exams relate to reading. Completion of self teach-
ing examinations will not satisfy Module 2 certification
requirement. An additional formal written examination would
be required for certification.
Subject
Varieties of Hazardous Wastes
and Their Characteristics
Safe Operating Procedures for
Hazardous Wastes
Facility Plan of Operation
Contingency Planning
Content
Categories of hazardous wastes
(eg explosive, noxious, toxic,
ecological hazard, etc.)
Health and safety hazards in
handling each category of
hazardous waste
Community health and safety
hazards
Environmental effects of hazardous
wastes by category
Explosives
Flammable materials
Toxic materials
Elements of a plan
Examples of plans
The role of the permit
Definition of a contingency
Examples of a contingency
Elements of a plan
Discussion of drills
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Subj ec t
Emergency Procedures
Facility Monitoring
Reporting and Record Keeping
Content
. First aid and rescue
. Fire fighting
. Rationale for monitoring (i.e., for
plant operation and for compliance
with permit)
. Log of wastes coming in-type and
quantity
. Accounting for the disposition of
the wastes
. Monitoring the ambient environment
. Forms for facility record keeping
. Comptuer vis a vis manual processing
of data
. Filing and storing records
. Legal requirements: data required
and forms
. Legal requirements: frequency of
reporting
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TRAINING MODULE 3
Title:
Hazardous Waste Treatment, Storage$ and Disposal Site Operation
Objective: To provide operating procedures for the major classes of
hazardous waste treatment and disposal sites.
Options: (a) Land disposal (b) Incineration (c) Final treatment
(d) Above ground storage
Theme: Final disposal and treatment techniques may be very special-
ized for the type of facility and wastes involved. Strict
adherence to the plan of operation and congnizance of the
hazards are required.
Time: 4-8 hours each training option
Format: Video tape with self teaching examinations. These can
be supplemented with classroom instruction, group discussion,
or site visits.
OPTION A: LAND DISPOSAL
Subject Content
Categories of Land Disposal
Categories of Wastes Suitable
for Land Disposal
Land Disposal Procedures
Disposal Site Maintenance
OPTION B:
Subject
Types of Incineration
. Approved Landfills
. Secure Landfills
. Near-Surface Burial
. Deep Burial
. Toxic materials
. Bioconcentrators
. Carcinogens
. Radioactive, etc.
. Burial techniques
. Recordkeeping
. Segregation of wastes
. Ground water/leachate monitoring
. Surface runoff control
. Access control
. Site restoration
INCINERATION
Content
. Multiple Hearth
. Fluidized Bed, etc.
348
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Subject
Categories of Substances Suitable
Operating Procedures
Content
Flammable compounds
Toxic Gases, etc.
Process control techniques
Hazardous waste handling
Maintenance of air pollution
Handling of residues control
equipment
Subject
OPTION C: FINAL TREATMENT
Content
Types of Final Treatment
Processes
Categories of Substances Amenable
to Final Treatment
Operating Procedures
Oxidation/reduction
Neutralization
Chemical degradation
Detoxification
Open burning/detonation
Hydrolysis
Biological degradation
Resource recovery
Strong acids/bases
Hazardous organics, etc.
Process control parameters
Handling the residues
Recordkeeping
Subject
OPTION D: ABOVE GROUND STORAGE
Content
General Precautions for Storage
of Wastes
Precautions for Specific Wastes
. Segregation of waste types
. Cleanliness of containers
. Prevention of siphoning
. Flammable liquids
. Corrosives
. Radioactive wastes
349
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TRAINING MODULE 4
Title: Site Specific Training
Objective: To provide supervised on the job training relative to
operating a facility for processing of hazardous wastes.
Theme: The general knowledge of Modules 1, 2, and 3 must be applied
in the context of the unique features of a particular facil-
ity; this can be achieved only by specific training on the
job which is oriented about applying such knowledge to
specific job tasks. This module is intended for new person-
nel so that they may become familiar with the facility
operation; it is not a part of continuing training.
Time: 60 minutes per week
Format: Supervised periods may be formal, i.e., in a classroom situ-
ation, or informal, i.e., on the job. The instruction is to be
done by a person who has Class A certification qualifica-
tions, or greater. Question and answer sessions are en-
couraged. Certification will consist of sign-off of com-
pletion by a Class A certified person and by the RFC.
Subject
Purpose of the Facility
Authorization for the Facility
to Operate
Plan of Operation
Record Keeping
Reporting
Plant Maintenance
Contingency Plan
Emergency Procedures
Safety Protocols
Operation of Plant Equipment
Operating Rules
Content
. Permit
. Certified operators
. Responsible ownership
. Responsible Class A or
Professional in Charge
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TRAINING MODULE 5
Title: Optional Basics
Objective: To provide a digest of some of the essential operational
concepts, or procedures, or information for a given subject
area.
Theme: The knowledge underlying a hazardous waste operatoin
is comprised of a number of subject areas. A graphic under-
standing of some of the key conceptual ideas or procedures
will aid in developing rational and knowledgeable behavior
patterns and responses to the large variety of situations
which occur both in day to day operations and in emergencies.
This module should provide access to video tapes which cover
a range of topics. The library should be thought of as
expandable, i.e., not constrained by the subject below.
Time:
Format:
Subject
30-60 minutes each subject
Video tape supplemented by self teaching examinations.
Tapes may also function as a point of departure in classroom
teaching demonstrations, drills, practices, etc.
Intuitive Physical Chemistry
(All of the ideas of this
course should be demonstrated
as laboratory experiments
and then illustrated in terms
of various field situations.)
Applications of Physical
Chemistry in Facility Operation
Content
. Reactions - what it takes to
make them happen, i.e., negative free
energy of reaction
. Heats of reaction (i.e. put a thermometer
in a beaker of water and pour in acid;
show the rise in temperature)
. Equilibrium and distribution of
species
. Precipitation reactions
. Vaporization
. Adsorption reactions
. Ion-exchange reactions
. Complexes
. Leaching from land fills as an
equilibrium phenomenon
. Ground water disposal and the
role of adsorption and ion-
exchange
. Removal of heavy metals by
precipitation
. Gas stripping
. Removal of organic by adsorption
351
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Subject
Toxicology Fundamentals
Content
Categories of toxic substances
Concentration of toxic substance
and duration of exposure to it
Concentration by the food chain
Toxic effects
Explosives and Flammable
Substances
The Contingency Business
- Parts of the Infrastructure
OSHA - its business and its
literature
Manufacturing Chemists Association
National Safety Council
State Health Departments
EPA
Local police, fire, and medical
services
352
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TRAINING MODULE 6
Title:
Objective:
Theme:
Time:
Format:
Subject
Mathematics
Chemistry
Remedial Topics
To provide a means for facility personnel to learn or review
some of the skills and knowledge required which is expected
of most plant personnel at the high school level.
The basic knowledge and skills required to function at a
hazardous waste facility at a Class C certification level is
reviewed starting at a beginning level and progressing to the
equivalent high school level, but limited in scope to the job
need to know requirement.
15-30 minutes each topic within respective subject
Video tape and self teaching examinations.
Content
. Arithmetic operations
. Calculations of volumes, rates,
loadings, capacities, etc.
. Elements and Compounds
. Reactions
. Equilibrium
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TRAINING MODULE 7
Title: Continuing Training
Objective: To provide a format for continuing the training.
Theme: Training may have a variety of formats. The important
requirement is that it be continuous so that new persons are
properly indoctrinated and that the existing personnel may
stay aware of new developments and maintain their awareness
of contingency procedures.
Time: Variable depending upon the specific training activity.
Format: The variety of training formats may include: teaching
short courses, individual viewing of video tapes, facility
classroom training sessions, facility drills of various
sorts, attendance at various short courses, etc. However,
despite the encouraged flexibility, continued training at
the site should be a part of the facility training program.
On-site training should include: contingency plan drills,
first aid rescue practices, safety meetings, etc. Attendance
at these sessions should be a part of the personnel record of
each employee. Also, the record of sessions should be a part
of the reporting requirements for each facility or at least
available to regulatory personnel.
ya!829
SW-183C
354
•U.S. GOVERNMENT PRINTING OFFICE : 1979 0-311-132/161*
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