Thursday
September 13, 1979
Part  IX



Environmental

Protection Agency

Criteria for Classification of Solid Waste
Disposal Facilities and Practices; Final,
Interim Final, and Proposed Regulations (as
corrected in the Federal Register of
September 21, 1979)

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53438     Federal Register  / Vol. 44. No. 179 / Thursday. September 13. 1979  /  Rules and Regulations
ENVIRONMENTAL PROTECTION
AGENCY
 40 CFR Part 257
 [Docket NO. 4004, FRL 1234-1]
 Criteria for Classification of Solid
 Waste Disposal Facilities and
 Practices
 AGENCY: Environmental Protection
 Agency
 ACTION: Final rule and interim rule.

 SUMMARY: This regulation contains
 minimum criteria for determining what
 solid waste disposal facilities and
 practices pose a reasonable probability
 of adverse effects on health or the
 environment. Those facilities that
 violate the criteria are "open dumps" for
 purposes of the State Solid Waste
 Management planning effort supported
 by EPA under Subtitle D of the Resource
 Conservation and Recovery Act (RCRA
 or the Act) The  criteria also provide the
 standard to be applied by the Federal
 district courts in determining whether
 parties have engaged in acts that violate
 the prohibition of open dumping, also
 contained in Subtitle D of RCRA The
 criteria also partially fulfill the
 requirement of Section 405 of the Clean
 Water Act (CWA) to provide guidelines
 for the disposal and utilization of
 wastewater treatment plant sludge Any
 owner or operator of a publicly owned
 treatment works must comply with these
 criteria when disposing  of sludge on the
 land.
 EFFECTIVE DATE: October 15,1979.
DATE: For purposes of the Interim Final
portions of the criteria [sections 2573-5
and 257.3-6(b)j,  public comments will be
accepted until November 20, 1979.
 ADDRESS: Submit comments to' Mr.
Emery Lazar, Docket 4004 1, Office of
Solid Waste [WH-564), EPA,
Washington. D C. 20460
FOR FURTHER INFORMATION CONTACT:
Mr Truett V. DeGeare, Jr. P E., Office of
Solid Waste (WH-563), U.S.
Environmental Protection Agency. 401 M
Street. S W , Washington, D C. 20460,
Telephone (202)  755-9120.
SUPPLEMENTARY INFORMATION:
I. Authority
  This regulation is issued under
authority of Sections 1008(a)(3) and
4Q04(a) of the Solid Waste Disposal Act,
as amended by the Resource
Conservation and Recovery Act of 1976.
42 U.S C 6907(a)(3) and 6944{a). as well
as Section 405(d) of the Clean Water
Act, as amended, 42 U.S C 345.
H. Background
  This regulation was published in the
Federal Register  in proposed form for
public review and comment on February
6,1978. The Agency held five public
hearings and eleven public meetings to
discuss the proposed regulation and
 received a substantial number of written
 comments on the proposal. Having
 considered the views of the public, the
 Agency is now promulgating this
 regulation in final form. This preamble
 discusses some of the more significant
 issues raised during the public comment
 period and revisions made  on the basis
 of those comments,
  The objectives of the Act are to
 promote the protection of health and the
 environment and to conserve valuable
 material and energy resources. In order
 to accomplish this, the Act  sets forth a
 national program to improve solid waste
 management, including control of
 hazardous wastes, resource
 conservation, resource recovery, and
 establishment of environmentally sound
 solid waste disposal practices. This is to
 be carried out through a cooperative
 effort among Federal. State, and
 substate governments and private
 enterprise
  Subtitle D of the Act fosters this
 cooperative effort by providing for  the
 development of State and regional  solid
 waste mdnagement plans that involve
 all three levels of government. As the
 Federal partner in this process, EPA
 seeks, through regulations and financial
 assistance, to aid State initiatives in the
 formulation and implementation of such
 plans.
  Section 4002(b) of the Act requires the
 Administrator to promulgate Guidelines
 for the Development and
 Implementation of State Solid Waste
 Management Plans  On July'31, 1£[79,
 EPA issued those guidelines (44 FR
 45066) While those guidelines are to
 consider a broad range of topics, Section
 4003 of the Act identifies the minimum
 requirements which State plans must
 address. EPA provides financial
 assistance to help the States develop
 and implement their plans.  Under -
 Section 4007, EPA reviews and approves
 State plans which satisfy the minimum
 requirements of Section 4003.
  The State solid waste management
 plan is the centerpiece of the Subtitle D
 program. Through the plan  the State
 identifies a general strategy for
 protecting public health and the
 environment from adverse effects
 associated with solid waste disposal, for
 encouraging resource recovery and
 resource conservation, for providing
 adequate disposal capacity in the State,
 and for dealing with other issues
relevant to solid  waste management
The plan must also set forth the
 institutional arrangements that the State
will use to implement this strategy.  (A
more  detailed description of the
planning program is contained in the
Preamble accompanying the Section
4002(b) guidelines )
A Section 4004. Disposal Facility
Criteria
   Under section 4004(a) of the Act the
Administrator is to promulgate
"regulations containing criteria for
determining which facilities shall be
classified as sanitary landfills and
which shall be classified as open dumps
* * *" The criteria establish the leve of
protection necessary to provide that "no
reasonable probability of adverse
effects on health or the environment"
will result from operation of the facility
In setting these criteria EPA is providing
a general definition of  "sanitary landfill"
and "open dump". As part of their
planning programs, the States will
evaluate existing disposal facilities to
determine whether they comply with the
Section 4004 criteria. Those facilities
which do not satisfy the criteria are
"open dumps" under the Act  EPA vail,
under authority of Section 4005(b),
publish a list of open dumps in the
Federal Register
   The inventory of "open dumps" v\ ill
serve two major functions First, it will
inform the Congress and the public
about the extent of the problem
presented by disposal  facilities whi^h
do not adequately protect public health
and the environment. Second, it will
provide an agenda for  action by
identifying a set of problem facilities,
routinely used for disposal, which
should be addressed by State solid
waste management plans in accordance
with Section 4003 of the Act.
   Essentially, the inventory is a
planning tool which supports the Stdte
planning effort  The States must know
where the problem facilities are in order
to satisfy Section 4003(3) which requires
that the plan "provide  for the closing or
upgrading of all existing open dumps
within the States * * *."
B. Section 1008(a)(3). Open Dumping
Criteria
  Under Section 1008(a)(3) of the Act
the Administrator is to  publish
suggested guidelines that provide
minimum criteria "to define those solid
waste management practices which
constitute the open dumping of solid
waste or hazardous waste " Thus, these
criteria are to establish a broad
definition of the act of open dumping,
which is prohibited under Section
4005(c) of the Act.
  The prohibition may  be enforced in
Federal distuct court through the citizen
suit provision in Section 7002 The Act
does not give EPA authority to take legal
action against parties that may violate
the open dumping prohibition. The
application of the open dumping criteria
to the specific acts of specific

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          Federal Register / Vol. 44. No. 179 / Thursday. Ser. timber- 13.  1979 /  Rules and Regulations   53439
 individuals is a matter for (he Federal
 courts to determine in the context of
 particular cases Judicial review of
 specific  ,icts in the context of open
 dumping suits should not be confused
 v\ith State planning activities
 particularly the evaluation of disposal
 facilities for the inventory of open
 dumps The inclusion ;jt a facility in the
 list of open dumps is not an
 administrative deterr"nation by EPA
 that anv particular parhps are engaging
 in prohibited acts of open dumping  (The
 Preamble accompanying the  Guidelines
 for Development and Implementation of
 State Solid Waste Management Plans
 (44 FR 45066) provides a more detailed
 explanahon of this issue ]

 C Section 4Q5(d) Sludge Disposal
 Guidelines
   Under Section 405(d) of the Clean
 Water Act EPA issues guidelines for the
 disposal and utilization of sludge Under
 Section 405(e) of the CWA owners and
 operators of publicly owned  treatment
 works (POTW's) must dispose of
 sludges from such works in accordance
 with those guidelines Criteria designed
 to avoid a reasonable probability of
 adverse effects on health or the
 environment from disposal of sludge on
 tend are clearly within the scope of this
 provision of the CWA
 D Copromulgation of the Criteria
  The criteria which EPA promulgates
 today  are designed to fulfill or partially
 fulfill the requirements of each of the
 provisions discussed above While all
 three provisions embody different
 implementation schemes, they all are
 concerned with the adverse effects on
 health or the environment that may be
 caused by solid waste disposal
 activities Since there is an inherent
 compatibility of purpose among the
 three provisions, EPA has decided to
 structure the criteria so they may be
 used m all three contexts EPA believes
 that co-promulgation of regulations,
 where possible, improves the quality of
 its regulatory efforts by eliminating the
 potential for inconsistencies among
 similar regulations and by providing a
 clear statement to the regulated
 community of the standards to which
 they will be held
  As an  example of the compatibility
 between provisions, the facility
 classification criteria for purposes of the
 State planning program can, and
 probably should, be concerned with the
 same set of environmental effects as the
 criteria defining the prohibited act of
 open dumping. Regardless of whether
one is evaluating facilities to aid in the
establishment of setting state planning
priorities or examining the acts of
 specific individuals to determine Ipgal
 liability for open dumping the same set
 of environmental effects should be of
 concern  At the same tirp°. having -i
 single set of criteria for  defining
 unacceptable environmental eftects
 does not undermine the use of th..t
 dcfin^KMi for different purposes
   It should be pointed out that these
 criteria are not nere^sanlv the or.!\
 guidelines to be promulgated under
 Section 405(d) of the CWA These
 criteria apply where the owners «nd
 operators of POTW engage in the
 placement of sludge on  the land  Future
 EPA guidelines on sludge disposal and
 utilization may address incineration.
 energy recovery and give-awav or sdle
 of processed sludge
 III General Approach
   This regulation sets forth eight criteria
 that address broad classes of health and
 environmental effects that may be
 caused by solid waste disposal
 activities The criteria are structured to
 define unacceptable impacts, those that
 present a 'reasonable probability of
 adverse effects on health or the
 environment " In terms  of the three
 statutory' provisions authorizing this
 regulation, the criteria define an open
 dump (RCRA Section 4004), the
 minimum elements of prohibited open
 dumping practices [RCRA Section
 1008(a)(3)) and the effects which must
 be avoided by POTW owners and
 operators (CWA Section 405]
   EPA recognizes that these criteria will
 be* aftphed to a variety of situations and
 that there is a need for flexibility m the
 standards to allow them to be applied to
 particular circumstances During the
 comment period some reviewers
 expressed preference for greater
 specificity m the criteria, including more
 detailed design and operating
 requirements Others favored greater
 flexibility and opportunity for
 consideration of local, site-specific
 conditions
   In developing the final criteria the
 Agency attempted to be as specific as
 possible without reducing  the
 opportunity for State and local solid
 waste management and enforcement
 agencies to take into account the site-
 by-site variations and make
 assessments based on local conditions.
 Wherever possible EPA tried to set
 specific performance standards that
 define unacceptable environmental
 effects. Such an approach should
 provide a concise and measurable
means of determining compliance with
the criteria However, in some situations
it was not possible to devise a
meaningful performance standard for
the environmental effect of concern.
given the lark of experience with such
an approac h to regulation of so d
watiU'
   Where specific performance
standards wcre not possible EPA
spedfied an operational tec hmqiie to
arhicv e  the des'red level of protection
When that ,,pproarh v\ds  nt n--sarj the
( riten i maintain regulator flpMl^itv,
h\ ai!ov\|ng for the use of alternate e
k t r.n.qafs that achieve (he same
general performance level Parties
clc'irriinjj thdt alternative approaches
prov ide  protection equivalent to that of
methods drprnbed m the  critena ha\p
the burden of establishing that fact
   In addition FPA wishes to emphdsiye
that the  standards established m One
criteria constitute minimum
requireTie.i's These criteria do not pre-
empt other State and Federal
requirements Nothing in the Act  or the
CWA precludes the imposition of
additional obligations under authority  of
other laws on parties engaged m solid
wa^le disposal.
   Various commenters criticized EPA's
general approach as being either too
restrictive or too lenient  Some argued
that implementation of the criteria
would substantially reduce needed
disposal capacity  The Agency
recognizes that one of the most critical
problems in the solid waste
management field today is the lack of
acceptable disposal facilities due, in
part, to public opposition  to their siting
However, this particular rulemakmg
cannot deal directly with  this problem
   The Agency is committed to
evaluating other means by which it can
help with the problem, Adequate
disposal capacity is essential
nationwide Hopefully, implementation
of the criteria will increase the
credibility of disposal operations.
thereby aiding m reducing public
opposition to acceptable and needed
facilities
   Some commenters felt that the critena
should be written very stringently in
order to  provide an incentive for
initiation of resource recovery and
conservation practices. Other
commenters observed that, even with
increased levels of resource recovery
and conservation, disposal facilities
would continue to be required into the
foreseeable future, even resource
recovery facilities produce a residue
which  requires disposal The Agency
believes  that resource recovery and
conservation are desirable solid waste
management approaches which should
be actively pursued However, the
purpose of the criteria is to define
disposal  activities which pose no
reasonable probability of adverse
effects on health or the environment.

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 53440   Federal Register / Vol. 44, No.  179 / Thursday,  September 13,  1979 / Rules and Regulations
 and the criteria have been developed
 with that goal m mind. While the
 implementation of these criteria may
 make resource conservation and
 recovery more economically
 competitive, these regulations have not
 been formulated simply to advance that
 cause Such an approach is not
 authorized by the Act.
   EPA also received comments
 attacking the Agency's use of standards,
 definitions and approaches developed
 under other Federal environmental and
 public health programs. They claimed
 that incorporating these items into the
 criteria extends those other programs
 beyond their statutory authority While
 the use of particular Federal standards
 will be discussed later in this Preamble
 in the context of each criterion, a
 general point should be made about the
 use of approaches developed or
 employed in other programs. The Act
 requires that the criteria address
 adverse health and environmental
 effects of solid waste disposal, whatever
 those might be. The use of other Federal
 Standards in responding to this broad
 mandate is, in fact, quite desirable in
 order to minimize duphcative,
 o\erlappmg and conflicting policies and
 programs. Unless it can be shown that
 other Federal standards and approaches
 are clearly inconsistent with the Act's
 objectives, it is within the Agency's
 discretion to use them, where
 applicable, in writing RCRA regulations

 IV. The Criteria

 A Scope

   These criteria apply to the full range
 of facilities and practices for "disposal"
 of "solid waste", as those terms are
 defined in Section 1004 of the Act
 Various commenters suggested the
 exclusion or inclusion of specific types
 of solid waste disposal activities. EPA
 examined these suggestions in light of
 the Act's definitions, Section 1006 of the
 Act (which directs the Agency to avoid
 duplicative regulatory programs), the
 Act's legislative history and the
 objectives of Subtitle D. EPA has
 concluded that the criteria apply to all
 solid waste disposal with the following
 exceptions:
   1 The criteria do not apply to
 agricultural wastes, including manures
 and crop residues, returned to the soil as
 fertilizers or soil conditioners  All other
 disposal of agricultural wastes,
 including placement in a landfill or
 surface impoundment, is subject to  these
criteria. This exclusion is based on the
House Report (H.R. Rep  No. 94-1491,
94th Cong , 2nd Sess. 2(1976)) which
explicitly indicates that agricultural
 wastes returned to the soil are not to be
 subject to the Act
   2. The criteria do not, at this time,
 apply to overburden from mining
 operations intended for return to the
 mine site. The House Report indicates
 that this type of overburden is not to be
 the immediate focjs of the Act's
 programs.
   3  The criteria do not apply to
 domestic sewage or treated domestic
 sewage However the criteria do apply
 to disposal of sludge resulting from the
 treatment of domestic sewage. In
 defining "solid waste" the Act
 specifically excludes solid or dissolved
 material m domestic sewage. Treated
 domestic sewage from which pollutants
 have been removed in a wastewater
 treatment plant is still considered to be
 domestic sewage for purposes of the
 Act Including such wastewater
 effluents within the Act's scope is
 particularly unnecessary because
 existing EPA programs concerning
 treatment of domestic sewage are
 seeking to assure that these effluents are
 disposed of in an environmentally sound
 manner
   However, during the treatment of
 domestic sewage,  solid and dissolved
 materials are removed from the sewage
 and collected as sludges Typically,
 these sludges are disposed of separately
 from the treated sewage which passes
 through the treatment plant. The
 language of Sections 1004(27) and
 1004(26A) indicate that sludge generated
 by a wastewater treatment plant, waje/-
 supply treatment plant or air pollution
 control facility is solid waste for
 purposes of the Act.  EPA believes that
 while the Congress intended to exempt
 treated sewage effluents from the Adt's
 provisions, it intended to include
 sludges created by the operation off
 treatment facilities. This approaches
 consistent with Congressional intent,
 expressed in Section 1002(b)(3) and the
 legislative history, that the Act
 specifically address the new solid waste
 management problem that resulted from
 effective implementation of programs
 designed to protect the air, water and
 other environmental resources.
  With this interpretation a question is
 raised about  the operation of septic
 tanks, a particular type of sewage
 treatment device. The materials which
 pass through the tank and are released
 into drainage fields are analogous to the
 treated sewage effluent passing through
 a treatment plant, and thus are not
considered solid waste. The materials
which settle to the bottom of the septic
tank and are  subsequently removed for
disposal at some other facility are
analogous to  the sludge created by the
operation of other sewage treatment
 processes Therefore, septic tank
 pumpmgs fall within the Act's definition
 of solid waste
  4  The criteria do not apply to solid or
 dissolved materials in irrigation return
 flows This exemption is clearly stated
 in Section 1004(27) of the Act
  5  The criteria do nof apply lo source.
 special nuclear, or byproduct material
 a
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          Federal Register  / Vol. 44, No.  179 / Thursday,  September  13,  1979 / Rules and Regulations   53441
 as wastewater treatment lagoons.
 potable water treatment lagoons,
 surface impoundments (pits, ponds,
 lagoons, basins), mining waste disposal
 facilities, utility  waste disposal facilities
 and agricultural waste disposal
 facilities The Act does not define the
 term "facility". EPA believes that the
 term should be interpreted broadly
 unless such an interpretation clearly
 conflicts with other provisions or
 objectives of the Act.
   After examining these requests for
 exemptions in light of the Act and its
 legislative history, EPA concluded that
 there was no statutory basis for
 excluding these  types of facilities All
 such facilities could present a
 reasonable probability of adverse
 effects on health or the environment
 EPA does not have any basis for
 determining that such facilities are not
 "solid waste disposal facilities" for
 purposes of the Act.
   Several commenters asked whether
 the definition of "facility" would
 encompass "backyard" disposal
 practices such as home compost piles or
 burning of household wastes EPA does
 not believe that  Congress intended the
 Subtitle D classification scheme to be
 implemented at the household level.
 Section 1004(27)  refers to wastes from
 "community activities" In addition, the
 legislative history indicates at several
 points that "municipal" wastes are of
 concern under Subtitle D  The Act's
 emphasis on "community" or
 "municipal" waste, indicates that the
 Congress intended to focus on solid
 waste managment at that level rather
 than at the household level. EPA
 believes that "backyard" practices
 should be controlled through State or
 local nuisance and public health laws
   Some commenters suggested that
 disposal facilities used by small
 communities {especially small facilities
 in rural areas) be excluded from
 coverage due to the anticipated higher
 unit cost (cost per capita or cost per ton
 of waste) uf compliance for such
 facilities  The Agency found no basis for
 such an exclusion, In fdct, such an
 exclusion could foster the development
 of additional small facilities in order to
 escape the cost of compliance and,
 cumulatively, could result in greater
 environmental damage in rural areas
 Thus, the  criteria  apply to laige and
 small facilities, whether urban or raial,
 because it is essential that all facilities
 prevent adverse impacts on health and
 the environment in accordance wilh the
 criteria
  Less sophisticated and less costly
design  and operational techniques,
however, may be  applicable at smaller
facilities due to the smaller quantities of
 waste disposed and reduced magnitude
 of potential adverse effects, In addition,
 small or rural communities may take
 various approaches to reduce the per
 capita cost burden and achieve
 economy of scale through regionalized
 collection and disposal systems, sharing
 of equipment among facilities, or
 operation of facilities only dui ing
 limited hours.
   During the  public comment period it
 was suggested that there be less
 stringent criteria for existing facilities
 than for new  facilities. In considering
 this suggestion the Agency has found no
 difference in  the potential adverse
 effects from existing as opposed lo new,
 facilities. With regard to implementation
 of the criteria, however, the Act does
 recognize the need to continue the
 controlled use of existing facilities while
 alternatives which comply with the
 criteria are being developed. In taking
 steps to close or upgrade existing open
 dumps, a State may issue compliance
 schedules that allow use of a disposal
 facility while it is being upgraded or
 while alternative disposal options are
 being developed.
   A few commenters also raised the
 question of whether a junk yard, which
 may buy or sell waste items, is a solid
 waste disposal facility. While a junk
 yard is clearly a "solid waste
 management" facility under the Act
 there is some question whether the
 operation of a junk yard constitutes the
 disposal of solid waste
   Under Section 1004(3) "disposal'
 involves the placement of solid wasie
 into or on any land or water so that a
 constituent of the waste may enter the
 environment.  This entry of waste
 materials into the environment is an
 essential component of the Act's
 definition As the Senate Report states.
 "Disposal is letting wastes out of
 control" (Sen. Rept, No 94-9R8. 94th
 Cong, 2dSess 26(1976))
   If a junk yard is operated in such a
 v ay that no waste material enters the
 environment then it is possible that  it is
 not a solid waste disposal facility If
 constituents of the waste, however, are
 entering  the environment (e g battery
 acids from automobiles leaching into the
 ground),  then the junk yard would be a
 disposal facility It is up to the State to
 determine whether particular junk yard
 operations constitute disposal  of solid
 waste

 C  Reorganization of the Criteria
  After reviewing the comments EPA
 has decided to change the format of two
portions of the criteria as they appeared
in  the proposed regulation The criteria
concerning environmentally  sensitive
 areas and disease have been
 reorganized.
   The proposed regulation had one
 section that addressed the location of
 disposal facilities in wetlands.
 floodplams, permafrost areas, critical
 habitats  of endangered species, and
 recharge zones of sole  source aquifers,
 all of which were categorized as
 "environmentally sensitive areas"  In
 the Preamble to the proposed regulation
 the Agency also requested comment on
 other areas, specifically karst terrain
 and active fault zones,  for similar
 Consideration
   Environmentally sensitive areas arp
 no longer addressed in a separate
 section. Criteria regarding floodplams
 and critical habitats of endangered
 species appear in independent sections
 discussed later Wetlands are addressed
 in the section on surface water, since
 wetlands are treated in the same
 manner as surface waters under the
 Clean Water Act  Concerns for redidrge
 zones of sole source aquifers are
 directly related to those for ground-
 water protection, thus,  protection of sole
 source aquifers has been incorporated
 into the ground-water section of the
 criteria.
   Permafrost aieas, are no longer
 addressed in the criteria While EPA is
 concerned with (he effects of solid
 waste disposal in permafrost areas
 there are several reasons why U is nut
 appropriate to establish a national
 criterion concerning permafrost.
 Permafrost areas only occur m Alaska in
 the  United States. The State of Alaska
 has authority to regulate solid waste
 disposal  and to protect  permafrost  EPA
 believes that the State's program is
 adequate to protect these areas  Under
 Section 6001 of the Act  Federal facilities
 must comply with applicable State, solid
 waste disposal requirements Thus.
 there should be full compliance with
 those State disposal requirements
 affecting permafrost areas  Moreover,
 the criteria addressing floodplams,
 surface water and ground water will
 cover many of (he environmental effects
 uf concern in such areas Under these
 circumstances it does not seem
 necessary to establish separate
 permafrost criteria at this time
   In response to the Agency's reque&l,
 some rommenters described risks
 inherent in disposal of solid  waste in
 karst terrain and active  fault  zones  1'he
 concerns raised pertained primarily (o
 graur-d water  TVe Agenry believes that
 these concerns are adequately
 addressed by the groumj-water criteiia
 and h,  s not provided a separa'e criteria
 for karst terrain or active fault zones
  In  the proposed regulation the
criterion for disease jiut addressed the

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53442   Federal  Register / Vol. 44, No.  179 / Thursday,  September  13, 1979 / Rules and Regulations
problem presented by disease-carrying
vectors. In Jhe section addressing food-
chain crops, the proposed criteria
provided for controls to reduce the
likelihood for transmission of pathogens
from the solid waste to humans. Since
both provisions concerned the
prevention of disease, they have been
combined in § 257,3-6
D Floodplains (Section 257 ^-1)
  Disposal of solid waste in floodplains
may have several significant adverse
impacts- (1) If not adequately protected,
wastes may be earned by flood waters
and flow from the site, affecting
downstream water quality and
structures,  (2) filling in the floodplain
may restrict the flow of flood waters,
causing greater flooding upstream; and
(3) filling m the floodplain may reduce
the size and effectiveness of the flood-
flow retaining capacity of the floodplain,
which may cause a more rapid
movement  of flood waters downstream,
resulting in higher flood levels and
greater flood damages downstream  For
these reasons it is generally desirable to
locate disposal  facilities outside of
floodplains.
  The proposed criteria  required that a
facility not restrict the flow of the base
flood nor reduce the temporary water-
storage capacity of the floodplain, in
order to prevent increased flooding
upstream or downstream resulting from
the base flood. In addition, the proposal
required that the facility be protected
against inundation by the base flood,
unless the facility is for land application
of solid waste for beneficial utilization
as agricultural soil conditioners or
fertilizers.
  In developing this criterion EPA
sought to comply with Executive Order
11988, "Floodplain Management" (42 FR
28951), which requires Federal agencies,
in carrying out their responsibilities, to
take actions to reduce the risk of flood
loss, to minimize the impact of floods on
human safety, health and welfare, and
to restore and preserve the natural and
beneficial values served by floodplains.
In accordance with Executive Order
11988, EPA consulted with the Water
Resources Council and the Federal
Insurance Administration of  the
Department of Housing and Urban
Development. Both of these agencies
deal with floodplain management issues.
  A few commenters questioned
whether flpodplain concerns were
within the statutory scope of these
regulations. Clearly, improper disposal
of solid waste in a floodplain can have
adverse effects on health and the
environment EPA is not aware of any
other Federal program that addresses
the particular environmental  threat
presented by solid waste disposal
activities in floodplains. Therefore, there
is no question that these concerns are
within the purview of this regulation.
  After evaluating the proposed
floodplains criterion in light of the
comments, EPA re-evaluated the
rationale for the proposed regulation.
There was an apparent contradiction in
the criterion between the requirement to
prevent any increased flooding and the
provision to protect against inundation.
As several commenters pointed out,
compliance with one was likely to lead
to violation of the other. In addition EPA
concluded that it was not necessary to
eliminate any and all marginal
increases, however small, in flood levels
caused by disposal operations.
Moreover, not all inundation of disposal
facilities leads to adverse environmental
effects. Depending on the waste material
there may be no adverse downstream
effects; where such effects could  occur,
proper control measures to prevent
washout of the waste materials (e g.
diking) would be sufficient to avoid the
problem.
  Therefore, EPA made the following
changes in the floodplain criterion:
  1. The disposal facility or practice
should seek to avoid washout of  solid
waste, rather than necessarily prevent
inundation of the waste. This change
allows for the development of
management practices or facility designs
that can avoid washout of the solid
waste without preventing all inundation
by flood waters. (Several commenters
indicated that such approaches were
feasible )
  2. All of the requirements are linked to
an assessment of the hazard to human
life, wildlife, land or water. This is
designed to avoid a situation  where any
increase in flood levels attributable to
disposal  activities or washout of waste
is automatically precluded.  EPA does
not believe that the incremental effect of
solid waste operations on floodplain
management justifies such a drastic
approach. In, some cases, however,
disposal activities may present a
significant marginal increase in the risk
of flood damage. It is appropriate to
avoid such a nsk. EPA cannot specify
for all situations what that unacceptable
risk will be This issue must be resolved
on a case-by-case basis in the
implementation of these criteria
  3. The exception for land application
of solid waste for beneficial utilization
as an agricultural soil conditioner or
fertilizer has been eliminated  EPA
believes that special exceptions for
classes of activities are no longer
necessary. In more clearly specifying the
performance objective for disposal in
floodplains, the criteria provide the
flexibility to allow continuation of those
activities that do not present health and
environmental hazards.
  Some commenters questioned the use
of the 100-year base flood in defining the
floodplain of concern. EPA believes that
this is an appropriate definition. The1
100-year floodplain does not represent a
flood that will occur only once in 101)
years. It is the flood which has a one
percent or greater chance of occurring in
any one year. Such a flood may occur
several times or never occur within a
given 100-year period. In selecting the
100-year flood to define the floodplain of
concern EPA is maintaining consistency
with the approach in other Federal
programs and in Executive Order 11988.
  Some commenters misinterpreted the
criteria as a prohibition against locating
facilities in floodplains. While areas
other than floodplains are often
preferable locations for disposal
facilities, the proposed criteria did not
provide such a prohibition. Certainly,
that point is even clearer in the
floodplain criterion issued today.

E. Endangered and Threatened Species
(Section 257.3-2)
  Solid waste disposal activities can
adversely affect endangered and
threatened wildlife by releasing toxic
materials into the environment and by
disrupting the ecosystems on which they
rdy for food and shelter Therefore, it is
appropriate for these criteria to contain
provisions designed to mitigate adverse
effects of«olid waste disposal activities
on endangered and  threatened species
of plants, fish or wildlife
  The proposed criterion was designed
to ensure that disposal activities did not
occur in the critical habitats of
endangered species unless it was
determined that the activities would not
jeopardize the continued existence of
endangered species The proposal also
required the approval of disposal plans
by the Office of Endangered Species
(OES) in the Department of Interior
(DOI).
  Under Section 7 of the Endangered
Species Act [ESA), as amended. 16
U.S.C. 1536, all Federal agencies, in
consultation with the Secretary of the
Interior or the Secretary of Commerce,
are to utilize their authorities in
furtherance of the purposes of the ESA.
EPA held forma! consultations with the
DOI and received a "biological opinion"
recommending changes in the criteria.
EPA considered this recommendation
from DOI and all public comments in
setting this criterion.
  EPA has concluded that the criteria
should assure that no solid waste
disposal facilities or practices criuse or
contnbute to the taking of endangered

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          Federal  Register / Vol  44, No, 179  /  Thursday, September 13. 1979  /  Rules  and  Regulations    53443
 or threatened species Taking means
 harassing, harming, pursuing, hunting,
 wounding, killing, trapping, capturing or
 collecting, or attempting to engage in
 such conduct In addition such
 activities should not destroy or
 adversely modify the ciitmal habitats cf
 these species EPA believes that this
 cuterion is cleaily within the scope of
 the Act and  that it satisfies Agency
 responsibility under the ESA
   Some commenters questioned EPA's
 authority to  addiess effects on
 endangered  species in the criteria The
 Act gives EPA authority to set cn!ena
 concerning the full range of health and
 envuonmental effects resulting from
 solid waste disposal  The taking of
 endangered  or threatened species by
 solid was'e disposal activities is
 certainly an  environmental efiWt of
 concern I.i addition the ESA plac.es a
 responsibility on the Agency to use its
 authority under (he Act to mitigate such
 effects
   The ma)or change m  this criterion
 from what was contained in  the
 proposed regulation is the shift in
 concei n to the taking of endangered and
 threatened species The proposed
 regulation focused on avoiding
 modifications of critical habitats that
 jeopardized  the continued e\jstence of a
 species After examining that approach
 in light of the comments, EPA decided
 that the "jeopardize" language was
 inappropriate for a definition that would
 be applied to a vast number of site-
 specific conditions. In deciding whether
 an act or facility would jeopardize the
 continued existence of a species, the
 officials implementing the criteria would
 have to examine the marginal effect that
 harm to particular members of a species
 would have on the national population
 of that species Particularly in the case
 of the open dump inventory, which
 involves the  evdluation of thousands of
 solid waste disposal facilities, it would
 be extremely difficult to implement a
 "jeopardize"  standard,
   A determination of whether disposal
 activities  are "taking" endangered
 species is more readily applicable to the
 site-specific situations for which these
 regulations will be used Officials
 charged with implementing the criteria,
 as wet! as parties engaged in solid
 waste disposal, can quickly determine
 what is necessary to achieve
 compliance Such an approach is
 consistent with EPA's general intent to
 establish concise, measurdble
 performance  siandards wheic-ver
possible
  The use of  the "taking" concept does
not reflect an EPA belief that  the ESA
requires such an approach. EPA's
obligation under Section 7 of the ESA. if
 a'iv, is to assure that ihe criteria, which
 piovde a national definition of the
 unacceptable environmental effects of
 solid waste disposal, do not jeopardize
 endangered specks Where those
 criteria i;e applied Ly Stale agencies,
 such implementation activities a;e not
 subject 'o Sp( tion 7 because no Fed^rdl
 action '3 inxoK rd
   Sorne commenters suggested that in
 complying with Section 7 EPA could not
 set cn'ena appbcable  to non-Federal
 parties that are more restrictive (han
 what Section 9 of the ESA now requucs
 of such parties (Sec tion 9 prohibits ihe
 taking of endangered species ) EPA
 rejects that argument  'Ihe Act and
 Section 7 of the ESA give EPA authonty
 to set criteria different than the
 requirements otheiwise applicable
 under Section 9
   EPA believes, that the best way to
 ensure that national populations of
 endangered and threatened species are
 not jeopardized is to avoid the
 destruction of members of ihat
 population in site-specific situations
 While the standard could have been
 written several ways to accomplish that
 objective, EPA believes thdt preventing
 the "taking" of endangered and
 threatened species has several
 advantages This approach will aid
 coordination between  solid waste and
 endangered species programs where
 feasible  It also gives the regulated
 community a uniform standard defining
 its responsibility in both contexts The
 "taking  definition  is broadly stated and
 thus would encompass the variety of
 adverse effects on endangered and
 threatened species  that could be caused
 by solid waste disposal In its
 "biological opinion" DOI endorsed this
 approach
   In the proposed regulation EPA only
 addressed endangered species  Several
 commenters suggested that ' threatened"
 species identified by DOI also be
 included for consideration EPA believes
 that sur.h threatened species of wildlife
 are also deserving of protection and,
 therefore, has included them m the
 criteria Thus, the endangered ,ind
 threatened species  of concern are those
 IjSted under authority of Section 4 of ihe
 ESA
   In endorsing the "taking" language,
 DOI s "biological opinion" included
 exceptions for activities covered by
 permits under Section 10 of the ESA or
 alluded by Section  6(gj(2) of the ESA
 Sec lion 10 authorizes the issuance of
 permits for the taking of specie-, "for
 S( u'nUiic purposes or to enhance the
 propagation or survival of the affected
 species " The operative portion of
Section 6[fi](2) makes the Section 9
prohibition of taking inapplicable in
 slates thiii have nt^otia'rd uvjpr ratiie
 agreements with DOI Under
 c ooperdlive agieement, designated Stats
 (plfiv ia!s may take enda^g^ird sptx.es
 for conservation pur^c&es  S'ncc1 ne tbcr
 cf these s.tudtiGPo seemed applicable to
 solid vva^tp disposal aC-iViuCj they have
 i,ot bten included m the catena
   EPA has decided to retain thM part nf
 tlie proposed regulation thtii reflected a
 concern for the wildlife ha'oita's Where
 ' critical' habitats of ihreatened or
 endangeied species have been identified
 bv DOI it is unacceptable under the Act
 f r solid was'e disposal activities  to
 destroy or adversely modify such
 habitats In seeing this criterion EPA  it.
 not precluding all disposal in a cniit .1!
 habitat area Only when such disposal
 appreciably diminishes the likelihood of
 the survival and recovery of threatened
 ur endangeied species using the habitat
 does a vio'atioi occur The "b'ological
 opinion" fiom DOI endorses this
 approach
   EPA has decided to drop that portion
 of the proposed cnteiia which required
 approval of disposal plans by the Office
 of Endangered Species. Department of
 Interior  EPA agrees wnh the several
 c ommenters including OES, who sai J
 that si'L.h a requirement was
 inappropriate The Act and the CWA
 r reate the  implementing mei nanisms  for
 tnese criteria  While the OES may, and
 probably should, be consulted on ihe
 opphcation of § 257 3-2 to particular
 situations, the officials responsible for
 dpplyirg the criteria, lather than the
 OES, must d( iPitnne whether a
 violation has occurred

 /•' Su-focf Waters (Section 2573-3)
   It is essential  that solid Waste
 activities not adversely affect the
 quality of the nation s surface waters,
 Rivers, lakes and^streams .are important
 aj> sources of drinking water, as
 recreational resources and as habitats
 for a wide  variety of fish and other
 aquatic organisms The nation's coastal
 and inland wetlands provide natural
 flood dnd storm  control, sediment and
 erosion control,  recharge of acquifers.
 natural purification of waters, and flow
 stabilisation of streams  and rivers
 Wetlands produce nutrients which
 support complex ecosystems extending
 into estuaries and streams well beyond
 the marshes and wetland areas
 Wetland habitats support fish, shellfish.
 mammals, wateifowl and other wildlife
 ftiuna dnd flora
  Solid waste disposal has  led to
 surface-water contamination from runoff
of leachate. accidental spills, and drift of
spray occurring at dumps, landfills,
surface impoundments, farmlands,  and
landspreading operations. In the

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53444   Federal Register / Vol. 44, No. 179 / Thursday,  September  13. 1979 / Rules and Regulations
proposed criteria EPA sought to
coordinate its surface water standards
under the Act with programs developed
under the Clean Water Act (CWA) to
restore and maintain the integrity of the
waters of the United States (including
wetlands )
   The proposed criteria required that
pnmt source discharges of pollutants
*  -inply with a National Pollutant
Discharge Elimination System (NPDES)
permit issued for the facility according
to Section 402 of the Clean Water Act  A
separate section addressed wetlands, a
particular category of waters of the
United States This section, which has
now been combined with the other
surface water provisions, required that
facilities not be  located in wetlands
unless permits were obtained under
provisions  of Section 402 and/or 404 of
'he Clean Water Act The proposed
criteria also required non-point source
discharges of pollutants to be prevented
or minimized
   The final regulation maintains this
general approach and has eliminated
those parts of the proposed regulation
that might  have created conflicting
RCRA and CWA requirements
concerning the adverse effects of solid
wdsie disposal on  surface waters The
srparate section for wetlands was
eliminated because they are treated like
all other surface waters under the CWA
The provision affecting non-point source
discharges to surface water has been
linked more directly to applicable
requirements developed for State and
aredwide water quality management
planning programs under Section 208 of
t*ie CWA
   Under Section 1006 EPA is required to
integrate, to the maximum extent
prat ticable. the provisions of the Act
with the  Clean Water Act and other
statutes  Under the CWA, EPA conducts
programs designed "to restore and
maintain the chemical, physical and
biological integrity of the Nation's
water " EPA believes that this goal is
also a legitimate objective for its
regulatory activity under  the Act and
that, in the spirit of Section 1006, EPA
should use its authority under the Act to
see that the goals of the CWA are
achieved, Thus,  in  defining unacceptable
solid waste disposal activities, EPA can
and should determine that facilities and
practices violating the Clean Water Act
cannot be acceptable for purposes of
RCRA
  Thus, in establishing the surface
water criterion EPA used concepts and
approaches used under the CWA  The
surface waters of concern are the waters
of the United States, which include
"wetlands" meeting the Agency's and
the Corps of Engineers' definition of that
term. All point source discharges of
pollutants must comply with
requirements for NPDES permits
pursuant to Section 402 of the CWA
Discharge of dredge or fill material to
waters of the United  States must comply
with requirements for permits
established pursuant to Section 404 of
the CWA. (' Requirements" under the
402 and 404 permit programs include the
general requirement to apply for such
permits, as well as the substantive
provisions of issued permits ) Non-point
source pollution from solid waste
disposal activities must not be  in
violation of legal requirements
established to implement a water
quality management  plan under Section
208 of the CWA. Water quality
standards developed to satisfy Section
303 of the CWA may be implemented
through either NPDES permits, Section
404 dredge and fill permits,  or legal
requirements developed to implement a
Section 208 plan.
  Some commenters  suggested that in
using a CWA-based  approach in these
regulations EPA was attempting to
regulate discharges to waters of the
United States under the Act. This is
certainly not the intent or result of these
criteria. The implementation of CWA
programs will be left to those
responsible for those programs  In these
criteria EPA is merely indicating that
where  solid waste activities violate the
CWA,  as determined by officials
implementing that law, EPA cannot
determine that those activities  provide
adequate protection to public health and
the environment for purposes of RCRA
  Commenters also expressed  concern
over the definition of "wetlands",
arguing that man-made channels and
basins (particularly wastewater
treatment lagoons) that happen to
support vegetation should not be subject
to protection under this criterion. In
keeping with the goal of coordination,
EPA is accepting the approach taken
under the CWA, as expressed in  the
recently issued NPDES regulations (44
FR 32854) Thus, waste treatment
lagoons or other waste treatment
systems that happen to support
vegetation are not waters of the United
States  (As indicated in the NPDES
regulations, cooling lakes and ponds are
generally within the definition of waters
of the United States,  but certain kinds of
cooling ponds may be excluded }
  Several commenters questioned the
proposed inclusion of "surface  runoff
ds a point source discharge of
pollutants Under the existing NPDES
regulations the term "discharge of
pollutant" is defined  to include "* * *
surface runoff which  is collected or
channelled by man " EPA will maintain
that approach in these criteria. All other
surface runoff is subjec t to applicable
requirements developed under section
208 plans for non-point source pollution
  Se\pral public comments reflected
concern about what permits would be
necessary under the CWA for solid
waste disposal  in wetlands Diking or
other dredge or fill operations designed
to prepare an area within waters of the
United States for disposal of wastes
would  require a 404 permit as a matter
of course  A question arises, however.
concerning the actual deposit of the
waste material  into waters of the United
States  Such a discharge could be
treated as a discharge of pollutants
requiring a Section 402 NPDES permit or
as a discharge of dredged or fill material
requiring a 404 permit,
  Under previously issued regulation!)
implementing the CWA [42 FR 37122],
where  the "primary purpose" of the
discharge of waste material is  for
disposal, rather than for filling an area.
the discharge is subject to the NPDES
program.
  Some commenters suggested a need
for procedures establishing how NPDES
permits will be  applied to solid waste
disposal In response the Agency is
developing policy guidance for this
permitting process  As of this  writing, a
draft of this policy guidance, "NPDES
Permits for Solid Waste Disposal
Facilities in Waters of the United
States—Policy Guidance Memorandum,
August 23,1978," has been distributed
for external review A public meeting for
discussion of the draft policy guidance
memorandum was held on December 11,
1978 EPA is currently reviewing the
public  comments submitted on this
issue EPA is also considering  whether
solid waste disposal in wetlands is more
appropriately handled under the Section
404 permit program EPA intends to
explore this issue with the Corps of
Engineers
  EPA has dropped any reference to a
presumption against issuance of an
NPDES permit for discharge of solid
waste into wetlands That reference,
contained as a comment in the proposed
regulation, reflected EPA's general belief
that disposal activities should  not be
conducted in wetlands jf other
alternatives exist The NPDES  permit.
however, will define the legal
responsibilities of parties engaging in
disposal of solid waste near or in waters
of the United States If the requirements
of an applicable NPDES permit can be
satisfied, then there will be no added
"presumption" against the facility or
practice
  Commenters raised concerns over the
ability  of NPDES permitting agencies to

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          Federal Register / Vol  44, No. 179 / Thursday,  September  13, 1979  / Rules  and  Regulations   53445
 arocess applications and issue permits
  or point source discharges of pollutants
  rom solid waste disposal facilities. It
  vas noted that not many NPDES
  ermits have been issued to such
  ischarges,
   It has been Agency policy to prioritize
  ssuance of NPDES permits based on the
  potential adverse environmental impact
  •f the discharge  However, all
  iischarges require NPDES permits, and
  t is incumbent on the discharger to
 apply for the NPDES permit. Generally,
 no enforcement action is taken if
 application for an NPDES permit has
 been made, but the permit has not yet
 been issued. Upon issuance, the
 discharger must maintain compliance
 with the NPDES permit. Upon denial or
 revocation of a permit, the discharge
 must be discontinued.
   In using the 208 planning program,
 EPA has dropped the proposed
 requirement to "prevent or minimize"
 nonpomt source pollution from solid
 waste disposal activity Several
 "ommenters were concerned that such a
 requirement might duplicate or conflict
 with provisions developed to implement
 d State water quality management plan.
 EPA shares that concern and,  therefore,
 has made the changes described above
 However, EPA is also aware that not all
 208 plans will have addressed the non-
 point source pollution problems
 presented by solid waste disposal EPA
 intends to explore this problem further
 to determine whether uniform national
 guidance is needed and can be given on
 how to handle this type of pollution
 problem If a set of standards can be
 devised EPA will consider amending
 these criteria
   Not all portions of a 208 plan will
 necessarily be applicable to solid waste
 disposal activities, and it will be up to
 officials implementing the criteria to
 make the appropriate determination
 The criteria are linked only to those
 portions of the plan that have been
 translated into legal requirements (i e
 statute, regulation, ordinance,
 administrative orders ) This assures
 clarity on what is required, avoiding
 questions about how to comply with
 broadly-stated policy statements

 G Ground Water (Section 257 3-4)
  Ground water, generally a high
 quality, low cost, readily available
 source of water, is the drinking water
 source  for at least one half of the
 population of the United States, often it
 is the only economical and high quality
 water source available Ground water is
generally suitable for human
consumption with little or no treatment
necessary.
   Ground water has been contaminated
 by solid waste disposal on a local basis
 in many parts of the nation and on a
 regional basis in some heavily
 populated and industrialized areas,
 precluding its use as drinking water.
 Existing monitoring of ground-water
 contamination is largely inadequate,
 many known instances of contamination
 have been discovered only after ground-
 water users have been affected  The Act
 and its legislative history clearly reflect
 Congressional intent that protection of
 ground water is to be a prime concern of
 the criteria.
   The proposed criteria established
 requirements for ground-water
 protection based on the utilization of the
 ground water. Ground-water utilization
 was divided into two categories- Case I
 addressed ground water currently used
 or designated for use as drinking water
 supplies or ground water containing
 10,000 miligrams per liter (mg/1) total
 dissolved solids or less; and Case II
 addressed ground water designated for
 other uses
   For Case I, the proposed criteria
 required that the quality of ground water
 beyond the disposal facility be
 maintained for use as a drinking water
 supply. The proposed criteria were
 based on the "endangerment" approach
 adopted from previously proposed
 regulations for the Underground
 Injection Control Program (41 FR 36726).
 "Endangerment" was defined to mean
 introduction of a contaminant that
 would require additional treatment  of
 current or future drinking water supplies
 or would otherwise make the water unfit
 for human consumption. The proposed
 criteria required that the disposal
 facility not "endanger" Case I ground
 water beyond the property boundary
 (Comments were specifically requested
 on the use of other distances in lieu of or
 in addition to the property boundary )
 For Case II, States could, where
 consistent with their authority,
 designate ground water for uses other
 than drinking water and would establish
 the quality at which the ground water
 was to be maintained consistent  with
 the designated use
  In order to predict, as early as
 possible, the potential for ground-water
 endangerment, the proposed criteria
 required that ground water  be monitored
 so as to indicate the movement of
 contaminants from the disposal facility
 where endangerment was likely.
 Contingency plans were required for
 corrective actions to be taken m the
 event that an adverse jmpact was
 indicated by the monitoring
  For sole source aquifers, the proposed
criteria required that facilities not be
located in  the recharge zone unless
 alternatives were not feasible and
 unless "endangerment" was prevented
   Under the final ground-water criteria,
 the facility or practice must not
 contaminate an underground drinking
 water source beyond the solid waste
 boundary or an alternative boundary set
 by the State Contamination occurs
 when leachate from the disposal activity
 causes the  concentrations of certain
 pollutants in the ground water to either
 (1) exceed the maximum contaminant
 level (based on the primary drinking
 water standards) specified for that
 pollutant, or (2) increase at all where the
 background concentration of the
 pollutant already exceeds the applicable
 maximum contaminant level  An
 underground drinking water source is an
 aquifer currently supplying drinking
 water for human consumption or an
 aquifer in which the concentration of
 total dissolved solids is less than 10,000
 milligrams  per liter (mg/1) Generally,
 the existence of contamination is
 determined at the waste boundary
 However, States with approved solid
 waste management plans may establish
 an alternative boundary if, after
 thorough examination of the site-specific
 situation, a finding is made that an
 adjustment of the boundary would not
 result in contamination of ground water
 needed or used for human consumption
   (1) Approach to Ground-water
 Protection  A Few commenters suggested
 that the proposed regulation was
 beyond EPA's authority becaue it
 allegedly involved the establishment of
 ambient ground-water standards. This
 charge reflects a misunderstanding of
 the  approach taken in the proposed, as
 well as the  final, regulation EPA is not
 regulating ground water with these
 criteria, rather, EPA is setting standards
 applicable to disposal of solid  waste In
 defining the unacceptable effects of such
 disposal on ground water, EPA has
 concluded that solid waste activities
 should not degrade ground water
 beyond levels established to protect
 human health  The criteria are designed
 to achieve that objective
   EPA recognizes that ground-water
 quality is important for other purposes
 (e g  for irrigation of plants, for its effect
 on fragile ecosystems ) Differing
 standards may be appropriate  to protect
 its usefulness for these other purposes.
 At this time, however. EPA has decided
 to define "contamination" in terms of
 the water's use  as a drinking water
 source  EPA believes that the prevention
 of adverse human health effects from
 direct consumption of ground water,
should be the first among several
objectives in protecting ground-water
quality. Moreover, the Agency has

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53446   Federal Register / Vol 44, No. 179 / Thursday,  September 13. 1979 / Rules  and  Regulations
developed standards for drinking water
but has not established standards for
other uses
  These criteria reflect EPA's concern
for both present and future users of
ground water  A significant number of
people in  the country take their drinking
water directly from ground-water
resources EPA expeets that such direct
use will continue in the future  In
defining unacceptable solid waste
disposal activities, these criteria cannot
be based  only on current patterns of
ground-water use. Potential future users
of the aquifer must be considered.
  EPA believes that solid waste
activities  should not be allowed to cause
underground drinking water sources to
exceed established  drinking water
standards. Future users of the aquifer
will not be protected unless such an
approach is taken. Where maximum
contaminant levels  have already been
exceeded due  to other conditions or
actions affecting the aquifer, solid waste
activities  should not be allowed to
increase the risk of damage to present or
future users of the aquifer
  (2) Contaminants of Concern.
"iSommenters stated that the
"endangerment" standard in the
proposed  regulation was vague,
especially since it did not specify
contaminants that would make more
extensive treatment necessary or
otherwise make the water unfit for
human consumption Some felt this
approach would allow too much
contamination,'given the lack of
certainty regarding  toxicity of many
contaminants and ihe state-of-the-art of
monitoring and water treatment. Others
stated that it would require facility
operators to demonstrate protection
from a myriad of substances, that the
levels to which those substances should
be tolerated was not defined, that the
standard was based on unspecified
treatment and changing technology, and
that the capability of existing treatment
is a function of too many parameters  In
order to respond to  these comments the
Agency explored various lists of
contaminants upon  which to base the
critena
  Several reviewers supported the
proposed  criteria's use of the National
Interim Primary Drinking Water
Regulation (N1PDWR) in the definition
of "endangerment".  Some reviewers
pointed out, however, that the list  of
contaminants m the NIPDWR  (40 CFR
Part 141) was not created to serve as
ground-water quality standards, and
that it does not include ali potentially
harmful substances  which might be
associated with leachate from solid
waste
  EPA recognizes that the NIPDWR lists
only those parameters commonly found
m public drinking water supplies Other
substances which may be harmful to
human health were not included in Part
141 due to their relatively rare
occurrence in drinking water systems,
the unsuitabihty of analytical methods,
the high costs of monitoring, or the lack
of toxicity data For example, cyanide
was not listed in the NIPDWR because
of its low rate of occurrence Several
potentially dangerous substances which
were excluded from the NIPDWR are
present m leachate from waste disposal.
  There is no doubt, however, that the
contaminants identified in the NIPDWR
are appropriate for consideration in the
criteria. Generally, no commenters
opposed the inclusion of any listed
contaminant in this regulation. The one
exception 19 the manmade radionuchdes
identified m the NIPDWR. These
substances fall within the class of
radioactive substances excluded from
the Act's definition of solid waste and,
thus, the leaching of these materials into
ground water should not be addressed
by these criteria.
  EPA has evidence that all of the
contaminants identified in the NIPDWR
have been in wastes covered by these
criteria and that such materials are
likely to enter ground-water supplies.
Therefore, while it may be advisable to
expand the list of contaminants covered
by the criteria as new information is
developed by the Agency,  it is certainly
appropriate to use the contaminants
identified in the NIPDWR in the criteria
at this time
  The Agency has also explored the use
of the National Secondary Drinking
Water Regulations (NSDWR) in defining
maximum contaminant levels The
NSDWR (40 CFR Part 143) represent the
Agency's best judgment on the
standards necessary to protect
underground drinking water supplies
from adverse odor, taste, color and other
aesthetic changes that would make the
water unfit for human consumption, EPA
believes that this is a serious concern
which deserves consideration in the
criteria. In addition, many  of the
substances listed in the NSDWR often
occur together with other substances in
leachate which can be injurious to
health
  However, EPA has decided not to
include the contaminants identified in
the NSDWR m the criteria  at this time  It
was not clear in the proposed regulation
that EPA was considering their use for
purposes of the criteria To avoid any
question about the adequacy of
opportunity to comment on the use of
the NSDWR in the criteria, EPA has
decided to specifically seek public
comment on this issue, Thus, EPA is also
issuing today a proposed amendment to
the criteria which would add the
maximum contaminant levels in the
NSDWR to the definition of ground-
water "contamination,"
  Two Other sets of pollution
parameters were considered for
inclusion m these criteria the Qualify
Criteria for Water {EPA 1976) and the
list of toxic pollutants referenced in
Section 307(a)(l) of the Clean Water
Act, as amended
  The publication Quality Criteria for
Water recommends levels for water
quality in accord with the objectives in
Section 101(a) and the requirements of
Section 304(a) of the Clean Water Act.
The primary purpose of that publica.ion
is to recommend levels for surface water
quality that will provide for the
protection and propagation of fish and
other aquatic life and for recreation.
Although  recommended levels  are also
presented for domestic water supply,
and for agricultural  and industrial use,
ground water was not a  major
consideration.
  Quality Criteria for Water lists most
of the substances in Parts 141 and 143.
Several of the additional parameters
listed are  only of interest in surface
water protection, such as mixing  zones
(one third the  width of a stream, 10
percent of the area of a lake, etc ),
temperature, and suspended solids
While several health related substances
that could be present in  leachate  are
listed (e.g , boron, berylhum, cyanide,
nickel and several insecticides and
other organics), the recommended limits
are specified for aquatic life protection
and these are not appropriate for ground
water. Furthermore, the  recommended
limits were written to be guidance m
developing standards, not to be used  as
standards themselves Therefore, EPA
decided that this list was inappropriate
for these criteria,
  Under Section 307 of the CWA  the
Agency may establish either technology-
based or stricter health-based standards
for toxic pollutants identified under
Section 307{a)(l) EPA is investigating
the appropriateness of using the health-
based standards in the criteria  Such
substances as  aldnn/dieldrm, DDT,
endrm, toxaphene, benzidme and
polychlormated biphenyls (PCB's) are
now subject to section 307 stdnddrd;,
EPA may be establishing such standards
for other pollutants some time in the
future At  this  time, howe\er for
purposes of these criteria. EPA will rely
only on established drinking water
standards
  (3) Levels of Contamination  While
the design of the ground-water  criteria is
similar to  the "endangerment" approdch

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          Federal Register  /  Vol.  44,  No. 179  /  Thursday, September 13,  1979 / Rules and Regulations   53447
  of the Underground Injection Control
  Program under the Safe Drinking Water
  Act, it provides for greater specificity
  and does not use the exact wording of
  that program or statute Therefore,  to
  avoid confusion  the term
  "endangerment" is no longer used in the
  criteria Instead, the word
  "contaminate" has been employed  A
  facility "contaminates" ground-water if
  it introduces a substance that would
  cause'
   (a) The concentration of that
  substance in the ground water to exceed
  specified maximum contaminant levels,
  or
   (b) An increase in the concentration of
  that substance in the ground water
  where the existing concentration of that
  substance exceeds the specified
  maximum contaminant level
   The  first pait of the abo\e definition is
  intended to protect water that can be
  used as drinking water without
  treatment. The second part is intended
  to protect ground water already at or
  above  the maximum contaminant level
  by preventing introduction of substances
  that would exacerbate the problem
   Many comments were received on
  levels of contamination. Some suggested
  using ihe maximum contaminant levels
  (MCL's} in the National Primary and
  Secondary Drinking Water Regulations,
  others  suggested using higher limits or
  using lower limits Some reviewers
  suggested varying the levels with the
  background quality or the potential use
  of the ground water.
   The reasons given for adopting higher
 allowable levels, or more lenient
 standards, (than  the MCL's) included
 contention (1) that the increased cost of
 land disposal would be greater than the
 value of the threatened resource, (2) that
 the more efficient approach for some of
 the substdnc.es was to remove them
 from the water supply by treatment after
 contamination, and (3) that some of the
 Secondary MCL's are commonly
 exceeded in ambient or native ground
 water, thp-eby effectively resulting in a
 non-deg: .idation standard for those
 aquifeis EPA sees no reason to doubt
 that some people  will continue to
 consume ground water directly without
 treatment That portion of the public
 should be protected from adverse effects
 (as defined by the drinking water
 standards) caused by solid waste
 leachnte entering  their drinking water
 In some situations protection of the
 public will require non-degradation of
 an aquifer The Act does not call for a
 balancing of the costs of disposal
 against the "value" of ground-water
resources EPA believes that this
criterion represents a leasonable
approach to ground-water protection It
 allows for the use of natural
 mechanisms (e g soil attenuation,
 diffusion of contaminants in the aquifer)
 to reduce the risk of adverse health
 effects without compromising the
 general objective of protecting drinking
 water supplies
   The reasons given for more  stringent
 limits included- (1) Land disposal
 facilities are but one of several sources
 of ground-water contamination, and
 each source contributes to the overall
 rise in contaminant levels, (2) future
 research may find that lower levels are
 necessary to adequately protect health,
 (3) some agricultural, industrial and
 other important uses of ground water
 may be impaired, and (4) since ground
 water is often consumed without
 treatment, more stringent limits would
 require  less reliance on programs to
 monitor and to require treatment before
 domestic uj>age
   Generally, EPA has  not wntten more
 stringent standards because existing
 information does not indicate  that such
 standards are needed  to protect public
 health  Future research results might, of
 course, justify changing the criteria As
 discussed earlier EPA  does not now
 have the scientific basis for setting
 stricter standards designed to protect
 ground-water's use for non-dnnking
 water purposes  The standard does
 recognize that an aquifer may  be
 polluted by several sources Where
 existing ground-water  quality  levels
 exceed the MCL's, the  solid waste
 activity  may not degrade ground-water
 quality at all No matter what  the
 standard, the need for  monitoring must
 be determined on a case-by-case basis,
 and it seems doubtful that differing
 standards would change that need
   Some  reviewers mentioned that
 relying only on upper water quality
 limits results in more stringent
 requirements for protection of
 contaminated water than for
 uncontammated waler (i e, facilities
 over uncontammated waters could
 introduce substances up to the
 maximum contaminant levels  while
 facilities over contaminated waters
 could not introduce any substance  that
 would increase contaminant levels)
 While this is a possible result of the
 standard, EPA does not believe that the
 health risk justifies a complete non-
 degradation standard
  In adapting the NIPDWR for  the
 criteria a few modifications were
 necessary As indicated earlier the
 standdids for man-made radionuchdea
 werp not included because the  statutory
definition of solid waste excludes such
materials from the Act's scope  The
contammant level for cohform bacteria
had to be modified because under the
 NIPDWR the MCL varied somewhat
 depending on sampling frequency and
 community size  EPA assumed that
 sampling of ground water around
 disposal sites would be less frequent
 than in a public water system, and so
 the NIPDWR cohform standard related
 to the least frequent sampling regimen
 was selected for the criteria  Also, the
 criteria do not include the NIPDWR limit
 for turbidity,  since that limit  was
 established for surface water supplies
   (4) Where the Standard is Applied
 Another concern regarding the ground-
 water criterion is the issue of where the
 standard is to be applied (i e  at what
 point in the aquifer does contamination
 from the facility or practice constitute
 non-compliance)  In the proposed
 criteria, the point of application was at
 the facility property boundary The
 rationale for applying the standard at
 the property boundary was that it would
 provide for protection of off-site ground
 water while affording the opportunity
 for natural soil attenuation and
 dispersion and dilution of leachate in
 ground water underlying the  area
 designated for waste deposition (i e
 within the facility)
   However, the proposed criteria
 recognized that monitoring and control
 of leachate within the property
 boundary  would generally be necessary
 in order to assure that the standard at
 the property bountary would be met
 Therefore, there also were proposed
 operational requirements including
 monitoring of ground water, prediction
 and control of leachate migration,
 collection  and removal of ieachate and
 prevention of water infiltration.
   Commenters indicated two potential
 shortcomings of the facility property
 boundary approach (1) That  future
 owners of the facility property might use
 contaminated ground water underlying
 the  facility as drinking water and (2)
 that if the facility property were very
 large, great expanses of ground water
 could be contaminated and purchase of
 additional  property could be used to
 circumvent the intent EPA agrees that
 such results could occur.
   Commenters also expressed concern
 that the operational controls and
 monitoring provisions were vague and
 could be meaningful only if specified on
 a site-by-site basis, rather than
 generally prescribed in a regulation of
 national applicability. Commenters also
 described these operational provisions
 as inappropriate to a regulation which
 must delineate acceptable performance
 levels
  The Agency considered use of other
distance specifications in lieu  of the
property boundary in order to try to
respond to reviewers' concerns about

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53448   Federal Register  /  Vol  44,  No  179  / Thursday, September 13. 1979  /  Rules  and  Regulations
the potential for contamination of large
expanses of ground water The proposed
criteria requested comments on
alternative distances and the rationale
for specification of such distances.
Various distances were suggested in the
public comments; however, there was no
basis presented for  selection of one
distance over another While there is a
rationale for limiting migration of
contamination to within the areas to be
used for waste.disposal in order to
protect neighbors who may use the
ground water untreated as a drinking
water supply, there  is no rationale for
limiting migration to any particular
distance
   In evaluating this issue EPA
recognized that the  point of application
of the standard must be mindful of the
abhlity to monitor at that point. Ideally.
the best way to protect present and
future users of an aquifer is to  assure
that drinking water standards  are not
violated anywhere in the aquifer,
including the area immediately under
the waste material
   However, any attempt to monitor
directly under the waste presents two
major difficulties, First, an
environmental risk may be posed by the
installation of monitoring wells through
the waste material or in areas  where
wjste will be deposited. These wells
may become conduits for direct flow of
Wdste constituents (e g leachate)  into
the aquifer  While it may be
theoretically possible to construct a well
that doesn't allow such infiltration, the
technology for this has not been
sufficiently demonstrated that  EPA
would want to encourage this practice
on a national scale  Secondly,  the
immediate proximity of waste  to the
well, in conjunction with the "conduit"
phenomenon, would undermine the
utility of the monitoring well. Samples
extracted would not be likely to be
representative of the aquifer; rather,
they would be likely to contain
concentrated leachate, overestimating
the contamination of the aquifer.
   EPA also examined the possibility of
other fixed distances from the  center of
the waste area  This approach  was
rejected because it was impossible to
establish a uniform  distance that would
be meaningful for the vast number of
situations to which this standard
applied, In some instances a fixed
distance would mean that monitoring
wells would still be  placed through
waste  material. A longer distance might.
in some cases, put the point of
measurement beyond the area  of likely
placement of drinking water wells.
  After examining all of these
approaches EPA concluded that the
solid waste boundary is the appropriate
point for application of the standard
The solid waste boundary is intended to
be taken as the outermost perimeter of
the solid waste as it would exist at
completion of the disposal activity. With
that as the point  of measurement.
ground-water contamination will be
detected as soon as possible without
presenting the risks inherent m
monitoring under the waste Likewise, it
avoids the problem of guessing the
distance at which a potentially affected
party is likely to  put a drinking water
well (The only assumption is that
drinking water won't be taken from
wells drilled  directly through  the area of
solid waste deposition)
  In most cases,  for disposal facilities,
the solid waste boundary would be the
boundary of the solid waste as shown
on the  design and operating plans which
are provided  to and approved by the
State agency  as part of the State's
facility permitting or certification
program Where  such plans do not exist
to designate the perimeter at
completion, especially for the practice of
indiscriminate or unauthorized disposal,
the perimeter at completion can only be
taken as the current boundary of the
deposited waste
  With this approach to the point of
application for the MCL's, the
monitoring requirements are relatively
clear. Monitoring wells should be placed
so as to avoid their becoming conduits
for waste materials Unsaturated and
saturated zones underlying the area of
the facility  designated  for waste
deposition (i.e. within the solid waste
boundary) may be  employed for
attenuation or control of leachate
migration, but contamination of
underground  drinking water sources
outside of these zones constitutes non-
compliance with the criteria.
  The point of application of the MCL's
may be modified under certain
circumstances. EPA recognizes that
hydrogeological conditions, property
rights or legal arrangements concerning
an aquifer may limit the ability of the
public  to directly use some or any part
of a particular aquifer as a drinking
water source  EPA believes that some
flexibility is needed in  the criteria to
provide for such  situations. Therefore.
the criteria allow the State to modify the
point for application of the MCL's.
  To prevent this from becoming a
major loophole, the criteria establish
limits to this flexibility. Only States with
approved solid waste management
plans may modify the point of
measurement. This may only occur
where the State has conducted a
thorough examination of the site-specific
situation and has made a specific
finding that establishment of the
alternative boundary would not result in
contamination of ground water needed
or used for human consumption The
examination leading to the finding
should include the opportunity for public
participation  The criteria specify the
key factors that must go into this
determination.
  The proposed criteria would have
allowed a State to designate an aqutfer
as a Case II aquifer (an aquifer
designated for use other than as a
drinking water supply), For an aquifer so
designated, the proposed  criteria
required the ground water to be
maintained at a quality as specified by
the  State  Several commenters
challenged the use of this approach.
Some argued  that, give-n the
uncertainties in future drinking  water
needs, all potentially usable drinking
water should be  conserved They also
pointed out that  there was inadequate
data on ground-water quantity,  quality
and use projections to make such
designations  and that institutions arid
authorities to make such trade-offs are
non-existent  Commenters also
suggested that it was improper for the
criteria to defer totally to State
standards for designated  aquifers
  EPA generally agrees with the
comments. These and other factors lead
EPA to drop the  aquifer designation
provision and rely on the alternative
boundary approach as the means foi
allowing flexible application of the
criteria.
  (5) Underground Drinking Water
Source The final criteria  maintain the
general approach found in the proposed
regulation The reference to aquifers
that "may be designated by the State for
future use as  a drinking water supply"
has been deleted EPA concluded thcit
this was unnecessarily vague Any
future drinking water source would be
likely to fall within the second portion of
the  definition (aquifers in which ground
water contains less than 10,000 mg/1
total dissolved solids)
  Some commenters questioned the use
of the 10,000 mg/I total dissolved solids
measure for usable aquifers  It is the
Agency's general policy that ground-
water resources  below that
concentration be protected for possible
use as  a drinking water source.  This
policy is based on the Safe Drinking
Water  Act and its legislative history
which reflects clear Congressional
intent that aquifers in that class deserve
protection
  (6) Sole Source Aquifers These
aquifers are those which the
Administrator specifically designates
under authority of Section 1424(e) of the
Safe Drinking Water Act [Pub L 93-523,
42 U S C. 300f, 300h-3(e). 88 Stat. 1660 et

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           Federal  Register / Vol 44, No,  179 / Thursday,  September  13  1979 / Rules and Regulations   5J449
  seq ] This provision of the Safe Drinking
  Water Act is administered through
  regulations proposed as 40 CFR Pait 148.
  As applied through RCRA, the Agency's
  concern for the impact of disposal
  facilities on these aquifers is not
  different from that for other
  underground drinking water sources as
  defined  in the criteria. Therefore, for
  clarity and consistency, this area of the
  proposed criteria has now been
  incorporated into the ground-water
  section.  Rather than addressing the
  location of facilities in recharge zones of
  such aquifers (an operational standard),
  the criteria apply the performance
  standard described above for all
  underground drinking water sources.
  including sole or principal drinking
  water sources, regardless of location
  H Application To Land Used For The
  Production Of Food-Cham Crops
  (Section 257 3-5)
   The conservation of the nation's
  natural resources is one of the Agency's
  highest priorities The application of
  sewage sludge, as well as other solid
  wastes, to the land surface or
  incorporation within the root zone of
  crops may provide significant benefit
  through the addition of organic matter,
  nitrogen, phosphorus and certain other
  essential trace elements to the soil
  Specifically, land application of solid
  waste coupled with good management
  techniques for enhancement of parks
  and forests and reclamation of poor or
  damaged terrain is a desirable land
  management technique
   Application of solid waste to
  agricultural lands may also be an
  environmentally acceptable method of
  disposal  However, when improperly
  managed, the application of solid waste
  to agricultural lands can create a
 potential threat to the human food chain
  through the entry of toxic elements,
 compounds, and  pathogens into the diet
 (It should be noted that pathogens are
 covered under the Disease section of the
 criteria )  In developing these criteria, the
 Agency attempted to achieve the
 benefits of resource conservation while
 at the same tsme providing for protection
 of public health and the environment. In
 recognition of the above public health
 concerns, the Agency prefers the
 application of solid waste to non-food-
 chain land rather than to agricultural
 lands  However, the Agency believes
 that food-chain land application
 practices which comply with these
 criteria will pose no reasonable
 probability of adverse effects on public
 health or the environment
  This section is only concerned with
 disposal activities affecting food-chain
crops. The other sections of the criteria
  apply to all disposal activities, including
  those occurring on lands producing
  food-chain crops However, solid waste
  facilities and practices are only affected
  by this  section if the site of disposal is
  also a field for production of food-chain
  crops.
    In their role as guidelines under
  Section 405 of the Clean Water Act the
  criteria define the responsibility of
  owners and operators of POTW's when
  they apply sewage sludge directly to the
  land  In an effort to encourage the
  beneficial use of sludge in small
  communities EPA is concerned that
  these criteria could present an
  unwarranted administrative burden
  upon such communities Therefore, EPA
  will explore the possibility of reducing
  monitoring and recordkeeping
  requirements for those POTW's with
  small design capacity which do not have
  Significant industrial inflow and  which
  generate a sludge with a low
  contaminant level  Such reduced
  requirements for facilities which apply
  sludge to land used for the production of
  food-chain crops would be a part of
  future regulations or guidance designed
  to implement Section 405 EPA is
  considering using a design  capacity of
  1 0 million gallons or less per day lo
  define "small" facilities and cadmium
  concentrations of less than 25 mg/kg
  (dry weight) to define "tow-
  contaminant" sludge,
   This section of the criteria is being
  issued today as an "interim final"
  regulation This means that, while the
  regulation is "final" and legally
  enforceable, EPA is seeking further
 public comment on the regulation If
 changes are warranted by suggestions
  or new information generated during the
 public comment period, EPA is quite
 willing to modify this section
   The "interim final" approach has been
 recognized by the courts as a
 permissible means for EPA to use when
 trying to satisfy the competing demands
 placed on its rulemakmg efforts
 Particularly where EPA is under court
 order to  issue regulations by certain
 dates,  this approach has been used to
 satisfy the spirit of the court's order
 without cuitailing opportunity for
 additional public participation in the
 rulemakmg process.
   These  criteria are subject to ihe
 mandate of the U S  District Court for
 the District of Columbia in State of
Illinois v  Costle No 78-1689 [D D C
Jan  3,1979) Under the order of that
court the criteria were to be issued hv
July 31, 1979, and EPA intends to satisfy
the spirit of that order EPA believes
that the standards established in th's
section provide a reasonable approach
to the environmental problem at issue
  However, the public has not had a full
  opportunity to comment on some of the
  technical data and analyses supporting
  this portion of the regulation The
  "interim final' approach is appropriate
  because it allows the Agency to
  accommodate these two competing
  interests It achieves substantial
  compliance with the court mandate
  while allowing full public participation
  in the rulemakmg effort.
   As proposed, this section of the
  cnteria addressed four general
  categories of pollutants (1) Cadmium,
  (2) pathogens, (3} pesticides and
  persistent organics, (4) mgestion of toxic
  organic chemicals and heavy metals
  (especially PCB's and lead). In the final
  regulation this section addresses
  cddmium and PCB's Pathogens are
  considered under the disease criterion
  (§257.3-6)  Lead,  pesticides and
  persistent organics will not be
  addressed at this time because current
  information available to the Agency is
  inadequate to support specific
  standards EPA will investigate the
  possibility of adding more pollutants to
  the criteria at a later date.
   (1) Cadmium.—The proposed criteria
  included two approaches for the land
  application of solid wastes containing
  cadmium The first approach
  incorporated four site management
  controls Control of the pH of the solid
  waste and soil mixture, annual cadmium
  application limits that were reduced
  over time, cumulative cadmium
  application limits  based on soil cation
 exchange capacity (CEC); and a
 restriction on the cadmium
 concentration in solid wastes applied to
 facilities where tobacco, leafy
 vegetables and root crops are grown
 The second approach required
 comparability of the cadmium content of
 crops and meats marketed for human
 consumption to the cadmium content of
 similar crops and meats produced
 locally where solid waste had not been
 applied  Also, a contingency plan was
 required which identified alternative
 courses of action that would be taken if
 the cadmium levels were not found to be
 comparable  This approach was only
 a\ ailable to facilities possessing the
 necessary resources and expertise to
 adequately manage and monitor their
 operations to assure such comparability.
  In the final regulation, application of
solid waste to land is specified as a
disposal piachre in which the solid
waste is  applied to within one meter
(three feet) of the surface of the land.
Ihdt distance WHS  selected to represent
the root zone of food-chain crops, where
uptake of cadmium by plants is likely to

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53450   Federal  Register / Vol. 44, No. 179 / Thursday, September 13,  1979 / Rules and  Regulations
  The final regulation maintains the
same general approach as the proposed
regulation. Under the first option
controls are placed on both annual
application rates and maximum
cumulative loadings The provision
mandating that the pH of the mixture of
soil and solid waste be maintained at 6 5
has been changed to a requirement that
the pH be at 6 5 or more at the time of
each  solid waste application (except
when cadmium concentrations  are 2 mg/
kg or less in the solid waste).
  While the annual application rate
limits are basically the same as those in
the proposed regulations, two changes
have been made. The limit for annual
cadmium application to "accumulator"
crops is now 0.5 kilograms per hectare/
yr.  {In the proposed regulation the limit
was expressed in milligrams per
kilogram dry weight of waste )  In
addition, the annual application rate
limit  for all other crops will be phased in
over a slightly longer time penod than
that which was proposed.
  The limits on cumulative loadings are
also basically the same as those in the
proposed regulation. However, they
have  been modified to account  for pH
effects. Where natural soil background
pH is at 6.5 or greater, or where the
natural soil background pH is less than
6,5  but safeguards exist at the site which
will assure that the soil pH will be
maintained at 6 5 or greater for as long
as food-chain crops are grown,  the
maximum limits contained in the
proposed regulation are applicable. In
all  other situations maximum
cumulative loadings may not exceed 5
kg/ha.
  As  in the proposed regulation, there is
a second approach that would allow
unlimited application of cadmium
providing that four specific control
measures are taken' First, the crop
grown can only be used as animal feed
Second, the pH of the soil must be
maintained at 6 5 or above for as  long as
food-chain crops are grown Third, a
facility operating plan must describe
how the animal feed will be distributed
to prevent human ingestion. The plan
must  also describe  measures that will be
taken to prevent cadmium from entering
the  human food-chain due to alternative
future land uses of the site Fourth,
future owners are provided notice
(through provisions in land records or
property deed) that there are high levels
of cadmium in the soil and that  food-
chain crops should  not be grown
  EPA received many comments on the
cadmium controls in the proposed
regulation In order to clearly explicate
the  final standard and respond  to major
public comment, this preamble will
discuss t ie issues under five headings:
(a) Health effects; (b) trace amounts of
cadmium; (c) maximum cumulative
loadings; (d) annual rates of application;
and (e) closely controlled facilities.
  (a) Health Effects of Cadmium.— The
comments that were received exhibited
widely divergent views on the health
implications of cadmium contained in
sofid waste. As a result, the Agency
reexammed the available scientific data
and reached the following conclusions
  A vanety of adverse health effects
have been documented in humans and
experimental animals under conditions
of acute as well as chronic exposure to
cadmium- While acute health effects in
humans are generally caused by high-
level occupational exposure through
inhalation, chronic health effects may
result through the diet and cigarette
smoking, which are the major routes of
cadmium intake for most people. The
kidney is considered  the main target
organ for chronic exposure to cadmium,
although chronic respiratory effects
have been observed in long-term
occupational settings  Upon mgestion or
inhalation, the metal  gradually
accumulates in the kidney cortex.
According to both clinical-
epidemiological and model-calculation
data, the critical concentration of
cadmium in the kidney cortex is
approximately 200 micrograms per gram
(ug/g), wet weight, in the average
human At (hat level, renal tubular
dysfunction, characterized by
protemuna, is expected to occur This
condition is manifested by the excretion
of Ba-microglobulin, which is the earliest
discernible laboralory evidence of organ
damage. Although mild or moderate
increases m excretion ofB,-
microglobulm, per se, are not life-
threatening, the condition is often
irreversible, and continued excessive
exposure to cadmium can lead to other
renal function abnormalities (such as
glycosuna, amino-acid uria, and
phosphatunaj
  Several autopsy studies have been
performed to determine the cadmium
content of various types of body tissue,
such as the kidney and the liver These
studies confirm that the kidney is the
organ which contains the highest
concentration of cadmium and that the
concentration of the metal increases
with age. Further, the autopsy data
indicate that for the general United
States population (smokers included)
the mean cadmium levels reached in the
kidney cortex are in the range of 20-35
micrograms per gram  wet weight
Smoking would tend to raise the mean
cadmium concentration since the data
also show that smokers have
approximately double the concentration
of non-smokers. There were significant
individual variations from the mean
value, with some concentrations over 60
micrograms per gram.
  Various models have been established
to calculate the daily level of exposure
which will result in a cadmium
concentration of 200 ug/g in the kidney
cortex, i e , the concentration at which
tubular protemuria can be expected to
occur. EPA scientists reviewed these
models and have reached the following
consensus, Ingestion of 440 micrograms
of cadmium per day over a 50-yedr
period is a reasonable estimate of the
amount of cadmium necessary for 50
percent of the individuals within the
population to develop  prole in uria It is
significant to point out, however, that
there are many individuals who may
develop proteinuna at lower exposure
levels The metabolic model, developed
by Fnberg. shows that ingestion uf
about 200 micrograms  per day over a 50-
year period is the level at which most
sensitive individuals accumulate 200 ug/
g cadmium in the kidney cortex. Thr
dose-rosponse model,  developed by
K|ellstrom and Nordberg, reflects a non-
threshold dose-response Using this
model, daily cadmium exposures m the
range of 100 to 125 micrograms would
produce renal dysfunction in about 5 "o
8 percent  of the population after some 50
years of exposure
  These model calculations are bdscd
on the assumption that all cadmium
intake is through the diet  Therefore.
allowances are necessary for non-
dietary routes of cadmium intake, such
as smoking or occupational  exposure
(The contribution of smoking to
cadmium  intake is readily quantifiable.
Available data show that smoking one
pack of cigarettes a day is roughly
equivatent to cadmium retention m the
body resulting from a dietary intake of
25 micrograms.)
  In 1972, the World Health
Organization (WHO) used a model such
as the ones referred to above to arrive at
a recommended maximum cadmium
intake level through the diet  Employing
a margin of safety to allow for nun-
dietary intake sources and for sensitive
individuals, the WHO  recommended
that human exposure to cadmium should
not exceed 57 to 71 micrograms per day
from the diet
  There is no general consensus on the
current dietary cadmium levels in the
United States, but there is wide
agreement that the daily intake levels
vary significantly according to
individual dietary hdbits. Based on
annual market basket surveys
conducted by the Food and Drug
Administration (FDA), the median
mgestion level is about 39 microgrems

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          Federal Register / Vol  44, No. 179  /  Thursday,  September  13, 1979 / Rules  and  Regulations   53451
  POT day and the mean mgestion level is
  about 72 micrograms per day for male
  teenagers, who have the highest per-
  capita food intake among any age group
  Any average value as an estimate for
  cadmium intake through the diet has the
  shortcoming that it does not represent
  those individuals with unusual dietary
  habits, such ds the heavy consumption
  of cadmium-rich foods [e g , leafy
  vegetables), and the available evidence
  shows that there is a wide range of
  dietary cadmium exposure among the
  population
   One other source for estimating
  cadmium intake levels m the human
  body was reviewed by the Agency  This
  comprises chemical analysis of fecal
  excretions  The fecal excretion studies
  are based on the experimental finding
  that only about 6 percent of ingested
  cadmium is retained in the body, while
  the rest is excreted. Three recent fecal
  excretion studies derived the daily mean
  dietary cadmium intake estimate of
  about 20 micrograms for American
  teenage males The reasons for the
  significant differences between the
  results of the fecal excretion studies and
  the FDA market basket surveys are not
  yet understood The fecal excretion
  studies also showed significant
  individual variations  in derived
  cadmium mgestion levels. Thus, five
  percent of the population appeared to
  exceed 30 to 40 micrograms per day
  intake, and one percent appeared to
  exceed 50 micrograms per day intake
   There are population groups for whom
  tin mi rease of cadmium levels in the
 diet may be more significant than for the
 average population Among these are
 the smokers, who are known to receive
 an added body burden of cadmium via
 inhalation Vegetarians also may be
 experiencing higher cadmium intake
 than lh.> dverage population, since
 certain vegetables  contain significantly
 more cadmium than other food items.
 Also, the  scientific hteiature indicates
 that certain nutritional deficiencies,
 sin h as low calcium, zinc, or protein,
 result in a marked  increase in cadmium
 absorption through the gastrointestinal
 tract, while individuals with vitamin D
 deficiency are more susceptible to injury
 by s given level of cadmium in the body.
  Doth the FDA approach and the fecai
 study approac-h are legitimate means of
 estimating current average intakes of
 cadmium  However it is also clear that
 "sensitive" individuals may be
 experiencing much  higher absorption of
 cadmium  Since under this regulation
higher estimates of current intake will
mean that lower levels of cadmium will
be allowed to be added from solid waste
disposal, EPA believes that it should use
 the higher estimate of current diet levels
 in order to provide greater protection for
 sensitive individuals Therefore, as will
 be explained later, the criteria will rely
 on the FDA estimate of 39 ug/day as the
 median level in the diet, which was
 derived by averaging the median levels
 over several years
   In addition to the concerns over renal
 toxicity, several commenters raised
 questions over potential oncogenic,
 carcinogenic, mutagenic and teratogenic
 e fleets of cadmium Based on an
 evaluation of the currently available
 scientific data, the Agency has
 concluded that the evidence that
 cadmium may cause  these effects in
 man is suggestive but not decisive
 enough to serve as the basis for this
 regulation. Consequently, the limitations
 on cadmium incorporated in the criteria
 are based on the substantial evidence of
 that metal's impact on the kidney,
 specifically the renal cortex, which the
 Agency considers to be the mam  target
 organ for chronic environmental
 exposure However, if cadmium is
 determined to cause the aforementioned
 effects in humans, the Agency will
 reevaluate the regulations and establish
 appropriate new limits
   The Agency is concerned over the
 conduct of any practice which could
 significantly increase the amount  of
 cadmium in the diet beyond current
 levels Therefore it is the intent of this
 rulenidking to minimize the movement of
 cadmium into the human food chain
 from solid waste applied to the hind
 After an evaluation of the full range of
 scientific information concerning
 cadmium, EPA has decided to make the
 following assumptions to serve as a
 basis for setting limits on solid waste
 application
   First, the Fnberg model, which defines
 200 ug/day as the "danger level" in the
 human diet, is most appropriate fur
 regulatory purposes There is more data
 to validate that approach than there is
 for the K)ellstrom dose-response model.
  Second, to provide an adequate safety
 margin in defining the risk from solid
 waste applied to food-chain crops, the
 criteria should be concerned about daily
 dietary intake of 70 ug/day of cadmium
  Thud, for analytical purposes, EPA
 will assume a maximum increment of 30
 ug/day in conjunction with high risk diet
 assumptions  In order to relate the
 health effects analysis to the diverse
 and complicated data  that exist on crop
 uptake, it is necessary to make a
 judgment about the incremental
 cadmium ingestion that must be
 prevented by this regulation  Clearly.
this is a difficult task in light of the
various sensitivities of particular
individuals, the long-term nature of the
 health risk and the various dietary
 patterns which may occur.
   In using this assumption, EPA is not
 slating that such an increase in the diet
 of the average American is acceptable.
 An increase of that magn'tude in the
 average diet would clearly be
 unacceptable  For the average to
 increase by this increment, many
 individuals would be experiencing much
 higher cadmium intakes
   It must be emphasized that the 30 ug/
 day figure will be used in an analysis of
 a high-risk situation, That high-risk
 situation is one where an individual
 receives 50°i of his vegetable diet from
 sludge-amended soils for a period of 40
 to 50 vears. While such a situation could
 occur,  due to a wide variety of other
 mitigating factors most people v\ ill
 experience much smallei exposures to
 cadmium.
   Realizing that any numerical
 expression of unacceptable health risk
 can only be an approximation, EPA used
 the 30 ug/day as a reasonable
 assumption for this analysis  The
 Agency's Office of Research  and
 Development determined that daily
 cadmium intake of about 200 ug/day
 could lead  to serious health affects  To
 provide a margin of safety, that office
 suggested that a limit of 150 ug/day from
 all sources  of exposure be considered
 for regulatory purposes EPA is also
 concerned about the added cadmium
 which may  enter the human body due to
 smoking Heavy smokers (those  smoking
 3 packs of cigarettes per day) can expect
 to add  the equivalent of 75 ug of
 cadmium to their daily intake
   Reducing the 150 ug/day by that figure
 gives an estimate of the "danger level"
 for dietary intake The result  of that
 calculation (75 ug/daj)  is close to the
 World Health Organization's
 recommendation of 57-71 ug/day EPA
 decided that a level of 70 ug/day
 represented a reasonable limit on the
 maximum acceptable daily dietary
 mlake of cadmium. The FDA  s estimate
 of current levels of cadmium in the
 median American is 39 ug/day
 Therefore the 30 ug/day assumption
 would keep cadmium ingestion within
 the limit of 70 ug/day
  (b) TroLe Amounts of Cadmium —
 W'here the cadmium content of sludges
 is quite  small the likelihood of a
 significant uptake in plants is also
 relatively small  Several commenters
 suggested that the requirement for pH
 control (65 at time of waste application)
 should not apply to those solid wastes
 which contain only trace amounts of
 cadmium EPA agrees with this
comment and, therefore, has exempted
wastes with cadmium concentrations of
2 mg/kg (dry weight) or less from the pH

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53452   Federal  Register / Vol. 44, No. 179 / Thursday,  September  13, 1979 / Rules and Regulations
control provision This modification
would allow such wastes as food
processing residuals to be landspread
without ^ni'ecpssi'rj  pH control
measures.
  [r]  Ma\ nwmCuwuIat,i,t> Loading? of
Ciu'/7"u/n —Comments received on the
C'j.Tulj'ivC cadmium application limits,
s< il pH. and soil cation exchange
capacity (CECj a~e interrelated tind,
theie'ore, w-11 be discussed
concurrently  in gem  --al. ro mm priors
felt i\ at varying degrees and
combinations of the three
aforementioned partimet£ rs will lirrrt
the uj;tuke of cadmium by fjod-chain
crops
  Most conm^nters agreed that it is
necessary to  control the pH of the solid
waste/soil mixture to minimize the
Uptake of cadmium by food chain  crops
The final regulator, -(-cognizes that need
b> requiring that the pH of the soi'/sohd
u a?te mixture be 6 5 dt the time of
application, The proposed regulation
lequired that pH be maintained  at 6 5 for
as lung as food chain crops were grown
Several Lfjmmenters pointed out that
such ,1 provision would be difficult to
implement or enfon e m  rrany
situations The Agerev agrees that this
m.''V be UUP in some instances but did
not want to prec ludu the application of
solid wiste to food-chain crops where
so.! pH can lie maintained at acceptable
leu-Is
  These  conMderabons prompted  EPA
to modify the standard for cumulative
luad'ngs to delineate three soil
(-I'f^ui les based on pH  (1) Those with
rali'fa! pH of 6 5 01 above; (2) those
with natural pH belcnv 65, and (3) those
with natural pH below 05 but where pH
v.i!l he m am lamed at or above 6 5 for as
Um» as ft,od-( ham crops die grown The
cntt'i-a establish the  same set of
standards for categories (!) and  (3) but
t'ghten the standard for soils with the
iiiOj"e dangerous condition reflected in
c.i:uSory (2)
  Tlie prime data l>ase for the
cai' i.lation of accept,'bio emulative
'•^ id'n^s  v\as a set of field studies  on
f'lfiiiei landspreodir.g sites where crops
v-vere groivn at least two vears after
appluat'on oi solid waste This
appioarh was appropriate for setting
rndXtTHim cumulative limits because
sue h standards are primarily concerned
with future uses of londspreading sites
for home gardening cr commercial
dgnuiiture
  These data con plated  cumulative
loadings  of solid wasle in the  soil to
p!first uptakes of cadmium )n
representative leafy vegetables  From
existing data  comparing  uptakes of leafy
vegetables to  other basic food classes,
EPA calculated the ratio of uptakes in
leafv vegetables to those in other
classes  The ratios were then applied to
the field data to predict what uptakes
would have been if other types of crops
had been grown on former
landspreadmg sites This gave an
estimate of cadmium uptakes that would
be likely to occur in fields with diifpfing
cumulative levels of cadmium
  EPA then used a "diet scenario"
analysis to translate the plant uptake
lev f\s into predictions about the amount
of cadmium entering the human food
chain The Agency  s assumptions about
intake of the various food classes
followed that of !hp U S Food and Drug
Administration's 1^74 Total Diet
Studios  From this, EPA calculated the
additional cadmium entering the human
diet, assuming varying levels of
dependence on crops fiom waste-
amended fields (EPA calculated intakes
for situations wheie 100%, 50%, 25% and
10% of the diet come from such fields )
  The 5 kg/ha limit for acid soils (below
6 5 pH) was established by relating the
diet scenario analj sis to the health
effects analysis The diet scenario
analysis indicated  that on  mildly acid
sods (pH = 58) 5 kg/ha of cadmium only
increased dietary cadmium by 22 ug/day
(making the assumption that no more
than 50 percent of one's vegetable diet is
derived from sluilgr fields) However a
cumulative loading of 7 kg/ha on very
acid sods (pH =4 9) intieasod the
dietary level by 211 ng/ddy This
marked increase in dietary cadmium
may be attributed to both the iru rease in
the cumulative cadmium application
rate from 5 kg/ha to 7 kg/ha and the
drop in pH from 5 0 to 4 9 Suf h an
increase is far above the acceptable
level m the diet 'Jhprefore EPA h-is
established the maximum cumulative
limit at 5 kg/ha for acid soils
  Soil cation exchange capacity was
also utilized jn calculating the
permissible loadings for suils with pi I of
b 5 01 greater The evidence available to
EPA indicates thai CEC is  an important
index of soil factors in limiting uptakes
in h'gh-pH soils However, in highly
acidic soils, pH becomes the dominant
factor affecting plant uptake
  Soil CEC is an easily measured index
of those properties paitic ularly ihe
nature and content of clay and organic
matter, that affect the  soil's ability- to
adsorb cadmium H'gh CEC levels mean
that a soil has a gre iter capacity to
adsoib cadmium and thus prevent  that
cddnMuii from entering plants grown in
the soil  Several studies have
demonstrated the inverse relationship
between CEC and plant uptake of
cadmium
  The proposed cadmium standard
recognized the importance of CEC and
established differing limits depending on
CEC levels in the background sod The
dct'ial numbers selected were based on
recommendations fiom recognized
agricultural research groups {including
the North Central Regional Extension
Services and the I! S. Department of
Agriculture) Several commenters
si pported the selected levels as
piovidmg adequate protection against
excessive uptake of cadmium.
  Where possible,  EPA also used
existing fjeld studies on former
landspreadmg sites to validate those
Eecommendations  An application of the
diet scenario analysis (o available da la
on high-pH sods with mid-range CEC'-i
supports the conclusion that the levels
established in the recommendations
provide adequate protection to the
public. As an example, again assuming
that half of the vegetable diet c omes
from sludge-amended fields, the data
show that a  cumulative  level of 7 kg/ha
could result  in an 11 9 ug/day dietary
increment, while a level of 15 kg/ha
could result  in a 39 2 ug/day increment.
Using the 30 ug/day increment
assumption discussed prevously, the 15
kg/ha loading is too high, while the 7
kg/hd loading is well within the
acceptable range EPA believes that this
analysis supports the selection of 10 kg/
ha is an appropriate standard for soils
v\ ith a mid-range CEC In light of the
other clear evidence of the rule of CEO
m limiting uptake EPA believes that it is,
therefore, appropr.ate to use the limit,';
recommended by the research
community
  1 he Afipnc y rerogniyps ihat thorr aio
seme fdciblies with naturally acid soils
where land management practices can
be implemented with adequate
safeguards to assure that the soil p[[
Hill be maintained at 6 5 or higher for as
long as food-chain crops are grown
Where such safeguards  exist  the
Criteria provide an option to permit such
facilities to use the CEC based cadmium
loading rates However, the Agency is
Concerned that the application of up to
20 kg of cadmium pei hectare may result
m significant cadmium up'ake bv crops
if the pH is not controlled for as long as
food-chain crops are grown Therefore.
urless the facility can clearly
demonstrate long-term control over pH,
the Agency strongly recommends that
thv>se facilities having naturally acid
sails select the option whiL,h limits the
cumuldJive cadmium application  rate 'o
5 kg/ha,
  The Agency considered establishing
even lower cumulative cadmium
application rates on soils with a natural
pi I that is very highly acidic (including
prohibition on landspreadmg on soils

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          Federal Register /  Vol.  44,  No. 179  /  Thursday, September  13,  1979 / Rules and Regulations    53453
  with very low pH) While it is clear that
  leafy vegetables, root crops and tobacco
  tend to accumulate cadmium in their
  ('-.sues and, therefore, are more
  sensitive to high soil cadmium
  concentrations under and soil
  conditions, insufficient data exist to
  establish more restrictive cumulative
  levels for such soils The Agency 13
  continuing to examine this situation and
  will, upon development of additional
  data and information, propose new
  cumulat.ve limits for highly acidic soil
  However, in recognition of the higher
  uptake of cadmium Ly these crops, the
  Agency recommends avoiding the
  application of solid waste containing
  cadmium (e g , sew age sludge) on very
  acidic soils used foi the production of
  leafy vegetables, root crops and tobacco
  and discourages the application to
  agricultural land which is hkely to be
  converted to production of such crops
   The Agency also considered requiring
  a soil analysis for total cadmium prior to
  the application of solid waste and
  adjusting the cumulative limit for
  cadmium additions downward to
  account for soils with high background
  cadmium concentrations However, the
  Agency was not able to justify the use of
  a background  correction factor since
  there is a paucity of data concerning the
  relationship between naturally occurring
  cadmium and solid waste-added
  cadmium, with respect to crop uptake.
  Until these questions are resolved, the
  Agency rf commends that a soil test be
  performed prior to initiating
  la ndt,p reading, in order to establish the
  background conditions at the site
  Further, for those facilities which have
  unusually h,gh background cadmium
 soil concentrations, the Agency
 recommends thai consideration be given
 to reducing cadmium application
   (d) Annual Cadmium Appl.cation
 L'mit—Comments received on the
 proposed annual cadmium application
 limits were widely divergent Several
 te"imrnters stdted that the proposed
 t cidmium limitation of 0 5 kilogram per
 hectare (kg/ha) per year was
 unnecessarily restrictive, The indicated
 reasons were primarily that the
 reduction in solid waste application
 would result in  increased costs and that
 the potential risk to human health was
 not sufficient to justify that reduction A
 second  group of commenters suggested
 that  the annual  limitations on cadmium
 upplication were not sufficiently
 piotective of public health and should
 be reduced much further or the
 application of cadmium-containing solid
 waste to agricultural lands be prohibited
altogether, since the proposed limits
would permit the entry of significant
  quantities of cadmium into the human
  diet.
    Comments were also received on the
  proposed cadmium concentration limit
  of 25 mg/kg for solid wastes applied to
  facilities where tobacco, leafy
  vegetables or root crops are grown for
  human consumption  Some commenters
  viewed the proposed limit as being
  overly restrictive, while others
  recommended that cultivation of those
  crops which tend to accumulate
  cadmium to relatively high levels should
  not be allowed on waste-amended soils.
   EPA believes that annual cadmium
  application limits are particularly
  important on those active sites which
  are nearing the cumulative cadmium
  application limits  As the total amount
  of soil cadmium at such sites begins to
  reach the cumulative loading limits, both
  the cadmium previously applied to the
  soil and new additions of cadmium from
  solid waste will affect crop uptake of
  cadmium, In setting annual application
  rates EPA must account for this factor,
   A\ ailable research indicates that
  there are significant differences in
  uptake among  crop species. It would,
  however, be impossible to write specific
  cadmium limits for each crop type based
  on the available data  Moreover, such
  an approach would complicate the
  regulation, making implementation
  confusing and  impractical.
   In looking at individual crop uptakes,
 however, EPA  determined that there is a
 set of "accumulator" crops which tend
 to absorb very large quantities of
 cadmium as compared to all other  crops.
 Tobacco, leafy vegetables and root
 crops constitute the "accumulator"
 class In order  to provide an adequate
 margin of safety EPA believes that the
 annual application rates should be
 based on data from representative
 "accumulator"  crops This assures  that
 when a mix of crops is grown on sludge-
 amended fields no crop will have
 dangerous up takes of cadmium
   The available data indicates that
 significant increases of cadmium occur
 even with small applications of waste.
 For example, annual rates of
 approximately 0 7 kg/ha applied to soils
 which have not received sludge
 previously have been shown to triple the
 amount of cadmium in lettuce leaves
 Using the diet scenario analysis it can
 be demonstrated that application rates
 of 0 8 kg/ha can lead to dietary
 increases of 10 3 ug/day from leafy
 vegetables alone Other data indicate
 that this level may be even greater
 where cadmium from landspieadmg in
previous years is already in the soil
Under these circumstances EPA
concluded that an annual limit of 0.5 kg/
 ha is necessary to provide adequate
 protection to the public health.
    EPA recognizes that not all crops will
 present the same risk as accumulator
 crops, particularly in the first few years
 of landspreadmg However, due to the
 factors  discussed above, applications of
 solid waste should eventually be limited
 to Q 5 kg/ha for all food-chain crops.
 Therefore, the Agency has decided to
 distinguish between accumulator and
 non-accumulator crops in the annual
 limits. When wastes  are applied to
 accumulator crops the annual limit will
 be 0 5 kg/hd immediately For all other
 crops a  phased reduction will be
 allowed.
    The criteria limit additions to 2,0 kg/
 ha until June 1984 and 1 25 kg/ha until
 December 1986 This  gives communities
 and industry  the time necessary to
 implement programs, such as cadmium
 source control and pretreatment of
 industrial discharges, to reduce current
 cadmium concentrations in their wastes
 or to develop alternative disposal
 practices. The schedule has been
 slightly  relaxed from  the proposed
 criteria  in order to make it compatible
 with the Agency's pretreatment program
 schedule, The Agency believes that
 allowing higher cadmium application
 rates than 0 5 kg/ha through  1986 will
 have a negligible human health effect
 because the health impacts from
 cadmium are long-term and cumulative
 in nature Based on assumptions similar
 to those used in the "diet scenario"
 analysis [see the discussion of
 cumulative loading limits,), it can be
 shown that during this initial period
 applications of 2 0 kg/ha do not present
 significant health risks
   The proposed regulation also
 distinguished  between accumulator and
 non-accumulator crops, and that
 approach is being maintained in the
 final criteria. However, the proposed
 limit for  accumulator  crops was
 expressed in terms of kludge quality
 (cadmium concentration in the waste
 not to exceed  25 mg/kg dry weight).
 Calculations show that a cadmium
 concentration limit of 25 mg/kg m the
 solid waste wiil not necessarily preclude
 application rates above 0 5 kg/ha, the
 !e\el which EPA believes is more
 directly related to the  human  health risk.
  For example, some solid wastes are
 often  applied to the land as soil
 conditioner or mulch Such a solid waste
 (e g , composted sewage sludge), at  a
 cadmium concentration of 25 mg/kg,
 would contribute cadmium to the soil at
the rate of about 1 5 kg/ha when applied
1 3 cm (0.5 inch) thick to the land
surface. Therefore, EPA decided to
integrate  this standard with the rest of

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H1454   Federal Register / Vol  44, No. 179 /  Thursday.  September  13,  1979 / Rules and Regulations
 tr>e section and express the limit in kg/

   [ej Closely ContiolledFacilities,
 Substantial public comment was
 received on the second major approach
 [•reposed fur  conlrolhng dietary intake
 of cadmii'm via the application of solid
 waste to land This approach  required
 cadmium levels in crops or meats
 produced from solid was!f'-JiTiended
 soils to be comparable to cadm>um
 levels  m similar crops or meats
 produced locally where solid waste had
 not been applied  Several commenters
 stated that this approach would be very
 difficult to  implement because of
 problems in establishing an effective
 system lo monitor and control
 agncultuial products  Moreover, terms
 Sach as ' local market" and "comparable
 levels" are vague dnd, therefore, subject
 to varying interpretations
   Commenters suggested two major
 alternatives to the proposed approach;
 both of these were considered by the
 Agency. The> wern dilution of cadmum-
 conlaining  crops and meats in the
 market place, and establishment by the
 FDA of maximum permissible levels of
 cadmium in food products Dilution m
 the market place was not selected as  a
 contro! option, partly because of the
 difficulty of implementation Mure
 importantly the dilution of a toxic
 contaminant  into  the food chain is an
 unacceptable long-term policy because
 it cnuld, over a number of ycdrs,
 significantly increase the total body
 burden m humans
  The  FDA indicated that the
 alternative approach of establishing a
 tolerance level for cadmium in food
 products is not possible at this  time
 because of insufficient data A
 nationwide survey is being conducted
 currently by the EPA, FDA, and USDA
 on cadmium levels in raw agricultural
 commodities, however, several  years
 will  be required to obtain the
 statistically meaningful data necessary
 to establish tolerance levels in
 agricultural crops
  Based on the public comments
 received, the  proposed criteria have
 been modified to simplify
 implementation yet still provide
 adequate health protection. As
promulgated,  !his  cadmium management
 approach sets forth four requirements
 which  will serve to minimize the
 increase of cadmium in the human food
 chain
  First, only animal feed may  be. grown
 under this option  Research data show
 (hat animals excrete most of the
 ingested cadmium, the small amount
that is  absorbed is .accumulated  m
viscera such as (he kidney and the liver
The likelihood of significantly increasing
individual or general dietary cadmium
levels through animal feeds is negligible.
Several commenters suggested that the
Agency consider prohibiting the
marketing of livers and kidneys of such
animals for human consumption There
is some question whether such an
approach is within EPA's authority
under the Act  Moreover, control of
distribution m this manner is
unnec essary because the marketing of
organs from such animals would not
result in a significant increase of
cadmium in an individual's diet
  The second  control to assure proper
management of the facility is the
requirement that the solid waste and
soil mixture have a pH of 6 5 or greater
at the time of solid waste application  or
at the tune the crop is planted,
whichever occurs later The Agency
believes that maintaining the soil pH  at
a near-neutral level is particularly
important under this cadmium
management approach where the
cadmium application rate is
unrestricted
  The third requirement calls for the
development of a facility operating plan.
The purpose of this plan is to
demonstrate how the animal feed will
be distributed and what safeguards are
utilized to prevent  the crop from
becoming  a direct human food source.
EPA is primarily concerned about  crops
such as corn, wheat and soybeans
which may be used for animal feed or
direct human ingestion In addition, the
facility operating plan should describe
the measures that have been taken to
safeguard against possible health
ha?ards resulting from  alternative future
uses of the land Some  future land uses,
such as the establishment of vegetable
farms or home vegetable gardens,  could
result in significant dietary increases  of
cadmium.  Such provisions in the facility
operating plan could cover a range of
options, such as dedication of the
facility as a public  park, placement of
fresh top soil over  the site, or removal of
the contaminated soil
  The fourth requirement is a stipulation
in the land record or property deed
which states that the property has
received solid waste at high cadmium
application rates dnd that foodcham
crops should not be grown, due to  a
possible health hazard.
  (2) Poly-chlorinated Bipheny Is
(PCB's) The proposed criteria required
that solid waste containing pesticides
and persistent organics, when applied to
land used for the production of food-
chain crops, not result in levels of these
substances in excess of the tolerances
set pursuant to the  authorities of the
Federal  Food, Drug and Cosmetic Act.
The proposed criteria also required that
solid waste of concern due to its toxic
organic chemical or heavy metal content
(e g , PCBs and lead) not be applied lo a
site so that the freshly applied solid
waste may be directly ingested by
animals raised for milk or by human1*
  At this time, EPA has decided not to
establish tolerances for pesticides arid
persistant organics in solid waste  They
were not developed because there were
no adequate dala on the amounts of
these substances in solid waste to
demonstrate a public health risk An
ongoing study is expected to obtain
information on the amount of pesticides
and persistent organics in sewage
sludge to help develop a standard
relating to this subject  After reviewng
existing FDA tolerance limits for such
substances, EPA has determined that
they are impractical as a basis for
standards for solid waste application to
food-chain lands, because those
tolerance limits are based on food
contamination from pesticide
application At this time there is almost
no information available indicating the
relationship between the level of such
substances in solid waste and the
resulting food contamination Direct
application of the FDA tolerance limits
would require  extensive chemical
analysis for a very large number of
pesticides and toxic organic substances
that might be present in the solid waste
m trace amounts Other data sources
also did not provide an adequate basis
for setting standards The Agency will
continue to evaluate data on this subject
and explore this problem with the FDA
and other interested parties  It is
possible that standards on this subject
could be part of pending sewage sludge
disposal guidelines under Section 405 of
the Clean Water Act, as well as future
amendments to the criteria
  While EPA is concerned about the
health problem posed by ingestion of
lead, the Agency is not aware of any
evidence that increased lead ingestion
by dairy animals results in elevated lead
levels in milk Consequently, the Agency
is not able to promulgate a standard for
lead based on  ingestion of solid waste
by dairy animals, as was suggested by
some commenters. While direct
ingestion of lead by children, which may
occur when they play in areas where
sludge has been applied, may also be a
concern, there is limited data available
to establish a standard for this situa'ion.
The Agency intends to explore this
potential problem further in the pending
sewage  sludge disposal guidelines under
Section  405 of the Clean Water Act.
  In establishing the standard forPC'B's,
the Agency looked to tolerance levels
established by the FDA to define the
health risk  The FDA has established
maximum tolerance levels of 0,2 mg/kg
(actual weight) for animal feeds and 1 5
mg/kg (fat basis) for milk. The standard

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          Federal Register  /  Vol.  44.  No. 179  / Thursday. September 13,  1979  /  Rules and Regulations   53455
 promulgated in the criteria is designed
 to prevent PCB levels from exceeding
 these levels due to application of solid
 waste to fields growing animal feed
 When solid wastes are applied to the
 land surface SO as to allow direct
 contact between the  solid waste and the
 crop, the animal feed can become
 contaminated By incorporation of the
 solid waste beneath  the soil surface
 (generally below the root zone of
 pasture grasses), the amount of ingested
 PCB's is greatly reduced Therefore, EPA
 has concluded that the proper regulatory
 strategy is to require incorporation  of
 the solid waste into the soil when the
 PCB level in the waste material is so
 high that direct contact between the
 crop and the soil could cause the FDA
 tolerances to be violated
   Based on  assumptions recommended
 by FDA, EPA calculated the
 concentration level of PCB's in solid
 waste which might cause the FDA
 tolerances to be violated These
 calculations established the PCB
 concentration threshold at 10 mg/kg
 Generally, then, any  sludge which
 exceeds that level of PCB's must be
 incorporated into the soil when applied
 to land used for the production of food-
 chain crops
   There is.  however,  one exception to
 that requirement Wastes which exceed
 10 mg/kg of PCB's may be applied to
 fields without incorporation if testing of
 the animal feed grown on the field
 demonstrates that the FDA standards
 will not be violated If such testing
 indicates that the FDA standards have
 been violated, then the solid waste
 disposal activities leading to the
 contamination have violated the criteria.
   It should be noted that the calculation
 of the 10 mg/kg level  for PCB levels m
 the waste is based on the assumption
 that the only way PCB's enter a grazing
 animal is through the  adherence of
 waste material to the  vegetation eaten
 EPA recognizes that a certain amount of
 PCB's may enter the animal due to direct
 mgestion of soil. At this time, however,
 EPA does not have sufficient data to
 know how that factor should be used in
 the analysis  Moreover, the
 recommendations from FDA did not
 take that factor into consideration
   As discussed earlier this portion of
 the regulation is being issued as "interim
 final", which means that further public
 comment is solicited  EPA encourages
 the public to provide suggestions and
 data that would help the Agency to
 account for the direct  mgestion of soil in
 setting a PCB standard
I. Disease (Section 257.3-6)
  Solid wastes can contain pathogenic
bacteria, viruses and parasites which
 can infect both humans and animals.
 Wastes can provide food and harborage
 for rodents and flies which are capable
 of transmitting these disease organisms
 to humans and animals  Other routes of
 disease transmission to humans and
 animals include direct contact with
 \vastes during landspreadmg operations,
 contact with soil or plants which have
 been contaminated with wastes,  or
 mgps-tion of food and water
 contaminated with wastes
   The  proposed criteria required
 protection of public health by control of
 disease vectors This requirement was
 to be met through minimizing the
 availability  of food and harborage for
 disease vectors or through other
 techniques where appropriate. In
 another section, the proposed criteria
 required stabilization bf solid waste of
 concern due to its pathogen content
 when applied directly to the surface of
 land used for the production of food-
 chain crops  In addition, a one-year
 waiting period was prescribed before
 growing human food crops which are
 normally eaten raw In yet another
 Section, the proposed criteria required
 controlled acce&s to solid waste
 disposal facilities so as to minimize
 exposure of  the public to exposed waste
   The  final disease criterion combines
 provisions concerning vectors and
 pathogens The provision concerning
 vectors calls for the minimization of on-
 site populations of disease vectors
 Periodic application of cover material
 (usually at the end of each operating
 day} or other appropriate techniques
 should satisfy the performance
 standard
   Sewage sludge and septic tank
 pumpings are the solid wastes which are
 generally applied to the surface of the
 land and are of concern due to their
 pathogen content  To  protect public
 health, the criteria provide for control of
 pathogens in disposal of these wastes
 by one  of several operational
 approaches as described below,
   Sewage sludge applied to the land
 surface or incorporated into the soil
 must be treated by a Process to
 Significantly  Reduce Pathogens Aerobic
 digestion, air drying, anaerobic
 digestion, composting, lime stabilization,
 or other similar techniques will satisfy
 this requirement In addition, public
 access to the site must be controlled for
 at least 12 months, and grazing by
 animals whose products are consumed
 by humans must be prevented for at
 least one month.
  Septic tank pumpings must be treated
 by one of the  Processes to Significantly
Reduce  Pathogens, unless public access
to the facility is controlled for at least 12
months  and grazing by animals whose
 products are consumed by huniiins is
 prevented for at least one month
 Neither set of provisions for sewage
 sludge or septic tank pumpings apply
 where these wastes are disposed of by a
 trenching or burial oppration
   Further public health protection is
 required when sewage sludge or septic
 tank pumpings are applied to  land
 where crops for direct human
 consumption are grown less than 18
 months after waste application  In these
 instances, the waste material  must be
 treated, prior to application, by a
 Process to Further Reduce Pathogens
 Beta ray irradiation, gamma ray
 irradiation, pasteurization or other
 equivalent methods will satisfy this
 requirement if performed after a Process
 to Significantly Reduce Pathogens High-
 temperature composting heat drying,
 heat treatment and thcrmopVnlic aerobic
 digestion will satisfy this requirement
 without prior treatment A Process to
 Further Reduce Pathogens is not
 required if there is no contact between
 the solid waste and the edible portion of
 the crop, as long as the solid waste is
 treated by a Process to Signficantly
 Reduce Pathogens prior to application
 In addition, public access to the facility
 must be controlled for at least 12 months
 after solid waste application, and
 grazing of animals whose products are
 consumed by humans must be prevented
 for at least one month
   Like the portion of the cutena
 c um,erning application of solid waste to
 food-chain crops [§ 257 3-4), the sewage
 sludge and septic  tank pumpings
 provisions of the disease section are
 being issued as an "interim final"
 regulation While there was extensive
 public review and comment on the
 proposed regulation, the public has not
 had a full opportunity to examine and
 analyze the new data and technical
 support for this section At the same
 time EPA believes that it must
 promulgate this portion of the regulation
 m order to satisfy  the spirit of  the court
 order mandating issuance of the criteria.
 EPA will fully review all comments and
 make changes in the regulation if surh
 modifications are warranted by tlu-
 data
  (1J Disease Vectors Some
 commentera sought a more specific
 statement of the performance objective
 of this provision  EPA explored the
 possibility of developing a numerical
 peiformance objective, but determined
 that such a standard would not be
 meaningful While  the risk from disease
vectors is very real, the risk cannot be
translated into a measure of "rats per
square meter" or "flies per cubic foot of
air space " Moreover, such performance

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53456   Federal  Register / Vol.  44, No  179  /  Thursday, September 13,  1979  /  Rules  and Regulations
standards could not be measured wilh
any accuracy Therefore, EPA made the
standard more specific by requiring
minimization of on-site populations of
disease vectors This statement of the
standard leaves no question that the
facility must not be a breeding ground,
habitat or feeding area for vector
populations At the same time, it
provides some flexibility in the
implementation of the standard.
  Several commenters indicated that,
since there are  a number of techniques
to protect public health from disease
vectors, the phrase "minimizing the
availability of food and harborage  for
vectors through periodic application of
cover material" should be deleted  EPA
agrees and has  done so.
  At most facilities which dispose  of
putrescible wastes, the most effective
means to control rodents is the
application of COVET material at the end
of each operating day Other means
include composting or processing the
waste, so as to  render it unattrartive to
rodents, or using rodenticides  At some
facilities, disease vectors such as flies
rray be more difficult lo control than
rodents, but certain practices,  such as
the periodic application of cover
material, can help alleviate the
problems Mosquitoes can be controlled
by eliminating stagnant water for
breeding, by predatory or reproductive
control and, if necessary, by sprjying
with insecticides or repellants.
  Cover material  also serves other
purposes {a] It  helps contain odor, litter,
and air emissions, thereby improving the
facility's aesthetic quality, (b)  it reduces
the potential for fires, (c) it reduces
rainwater infiltration, thereby
decreasing leachate generation and
surface and ground-water
contamination,  and (d) it improves the
facility's appearance and enhances
utilisation after completion.
  Since periodic application of cover
material is an effective, widely used and
generally preferred means of controlling
vectors, EPA believes that it is
appropriate to specify it in the criteria It
is impractical, however, to cover some
wastes Moreover, cover material is not
generally necessary for wastes which
are non-puirescible, relatively stable or
inert The criteria allow for other
techniques to be employed in these
situations
  EPA has not included the phrase
"minimizing the availability of food and
harborage ' m the final standard. That
language would not cover such control
measures as repellants, insecticides and
rodenticides, which could be effective in
meeting the objective of this section
  Commenters  also requested  a
definition of the term "disease vector "
Disease vectors are rodents, flies and
mosquitoes, since these are the known
organisms common at disposal facilities
that are capable of transmitting disease
  (2) Sewage Sludge and Septic Tank
Punipings In establishing regulations to
protect public health from pathogen-
induced disease, it must be recognized
that there is a distinction between being
exposed to disease-producung
organisms and actually acquiring a
disease Healthy humans and animals
can tolerate small numbers of
pathogenic organisms without acquiring
a disease  D'sease normally occurs
when the body's immune system is
impaired, or the dose of pathogens is so
great that it overwhelms the body's
defense mechanism In setting these
cuteria, the goal is to prevent human
exposure to large numbers of pathogenic
organisms due lo .solid waste disposal
activities
  Commenters requested specification
of which solid wastes are of concern
due to their pathogen content The
criteria  have been, modified to specify
sewage sludge and septic tank pumpings
as the wastes which are generally
applied to the surface of the land and
are of concern due to their pathogen
content Although little information is
available on septic tank pumpings, the
relatively long residence time of the bulk
of the waste material  in a septic tank
should reduce the density of pathogenic
organisms  Therefore, the Agency has
tentatively concluded that septic tank
pumpings have  the same general
characteristics with regard to land
application as partially treated
municipal sewage sludge The public is
invited to submit pertinent data on this
subject, the Agency will review any new
information and reassess these
regulations accordingly.
  Sewage sludge and septic tank
pumpings contain various types of
pathogenic bacteria, viruses and
parasites  While bacteria are greatly-
reduced by sunlight and drying, viruses
may persist in soils and on vegetation
for  several weeks or months Parasitic
ova and cysts are quite resistant to
disinfectants and adverse
environmental conditions Many, in fact,
require a period of free-living existence
in the soil before becoming infectious to
man  Therefore, a major reason for
requiring the control of pathogens is the
potential for human mgestion of soil or
plants contaminated with such was'es
containing ova or cysts
  Same commenters suggested fhat the
criteria require a  "pathogen-free"
sewage  sludge  EPA does not believe
that such regulation is necessary to
avoid a  reasonable probability of
adverse effects  on the population that
may come in contact with sludge-
amended fields. A greater degree of
protection is needed for certain solid
waste disposal practices {i e" ,
application to  land where food-chan
crops are grown), and this section
provides for such protection.
  The proposed regulation relied on
stabilization as the principal treatment
technique to reduce the risk of pathogen-
induced disease However,  because the
term "stabilization" conventionally
related to odor control and  to a lessor
degree pathogen reduction, this term is
no longer  used in the criteria  The
criteria have been revised to require
that sewage sludge and, under certain
conditions, septic tank pumpings be
treated by a Process to Significantly
Reduce Pathogens These processes
include aerobic digestion, air drying,
anaerobic digestion, composting  (thiee
techniques], lime stabilization or other
equivalent techniques
  EPA recognizes that not all of the;se
processes achieve exactly the same
K vel of pathogen reduction Variations
in weather,  residence times,
temperatures and other factors wiIJ
influence  the effectiveness  of each
process The Agency also recognizes
that different processes may be more or
less effective m destroying  certain types
of pathogens {i e., bacteria, viruses or
parasites) Each process, however, has
been shown to achieve a significant
reduction in pathogen levels  Therefore,
EPA believes  that they are  appropriate
to achieve the objectives of this section
  The proposed regulation  required
controlled access to disposal facilities
so as to minimize exposure of the public
fo hazards posed by exposed waste The
final regulation seeks to minimize
exposure  of the public to pathogens in
the upper layers of waste-amended
soils  Since  pathogens in the surface soil
are generally reduced to insignificant
levels within 12 months of  application,
the criteria require that public access lo
the facility be controlled for that period
of time  "Controlled" does not mean that
all entry on  the site be precluded The
term "controlled," rather than
"prevented," was chosen for regulating
public access, because with proper
precautions there appears to  be no
health hazard. However, there would be
a health hazard if, for example, children
were permitted to pi-ay on the waste
amended soil  Therefore, fencing would
be necessary if these wastes were
applied to areas frequented by the
general public (e g , park lands) but
fencing would not be necessary on farm
land which was not available for use by
the public.
  This section also  includes a limit  on
animal access to the fields  for grazing

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          Federal Register  /  Vol. 44,  No. 179  / Thursday, September 13, 1979  /  Rules  and Regulations   53457
 for one month after sewage sludge is
 applied. This is appropriate for several
 reasons, First, the animal acts as a first
 line of defense against human contact
 with pathogens The products derived
 from the animal (meat or milk) will not
 contain the same level of pathogens as
 might enter the animal due to grazing on
 waste-amended fields. Second, in many
 cases rainfall in the one-month period
 after application will wash the sludge
 off the crop  Third, available evidence
 indicates that where sludge does remain
 on the crop, a one-month period should
 be sufficient for natural weather
 conditions (e g , sunshine, wind) to
 destroy most pathogenic organisms.
    The  access restrictions described
 above are required for all facilities
 receiving sewage sludge, even after the
 waste  has been treated by a Process to
 Significantly Reduce Pathogens. For
 septic  tank pumpings, the access
 restrictions may be used as an
 alternative to such a Prqcess, This is due
 to the fact that containment in a septic
 tank will result m partial pathogen
 reduction in the waste and should
 dimmish its attractant potential to
 disease vectors such as flies and
 mosquitoes  However, septic tank
 pumpings do  not undergo the kind of
 pathogen destruction that can occur
 with anaerobic digestion, because the
 waste is being continually  reinoculated
 with fresh waste material.  Therefore,
 EPA concluded that such wastes should
 be treated with a Process to
 Significantly Reduce Pathogens or be
 subject to the access restrictions.
   As indicated earlier, special treatment
 is necessary for food-chain crop
 cultivation, where the  risk of direct
 human consumption of crops
 contaminated by pathogens is higher. To
 provide protection, the proposed
 regulation relied on a one-year waiting
 period between waste  application  and
 use of that land for  food-chain crops.
 The regulation now calls for the use of a
 Process to Further Reduce Pathogens if
 crops for direct human consumption are
 grown within 18 months of application
 or incorporation of the sewage sludge or
 septic tank pumpings  If no such crops
 are grown within 18 months of
 application, treatment by a Process to
 Further Reduce Pathogens is not
 required.
  The processes chosen should
 essentially destroy all bacteria and
 viruses  and greatly reduce the number
 of parasites in the waste material. Two
 sets of processes are permitted—those
 which are sufficient in themselves and
 those which must follow a Process  to
Significantly Reduce Pathogens in order
to be effective  Processes which are
 adequate in themselves are high-
 temperature composting, heat drying,
 heat treatment and theromophihc
 aerobic digestion. Processes which must
 follow a Process to Significantly Reduce
 Pathogens are beta ray irradiation,
 gamma ray irradiation and
 pasteurization. This sequence'of
 processes is necessary to assure that the
 waste is not an attractant  to vectors.
 Irradiation or pasteurization, while
 effective against pathogens, do not
 provide the volatile solids  reduction
 necessary to prevent a vector problem.
   Based on available data, the Agency
 concluded that a Process to Further
 Reduce Pathogens is not necessary
 when there is an 18-month interval
 between land application  of solid waste
 and the growing of crops for direct
 human consumption. EPA  recognizes
 that there is some uncertainty about the
 life expectancy of pathogens in wastes
 applied to croplands. Bacteria and
 viruses persist for only a few months,
 but parasites, particularly  resistant
 species such as Ascaris lumbncoides,
 may last much longer. Reports range
 from "no survivors" after a few months
 to "some survivors" [not necessarily
 viable) after ten years for such
 organisms.
   Survival is most likely in the soil
 below the top five centimeters of soil.
 Field conditions such as sunlight,
 desiccation, freezing, heat  and freeze-
 thaw cycles are effective at reducing
 survival times in the upper layer of the
 soil EPA selected the 18-month period
 because within that period most of the
 waste-amended soil will be exposed to
 the hostile environment found at the soil
 surface. Agricultural soils are typically
 plowed or cultivated at least annually.
 Thus,  an 18-month waiting  period
 assures that soil which was previously
 below the surface will be exposed to the
 harsh surface conditions for at least six
 months before planting. The growing
 period will provide additional exposure
 of the  pathogens before harvest  EPA
 believes-that this will provide a
 reasonable probability that pathogen
 levels  will be greatly reduced. Since this
 is an "interim final" regulation, EPA
 encourages public comment on the
 appropriateness of this rationale.
   EPA recognizes that for some crops
 (e g , citrus fruits, corn) the  edible
 portions are not exposed to nor are
 likely to come in contact with, the
 sewage sludge or septic tank pumpings.
Therefore, there is no need  to use a
Process to Further Reduce Pathogens
when such a crop is grown,  However, in
this case the waste must be treated by a
Process to Significantly Reduce
Pathogens, public access to  the facility
 must be controlled for at least 12
 months, and the grazing of animals
 prevented for at least one month after
 application of the waste. The Agency
 chose the more conservative approach
 of requiring significant pathogen
 reduction and controlled access for both
 sewage sludge and septic tank pumpings
 because even where direct contact
 appears unlikely, the quality of crops
 which are directly consumed by man
 must be assured.
   In examining the health risk presented
 by pathogens, EPA determined that
 pathogens are not likely to migrate in
 the soil. Pathogens tend to remain
 intimately associated with the waste
 material and are often too large to move
 through soil pore systems Also, soils
 have been reported to be effective in
 removing viruses and bacteria from
 water. Surface erosion with the resultant
 water runoff seems to be the only route
 for movement of pathogens Based on
 these findings, the Agency concluded
 that sewage sludge and septic tank
 pumpings that are placed underground
 by a trenching or burial operation
 should not be subject to this section.
 Under such circumstances there will be
 minimal movement of the organisms
 through the soil, and the risk of erosion
 is slight because the wastes are
 completely Covered
 / Air (Section 257,3-7)
   Open burning is the uncontrolled or
 unconfined combustion of solid wastes
 Open burning is a potential health
 hazard, can cause property damages,
 and can be a threat to public safety.
 Smoke from open burning can reduce
 aircraft and automobile visibility and
 has been linked to automobile accidents
 and death on expressways. The  air
 emissions associated with open burning
 are much higher than those associated
 with incinerators equipped with air
 pollution control devices.
   The proposed criteria provided for
 control of air emissions through three
 stipulations. First, the facility was to
 control air emissions so as to comply
 with Federal, State, and local air
 regulations. Second, all open burning of
 residential, commercial, institutional,
 and industrial solid wastes was
 prohibited Third, open burning of other
 solid wastes could be permitted if in
 compliance with State and local air
 regulations.
   This final air criterion has two
 components. First, there shall be no
 open burning of residential, commercial,
 institutional or industrial solid waste,
 (This provision does not apply to
 infrequent burning of agricultural
wastes, silvicultural wastes, land-
clearing debris, diseased trees, debris

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53458   Federal Register /  Vol  44.  No. 179  / Thursday. September 13. 1979  / Rules  and  Regulations
from emergency clean-up operations and
ordnance ) Second, air emissions caused
by solid waste disposal activities shall
not violate applicable requirements
developed for State implementation
plans (SIP's) under Section 110 of the
Clean Air Act.
   While several commenters suggested
that a ban  on open burning is
unnecessary, EPA has decided to retain
that provision for residential,
commercial, institutional or industrial
waste The ongoing open burning of
these wastes presents significant
hazards to human health, and no health
or environmental benefit is derived from
the practice Several commenters
suggested allowing open burning with a
variance, There is no environmental
rationale for such a variance because
open  burning does not lessen the need
for disease vector control or leachate
control for maintaining surface and
ground-water quality Moreover,
variance procedures for this situation
would be particularly difficult to
administer because of the dynamic
nature of the many variables involved
[existing air quality, wind speed,
humidity, mixing and vertical
dispersion, efficiency of the burn,
amount and type of waste, etc )
   EPA decided to exempt from the open
burning prohibition those wastes which
are typically burned infrequently The
burning of agricultural wastes in the
field,  land-clearing debris, standing
trees  in a forest, diseased trees, debris
from emergency clean-up operations  «md
ordnance is not typically an  ongoing
practice and, thus, does not present a
significant environmental risk  In
addition some of these practices,
particularly the destruction of disease-
carrying trees or debris from emergency
clean-up opeiations, provides an added
environmental benefit in preventing
chances of disease or accident. It should
be noted, however, that the criteria
assure that the  conduct of these
infrequent  acts  of burning must be  in
compliance with applicable
requirements developed under the  Slate
SIP
   In requiring compliance with the SIP,
EPA is seeking  to coordinate the criteria
with the Clean Air Act. as mandated  in
Section 1006 of the Act The  regional
health concerns addressed through the
SIP's are clearly of concern under the
Act as well The prohibition  of open
burning should prevent most air quality
problems  Where such concerns are not
covered by the open burning ban, EPA
believes that it is unacceptable for  solid
wasie disposal activities to cause
violations of SIP requirements
  EPA has eliminated that part of the
proposed regulation that required
compliance with "all applicable Federal,
State and local air regulations" and the
reference to protection of public health
and welfare, Some commenters said that
the proposed criteria "federalized" State
and local air regulations. EPA is not
federalizing any such regulations in the
final criteria In tying the criteria to the
SIP's, EPA is assuring that, at a
minimum, solid waste activities that
undermine Congressionally-estabhshed
Federal environmental air quality
objectives will not be considered
adequate under the Act.
  Several commenters requested
clarification regarding the impact of the
criteria on the use of pit or trench
incinerators Emission factors (i e ,
particuiates) for such incinerators equal
or exceed those for open burning dumps.
Since such devices do not control
emissions, they fit the definition of open
burning Thus, for purposes of the
criteria, combustion in a trench
incinerator constitutes "open dumping "
  Comments were requested in the
Preamble of Ehe proposed regulation on
the advisability of including in the final
promulgation specific air quality limits
which would be based on Occupational
Safety and Health Administration
(OSHA) air quality standards Several
commenters noted that since OSHA air
quality standards are based on
workplace exposure and not ambient air
quality, the inclusion of these standards
would be inappropriate  and possibly
confusing Air quality standards based
on OSHA regulations have  not been
included in the final promulgation
  Commenters also suggested that the
content of the air criteria be moved to
the safety criteria (§ 257 3-8) since many
of the dangers of open burning relate
directly to public safety The Agency
considers the problems of open burning
to be broader than just public safety;
thus, this change was not made
However, the safety criteria have bppn
revised to reference the a;r  criteria

K Safety (Section 257 3-8)
  This portion of the criteria addresses
a set of adverse effects involving
potential accidents which could be
caused by solid wasle disposal
activities The legislative history of (he
Act indicates that in passing the
provisions authorizing these criteria the
Congress was concerned about all of the
effects addressed in this section  The
safety hazards addressed in the final
regulation include explosive gas< s, firos,
bird hazards to  aircraft and public
exposure (o wastes due to uncontioiled
access to disposal sites
  The proposed regulation al^o
contained a piovision for toxic and
asphyxiating gases  While EPA is quite
concerned about the emission of such
gases from solid waste, EPA was unable
to identify sufficient information on the
nature of this problem to support the
setting of particular standards The
existing data on the generation of toxic
and asphyxiating gases in solid waste is
quite limited. In particular, it is difficult
to define a set of gases generated  in
solid waste disposal that present a
public health hazard. Even if such a set
of gases could be identified it is difficult
to determine, on the basis of data
currently available to EPA, what levels
of such gases may be tolerated without
a substantial risk to public health or Ehe
environment EPA will continue to
explore this problem However, at
present there is insufficient information
to support particular limits on toxic and
asphyxiating gases.
  [I) Explosive gases  Solid waste
disposal activities may produce
explosive gases In particular, methane
gas is a product of solid waste
decomposition. The accumulation of a
sufficient concentration of methane gas
in disposal facility structures or nearby
off-site structures may pose a senouf,
threat to the health and  welfare of
facility employees, users of the disposal
site, and occupants of nearby structures
Explosions resulting in injury and dedth
have been caused by gases from solnJ
waste disposal.
  The proposed criteria required thai
the concentration of explosive gases  in
facility structures and in soil at the
facility property boundary not reach  the
lower explosive limits (KEL) for the
gases  The final regulation is essentially
the same except that concentrations  in
facility structures will not be allowed to
exceed 25 percent of the lower explosive
limit for the gas In addition the final
standard, which could potentially be
applicable to several explosive gases,
will only be concerned with methane at
this time.
  Commenfers suggested  (hat the gas
criteria be deleted and that control be
left to the Occupational  Safety and
Health Administration (OSHA)
Following consultation with OSHA, the
Agency rejected this suggestion because
the jurisdiction of OSHA does not
include all solid waste disposal facilities
and practices of concern to the Act, nor
dors it include  off-site rrsiriences to
which gases can migrate.
  The Agency has decided to adjust the
standard for facility structures to
provide a margin  of safety Several
commenters suggested such a change,
since allowing explosive gas to
accumulate in concentrations just uncer
the lower explosive limit would be
extremely dangerous and  would not
pro\ ide for a reasonable probability of

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           Federal Register / Vol.  44, No. 179  /  Thursday, September 13, 1979 / Rules and Regulations   53459
  avoiding adverse effects In selecting the
  25% figure EPA is using a safety factor
  recognized by other Federal agencies as
  being appropriate for similar situations.
   EPA also concluded that such a safety
  factor was unnecessary at  the property
  boundary Gases at or below the LEL at
  the property boundary Will necessarily
  become somewhat diffused before
  passing into a structuie beyond the
  property boundary  Thus, in assuring
  that the LEL is not exceeded at the
  boundary EPA has provided a margin of
  safety against an off-site explosion
   EPA has selected methane as the
  single gas of concern The information
  available to EPA indicates  that build up
  of methane gas has been the principal
  source of explosions associated with
  solid waste disposal  Other gases may
  be added to Ihe list ds new information
  develops
   Commenlers recommended that
  disposal facilities not in close proximity
  to off-site structures be exempted from
  the gas criteria Considering that gas
  production in disposal facilities is a
  long-term process continuing for
  decades, the Agencj rejected this
  recommendation Fdcilities which are
  remote today may be surrounded by
  extensive development in the future,
  especially after completion of disposal
  operations
   (2) Fnes Flies at solid waste disposal
  facilities po,se the threat of  property
  damage and injury or death to facility
  employees, users, and nearby residents
  Examples of circumstances which can
  lead to fires associated with disposal
  facilities or piactices are Vandalism,
  carelessness, spontaneous combustion,
  open burning of wastes, and disposal of
 hot ashes.
   The proposed criteria required that all
 fnes be extinguished expeditiously and
 that fire hazards be  minimized through
 proper site construction and design and
 periodic application of cover material
 where appropriate
   According to the final regulation, the
 facility or practice shall not pose a
 hazard to the safety of persons or
 property from fires This objective can
 be served by compliance with the air
 criterion (§ 257 3-7],  particularly the
 open burning ban. and through periodic
 application of cover material
   Commenters objected to the vague
 nature of this provision as originally
 proposed While some level  of flexibility
 is necessary. EPA has tried to make this
 standard as specific as possible The
 reference to "expeditious" extinguishing
 of fires was eliminated  EPA also
 specified types of operational practices
 to accomplish the goals of this section
  Commenters suggested that, due to the
relationship between open burning and
 potential fire hazards, the prohibition on
 open burning be incorporated into this
 section. As explained previously the
 safety criteria now reference the air
 criterion [which contains the prohibition
 of open burning ]
   (3) Bird Hazards Many reports and
 investigations show that disposal
 facilities and practices involving
 putrcscible wastes often attract birds, in
 spite of vector control efforts
 (compaction and cover of wastes, etc )
 When solid wastes are disposed in  the
 vicinity of airports, the birds attracted to
 the area can present a significant risk of
 accidents due to collisions between
 birds and planes The Federal Aviation
 Administration (FA A) has issued FAA
 Order 5200 5, "FAA Guidance
 Concerning Sanitary Landfills on or
 Near Airports" (October 16. 1974) The
 order states that solid waste disposal
 facilities have been found by studj  and
 observation to be artificial attractants of
 birds and, therefore, "may be
 incompatible with safe flight
 operations" when  located in the vicinity
 of an airport
   The proposed criteria required that
 disposal facilities not be located within
 the two distance limits (10,000 feet for
 turbojets and 5 000 fret for piston-type
 aircraft) specified in FAA  Order 5200 5
 unless thp facility was found to not  pose
 a bird hazard to aircraft For facilities
 beyond  the specified distances, but
 within the conical  surface  described by
 FAA Regulations (FAR), Part 77,
 facilities were to be revipwed on a tase-
 by-cdse basis for a potential bird
 hazard
   The final regulation retains the basic
 approach but clarifies severe! terms,
 including "airport" and "bird hazard "
 The provision for case-by-case analysis
 of facilities within  the conical surface
 has been dropped
   Some commenters questioned whether
 the Act provides authority to control
 solid waste disposal on the basis of  bird
 hazards to aircraft They claimed that
 the FAA has adequate authority to
 prevent bird hazards to aircraft,
 concluding that this section of the
 criteria is not necessary
   The criteria are required to address
 the prevention of adverse effects on
 health and the environment from solid
 waste disposal facilities  The legislative
 history (HR Rep No 94-1491) cites  an
 aircraft crash resulting from birds
 attracted to a disposal facility as one
 example of adverse effects  of open
 dumps There are also many other
 examples of such hazards from disposal
 facilities Therefore, the Agency has
concluded that this  issue  is clearly
within the scope of  this regulation
   Although the FAA is authorized to
 control airport operations to reduce bird
 hazards to aircraft, its authority does
 not extend to disposal facilities outside
 airport boundaries which may pose such
 hazards It should be noted, however,
 that EPA is not "enforcing" the FAA
 order  The selection of the distances
 specified in that order is merely a
 recognition that they represent a
 reasonable determination of the danger
 zone around an airport  Likewise, it
 should be made clear that neither this
 regulation nor the proposed standard
 prohibited the disposal  of solid waste
 within the specified distances Instead,
 the distances define a "danger zone"
 within which particular care must be
 taken to assure that no bird hazard
 arises
   Some commenters challenged the
 relevancy of the 10 000 foot (for
 turbqjets) and 5,000 foot (for piston-type
 aircraft) distances for defining the
 danger zone for bird/aircraft  collisions.
 'I he distances cited were denv ed  from
 FAA Order 5200 5 The distances are
 based  on the consideration that over 62
 percent of all bird strikes occur below
 altitudes of 500 feet (150 meters), and
 that aircraft are generally below this
 altitude within the distances specified
   Some commenters emphasized that
 bird strikes do occur outside the
 distances established in the regulation
 Consultation with FAA personnel and
 other experts in the field of bird/aircraft
 h.iziirds bag revealed  that, even when
 d sf.'ridl facilities are located beyond
 ir,t' disMnces specified, hazards can
 ex-st where an airport is situated
 hh'twpen a disposal facility and bird
 feeding roosting, or watering  sites The
 hazard arisrs as birds traverse the
 airport in flying between the disposal
 facility and watering, feeding  or roosting
 areas However,  EPA does not have
 sufficient information  to indicate how
 serious this problem is Moreover, the
 available data is insufficient to support
 the setting of national regulations to
 cover such contingencies At some point
 it becomes difficult to  isolate the
 independent effect of solid waste
 disposal activities on the bird  hazard
 problem.
   EPA has also decided to give a clearer
 definition of some key terms The
 definition of "Airport" includes those
 airfields currently defined by the FAA
 as public-use airports  The regulation
 applies to that set of airports because
 existing data indicates that the
 preponderance of bird strikes occur at
 public-use airports For example, 120 of
 the 121  airports reporting strikes in 1977
were public-use airports, and 220 of the
223 airports reporting strikes in 1978

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53460   Federal Register /  Vol  44,  No. 179 / Thursday. September 13, 1979 / Rules and Regulations
were public-use airports  The FAA
agrees with this approach EPA, in
consultation with the FAA. may
broaden the class of airports of concern
if it receives information  demonstrating
that a similar bird hazard exists at other
fields.
  In defining the airports of concern
EPA has also eliminated  the proposed
criteria's reference to "runways planned
to be used." As several commenters
pointed out, such a reference would not
be workable because it would require
speculation about future  siting of
airports
  EPA also makes it clear that the "bird
hazard" of concern is "an increase in the
likelihood of bird/aircraft collisions."
Solid waste disposal within the danger
zone may continue as long as it can be
shown that the operation can be
managed in such a way as to not
increase the risk of collision within the
specified distances
  After considering public comments,
EPA has deleted portions of the
proposed standard  Several commenters
stated that the use of the conical surface
in the criteria was ambiguous and not
applicable to this standard The conical
surface is an imaginary plane
delineating an airspace segment 150 feet
above the established airport elevation.
The FAA prohibits stationary objects in
this space because they might interfere
with approaching and departing aircraft.
This is inapplicable to solid waste
disposal activities for two reasons. (1)
Birds, the "obstructions"  of concern in
this regulation, are hardly stationary,
and [2] solid waste disposal activities
are typically low-profile  operations
(below 150 feet) and are  not likely to
constitute obstructions into the conical
surfdce
  Commenters asked who was
responsible for determining whether a
facility posed a bird hazard to aircraft.
The Acf and (he CWA create (he
implementing mechanisms for these
criteria. However, in this  instance
consultation with the FAA and the Fish
and Wildlife Service would be very
helpful Furthermore, actions at both the
airport and the disposal facility can
reduce or eliminate hazards Therefore,
where appropriate this determination
should be made in consultation with
these agencies, as well as with the
owners and operators of the airport of
concern
  (4} Access, Materials and activities
associated with solid waste disposal
facilities can cause injury or death to
persons at the facilities Potential causes
of such harm include
  (a) Operation of heavy equipment and
haul vehicles,
  (b) Hazards associated with the types
of waste, including sharp objects,
pathogens, and toxic, explosive, or
flammable materials, and
  (c) Accidental or intentional fires
  The proposed criteria required that
entry to the facility be controlled in
order to minimize exposure of the public
to hazards of heavy equipment
operation and exposed waste.
  The final criteria call for control of
access to protect the public from on-site
exposure to health and safety hazards.
  The importance of access control
cannot be overstated, since persons
have suffered injury and even death at
uncontrolled waste disposal facilities.
Furthermore, in most cases, there is little
economic impact on solid waste
disposal operations in accomplishing
such control.
  During normal operating hours, proper
management controls can minimize
safety hazards. For example, potential
harm to facility operating personnel can
be reduced through proper training, use
of safety equipment, control of waste
types, and other practices. The most
effective means of minimizing the risk of
injury to other persons is by complete
prohibition of access to the site by non-
users (e g, by suitable fencing) and strict
control of users while on the site. For
individuals disposing of small amounts
of wastes,  storage or special disposal
facilities can be provided at the
entrance to the facility or away from the
area being utilized by professional solid
waste management personnel.
  The principal change from the
proposed regulation is the broadening of
the regulation's coverage Accidents at
solid waste disposal sites are not limited
to hazards caused by heavy equipment
operation and exposed waste  EPA
believes that particular types of hazards
should not be specified in the regulation,
thereby allowing for flexibility in how
the standard is applied.  Therefore, the
criteria seek to avoid public exposure  to
all potential health and safety hazards
at solid waste disposal sites
  Two commenters stated that the
proposed requirement for fencing  was
unreasonable  It should be noted that
the Agency did not propose a
requirement for fencing  At many
facilities natural barriers exist which
make public access very difficult,
however, even if the criteria were
complied with through the installation of
a fence around the entire property the
cost would be relatively insignificant
when compared to the other costs
required to properly operate a disposal
facility.
V, Environmental and Economic Impacts
  Voluntary environmental and
economic impact analyses onthis
regulation have been performed and are
presented in the "Final Environmental
Impact Statement on the Criteria foi
Classification of Solid Waste Disposal
Facilities". These analyses are not
required by the National Environmental
Policy Act but provide information
pertinent to the development and use of
this regulation Copies of this two-
volume report may be obtained on
request from. Solid Waste Information,
U S EPA, 26 West St  Clair, Cincinnati,
Ohio  45268.
  EPA has also prepared a number of
background documents that respond to
public comments not addressed in the
Preamble These documents may be
examined at E.P A , 401 M Street, S.W ,
Washington,  D C. 20460 in room 263.2. If
there  are apparent inconsistencies
between these documents and this
Preamble, the latter shall represent the
Agency's position.
  Dated September 10. 1979
Douglas M Costle,
Administrator

  Title 40 CFR is amended by adding a
new Part 257 to read as follows:

PART 257—CRITERIA FOR
CLASSIFICATION OF SOLID WASTE
DISPOSAL FACILITIES AND
PRACTICES
257 1  Scope and purpose
257 2  Definitions.
257 3  Criteria for classification of solid
    waste disposal facilities and practices.
2573-1  Floodplains.
257 3-2  Endangered species.
257 3-3  Surface water
257 3-4  Ground water
257 3-5  Application to land used for the
    production of food-chain crops (Interim
    final)
257 3-6  Disease
257 3-7  Air
257 3-fl  Safety.
257 4  Effective date.
  Authority: Sec. 1008[a}(3), and sec 4004[a),
Pub L. 94-580, 90 Stat 2803 and 2815 (42
LISC 6907(a)(3). 6944}, sec 405(d). Pub L.
95-217, 91 Stat 1591, 1606 [33 U S C 1345].

§ 257.1  Scope and purpose.
  (a) These criteria are for use under the
Resource Conservation and Recovery
Act (the Act) in determining which solid
waste disposal facilities and practices
pose a reasonable probability of adverse
effects on health or the environment.
  (1) Facilities failing to satisfy these
criteria will be considered open dumps
for purposes of State solid waste
management planning under the Act.

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           Federal Register / Vol 44, No. 179  /  Thursday. September 13. 1979  / Rules  and  Regulations   53461
    (2) Practices failing to satisfy these
  criteria constitute open dumping, which
  is prohibited under Section 4005 of (he
  Act
    (b) These criteria al&o provide
  guidelines for sludge utilization and
  disposal under Section 405(d) of the
  Clean Water Act, as amended To
  comply with Section 405(e) the owner or
  opeiator of any publicly owned
  treatment works  must not violate these
  criteria in the disposal of sludge on the
  land
    (c,) These  criteria apply to all solid
  waste disposal facilities and practices
  with the following exceptions'
    (1} The criteria do not apply to
  agricultural wastes, including manures
  and crop residues, returned to the soil as
  fertilizers or soil  conditioners
    (2) The criteria do not apply to
  overburden resulting from mining
  operations intended for return to the
  mine site
    (3) The criteria do not apply to the
  land application of domestic sewage or
  treated  domestic  sewage The criteria  do
  apply to disposal of sludges generated
  by treatment of domestic sewage
    (4) The criteria do not apply to the
  location and operation of septic tanks
  The criteria  do, howevei. apply to the
  disposal of septic tank pumpings
    [5] The criteria  do not apply to solid
  or dissolved materials in irrigation
  return flows
    (6) The criteria  do not apply to
  industrial discharges which are point
  sources subject to permits under Section
  402 of the Clean Water Act, as
  amended
   (7) The criteria  do not apply to source,
  special nuclear or byproduct material as
 defined  by the Atomic Energy Act, as
 amended [68 Stdt 923)
   (0) The criteria  do not apply to
 hazardous waste  disposal facilities
 which are subject to regulation under
 Subtitle  C of the Act,
   (y) The criteria  do not apply to
 disposal of solid waste by underground
 well injection subject to the regulations
 (40 CFR  Part 146)  for the Underground
 Injection Control Program (UICP) under
 the Safe Drinking  Wa'rr Art  as
 amended. 42 U S C 3007 et seq

 § 257 2  Definitions
  The definitions set forth in  Section
 1004 of the Act apply to this Part,
 Special definitions of general concern to
 this Part are provided below, and
 definitions especially pertinent to
 particular sections of this Part are
 provided in those sections
  "Disposal" means the discharge.
deposit, injection, dumping, spilling,
leaking, or placing of any soiicl was'e or
hazardous waste into or on any land or
 water so that such solid waste or
 hazardous waste or any constituent
 thereof may enter the environment or be
 emitted into the air or discharged into
 any waters, including ground waters,
   "Facility" means any land and
 acpurtenances theieto used for the
 disposal of solid wastes.
   '  Leachate" means liquid that has
 passed through or emerged from solid
 waste  and contains soluble, suspended
 or miscible materials removed from such
 wastes
   '  Open dump" means a facility for the
 disposal of solid waste which does not
 comply with this part
   "Practice" means the act of disposal
 of solid waste
   "Sanitary landfill" means a facility for
 the disposal of solid waste which
 complies with this part.
   "Sludge" means any solid, semisolid,
 or liquid waste generated from a
 municipal, commercial, or industrial
 \\astewater treatment plant, water
 supply treatment plant, or air pollution
 control facility or any other such waste
 having similar characteristics and effect
   "Solid waste" means 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 sohd or
 dissolved materials in irrigation return
 flows or mdustiial 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
 byproduct material as defined by trip
 Atomic Energy Act of 1954, as amended
 [68 Stat 923)
   "State" means any of the several
 States,  the District of Columbia, the
 Commonwealth of Puerto Rico, the
 Virgin Islands,  Guam, American Samoa,
 and the Commonwealth of the Northern
 Mariana Islands

 § 257 3  Criteria for classification of solid
 waste disposal facilities and practices.
   Solid waste disposal facilities or
 practices which violate any of the
 following mtena pose a reasonable
 probability of adverse effects on health
 or the environment

 §257.3-1  Floodplains.
  (a) Facilities or practices in
fluodpldins shall not restrict the flow of
the base flood, reduce the temporary
water storage capacity of the floodplain,
or result in washout of solid waste, so as
 to pose a hazard to human life, wildlife.
 or land or water resources.
    (b} As used in this section
    (1) "Based flood" means a flood that
 h;is a 1 perctnt or greater chance of
 recurring in any year or a flood of a
 magnitude equalled or exceeded once in
 100 years on the average over a
 S'gnificantly long period
    (2) "Floodplain"  means the lowland
 and  relatively flat areas adjoining inland
 and  coastal waters, including flood-
 prone areas of offshore  islands, which
 are inundated by the base flood.
    (3) "Washout" means the carrying
 away of solid waste by wateis of the
 base flood.

 § 257.3-2  Endangered species.
    (a) Facilities or practices shall not
 cause or contribute to the taking of any
 endangered or threatened species of
 plants, fish,  or wildlife
    (b) The facility or practice shall not
 result in the destruction or adverse
 modification of the critical habitat of
 endangered or threatened species as
 identified in 50 CFR Part 17
    (c) As used in this section
    (1) "Endangered or threatened
 species" means any species listed as
 such pursuant to Section 4 of the
 Endangered Species Act
   (2) "Destruction or adverse
 modification" means a direct or indirect
 alteration of critical habitat which
 appreciably diminishes the  likelihood of
 the survival  and recovery of threatened
 or endangered species using that
 habitat.
   (3) "Taking" moans harassing,
 harming, pursuing,  hunting,  wounding,
 killing, trapping, capturing, or collecting
 or attempting to engage in such conduct

 §257.3-3  Surface Water.
   [a) A facility or practice shall not
 cause a discharge of pollutants into
 waters of the United States  that is in
 violation of the requirements of the
 National Pollutant Discharge
 Elimination System (NPDES) under
 Section 402 of the Clean  Water Act. as
 amended.
   [b) A facility or practice shall not
 cause a discharge of dredged material or
 fill material to waters of the United
 States that is in violation of the
 requirements under Section 404 of the
 Clean Water Act, as amended
   (c)  A facility or practice shall not
 cause non-point source pollution of
 wafers of the United Stales that violates
 applicable legal requirements
 implementing an areawide or Statewide
 water quality management plan that has
 been  approved by the Administrator
under Section 208 of the  Clean Water
Act. as  amended

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5^462   Federal Register / Vol  44, No  179  /  Thursday. September 13,  1979 / Rules and Regulations
  (d) Definitions of the terms "Discharge
of dredged material", "Point source",
"Pollutant",  "Waters of the United
Slates", and "Wetlands" can be found in
the Clean Water Act, as amended 33
USC  1251 et seq , and implementing
regulations,  specifically 33 CFR Part 323
(42 FR 37122  July 19, 1977)

§ 257 3-4  Ground Water
  (a) A facility or practice shall not
contaminate an underground drinking
water source beyond the solid  waste
boundary or beyond an alternative
boundary specified in accordance with
paragraph (b) of this section
  (b) Only a State with a solid waste
management plan approved by the
Administrator pursuant to Section 4007
of the Act may establ-sh an alternative
boundary to be used in lieu of the solid
waste boundary A State may specifv
such a boundary only if it finds that
such a change would not result in
contamination of ground water which
may be needed or used for human
consumption This finding shall be
based on analysis and consideration of
ail of the following factors.
  (1) The hydrogeological
characteristics of the facility and
surrounding land,
  (2) The volume and physical and
chemical characteristics of the Seachate;
  (3) The quantity, quality, and
directions of flow of ground water,
  [4] The proximity and withdrawal
rates of ground-water users,
  (5) The availability of alternative
drinking  water supplies,
  (6) The existing quality of the ground
water including other sources of
contamination and their cumulative
impacts on the ground water, and
  (7) Public health, safety, and welfare
effects
  (c) As used in this section
  (1) "Aquifer"  means a geologic
formation, group of formations, or
portion of a formation capable of
jielding usable quantities of ground
•water to  wells or springs
  (2) "Contaminate' means introduce a
substance that would cause.
  (i) The concentration of that
substance in the ground water  to exceed
the maximum contaminant level
specified in Appendix I, or
  (n) An increase in the concentration of
that substance in the ground water
where the existing concentration of that
substance exceeds the maximum
contaminant level specified in Appendix
I.
  (3) "Ground water" means water
below the land surface in  the ?jne 01
saturation.
  (4) 'Underground drinking water
source" means
  (i) An aquifer supplying drinking
v ater for human consumption, or
  [n] An aquifer in which the ground
water contains less than 10,000 mg/l
tctal dissolved solids
  (5) "Solid waste boundary" means the
outermost perimeter of the solid waste
(protected in the horizontal plane) as it
vi ould exist at completion of the
Disposal activity

§ 257 3-5  Application to land used for the
production of food-chain crops (interim
final).
  (a) Cadmium A facility or practice
concerning application of solid waste to
within one meter (three feet) of the
surface  of land used for the production
of food-chain crops shall not exist or
occur, unless  in compliance with all
requirements of paragraph (a)(l) (i)
through (111) of this section or all
requirements of paragraph (a)(2) (i)
through (n) of th>s section
  (l)(i) The pH of the solid waste and
soil mixture is 6 5 or greater at the time
of each  solid waste application, except
for solid waste containing  cadmium at
concentrations of 2 mg/kg  (dry weight)
or less
  (n) The annual application of
cadmium from solid waste does no!
exceed 0 5 kilograms per hectare (kg/ha)
on land used for production of tobacco,
leafy vegetables or root crops grown for
human consumption  For other food-
chain crops, the annual cadmium
application rate does not exceed,

                             application rate
                                (kg/ha)
  (in) The cumulative application of
cadmium from solid waste does not
exceed the levels in either paragraph
(riJfl)fniJ(AJ of this section or paragraph
(a)(ljjni](B) of this section
  (A)
  (B) For soils with a background pH of
less than G.5. the cumulative cadmium
dpphcaticn rate dous not exceed the
levels below Provided, That the pH of
the solid waste and soil mixture is
adjusted to and maintained at 6 5 or
g'eater whenever food-chain crops are
grown
                         applicaton (kg/ha)
  (2)(i) The only food-chain crop
produced is animal feed
  (n) The pH of the solid waste and soil
mixture is 6 5 or greater at the time of
suhd waste application or at the time
the crop is planted, whichever occurs
11'er, and this pH level is maintained
v, hene\ cr food-chain crops are grown.
  (in) There is a facility operating plin
which demonstrates how the animal
feed will be distributed to preclude
mgestion by humans The facility
operating plan describes the measures
t,) be taken to safeguard against
possible health hazards from cadmium
entering the food rhain, which may
result from alternative land uses
  (ivj Future  property owners are
notified by a  stipulation in the land
record or property deed which states
that She property has received solid
waste at high cadmium application rates
and that food-chain crops should not be
grown, due to a possible health hazard
  (b) Po/j. chlorinated BiphenyIs (PCBs)
Solid waste containing concentrations of
PCBs equal to or greater than 10 mg/kg
(dry weight) is mcorpoidted into the soil
when applied to land used for producing
jimrral feed,  including pasture crops for
animals laised for milk  Incorporation  of
the solid waste into the soil is not
required if it  is assured that the PCD
content is less than 0 2 mg/kg (actual
weight) m animal feed nr less than 1 5
™gAg (fdt basis) in milk
  (r) As used in this section
  (1) "Animal feed" means any crop
grown for consumption by animals, such
as pasture crops, forage, and grain
  (2) "Background soil pH ' means the
pH of the soiJ prior to  the addition of
substances that alter the hydrogen ion
concentration
  (3) "Cation exchange capacity"  means
the sum of exchangeable cations a soil
can absorb expressed in milh-
equivalents per 100 grains of soil as
determined by sampling the soil to the
depth of cultivation or solid waste
placement, whichever is greater, and
analyzing by  the summation method Jor
distinctly acid soils or the sodium
acetate  method for neutral  calcareous
or saline soils ("Methods of Soil
Analysis, Agronomy Monograph No '3 "
C A Black, ed, American Society of
Agronomy, Madison, Wisconsin pp 891-
901, 1965)
  (4) "Food-chain crops" means
tobacco, crops grown for human

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           Federal Register / Vol. 44, No  179 / Thursday.  September  13, 1979 / Rules and Regulations   53463
  consumption, and animal feed for
  animals whose products are consumed
  by humans
    (5) "Incorporated into the soil" means
  the injection of solid waste beneath the
  surface of the soil or the mixing of solid
  waste with the surface soil.
    (6) "Pasture crops" means crops such
  as legumes, grasses, grain stubble and
  stover which are consumed by animals
  while grazing
    (7) "pH" means the logarithm of the
  reciprocal of hydrogen ion
  concentration.
    (8) "Root crops" means plants whose
  edible parts are grown below the
  surface of the soil
    [9] "Soil pH" is the value obtained by
  sampling  the soil to the depth of
  cultivation or solid waste placement,
  whichever is greater, and analyzing by
  the electrometric method ("Methods of
  Soil Analysis, Agronomy Monograph
  No 9,"CA Black, ed., American
  Society of Agronomy, Madison,
  Wisconsin, pp  914-926.1965 )

  §257.3-6  Disease.
    (a) Disease Vectors. The  facility or
  practice shall not exist or occur unless
  the on-site population of disease vectors
  is minimized through the periodic
  application of cover material or other
  techniques as appropriate so as to
  protect public health.
    (b) Sewage sludge and septic tank
 pumpmgs (Interim Final). A facility or
  practice involving disposal  of sewage
 sludge or septic tank pumpmgs shall not
  exist or occur unless  in compliance with
  paragraphs (b) (1), (2) or (3) of this
 section
    (1} Sewage sludge that is  applied to
 the land surface or is incorporated into
 the soil is  treated by a Process to
 Significantly Reduce Pathogens prior to
 application or incorporation Public
 access to the  facility is controlled for at
 least 12 months, and grazing by animals
 whose products are consumed by
 humans is prevented for at least one
 month Processes to Significantly
 Reduce Pathogens are listed in
 Appendix  II, Section A  (These
 provisions do not apply to sewage
 sludge disposed of by a trenching or
 burial operation }
   (2)  Septic tank pumpmgs that are
 applied to  the land surface or
 incorporated into the soil are treated by
 a Process to Significantly Reduce
 Pathogens  (as listed in Appendix II,
 Section A), prior to application or
 incorporation, unless public  access to
 the facility  is controlled for at least 12
 months and unless grazing by animals
whose products are consumed by
humans is prevented for at least one
month (These provisions do  not apply
  to septic tank pumpmgs disposed of by a
  trenching or burial operation )
   (3) Sewage sludge or septic tank
  pumpmgs that are applied to the land
  surface or are incorporated into the soil
  are treated by a Process to Further
  Reduce Pathogens, prior to application
  or incorporation, if crops for direct
  human consumption are grown within 18
  months subsequent to application or
  incorporation Such treatment is not
  required if there is no contact between
  the solid waste and the edible portion of
  the crop: however, in this case the sohd
  waste is treated by  a Process to
  Significantly Reduce Pathogens, prior to
  application, public access to the facility
  is controlled for at least 12 months, and
  grazing by animals whose products are
  consumed by humans is prevented for at
  least one month. If crops for direct
  human consumption are not grown
  within 18 months of application or
  incorporation, the requirements of
  paragraphs (b) (1) and (2) of this section
  apply  Processes to Further Reduce
  Pathogens are listed in Appendix II.
  Section B
   (c) As used in this section
   (1) "Crops for direct human
  consumption" means crops that are
  consumed by humans without
  processing to minimize pathogens prior
  to distribution to the consumer.
   (2) "Disease vector" means rodents,
  flies, and mosquitoes capable of
  transmitting disease  to humans
   (3) "Incorporated into the soil" means
  the injection of solid waste beneath the
  surface of the soil or the mixing of solid
 waste with the surface soil
   (4) "Periodic application of cover
 material" means the application and
 compaction of soil or other suitable
 material over disposed solid  waste at
 the end of each operating day or at such
 frequencies and in such a manner ag to
 reduce the risk of fire and to impede
 vectors' access to the waste.
   [5} "Trenching or burial operation"
 means the placement of sewage sludge
 or septic tank pumpmgs in  a trench or
 other natural or man-made depression
 and the covering with soil or  other
 suitable material at the end of each
 operating day such that the wastes do
 not migrate to the surface.

 §257.3-7  Air.
  (a)  The facility or practice shall not
 engage  in open burning of residential,
 commercial, institutional or industrial
 solid  waste This requirement does not
 apply to infrequent burning of
 agricultural wastes m the field,
silvicultural wastes for forest
management purposes, land-clearing
debris, diseased trees, debris from
  emergency clean-up operations, and
  ordnance.
    (b) The facility or practice shall not
  violate applicable requirements
  developed  under a State implementation
  plan approved or promulgated by the
  Administrator pursuant to Section 110 of
  the Clean Air Act
    (cj As used in this section "open
  burning" means the combustion of solid
  waste without (1) control of combustion
  air to maintain adequate temperature for
  efficient combustion, (2) containment of
  the combustion reaction in an enclosed
  device to provide Sufficient residence
  time and mixing for complete
  combustion, and (3) control of the
  emission of the combustion products

  § 257 3-8 Safety
    [a] Explosive gases The
  concentration of explosive gases
  generated by the facility or practice
  shall not exceed.
    (1) Twenty-five percent  (25%) of the
  lower explosive limit for the gases in
  facility structures (excluding gas control
  or recovery system components), and
    (2) The lower explosive  limit for the
  gases at the property boundary.
    (b) Fires  A facility or practice shall
  not pose a hazard to the safety of
  persons or  property from fires  This may
  be accomplished through compliance
  with § 257 3-7 and through the periodic
  application of cover material or other
  techniques  as appropriate
   (c) Bird hazards to aircraft A facility
 or practice  disposing of putrescible
 wastes that may attract birds and which
 occurs within 10,000 feet (3,048 meters)
 of any airport runway used by turbojet
 aircraft or within 5,000 feet (1,524
 meters) of any airport  runway used by
 only piston-type aircraft shdll not pose a
 bird hazard to aircraft
   (d) Access. A facility or practice shall
 not allow uncontrolled public access so
 as to expose the public to potential
 health and safety hazards at the
 disposal site.
   (e) As used in this section.
   [1] "Airport" means  public-use airport
 open to the public without prior
 permission and without restrictions
 within the physical capacities of
 available facilities,
   (2) "Bird hazard" means an increase
 in the likelihood of bird/aircraft
 collisions that may cause damage to the
 aircraft or injury to its occupants
   (3) "Explosive gas" means methane
 (CH4)
  (4) "Facility structures" means any
 buildings  and sheds or  utility or
 drainage lines on the facility.
  (5) "Lower explosive limit" means the
lowest percent by volume of a mixture
of explosive  gases which will propagate

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53464   Federal  Register  /  Vol  44  No  17'3 /  Thuisday,  September  U. 1379  /  Rules and  Rpgaldtions
a flame in air at 25rC and atmospheric
pjessurpi
   (6) "Periodic application of cover
material" means the application dnd
compaction of soil or other suitable
material over disposed solid waste at
the end of each operating day or at such
frequencies and in such a manner as  to
reduce the risk of fire and to impede
disease vectors' access to the waste
   (7) "Putrescibie wastes" means solid
waste which contains  organic matter
capable of being decomposed by
microorganisms and of such a characler
and proportion as to be capable of
attracting or providing food for birds

§ 257 4  Effective date.
   These criteria become cffet five
October 15, 1979.
Appendix I
   The maximum contaminant levels
promulgated herein are for use in determining
whether solid udste disposal activities
complj  with the ground-water criteria
[§ 257 .1-4) Analytical methods  for these
(ontammants may be found in 40 OR Part
141 which should be consulted in its entirety
   1 Maximum contaminant le\,t>lf>  for
inorganic rht'nurals  The following are the
maximum levels of inorganic chemicals other
than fluoride
          Contaminant          Level (milligrams per
                                       005
                                       005
                                       0002
   2.  MaxniKnn contaminant leieis for
oiganic chem'tah The following are the
maximum contaminant levels for organic
chemu aU
                                    Level
                                   [milligram
  (a) using the membrane filter technique
  (1) Four cohform bac tena per 100 milhhters
if one sample is taken, or
  (2) Four cohform bacteria per 100 milhhter
m more than one sample of ail  the samples,
analyzed in one month
Waste Water", American Public Health
Association, 13th Ed pp 662-688, and using
Standard sample, each portion being one fifl
of the sample
5pCi/l,
  (b) Gross alpha particle activity (indud;
r.idmm-226 but excluding radon and
  Mel
   oxyDhenyl| etnare)
  Toxaphene  [CinH,0C!, Ie<
   camphene 6 Mo 69 percent cnlo'ine)          0 005
(b) CnlO'opfienoxys
  2 4 0 (2 4 Dichlo'Ophenoxy acetic acid|          0 1
  2 4 5 Tp  Silvex  (2 4 5
Appendix II

4  PwcesbCi, to S,i;nifi( antly Reduce
Pathogens
  Aerobic digestion The process is
conducted by agitating sludge with air or
oxygen to maintain aerobic conditions at
residence times ranging from 60 days at 15" C
to 40 days at 20° C, with a volatile solids
redui tion of at least 38 percent
  Air Drying  Liquid sludge is allowed to
drain and/or dry on under-drained sand
beds, or paved or unpaved basins in which
(he sludge is at  a depth of nine inches  A

months of which temperatures average on a
daily basis above 0° C
  Anaerobic digestion  The process is
conducted in the absence of air at residence
times ranging from 60 days dt 20" C to 15
diys at 35" to 55° C, with a volatile solids
reduction of d( least 38 percent
  Composting Using the withm-vessel, static
aerated pile or windrow composting methods,
the solid  waste  is maintained at minimum
operating conditions of 40" C for 5 daj s For
four hours during this period the temperature
exceeds W C,
  Lime Stabilization Sufficient lime is added
to  produce a pH of 12 after 2 hours of contact
  Other methods  Other methods or operating
conditions may  be acceptable if pathogens
and vector attraction of the waste (volatile
solids] are reduced to  an extent equivalent to
the reduction achieved b>  any of the above
methods
           s to Furtl.tv Rc'da t> I'a>hoi>t'ni
  Composting Using the within-vessd
composting method the solid waste is
maintained at oprialing conditions of 55" C
or greater for three days Using the static,
aerated pile composting method, the solid
waste is maintained at operating conditions
of 55  C or greater for three days  Using the
windrow composting method, the solid waste
attains a temperature of 55° C or greater for
at least 15 days during the composting period
Also, dur.r.g the high temperature period,
there will be a minimum of five turnings of
the windrow
  Heat dr$ ng Dewatered sludge cake is
dried by direct or indirect contact  with hoi
gases, and moisture content is reduced to 13
percent ur lower  Sludge paiticles reach
temperatures well in excess of 80' C, or the
wet bulb temperature of the gds stream in
contact with the sludge at the point where it
leaves the dryer is in excess of 1)0° C
  Heat treatment Liquid sludge is heated t3
temperatures of 180° C for 30 minutes
   rherwophilic Aerobic. Digestion  Liquid
sludge is agitated with air or oxygen to
maintain aerobic  conditions at residence
times of 10 days at 55-60" C, with a volatile
solids reduction of at least 38 percent
  Othei int'thodb  Other methods or operating
conditions may be acceptable if pathogens
and vector attraction of the waste (volatile
solids) are reduced to an extent equivalent to
the reduction achieved by any of the above
methods
  Any of the processes listed below, if added
to the processes described in Section A
above  further reduce pathogens Because the
processes listed below, on their own  do not
reduce the attraction of disease vectors they
are only add-on in nature
  Beta ray irradiation Sludge is irradiated
with betd rays from dn accelerator at dosages
of at least 1 0 megardd at room temperature
(td 20' C)
  Comma ray irradiation  Sludge is
irradiated with gamma rays from certain
isotopes, such as  60Coba!t and '"Cesium, at
dosages of at least 1  0 megarad at room
temperature (ca 20" C)
  Pasteurization  Sludge is maintained  for tit
least 30 minutes at a minimum temperature of
70'  C
  Other methods  Other methods or operating
conditions may be acceptable if pathogens
are reduced to an extent equivalent to the
reduction achieved by any of the above add-
on methods
*H Dot  79-285JJ Hli'd  9-12 '9 845 am)
BILLING CODE 6S60-01-M

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              Federal Register / Vol. 44, No. 179 / Thursday. September 13, 1979  / Proposed Rules
                                                                                                               53485
 ENVIRONMENTAL PROTECTION
 AGENCY

 [40 CFR Part 257]

 [FRL 1234-2]

 Criteria for Classification of Solid
 Waste Disposal Facilities and
 Practices Amendment
 AGENCY: Environ mental Protection
 Agency.
 ACTION: Proposed Rule.

 SUMMARY: This proposed amendment
 would expand the list of maximum
 contaminant levels (MCL's) used in the
 ground-water quality standard of the
 Criteria for  Classification of Solid
 Waste Disposal Facilities and Practices
 (40 CFR Part 257) The criteria were
 developed and issued as a regulation
 under the authority of the Resource
 Conservation and Recovery Art of 1976.
 The purpose of the criteria 13 to provide
 the basis for determining whether solid
 waste disposal facilities or practices
 pose no reasonable probability of
 adv erse effects on health or the
 emironment.
   The ground-water quality standard
 which has been promulgated in the
 criteria contains maximum contaminant
 levels for health-related parameters
 (specific inorganic and organic
 chemicals, cohform bacteria, and
 radioactive  contamination). This
 amendment proposes limits for the
 following additional eleven
 contaminants. Chloride, color, copper,
 foaming agents, iron, manganese, odor,
 pH, sulfate.  total dissolved solids, and
 zinc These additions are designed to
 protect ground water from odor,
 discoloration, and taste-causing
 contaminants
 DATES: Comments are due November 13,
 1979 One hearing will be held; it will be
 on November 1,1979 at 9 00 AM.
 Registration for the hearing will begin at
 830AM
ADDRESSES: The official  record for this
amendment (Docket No  4004 2) is
located in room 2107, 401 M Street, SW,
Washington. D.C 20460 The record is
available for viewing from 9 00 AM to
4 00 PM Monday through Friday,
excluding holidays
  The public hearing will be held  in
 room 3906, 401 M Street, SW.
 Washington, D.C. Persons wishing to
 make oral presentations are requested
 to restrict their presentations to less
 than ten minutes
   Written comments may be submitted
 at the hearing or mailed to, Comments
 Clerk, Amended Criteria, Office of Solid
 Waste (WH-564), EPA. Washington,
 D C 20460.
 FOR FURTHER INFORMATION CONTACT:
 Mr. Truett V DeGeare, jr , P E, at  the
 above address or at (202) 755-9120.
 SUPPLEMENTARY INFORMATION!

 Authority
   The statutory authorities for this
 proposed amendment are  Sections 1008
 (a)[3) and 4004 (a) of the Solid Waste
 Disposal Act, as amended by the
 Resource Conservation and Recovery
 Act of 1976 (42 U.S.C. 6907(A)(3) and
 6944(a)), later referred to as RCRA or
 the Act;  also, Section 405(d) of the Clean
 Water Act, as amended (33 U S C. 1345).

 Discussion
   This action proposes to  amend the
 Criteria for Classification  of Solid
 Waste Disposal Facilities  and Practices
 (40 CFR Part 257} which has been
 promulgated pursuant to the above
 authorities.
   The purpose of the criteria is to
 provide the basis for determining
 whether  solid waste disposal activities
 pose "*  * * no reasonable probability of
 adverse effects on health or the
 environment*  * *" (RCRA, Section
 4004). The criteria define an open  dump
 (RCRA Section 4004), the minimum
 elements of prohibited open dumping
 practices {RCRA Section 1008(a)(3)), and
 the effects which must be avoided by
 POTW owners and operators (CWA
 Section 405J.  For a full discussion of the
 criteria's role see the Preamble to that
 regulation.
  The criteria provide a ground-water
 quality standard consisting of specified
 substances or parameters. When a
 facility or practice causes protected
ground water to exceed the
contamination levels  specified in that
standard, the facility fails to comply
with the criteria  The  standard which
has been  promulgated in the criteria
contains maximum contaminant levels
for health related parameters. This
 amendment proposes limits for the
 following additional eleven
 contaminants: chloride, color, copper.
 foaming agents, iron, manganese, odor,
 pH, sulfate, total dissolved solids, and
 zinc, in order to protect against
 malodorous, discoloring, foul-tasting
 substances in ground water.
   The criteria provide that solid waste
 disposal facilities or practices shall not
 contaminate an underground drinking
 water source beyond the solid waste
 boundary. The italicized terms are
 specifically defined for their use in the
 ground-water section of the criteria.
   Underground drinking water sources
 are aquifers supplying drinking water
 for human consumption or aquifers in
 vvhich the ground water contains less
 than 10,000 mg/1 total dissolved solids.
 Solid waste boundary is the outermost
 perimeter of the solid waste (projected^
 in the  horizontal plane) as it would exist
 at completion of the disposal activity.
 (There is a provision in the criteria
 allowing a State with an approved State
 solid waste management plan to
 establish an alternative boundary to be
 used in lieu of the solid waste boundary
 in accordance with specified procedures
 and conditions). Contamination is
 defined as the introduction of listed
 substances to ground water so as to
 cause  (1) the concentration of the
 substance in the ground water to exceed
 the maximum contaminant level
 specified, or (2) an increase in the
 concentration of the substance in the
 ground water where the existing
 concentration of the substance exceeds
 the specified maximum contaminant
 level.
   As promulgated, the criteria establish
 specified maximum contaminant levels
 which  were designed to be protective of
 the health of persons consuming the
 ground water. It includes levels for ten
 inorganic chemicals, six organic
 chemicals, coliform bacteria, and
 radioactive contaminants  These levels
 are based on the National Interim
 Primary Drinking Water Regulations (40
 CFR Part 141).
  The criteria were initially proposed
for public comment at 43 FR 4942 on
February 6,1978. In that proposal, the
water quality standard for  ground water
used or usable for human consumption
was that the water not be made unfit for

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53466       Federal Register  / Vol. 44,  No. 179  / Thursday, September 13,  1979 /  Proposed Rules
human consumption The maximum
contaminant levels (MCL's) of the
National Interim Primary Drinking
Water Regulations were included for
determining fitness. Commenters noted
that the term "fitness" was too vague to
be workable It was unclear whether
foul-smelling, discolored, but not
unhealthful water is "fit" for
consumption  Others noted that since
the proposed standard did not specify
the contaminants cr the  concentrations
at which unfitness  would be reached
enforcement would be troublesome In
considering the merits of these
comments, the Agency decided that the
ground water quality standard should
be specific regarding contaminants and
levels which represent adverse effects
on public health and the environment.
Since the maximum contaminant levels
in the National Interim Primary Drinking
Water Regulations were the only
specific contaminants and levels which
were contained in the proposed criteria,
the Agency has decided to promulgate
the criteria based only on those
contaminant levels Before other
contaminant levels are incorporated in
the standard, public scrutiny and the
opportunity for comment should be
offered. Thus, this amendment is
proposed for public review.
  RCRA clearly provides that the
criteria should address effects on the
environment as well as on health. The
House Report (No. 94-1491) instructs
(hat the legislative standard for the
Administrator in developing the Criteria
is "no reasonable chance of adverse
effects" on the environment The report
defines an open dump as a land disposal
site where discarded materials are
deposited with little or no regard for
pollution controls or aesthetics It
provides specific examples of the
impacts to be prevented, including 47
cases of recorded fishkills and 30 cases
of recorded contamination of drinking
water wells. The adverse impact on the
ground water at most of the cited
examples was principally due to high
color and odor characteristics
associated with iron, manganese and
other contaminants not generally
associated with direct health effects. It
is thus evident that Congress intended
to include foulsmellmg, discolored
ground water as an adverse
environmental effect
  The Agency has reviewed monitoring
data from a number of facilities which
indicates that about half of those
monitored facilities have caused ground
water to exceed the health-based
maximum contaminant levels
promulgated in the criteria  An
additional thirty percent of these
contain unacceptable levels of other
(non-health-related) contaminants
Additional research is needed regarding
the probability that disposal activities
may cause adverse environmental
effects without posing direct health
threats Nevertheless,  the existing
literature docs indicate that including
malodorous, distasteful and discoloring
contaminants in the ground-water
quality standard might significantly
increase the number of facilities in
violation,  and that unless these
contaminants are included in the
standard,  a sigmf.t.ant number of
fat ihties which cause  giound water to
be foul-smelling and bad-tasting will not
be classified as unacceptable
   Therefore, the Agency has decided to
propose an amendment to the criteria's
ground-water quality standard which
would include contaminant limitations
protective against malodorous.
distasteful, foaming, staining.  corrosive
and  otherwise adverse effec's on ground
water In this proposed amendment,
comment is being solicited on the use of
the maximum contaminant levels
published in the National Secondary
Drinking Water Regulations (40 CFR
Part 143) for that purpose Eleven
contaminant levels were specified in 40
CFR Part 143 which are of significance
in the classification of disposal
activities;  some discussion is provided
below, giving rationale and po'ential
problems for each of the eleven and
pertinent comments received by the
Agency when the National Secondary
Drinking Water Regulations were
originally  proposed
   A  Chloride (250 mg/1). The proposed
MCL for chloride is  the level above
which the taste of the  water may
become objectionable to the consumer.
In addtion to the adverse taste effects,
high chloride concentration levels in the
water will contribute to the
deterioration of domestic plumbing,
water heaters, and municipal water
works equipment. Higher concentrations
may also be indicative of the presence
of sodium and other contaminants
commonly occurring m leachate, which
are not listed in either of the national
drinking water regulations and, thus, not
directly a  part of the ground-water
quality standard.
  Leachate commonly contains high
concentrations of chlorides  Since
chloride ions are quite mobile in both
saturated and unsaturated zones,
isograms of chloride concentrations are
particularly useful for  inscribing
leachate plume env elopes Inmost
cases, the  chloride concentration is a
key parameter which will indicate the
potential presence of any other leachate
constituent
  Comments received by the Agency on
the proposed leve 1 for chlorides
concerned the  high costs of removal and
consumer tc'erance or acclimatization
Neither cf these issues is appropriate for
consideration in the water quality
standard for the criteria High removal
costs support keeping the contaminant
out, and leachate-caused concentrations
are too  unstable to allow
acclimatization In regions where
naturally occurring or background
concentrations of chloride are
consistently high, people can become
tolerant of the taste well in excess ol the
MCL In such regions, the National
Secondary Drinking Water Regulations
suggest that States exercise discretion,
establishing limitations commensurate
with local conditions  However, such
d.scretion is inappropriate for a leachate
induced violation of the water quality
standard The  concentrations of chloride
often fluctuate widely in a leachate
plume, and their introduction would
represent a new condition to which
acclimatization may take years, and
increasing concentrations of chlorides is
a harbinger indicating the likelihood of
the presence of harmful constituents of
leachate.
  B  Color (15  Color Units) Color may
be indicative of the presence of a host of
organic materials against which
protection is not provided elsewhere in
the ground-water quality standard,
Many of these organic materials are of
direct health concern and of indirect
concern as precursers for the formation
of trihalomethanes and other
halogenated organic compounds
  Experience has shown that changes in
color levels will stimulate consumers'
complaints more readily than a
relatively high constant level. The MCL
at 15 color units is set quite high;
consumers of clear water would be
immediately aware of the presence of
leachate if it were to cause color to
exceed  that level  The color standard is
not redundant for the staining problems
which are caused by iron or manganese,
since these constituents are not visible
until oxidation, usually only occurring
after withdrawal of the water
  The only comments rceived on the
proposed color standard were that it
was  set too high  Support for a lower
MCL included  the argument that
protection from halogenated organic
compounds would be enhanced. This
argument is quite  significant for solid
waste purposes. Fifteen color units may
allow quite a high level of contaminants
to be present However, the Agency has
proposed inclusion of these compounds
directly in the  Primary Regulations

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             Federal Register / Vol.  44, No. 179  /  Thursday, September  13.  1979 / Proposed  Rules	53467
 (Federal Register notice, February 9,
 1978, 40 CFR Part 141) The approach
 proposed herein, then, is to employ the
 higher color standard and wait for the
 specific MCL to be established for those
 compounds in the Primary Regulations,
   C Copper  (1 mg/1). Copper, in trace
 quantities, is an essential  and beneficial
 element in human metabolism but
 imparts an undesirable taste to drinking
 water at the MCL. Small amounts are
 generally regarded as non-toxic, but
 large doses may produce emesis, and
 prolonged consumption may result in
 liver damage. Copper, in some soft
 waters, will cause staining at the MCL.
   Copper is generally quite low in both
 native ground water arid in leachate
 from mixed municipal refuse, it
 generally occurs at concentrations less
 than 20 micrograms per liter except at
 facilities receiving wastes from
 industrial sources The metal is used
 extensively in electroplating, chemical
 manufacturing and in oil refining, and
 the salts of copper are used in textiles,
 photography and pesticides The
 inclusion of copper in the  standard
 should only affect the assessment of
 industrial waste facilities
   High cost of removal was the basis for
 comments for relaxing the MCL for
 copper This  comment supports
 maintaining stringent water quality
 standards for the criteria  In responding
 to that comment, the Agency notes that
 the MCL was only exceeded in 1 6% of
 the samples in EPA's 1970 Community
 Water Supply Study, and that wherever
 high copper concentrations were
 observed the other heavy metals were
 also high. Consequently, the inclusion of
 the copper standard appears
 appropriate.
   D. Foaming Agents (0 5 mg/1).
 Foaming is a characteristic of water
 which has been contaminated by the
 presence of detergents and similar
 substances Water which foams in
 excess of the MCL will exhibit
 undesirable taste and foaming
 properties  Comments received
 suggested that the MCL was too
 stringent and that since the analytical
 procedure specified for the detection of
 foaming agents is the methylene blue
 test, the MCL should be stated in terms
 of methylene blue active substances.
  The 0 5 mg/1 limit for foaming agents
 is based upon the fact that at higher
 concentration levels the  water may
 exhibit undesirable taste and foaming
 properties. Also concentrations above
 the limit may be indicative of
 undesirable levels of pollutants from
 questionable  sources, such as
 infiltration by sewage. Because there is
no standardized foamability test, this
property is determined indirectly by
 measuring the anionic surfactant
 concentration in the water utilizing the
 test procedure specified for methylene
 active substances. Many substances
 other than detergents will cause foaming
 and interfere with the methylene blue
 test. Since most of these interferences
 are positive, the Agency believes that
 the MCL designated for foaming agents
 is the correct one.
   E. Iron (0  3 mg/1). Iron is a highly
 objectionable constituent of water
 supplies. It imparts a brownish
 discoloration to laundry, a bitter or
 astringent taste to drinking water, and
 stains to clothing, dishes and plumbing
 fixtures However, in some areas of the
 country, the native concentration of iron
 well exceeds the  MCL. The limit on iron
 may be one of the most frequently
 violated standards in the criteria. Iron 13
 very common in leachate, quite mobile
 in most soils, and, significantly, the
 concentration may be further elevated
 due to the release of soil-fixed iron as an
 effect of pH and other changes caused
 by the passage of leachate through the
 soil
   At 1 0 mg/1, a substantial number of
 people will  note the bitter astringent
 taste of iron Also, at this concentration
 level the staining problems associated.
 with iron  will  be pronounced, thus
 making the  water unpleasant to the
 consumer and unsatisfactory for most
 industries. Therefore, the Agency
 believes that the proposed MCL of 0 3
 mg/1) for iron  is reasonable.
   F. Manganese (0.05 mg/1). Manganese,
 like iron, discolors and imparts taste  At
 concentrations exceeding MCL it can
 cause build-up in distribution piping
 which can slough off and cause laundry
 spotting and unaesthtic black
 precipitates. Relatively fewer regions
 have high native manganese than have
 high native iron; however, it is not
 unusual For instance, New York State
 Health Department surveys indicate that
 manganese  is found m every public
 drinking water system, and exceeds the
 MCL in about  10%. The Agency received
 no comments on the proposed standard
 for manganese.
  G Odor (3 threshold odor number)
 The principal reason for establishing
 this MCL at  3 Threshold Odor Number
 in the Secondary Drinking Water
 Regulations  is  that beyond that odor
 level, consumers would be tempted to
 avoid the public water system and
 choose alternative, possibly
 unmomtored, water sources. Thus, it is
 an odor level which is considered
 definitely unacceptable, particularly
 when newly or intermittently
introduced, as  may be the case from
leachate.
   Odor is due to the presence of a
variety of substances. Most organic and
some inorganic chemicals contribute
taste and odor. Because odorous
materials are detectable when present
in only a few micrograms per liter and
are often complex, it is usually
impractical and often impossible to
isolate and identify the odor-producing
chemical. Although many of the odor-
producing chemicals are not known to
have other adverse effects, inclusion  of
odor in the standard has the additional
advantage of warning of the presence of
organic and inorganic pollutants often
associated with municipal and industrial
wastes but not otherwise listed in the
standard
   Comments received by the Agency on
the proposed regulation suggested that
the proposed MCL should be deleted
from the regulations, arguing that the
threshold odor number is an arbitrary
value and the analytical results
obtained vary greatly from person to
person. On the other hand, one
commenter suggested that the MCL
should be lowered to one. The level of
three was determined by the Agency to
be appropriate because most consumers
find the water at this limit unacceptable.
Determination of odor at that level is
considered reliable, but below the MCL
it is difficult because of possible
interferences from other sources and
variation of the sensing capabilities of
the personnel performing the test.
   H pH (6.5—8 5)  A variety of health
and environmental effects are
associated with the range of pH which
could result from contamination by
leachate pH is an important
determinant of corrosivity; below 6.5,
significant corrosion effects become
noticeable. The treatability of many of
the other parameters in the water
quality standard is also dependent upon
pH For example, while a facility might
emit no selenium, the selenium
treatment which would be required
because of high background
concentrations could be rendered
ineffective due to the facility's effect on
pH Also,  pH can interfere with existing
treatment because of its effects on the
efficiency of chlormation and on the
solubility of toxic metals.
  Naturally occurring pH is found lower
than two in some volcanic situations
and nearly 11 in contact with some
silicates in desert basins However.
acidities and'alkalmities of these
magnitudes are quickly reduced by
reaction with their environment. Most
ground waters which he subject to
contamination by solid waste disposal
activities are subjected also to
atmospheric and other neutralizing

-------
53468
Federal Register / Vol. 44, No. 179 / Thursday, September 13, 1979 / Proposed Rules
influences A reasonable range of pH at
the water table may be considered to lie
between 4 and 9, numbers which also
represent the reported range of the pH
of leachate Naturally occurring pH in
ground water is slightly basic in most
regions of the country, with sufficient
buffering capacity to withstand
significant stresses associated with solid
waste disposal activities. Leachate from
mixed municipal wastes is quite erratic,
varying by both age and constituents of
the waste. The occurrence of
contaminated ground water in which the
MCL for pH is exceeded after a
reasonable mixing zone is highly
indicative of adverse health and
environmental effects.
  Most of the comments received by the
Agency concerned the upper limit for
pH. Since raw leachate seldom exceeds
the upper limit, these comments are not
applicable for the Criteria. The
remainder of the comments concerned
corrosivity. The Agency is still
evaluating tests and maximum
concentration levels for corrosivity,
these comments and the issue of
corrosivity in leachate  will be addressed
on conclusion of the evaluations.
  I. Sulfate (250 mg/lj  Sulfate is a
commonly occurring natural constituent
of ground water in many regions of the
country. Some States report as much as
10 percent of the underground drinking
water supplies exceed  the MCL. Sulfate
is listed  in the Secondary Drinking
Water Regulations principally because
of its cathartic or laxative effect in
humans  and to a lesser extent because
of taste considerations. Its presence in
leachate is frequently attributable to
industrial sources of refuse such as
textile and paper industries  Leachatp
analyses frequently report sulfate far
below MCL, with occasional reports as
high as 1500 to 2000 mg/1. For these
facilities it is a good indicator of the
extent of contamination, and its laxative
and taste effects are useful indices of
the adverse effects.
  Comments received by the Agency
were not appropriate to this amendment.
considering the objectives of the criteria
Cost  of treatment, and long-term
acclimatization do not suggest allowing
greater concentrations  to result from
land disposal.
  J. Total Dissolved Sohds (TDS) (500
mg/1). Dissolved solids content is useful
as the single parameter which most
closely describes a given water in terms
of usefulness of the native water and
influence of a heterogenous contaminant
source. It reflects the influence of all the
dissolved constituents  It reflects
mineralization and, thus, the taste of
water Additionally it accelerates
deterioration of plumbing and water
fixtures  (One study finds a reduction of
one year of water heater life per 200 mg/
                          1 TDS) Although it is a very non-specific
                          indicator which may be difficult to
                          isolate by source, it is useful for
                          covering both hardness and corrosivity
                          effects which are not otherwise a part of
                          the water quality standard of the
                          criteria.
                            In some regions of the country,
                          particularly m the Southwest, the ground
                          water commonly exceeds the MCL for
                          TDS  A dissolved solids limit (10,000
                          mg/1) is used as the demarcation in the
                          criteria for water too contaminated to
                          warrant protection. Leachate is high in
                          TDS, commonly reported between 5,000
                          and 40,000 mg/1.
                            Excessive hardness, taste, mineral
                          deposition and corrosion are among the
                          associated adverse effects listed in the
                          rationale for limiting TDS in the
                          Drinking Water Regulations. Comments
                          received on TDS were mostly requests
                          for flexibility or for a higher limit from
                          water suppliers in area of high
                          background TDS levrls. No comments of
                          concern to the criteria addressed areas
                          of low background TDS.
                            K Zinc (5 mg/1) Like copper, zinc is
                          an essential and beneficial element in
                          human metabolism, but it imparts an
                          undesirable taste to water. It also can
                          create a milky appearance in water and
                          cause a greasy film on boiling In native
                          ground  water it is seldom found m
                          concentrations exceeding 2 or 3 mg/1.
                          Frequently, it is reported in leachate  at
                          concentrations below the MCL;
                          however,  in industrial areas zinc
                          concentrations in leachate have been
                          reported up to 370 mg/1. The Agency
                          received no comments on the proposed
                          MCL.

                          Key Issues
                            EPA believes that this list of eleven
                          maximum concentration levels may be
                          appropriate for addition to the criteria
                          In order to properly solicit public
                          comment, yet not delay State
                          implementation of RCRA, the Agency is
                          promulgating the criteria at the same
                          time as this amendment is being
                          proposed; the alternative of
                          promulgating interim regulations, with
                          the expanded ground-water quality
                          standard in effect during the comment
                          period,  was rejected.
                            Several key questions are  specifically
                          highlighted for public  comment First,
                          are these eleven proposed contaminant
                          levels appropriate for the objectives of
                          the criteria? Are they  characteristic of
                          leachate? Are they too commonly
                          present in ground water to serve the
                          purpose? Secondly, are there additional
                          contaminants or characteristics which
                          should be used to determine adverse
                          effects on health and environment?
                          Thirdly, what effect will the  expansion
                          of the standard have on compliance
with the criteria? Will only those
facilities with impervious liners for the
prevention of discharges be acceptable,
or will there be only a small incremental
increase in non-complying facilities
consisting of sites which do cause
adverse environmental effects?
  We specifically highlight for comment
the  fact that several States have
considered these contaminant levels as
they were proposed in the National
Secondary Drinking Water Regulations
and have chosen to promulgate State
drinking water regulations based on
higher or lower levels. Should these
criteria permit similar State-by-State
variations in the ground-water quality
standard? This question should be
addressed considering that without
State discretion, some State agencies
may be in the awkward position of
requiring facilities to close or upgrade
for  causing effects which the State
considers acceptable in drinking water
supplies  Yet, on the other hand, in order
to protect against the  potential for
inconsistencies and abuses, a flexible
standard will require adding a
justification and approval process  This
is a level of EPA oversight not otheiwise
needed m implementation of the
regulation.
  Comments are also  requested on the
practicality of implementation (such as
replicabihty of taste and odor tests),
potential impacts of this amendment on
segments of society and the economy,
and the adequacy of the amended
regulation in providing for protectioT of
the  public health and the environment.
Written public comment is invited on all
issues  raised by the proposal.
  Ddled September 10. 1979
Douglas M Costle,
Administrator

Appendix A [Amended]

  Accordingly, 40 CFR Part 257 is
amended by adding to Appendix A .1
paragraph 6 as follows.

  6  Max,mum contaminant levels for other
than health effects
  The following are the maximum levels for
odor, taste and miscellaneous contaminants
Contaminant
Chloride
Color
Copper
Foaming agents

Manganese
Odof
pH
Sulfate
IDS
Zinc
Level
260 mg/1
15 Color jnits
1 mg/l
0 5 mg/l
03 rrg/l
005 mq/l
3 Threshold odor No
65-8 S
250 mg/l
500 mg/L
5 mg/l
[FRDoc 79-28SJ3 Filed 9-12-79 845nm)

BILLING CODE 6560-01-M

-------
         APPENDIX B
METHODOLOGY FOR DETERMINING
  ECONOMIC IMPACT ANALYSIS

-------

-------
                                APPENDIX

       B.   METHODOLOGY FOR DETERMINING ECONOMIC IMPACT ANALYSIS

     Chapter    III         summarized  the  economic impacts of three
regulatory approaches  —  the final,  a more  restrictive, and a less
restrictive  —  identifying these  as Federally induced costs. State-
standard-induced,  and combined  (State-standard-induced plus Federally
induced) costs for landfills, surface impoundments, and landspreading.
Chapter    IV   briefly   discussed   the   approach  and  methodology
used in analyzing the economic impacts  of the criteria,  and outlined
the major assumptions for each disposal method.

     In this chapter  the methodology  underlying  the economic impact
analysis is discussed in greater detail, including:    (1) an explana-
tion of the methodology used  to differentiate between State-standard-
induced  and Federally induced costs;  (2)  a summary  of the analysis
used to evaluate  the final,  more-restrictive,  and  less-restrictive
alternatives,  with  the  assumptions  supporting  this  analysis;  (3)
information concerning the data base;  and  (4)  methodologies used in
developing the data base and costs.

A.   ANALYSIS OF STATE STANDARDS VS. FEDERAL CRITERIA

     The cost figures developed for the Economic Impact Analysis (EIA)
represent  the  increments or additional cost  above  current disposal
costs to bring existing facilities into compliance  with the criteria.
By comparing the criteria to existing State standards,  it is possible
to divide  these incremental costs  into two categories:   State-stan-
dard-induced cost  (cost  to come into compliance  with existing State
standards)  and Federally induced cost  (costs beyond those needed  to
achieve compliance  with State standards).   This breakdown was neces-
sary  because a number of disposal facilities  do not yet comply  with
existing State standards  (corrective  or compliance technologies  and
methods often take years to implement).  Without the Federal criteria,
facilities  can be expected  to eventually  come into compliance  with
State standards.   The combined costs demonstrate the total additional
                                  B-l

-------
expenditures  necessary to bring  existing facilities  into compliance
with State standards and the criteria.

     In order to determine  State-standard-induced  and Federally  in-
duced costs,  State standards and regulations  were reviewed and eval-
uated;  State regulations  were then  compared  with  the criteria  to
establish their degree of conformance with the criteria.

     This legislative analysis  is summarized below  and in Table B-l;
the latter  identifies the specific criteria  addressed in the regula-
tions of each State.

     Floodplains.   A review  of State solid waste  legislation  shows
that 23 States  (46%) had regulations  that are intended  to avoid ad-
verse impacts  associated with the disposal  of wastes in floodplains.

     Endangered and Threatened Species.   Only one State,  California,
addressed this criterion in its regulations, through a requirement for
environmental  impact reports  which consider  the impact  of proposed
actions on endangered and threatened species.

     Surface Water.   The surface water criteria  address all water of
the United States,  including wetlands.   Because of the unique nature
of wetlands, State regulations were examined for specific reference to
these areas.   The surface water  criteria were addressed  in existing
regulations  in  all  but  three  States  —  Kansas,  Louisiana,  and
Mississippi.  Eleven States make specific reference to wetlands.

     Ground Water.    The ground-water  criteria  include  sole source
aquifers and were determined  to have been met in 37 States.   Several
of those States  determined not to meet  the ground-water criteriei did
make provision for some ground-water protection,  usually expressing a
minimum vertical separation between wastes and ground water.
                                  B-2

-------
                   Table   B-l
ANALYSIS OF STATE REGULATIONS vs.         FEDERAL CRITERIA
            (X Indicates  State Compliance)


STATE
Alabama
Alaska
Arizona
Arkansas
Colorado

Delaware
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland

Michigan
Minnesota
Mississippi
Montana
Nebraska
Nevada
New Hampshire

Mow Mexico
•Jew York
North Carolina
Nortel Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
; South Carolina
> South Dakota
1 Tennessee
Texas
Jtah
Vermont
, Virginia
' Washington
West Virginia
Wisconsin
i Wyoming
TOTAL
7. OF TOTAL


Flood



X
X
x


x



X

X


X
X

X
X
X
X

X



X



X
X

X
X
x



X



23/50
46Z |


Cpitlca

j
I
j










































1/50
27.


Surface Water Ground
X > X
X X
! X X
X X
X '
i x
i x x x
X ' X X
X '
X X
X j X
X !
X

! X X
X
X X
< X X
X X
X ' X
XXX

X ' X
X X
X ' X
XXX

X X
X X
X ' X
X
X X
X
X X
X . X
X ( X
X X
X ' X
X ; 'X
X
X
X X 1
i K X '
•< x
XXX
X X '
47/50 11/50 37/50
94Z 22t 74J



X
X
X
X
x


X

I X
1 X
X
: x
i x
; x


X
x
X
X
X
X
X
X
X


X
X ^


x
X
X
X
X
X
X
X
X i
X '
X
X
X
X
42/50
842


Disease
X
X
X
X
X
x
X
X
X
X
X
X
X
X
X
x
X
X
X
X
x
x
X
X
x
X

X
X
X
x
X
X
X
X
X
X
X
X
t
X
X
X
X !
X
X i
50/50
100Z


Expl.
Gases





X
X




x





X


X




X












X



X

x

14/50 !
». i

SAP
Toxic
Gases





X





X





X


X




X












X



X

X

If/50
287.

ETY
Birds




















X

















X



X



S/5Q
lot


Access

X

X
X
x
X
x

X
X
X
X
X
X

X
X
X
X
X
X
X
X
X
X

X
X
x
X
X
X
x
X
X
X _,
X
X

X



X
X >
42/30
842


Fires
X

X
X
X
X
U — |
X
X
X
X
x
X
X
X

X
X
<
X
X
X

X
x
y
^
X

X

X
X
X
*
X
X
X
x
X

X
\

jC
X
42/50
34S
                    B-3

-------
     Air.  The air criteria were addressed in 42 States  (84%), through
at least limited bans on open burning.

     Disease.  Control of disease was provided in all 50 States.  This
criterion was  met largely  because of  provisions in  each State  for
periodic cover of waste material.

     Safety.   The five components of the safety criteria  were met in
varying degrees by the States; 42 States (84%) required provisions for
prevention and control of fires, while 42 States  (84%)  also included
provisions for  the control  of facility access  in their solid  waste
regulations.   Safety provisions which address the  problems of explo-
sive and toxic gases were less common in State rules  and regulations.
Fourteen States (28%) required controls for toxic and explosive gases.
The criterion  which addresses potential bird hazards  to airports was
met in the rules and regulations of only five States.

B.   METHODOLOGY FOR EACH DISPOSAL METHOD

     The  methodology  for the economic impact analysis  was developed
with the aid of fairly complete data on the number of landfills and on
State  solid  waste disposal regulations, but with limited data on the
number  of  landspreading  operations  and surface impoundments    and
overall conditions or current impacts of all three types of land  dis-
posal facilities.    In lieu of complete information on the number and
condition  of landspreading sites, substantial data has been collected
on  the  amount and characteristics of municipal sewage which is land-
spread.     Although  some industrial waste disposal facilities may be
regulated  by the hazardous waste regulations of RCRA and not by these
criteria, no attempt  was made to estimate how many facilities  may be
so affected;  therefore, criteria costs may include estimates for some
f acJlities  that  are  regulated by the hazardous waste regulations of
RCRA.
     Unfortunately, the inventory of disposal  facilities to be devel-
oped under RCRA is to occur after the regulation is  finalized.  Conse-
quently, a number of assumptions had to be made  because the following
information is sketchy or not well known:
                                B-4

-------
     (1)  number and size  of surface  impoundments  (an estimate
              considered to be incomplete or conservative  —  is
          available on  the number of surface  impoundment sites.
          (Ref. 107);

     (2)  number  and size of  landspreading operations  on food-
          chain cropland ;

     (3)  the specific  locations and  conditions of  all catego-
          ries of solid waste disposal facilities.

     In  analyzing the  economic impacts  of the criteria,  the  basic
method used on a State-by-State basis was fourfold:

     (1)  estimate  the number  of disposal  facilities   (by size
          and location); In addition to partial estimating of the
          number of landspreading sites, estimate the amount   of
          municipal sewage sludge landspread nationally;

     (2)  estimate the condition (environmental impact) of exist-
          ing facilities (by size and location);

     (3)  identify control technologies  (by  adverse  effect and
          regulatory alternative)  and estimate unit costs (based
          on facility size) to meet each criterion; and

     (4)  derive total control  costs of closure or upgrading for
          the major regulatory  alternatives by summing costs  of
          each criterion  for the three types of disposal for the
          total number of affected facilities.

     All costs in this report are in terms of annualized 1978 dollars.
The methodology for cost calculations is based upon three assumptions:
                                   B-5

-------
     •    facilities have a life of 10  years (a 10 year planning
          period was assumed to be appropriate in the landspread-
          ing analysis) ;
     •    interest is 10% ;  and
     •    inflation affects all variables equally.

     Thus,  costs were developed  by calculating annual payment spread
over 10 years.

     For  capital  expenditures (A^),  the following  calculation  was
used:

     A^ = (K)  (0.163) = cost spread over 10 yea/.s
                         where K = capital = present worth
                         0.163 = annuity factor to 10 years at 10%

     The formula used for derivation of the .163 factor was:

        = k     i      or k i(1+i
      k     l-U+U-n       (l+i)n-i

     Where:

     K = Capital Cost
     A,  = Annualized capital cost
     i = Interest rate, per year
     n = Number of years

     For operation and maintenance (0+M),
     A    = Annual operation and maintenance
      o+m

     Overall,  the calculation  used to develop total  annualized unit
     costs, A, was
                 • Ak
                                  3-6

-------
1.   Methodology and Assumptions for Landfills

     a.   Data Source

          The 1977 update  to the 1976  Waste Age  survey provided the
initial data base for the  economic impact  assessment.   Feedback was
requested from the States  on two occasions  regarding the accuracy of
the data,  and updated numbers were obtained in some cases,  as refer-
enced in  this final EIS.   The Fred  C.  Hart Associates, Inc. study,
"The Technology,  Prevalence,  and Economics  of Landfill Disposal  of
Solid Waste,"  was used as the base source  of information  concerning
the national prevalence  of on-site industrial landfills  (those land-
fills on industry-owned property)  by size category for each two-digit
SIC manufacturing industry group.

     b.   Assumptions and Other Data Considerations

     (1)  Impact Receptors

          All known landfill facilities,  whether "permitted," "autho-
rized,"  or  "illegal,"*  as documented  by the Waste Age survey, were
considered  to be affected  by the criteria,  as well as known on site
industrial landfills.   The degree of impact varied  according to five
factors:  numbers of authorized facilities; numbers of illegal facili-
ties;  number of on-site  industrial  landfills;  the degree  to which
State regulations met the requirements of the criteria;  and the loca-
tion of facilities based upon the percentage of total population with-
in a given State that could be classified as residing in a  wetland or
floodplain.

     (2)  Applicable Criteria

          All criteria were considered to have the potential to gener-
ate  economic impacts except the point-source  requirements of surface
*These are assumed  to be  open dumps  and thus require  closing under
 RCRA within five years.
                                  B-7

-------
water, land application,  endangered and threatened species,  and bird
hazards to aircraft.  The following assumptions were made:

     •    Land  application  was  not  considered  for  landfills
          because  traditional landfill  wastes  are usually  not
          spread on land for beneficial utilization.

     •    Bird hazards to aircraft  and endangered and threatened
          species do not have cost impacts, but these impacts are
          considered minimal  due to the small number of disposal
          sites affected by these criteria.

     (3)  Regulatory Alternatives

          Table B-2 shows,  on a  criterion-by-criterion basis,  which
regulatory  alternatives  were  considered  in  analyzing the economic
impacts of the criteria on landfills.

     The following assumptions  were made  in regard to the regulatory
alternatives:

     •    For  ground water,  the regulatory  alternatives  are a
          function of State regulations and potential for adverse
          impacts on  ground water.  Since required  technologies
          are a function of the rates of infiltration in particu-
          lar States,  the final criteria considered ground-water
          technology with  respect to those  facilities in states
          with  negative  rates of  infiltration  versus those in
          States with net rates of infiltration.   All facilities
          in wetlands received maximum technology.  In net infil-
          tration States, fifty percent of the authorized munici-
          pal landfills and on-site industrial landfills received
          maximum ground-water technology. Fifty percent of these
          facilities  also were  assumed to require  ground-water
          quality monitoring. These same percentages were applied

-------




































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-------
to permitted  municipal landfills  in States  which had
no standards  equivalent to the  Federal criteria.  The
regulatory  alternatives considered  these same facili-
ties, but provided maximum technology in all States for
the  more  restrictive  and minimum  technology  in all
States for the less restrictive.

For safety,  more-  and  less- restrictive alternatives
were not considered feasible for gas,  fire, and access
because of the need to control these factors  to ensure
public safety.

For surface water, the final  criteria were  considered
to consist of two parts  — one part addressing surface
waters in general,  and  the other  addressing wetlands
because of their unique nature.   The regulatory alter-
natives considered  the surface water  criterion in the
same  manner  by  providing  alternatives  both for the
general non-point-source provisions of the criteria and
for wetlands.

For the purpose  of assessing costs,  it was determined
that the costs  attributed  to the surface water crite-
ria  should  not  be  assigned  to the  total  criteria
costs, because the surface water criteria merely focus-
es existing Federal legislation — the  Clean Water Act
-- to the operation of solid waste disposal facilities.
Costs are more  accurately a reflection of Sec. 103 of
this Act.

For  air, the  regulatory  alternatives involved an as-
sessment of increased land required as a result of res-
tricted  burning.   The  more  restrictive  alternative
considered  this,  as  well  as additional  land  needs
                      B-10

-------
          resulting from  a  total  ban  of burning.   Under  the

          final criteria,  some  burning  is  allowed  on a site-

          specific basis 'by permit from individual States.


     (4)  Technologies and Cost Considerations


          Applicable  technologies  and  unit costs on a criterion-by-
criterion  basis  are  discussed  in  Chapter in.   Costs  were  based
upon three factors:  numbers of facilities, facility size and quantity

of control needed;  and  facility  size was based  upon a scenario  of
average  conditions.  Table B-3  summarizes the assumptions  regarding

facility size.


                               TABLE B-3

                     LANDFILL FACILITY SIZE DATA*
Facility category, (metric
  tons/day)
Refuse Capacity, m ..
                (ydj)
                (tons)
Edge*
Area
   (ft)

Hectare
 (acre)
Refuse-to-Soil Cover
Ratio (Daily and
Intermediate Cover)
    9.1

   (10)

 39,800
(52,000)
(26,000)

    152
   (500)

    2.4
    (6)

    1:1
    9.1

   (100)

 397,800
(520,000)
(260,000)

     336
  (1,100)

    11.3
    (28)

     2:1
      272

     (300)

 1,193,400
(1,560,000)
  (780,000)

       549
    (1,800)

       30.4
       (75)

        3:1
*Assumptions are as follows:

      (1)  Refuse is placed in 2 successive 2.43-meter (10') high
           lifts.
      (2)  260 days per year
      (3)  Soil cover excavated on site       3
      (4)  In-place refuse density of 593 kg/m  (1000 Ib/cy)
      (5)  Perimeter fill slopes are 3 horizontal to 1 vertical
      (6)  Facility service life of 10 years.
**Edge distance is based on a square facility, with a 30. 5m( 100';
  back from top of fill to property line.
                                                                  set-
                               B-ll

-------
     The ground-water criteria  had the most detailed  cost considera-
tions.   Clay lining,  monitoring  wells,  and leachate collection and
treatment facilities were considered to be the best available technol-
ogy for purposes of upgrading.    Leachate removal  and treatment  was
considered  an  operation  and maintenance (O&M)  cost, because of  the
likelihood that  leachate  would be discharged  to a POTW; the assump-
tions to calculate costs for leachate were as follows:

     •    A surcharge  would be collected  annually  and put in a
          trust fund.  Funds accrued during the life of the land-
          fill would be used  for leachate removal  and treatment
          during the last 5 years of facility service life and 10
          years thereafter.

     •    Leachate  infiltration  is 6 inches/year  and treatment
          costs are 2.5,  1.0,  and 0.5  cents per gallon for 10,
          100 and 300 ton per day facilities, respectively.

     •    Surcharge over a 10-year  period is equal to annual ex-
          penditures over 15 years.  Inflation is assumed to off-
          set interest accrual,  hence neither  of these  factors
          has been incorporated in the calculations.

     c.   Data Base

     (1)  Facility Conditions

          Evaluation of municipal  facility conditions  was based upon
categories of disposal facilities,as provided by the Waste Age survey,
and an assessment of the stringency of State regulations, as discussed
in Chapter VA.

          Landfill facilities were divided into four categories:  per-
mitted,  authorized, illegal, and  on-site industrial.   The following
assumptions were made for municipal landfills:
                                 B-12

-------
Permitted Facilities.  The  facility  conditions  are a
function of the  degree  to which  their  States' solid
waste  regulations comply  with the criteria.  (This as-
sumes that the  permitted  facilities  comply  with the
State regulations.)  Thus, for any  given State, if the
condition  of their  landfills can be said to be XI and
the Federal criteria  mandate  a condition  of X2, then
the  difference  between  these  two  conditions is the
amount of  upgrading needed on a criterion-by-criterion
basis.

     State permitted facility      Federal criteria
           condition                    mandates
               XI	X2

Authorized Facilities.   An authorized facility, accord-
ing to the Waste Age survey,   is one which is not quite
ready to be permitted.    However, there is no available
definition  of  "quite ready;"  therefore,  in order to
maintain  consistency  it is  necessary  to define this
condition with respect to the State regulations and the
Federal  criteria.  For example, if authorized  facili-
ties are  at condition XO, then they have to reach both
conditions XI  (State regulations) and X2 (Federal cri-
teria) .
Authorized
condition

YD-- 	
State regulations
condition
XI
Y1
Federal
criteria
X2
Y9
In addition to being upgraded  from State permit condi-
tion to Federal criteria (X2-X1), all authorized facil-
ities need to be upgraded to the level of current State
                       B-13

-------
          regulations  (Xl-XO) for ground-water and surface water
          criteria.  With respect to all other disposal criteria,
          these  authorized facilities  were  assumed  to already
          meet current State regulations.  The basis for this as-
          sumption is  that it is relatively easy and inexpensive
          to comply with the other criteria;  hence an assumption
          was made that authorized facilities are probably in com-
          pliance.

     •    Illegal Facilities.  The remaining,  or illegal facili-
          ties within a State  will be assumed  to be open dumps,
          which are mandated  by RCRA  to be closed  within  five
          years.   In other words, illegal dumps meet none of the
          criteria,  and consequently, costs for these facilities
          will be determined by costs for closure.

     The 1977 update to the 1976 Waste Age survey provides the numbers
of municipal landfills  according to the above two categories,  and by
inference, a third category — illegal facilities.   For example, in a
given State,  there may be 300 known disposal facilities,  of which 94
are permitted and 108 are authorized,  leaving 91 facilities which are
considered illegal.  The formula for this computation is:

Illegal facilities = (known facilities) - (permitted facilities) -
                     (authorized facilities)

However,  the Waste Age Survey has several inconsistencies,  resulting
from differing  reporting  methods among the States.   These inconsis-
tencies are resolved as follows:

          1.   When the number  of authorized facilities  is less than
the number  of permitted facilities,  it is assumed that the permitted
facilities were not included in the authorized category,and therefore:

               Total - (authorized + permitted) = illegal
                                  B-14

-------
          2.   When the number  of authorized facilities  is  equal to
the total number of facilities, it is assumed that there are  no ille-
gal facilities  and the authorized category includes permitted facili-
ties.
Therefore:

               Total - permitted = true authorized

          3.   When the number  of authorized  facilities  is equal to
the number of permitted facilities, and the total of authorized + per-
mitted exceeds the stated total, it is assumed that the authorized are
the same as permitted.  Therefore:

               Total - permitted = illegal

          4.   When the total number  of facilities  is equal  to both
the number of authorized facilities and the number of permitted facil-
ties and the number of permitted facilities (total = authorized = per-
mitted),  all facilities are assumed to be permitted and no facilities
are assumed to be illegal.  Therefore:

               Total = Permitted

          5.   When  the number  of authorized  facilities  is greater
than the number of permitted facilities,  but the sum of permitted and
authorized is less than the stated total,  the difference from the to-
tal of this sum are assumed to be illegal.  Therefore:

               Total - (authorized + permitted) = illegal

          6.   When  the number  of authorized  facilities  is greater
than the number of permitted facilities,  but the sum of permitted and
authorized  is greater than the stated total,   it is assumed  that the
authorized category includes both permitted and authorized facilities.
Therefore:

               True authorized = stated authorized - permitted
               Total - (true authorized + permitted) = illegal
                                 B-15

-------
          7.   When the number  of authorized facilities  is equal  to
the number of permitted facilities,  but the sum of these is less than
the stated total,  it is assumed  that there  are  an equal number  of
authorized and permitted facilities.  Therefore:

               Total - (authorized + permitted) = illegal

          8.   Number of authorized facilities is less than the number
of permitted facilities  and the total of authorized and permitted  is
greater than total number of facilities.  It is assumed that the defi-
nitions of authorized and permitted facilities differ in these states.
Therefore:

               Actual permitted = given authorized
               Actual authorized = given permitted - given authorized

     In addition,  it is assumed  that the actual  authorized  include
actual permitted.  Therefore:

               Total - (actual authorized + actual permitted)^ illegal

     For  industrial  landfills,  the following assumptions  were
made:
          Al1 industrial landfills will require upgrading, except
          for  the gas  component  of the  safety  criteria,  the
          groundwater criteria  and disease criterion.   This as-
          sumption  was based  on the presumption  that  industry
          would  find  it more  cost-effective  to upgrade  their
          landfill  disposal facilities,  rather than  close them
          and find alternative disposal methods.

          For the ground-water criteria,  it was assumed that all
          on-site  industrial landfills  located in wetlands will
          be upgraded;  fifty percent of those  facilities located
          in net infiltration areas will be upgraded with maximum
          technology, and fifty percent in these same areas would
          require ground-water quality monitoring.
                                  B-16

-------
     •    For the gas  criteria,  10% of the industrial landfills
          will require  upgrading.   This assumption  is based on
          the fact  that most industrial wastes  are non-organic,
          and therefore not conducive to gas generation.

     •    For the disease criterion,  10% of the industrial land-
          fills  will  require  upgrading.   This  assumption  is
          based on the fact  that most industrial wastes are non-
          organic, and therefore  not conducive to the support of
          disease vectors.

     The Fred C. Hart Associates,  Inc.  study  (Ref. 141) was used as
the base source  of information  for determining the number of on-site
industrial landfills by size category and State for each two-digit SIC
industry group.   The methodology is detailed  in the Data Base Calcu-
lations Section.

     In regard  to closure,  EPA  is currently  developing policy  and
procedural guidance on what constitutes closure of solid waste dispos-
al facilities.  The following assumptions were made:

     •    A closed  facility  by definition  does not receive any
          more solid wastes.

     •    All  closed  facilities  shall be  "window dressed"  or
          "topped off"  (to minimize infiltration,  disease  vec-
          tors, bird attractions, and waste exposure).  In regard
          to landfills and dumps,  a minimum  of 2 feet  of cover
          material suitable to support vegetation, and vegetation
          adequate to prevent soil erosion is necessary.

     •    No open burning.

     •    One year after closure, the facility shall be inspected
          for settlement,  vegetation, cover material,  and effec-
          tiveness of vents.
                                  B-17

-------
     •    No other corrective actions.

     These assumptions  are based  to a large extent  on the following
information:   (1) corrective actions  for ground-water  contamination
are very  expensive  and generally  do not clean  up the aquifer,  but
merely inhibit  additional leachate migration,  (2) revenue sources at
closed facilities have ceased  and the property may have changed hands
so that  the  desired outcome  of any suit  for  corrective action  is
doubtful, and (3) in general,  it is better to concentrate on protect-
ing ground water from damage than to dwell on corrective actions.

     It is further assumed that closure requirements  are the same for
abandoned facilities and active facilities.

     Since RCRA mandates the closure of all open dumps (illegal facil-
ities) closure costs were considered to be Federally induced.

     (2)  Facility Location

     In order to assess  the impact  of  the floodplains  and the wet-
lands component of the surface water criteria,  assumptions  had to be
made regarding the number of facilities located in wetlands and flood-
plains.  The basic assumption is that:

     •    The number of facilities located in wetlands and flood-
          plains is a function  of the percentage of each State's
          population living  in wetlands  and floodplains,  since
          waste generation  and industry  activity  are generally
          correlated with population centers or concentrations.

     Thus,  if 30%  of the population  within a given  State  lives in
floodplains  and  wetlands,  then the assumption was made  that 30% of
the landfills in that State were located  in floodplains and wetlands.
In each State,  the number of facilities in floodplains was determined
as follows:
                                 B-18

-------
     Number of facilities in floodplains =
                     (State Floodplains Population)     Total
                     (Total State Population)        x  number of
                                                       facilities

     For each State, the number of  facilities in wetlands was deter-
mined as follows:

     Number of facilities in wetlands =
                     (State Wetlands Population)     Total number
                     (Total State Population)        of facilities

     The methodologies for determining the State floodplains  and wet-
lands population is given in the Data Base Calculations section.

     (3)  Facility Size

     The Waste Age survey  breaks facility sizes  into six categories.
For ease of computation,  these facility sizes were grouped into three
categories and a modal value chosen for each category, as follows:

Waste Age                        New                             Modal
Categories                    Categories                         Value
(tons/day)                     (tons/day)                        in TPD

   0-50 	  0-50                             10
  5°-100)	 50-200                           100
 100-200
 200-500)
 500-1000)	    200                           300
   1000  '
     (4)  Data Base Calculations

          Data base calculations were designed to provide  information
on a State-by-State basis for a number of facilities by category (per-
mitted, authorized, illegal); by size (10 TPD, 100 TPD or 300 TPD); by
                                 B-19

-------
type (industrial or municipal):  and by location  (in or out of flood-
plains and wetlands).   Once these calculations  were made,  they were;
used  for  determinations  of  cost.   The  following steps detail the
methodological approach.

     •    Facilities by Location

          The  number  of facilities  located  in  or outside  of
          floodplains  and wetlands  was based  on the assumption
          that the number  of facilities  located  in floodplains
          and wetlands  is a function  of the percentage  of each
          State's population living  in floodplains and wetlands.
          The following methodologies were to determine the State
          population in these areas:

     For floodplains:

     1.   Determine  urban floodplains  land area by multiplying 19.8%
(Schaeffer and Roland, Inc., Ref. 151) by the total urban land area by
State as provided by 1972 Bureau of Census data.

     2.   Multiply urban floodplains land area by the urban population
density  as determined from census  data, to obtain  urban floodplains
population.

     3.   Determine  rural  floodplains land area by subtracting urban
floodplains land area from total floodplains land area.

     4.   Multiply  rural  floodplains land  area by  rural population
density  as determined using census data  to obtain rural  floodplains
population.

     5.   Add  rural  and  urban  floodplains  populations  to  obtain
national floodplains population.
                                   B-20

-------
     6.   Use  State  populations  as  provided  in 1972 Bureau of the
Census  data to determine the percentage of the national population in
each State.

     7.   Use  floodplains  land  area  for  each  State   (as provided
by  Federal Insurance Administration data) to determine the percentage
(for each State) of the national floodplains land area.

     8.   Find average of the #6 and #7 above for each State.

     9.   Apply  average in  #8 to national  floodplains population to
determine State floodplains population.

     10.  Determine percent of total State population  in  floodplains.

     11.  Apply percentage  to total number of facilities  in State to
determine number of facilities in floodplains.
     For wetlands, a similar approach was taken:

     1.   Determine urban  wetlands land  area  by  multiplying  19.8%
(Schaeffer and Roland,  Inc., Ref. 151)  by the total  urban land area
and by .5 (to account for the floodplains/wetlands overlap).

     2.   Multiply urban wetlands land area by urban population densi-
ty  (as determined using  1972  Bureau of the Census  data)  to obtain
urban wetlands population.

     3.   Determine  rural  wetlands land  area  by  subtracting urban
wetlands  land area from % the total wetlands land area as provided in
the 1954 National  Wetlands  Inventory of the U. S. Fish and  Wildlife
Service.

     4.   Multiply rural wetlands land area by rural  population  den-
sity to obtain rural wetlands population.
                                 B-21

-------
     5.   Add  total and urban wetlands populations to obtain national
wetlands population.

     6.   Use State  populations  as provided  in  the 1972  Bureau oE
Census data to determine the percentage of the national  population in
each State.

     7.   Use the wetlands land area for each State as provided by the
1954 National Wetlands Inventory of the U.S. Fish and Wildlife Service
to determine the percentage (for each State) of National Wetlands land
area.

     8.   Find average of #6 plus #7 for each State.

     9.   Apply  average  in  #8  to  national  wetlands population to
determine State wetlands population.

     10.  Determine percent of total State population in wetlands.

     11.  Apply  percentage to  total number of facilities in State to
determine number of facilities in wetlands.
For example, the following data are provided:
          Total land area in U.S. = 3,536,855 sq. mi.
          Urban land area in U.S. = 55,047 sg. mi.
          Rural land area in U.S. = 3,481,808 sq. mi.
          Total population in U.S. = 203,211,926
          Urban population in U.S. = 149,324,930
          Rural population in U.S. = 53,886,996
          Floodplains land area in U.S. = 148,985 sq. mi.
          Wetlands land area in U.S. = 117,574 sq. mi.

-------
Therefore,

     •    Urban population density = 2,713 per sq. mi.
     •    Rural pooulation density = 15 per sq. mi.

Using the given data and methodology:
          Urban floodplains land area in U.S. = 10,899 sq. mi.
          Urban floodplains population in U.S. = 29,568,987
          Rural floodplains land area in U.S. = 138,086 sq. mi.
          Rural floodplains population in U.S. = 2,071,290
          Total floodplains population in U.S. = 31,640,277
          Urban wetlands land area in U.S. = 5,450 sq. mi.
          Urban wetlands population in U.S. = 14,785,850
          Rural wetlands land area in U.S. = 53,337 sq. mi.
          Rural wetlands population in U.S. = 800,055
          Total wetlands population in U.S. = 15,585,905
For States A and B, the following data are given:
     •    Population in State A = 3,000,000
     •    Population in State B = 15,000,000
     •    Floodplains land area in State A = 5,000 sq. mi.
     •    Floodplains land area in State B = 3,000 sq. mi.
     •    Wetlands land area in State A = 700 sq. mi.
     •    Wetlands land area in State B = 1,000 sq. mi.

Applying all  data provided,  the following  figures are derived using
the above methodology:

                                           State        State
        % of U.S.  % of U.S.   % of U.S.   Floodplains  Wetlands
State  Population  Floodplains  Wetlands   Population   Population
A
B

1.5
7.4

3.4
2'.0

1.2
1.7
B-23
791,007
1,487,093

218,203
716,952


-------
     •    Facilities by Location by Type

          To determine the number of on-site industrial landfills
          in each State, the following methodology was used:

     The  number  of  establishments  for  each two-digit SIC industry
group for each State is available in the 1972 Census of Manufacturers,
compiled  by  the U.S. Bureau of Census.    These numbers are  divide;d
by the total number of establishments nationwide to yield the percent-
ages  of  the total number  of each  industry group within each State;.
These percentages are applied to the total number of on-site industri-
al landfills by size, as determined in the Hart study, for each indus-
try group  to determine  the total number  of on-site industrial land-
fills by size and industry group for  each State.  For example, if the
total  number of on-site industrial landfills nationwide is 90,000 and
the  following information is provided by the Census of Manufacturers:
     STATE
                              SIC GROUP
                                                 NO. OF ESTABLISHMENTS
     National
                                 20
                                 21
                                 22
                                 23
                               Others
8000
1200
3000
2400
6000
     XYZ
                                 20
                                 21
                                 22
                                 23
                               Others
 200
  30
 150
 300 300
  78
     Then,  the  percentages
nationwide in State XYZ are:
                              of  the  total  number of establishments
                                 B-24

-------
                              SIC GROUP           PERCENTAGE

                                 20                    2.5
                                 21                    2.5
                                 22                    5.0
                                 23                   12.5
                               Others                  1.3

     Applying these percentages to the total number  of on-site indus-
trial landfills for each 2-digit SIC industry nationwide, yields:

                 NO. OF ON-SITE                   NO. OF ON-SITE
SIC GROUP      LANDFILLS, NATIONAL      %      LANDFILLS IN STATE XYZ

     20             6,186              2.5              155
     21                60              2.5                2
     22             1,584              5.0               79
     23             5,376             12.5              672
   Others          62,499              1.3              812
          TOTAL    75,705                             1,720
     To determine the number of municipal landfills by State, the  1977
update  to the 1976  Waste Age Survey  was used.  The survey lists the
total number of facilities per State.

     The next step was to allocate the municipal and on-site industri-
al landfills  to wetlands and floodplains.   This was done by applying
the  percentage  of the State's  population  in these  areas  to  each
State's landfill data base.

     Floodplains:

On-site  industrial landfills x % State floodplain population = number
of on-site industrial landfills in State's floodplains
                                  B-25

-------
Municipal landfills x % State floodplain population = number of munic-
ipal landfills in State's floodplain

              TOTAL = Total number of State's landfills in floodplains

     Wetlands:

On-site industrial landfills x % State wetlands population = number of
on-site industrial landfills in wetlands

Municipal landfills x % State wetlands population = number of municipal
landfills in State's wetlands

               TOTAL = Total number of State's landfills in wetlands


     •    Facilities by Location by Type by Size

          Next, the number of industrial and municipal facilities
          both in and out of floodplains and wetlands,  according
          to size, was determined.  This was done using the Waste
          Age  survey  for municipal landfills  and the  Fred  C.
          Hart Associates study (Ref. 141) for on-site industrial
          landfills.

          For example, for a  given State,  the  Waste Age survey
          supplies the following numbers:

Distribution  0-50   50-100   100-200   200-500   500-1000   1000

Number of
 Facilities    255     25        15        4         1         0

          Using the new  facility size categories,  the following
          data were generated:
                                 B-26

-------
Distribution
Modal Value
Number of
 Facilities
0-50
 10
                255
50-200
 100
                          40
200
300
          The number  of landfills  in and  the number outside of
          the State's floodplains and wetlands were developed as-
          suming 20% of the  State's population lives in  each of
          these areas;
Facility Size
Raw Data
Facilities in Wetlands
Facilities in Floodplains
Other Facilities
                   10 TPD
                     255
                      51
                      51
                     153
                     100 TPD
                        40
                         8
                         8
                        24
                       300 TPD
                          5
                          1
                          1
                          3
     The Fred C. Hart Associates study (Ref. 141)supplies numbers
     of on-site landfills by size and by industry group. The Hart
     size categories, 0-50  TPD, 50-200  TPD, and  200 TPD,  were
     converted to the  modal values previously discussed, as fol-
     lows:
                                  B-27

-------
                                        NUMBER OF  ON-SITE  LANDFILLS
                                     0-50 TPD     50-200  TPD    200 TPD
SIC CODE  INDUSTRY                   (10 TPD)      (100 TPD)    (300 TPD)
20
21
22
23
24
25
26
28
29
30
31
32
33
34
35
36
37
38
39
Food Processing
Tobacco
Textile
Apparel
Wood Products
Furniture
Paper & Allied Prod.
Chera. & Allied Prod.
Petroleum
Rubber & Plastics
Leather
Stone, Clay
Primary Metals
Fabricated Metals
NonElectrical Mach.
Electrical Mach.
Transportation Equip.
Prof. & Scientific Inst.
Miscellaneous Manuf.
6,186 14
60
1,584
5,376
7,466 3
2,031
1,328
4,527 43
403
-
160
3,518 5
1,346 13
6,479 16
28,554
-
1,905 31
1,316
3,341

-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
               TOTAL                  75,580           125
          Number of Facilities by Location,  Type,  Size  and Category

          The next step  was to determine  the  number  of municipal
          landfills  that are permitted, authorized,  and illegal.
                             B-28

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     For a given State,  the following were derived from the 1977
     update to the 1976 Waste Age survey:

     State XYZ - Permitted Facilities, 94
                 Authorized Facilities, 108
                 Illegal Facilities, 98

     What was not known was how many of these types of facilities
     are in each category.   This was determined by assuming that
     the type of landfill by size is a function of the percentage
     of landfill types divided  by the total number of landfills,
     times the  number of facilities  by size.  The computational
     formula for this is:
Percentage of
sani ary     ^ number of sanitary, authorized or illegal landfills
lanatills or -           tofcal number of landfills
authorized
or illegal

. um*?1:j:1 ?  ,   _ no. of sanitary, authorized, or illegal landfills x
landfills by - no. of facilities by size	
category and   	total number of landfills	
          This was  done for  landfills  located both  in and out  of
          floodplains and wetlands.  Thus, for a given State, the fol-
          lowing was generated:

               Sanitary landfills    = 31.3%
               Authorized landfills  = 36.0%
               Illegal landfills     = 32.7%

          This information  was used in  conjunction with  knowledge of
          the number of facilities by size to obtain:
                                  B-29

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Areas
All
          Percentage
                              10 TPD
                                             100 TPD
                                                            300 TPD
Sanitary
Authorized
Illegal
  TOTAL
 31.3
 36.0
 32.7
100%
 80
 92
 12
255
13
14
jj
40
Floodplains
Sanitary
Authorized
Illegal
TOTAL
Wetlands
Sanitary
Authorized
Illegal
TOTAL
• Cost
31.3
36.0
32.7
100%

31.3
36.0
32.7
100%
Calculations
                                16
                                18
                                17
                                51
                                16
                                18
                                17
                                51
          Cost calculations   were  based  upon a  State-by-State
          assessment  of  upgrading  needs.  For each  criterion,
          unit costs for the  best available  technology were de-
          veloped according to facility size.   Cost calculations
          were based upon the following formula:

Costs = (quantity)x(price)x(applicable numbers of facilities by size)

          In this formula, quantity  refers to the amount of con-
          trol technology  needed  (i.e., the  square feet, cubic
          yards, lineal feet, etc.)
                                  B-30

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     State costs were developed by summing costs for each criter-
     ion;  national  costs  were developed  by  summing all State
     costs on a criterion-by-criterion basis.

•    Combined Cost

     Costs were assessed on the following basis:

    AB1 = Federal Costs (difference between State standards and
          Federal criteria)

    AB2 = Costs to upgrade or comply with State standards for
          surface water and ground water

    AB3 = Costs to close an illegal facility

     Nl = Number of permitted municipal facilities

     N2 = Number of authorized municipal facilities

     N3 = Number of illegal municipal facilities, exclusive of
          those in floodplains and wetlands

     N4 = Number of on-site industrial landfill facilities

•    Permitted Facilities

     Costs = Nl (AB1)

•    Authorized Facilities

     Costs = N2 (AB2) + N2 (AB1) = N2 (AB1 + AB2)
                             B-31

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     •    Illegal Facilities

          Costs = N3 (AB3)

     •    On-Site Industrial Landfill Facilities

          Costs = N4 (AB1) + N4 (AB2) = N4 (AB1 + AB2)

     •    Total Combined Costs

          Nl (AB1) + N2 (AB1 + AB2) + N4 (AB1 + AB2) + N3 (AB3.)

     •    Federally Induced Costs vs. State-Standard-Induced Costs

               When State standard meets Federal criterion:

               State Standard-Induced Costs = N2 (AB1 + AB2) +
                                              N4 (AB1 + AB2)

               Federally Induced Costs = N3 (AB3)
                        (closure)

               When State does not meet Federal criterion:

               Federally Induced Costs =  Nl (AB1) + N2 (AB1+ B2) +
                                         N4 (AB1+AB2)

               Federally Induced Costs = N3 (AB3)
                        (closure)

2.    Methodology and Assumptions for Surface Impoundments


     a.   Data Source


     This methodology is  predicated on data from an EPA report, HSEPA

Contract   No. 68-01-4342:    Surface Impoundments and Their Effect on.

Ground Water in_ the United States  (Ref. 107).       In addition to the

above, The Ground Water Report to Congress (Ref. 7) provided necessary

information.
*Closure costs are included in costs for floodplains and wetlands  for
facilities sited  in these  areas.           Facilities which are closed
but where not located in these areas were not  attributed to any spec-
fic criterion but to the criteria in general.
                                 B-32

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     b.   Assumptions and Other Data Considerations

          (1)  Impact Receptors

               For purposes  of this analysis, the following types  of
surface impoundments were considered:

               Municipal surface impoundments
               Industrial surface impoundments
               Agricultural surface impoundments

     Information as to  the number of facilities  by State within each
of these groupings came from the Surface Impoundments report referenc-
ed above (Ref. 107), as well as updates provided by the States through
contacts made by the EPA regional offices.

          (2)  Applicable Criteria

               Only the criteria  for ground  water, floodplains, sur-
face water (wetlands), and the access component of the safety criteria
were  considered to have economic impacts.   The following assumptions
were made:

     •    Costs incurred  for the point source  provisions of the
          surface water criteria  were more appropriately a func-
          tion of the NPDES program.    The nonpoint source prov-
          isions  were more appropriately  a function of  ground-
          water considerations.  For these reasons, only impound-
          ments located  in wetlands incurred any costs attribut-
          able to the the surface water criteria.

     •    No  open  burning  at surface  impoundments occurs on a
          regular basis as a means for volume reduction of waste.

     •    The  disease aspects of these criteria were assumed not
          to be problems at surface impoundments.
                               B-33

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     •    Not enough  information exists on the  land application
          of surface  impoundment  wastes.  It was  assumed  that
          this was not a viable practice.

     •    The gas control,   fire,   and bird hazards to aircraft
          components  of the safety  criteria were  considered to
          have a  minimal economic impact on surface impoundments
          because these  factors are  more likely a  problem with
          nonliquid organic wastes.

     (3)  Regulatory Alternatives

          More and less restrictive alternatives  were  considered for
the ground-water, surface water (wetlands),  and floodplains criteria,
No alternatives were considered practical by EPA for the access compo-
nent of the safety  criteria because of the need  to ensure protection
of the public.

     (4)  Technologies and Cost Considerations

          To  upgrade facilities  to meet  the ground-water  criteria,
facility  lining with imported  clay was deemed to be the  most appro-
priate maximum technology.    This technology represents a  compromise
between  the costs  of two other applicable  technologies—lining with
onsite clay, and lining with a synthetic membrane.   Costs for ground-
water quality monitoring were also considered.   Access considerations
were considered to be  met through use of a minimal perimeter gate and
fence.

     Closure costs for the surface water  (wetlands), ground water, and
floodplains criteria  included only costs for closure of the facility.
This was based on the following assumptions:

     •    Facilities forced to  close in wetlands and floodplains
          do  so because  of their location  in these areas,  and
          their  inability  to  meet the costs for compliance  in
          these areas.

                               B-34

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     •    Facilities  may be forced  to close by the ground-water
          criteria because of the high cost of compliance in some
          cases.

     •    Technology  costs  for all other  criteria will include
          those  facilities located in wetlands and  floodplains,
          inclusive of those facilities closed, because they will
          be  relocated  in an  acceptable manner  in wetland and
          floodplain areas.

     For purposes of assessing costs, assumptions had to be made as to
facility sizes and configurations.  Table B4 summarizes the assumption
regarding surface impoundment size.    The following assumptions  were
made:

     •    100% of all municipal and  agricultural facilities, and
          95% of all industrial facilities are 2.5 acres.

     •    5% of all industrial facilities are 50 acres.

                          TABLE B-4

                SURFACE IMPOUNDMENT SIZE DATA

Size:          Hectare                  1              20
                 (acre)               (2.5)           (50)

Edge*;         Meters                  107            457
                 (feet)               (350)         (1500)
*The impoundments are square and the edge distance is that used for
 fence and levy lengths.
                                3-35

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     The assumptions  were based on the presumption that virtually all
municipal and agricultural activities requiring the use of surface im-
poundments would be on a small scale.    This same presumption was ap-
plied to industrial activity,  however,  there is a need in the indus-
trial area for some large impoundments.  No data exists which provides
an accurate assessment of these groupings.   Flow data alone is inade-
quate,  as the size necessary to accoraodate a particular  flow is more
appropriately a function of geologic conditions.

     Furthermore, because no detailed accurate data exists on the con-
dition of facilities, the following assumptions were made:

     •    To meet the alternatives for the ground water criteria,
          50% of the  facilities were upgraded with maximum tech-
          nology; 50% also received ground-water quality monitor-
          ing.  Five percent of the total were assumed to require
          closure.

     This  assumption  was based upon an  assessment of the  industrial
studies provided in Appendix C.

     •    To  meet the alternatives  for floodplains  and surface
          water  (wetlands),  2/3 were upgraded or closed; 5% were
          considered  for  closure.    For the  more  restrictive
          alternatives, 100% were closed.

     The  assumptions  for the   final    alternatives were  based on  a
presumption that the same percentage of surface impoundments that were
inadequate to effectively control groundwater  contamination, would be
inadequate to comply with the wetlands and floodplains criteria.

     •    To  meet the  access component of the  safety criteria,
          which  remains  the same for all  alternatives, 25%  of
          the facilities were upgraded.
                                  B-36

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     This  assumption  was based on the  presumption that most surface
impoundments  located in populated areas  would have controlled access
in order  to ensure against  the likelihood of  liability  for damages
resulting from uncontrolled access.  Furthermore, it was presumed that
many  impoundments in unpopulated  areas would not be required to con-
trol access at this time,  given their limited or nonexistent exposure
to unauthorized persons.

     c.   Data Base

          (1)  Facility Sizes, Conditions and Locations

               Supplementing the above assumptions concerning facility
sizes and facilities in need of upgrading, was information relating to
the numbers of facilities by type, by State, and by location.

     Information  regarding the number of surface impoundment facilit-
ies  by type was  obtained from the  Geraghty and Miller report  (Ref.
107) and from updates  provided by the States through the EPA regional
offices.

     The total number of surface impoundments in each State was deter-
mined by multiplying the number of facilities within each type (munic-
ipal, industrial, agricultural) by a factor of 2.5.    This factor was
chosen  because most estimates place the actual number of impoundments
as two or three times greater than the number of sites (Ref. 107).

     The number of surface impoundments,  by State, for each type that
was  apportioned to  the average surface  impoundment size categories,
was  determined by applying the estimated percentage  of each type  of
surface impoundments which fall within each size category.   For exam-
ple,  if it is determined that 95% of all  industrial surface impound-
ments are two acres,   and 5% are fifty acres,  then 95% of  the indus-
trial impoundments in State A are 2.5 acres, 5% are fifty acres.
                                  B-37

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     The total number  of surface impoundments  for each size category
was  determined by summing  the size categories within each  State for
each type of impoundment.    For example,  the total of State A's five
acre impoundments will be the sum of the five-acre impoundments in the
municipal, industrial, and agricultural categories for that State.

     The number of surface impoundments for each State by size located
in  floodplains  was determined  by applying  the  percentage  of  the
State's population  living in floodplains to the  total number of sur-
face impoundments by size, as discussed above. The percentage of those
facilities which require closure was applied to the number of impound-
ments in floodplains  to determine the  number of surface impoundments
in  floodplains to be closed.    The remainder  required upgrading  to
comply with this criterion.

     This same methodology was used to determine the number of facili-
ties by size located in wetlands,  and to determine the number requir-
ing closure and upgrading.

     The data base for  determining compliance costs for all criteria,
except floodplains and surface water (wetlands), was the total surface
impoundment data base.    For floodplains and wetlands,  the data base
was those facilities located in these areas.

     d.   Cost Calculations

          Criteria costs were assessed on the following basis:

          Cost =  (number of facilities to be upgraded) x (cost to
                  upgrade) + (number of facilities to be closed) x
                  (cost to close)
                                   B-38

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      e.   Combined Cost

            (1)  Combined Costs =  (number of facilities  to be  upgraded
  for ground-water criteria in wetlands)  x  (cost to upgrade) +  (number
  of facilities to be  upgraded for groundwater criteria in other areas)
  x  (cost to upgrade) +  (number of  facilities to be upgraded for flood-
  plains and surface water  (wetlands)  x  (cost to upgrade) + (number of
  facilities to be closed for ground-water criteria)  x  (cost to close)
  +  (number of facilities  to be closed  in floodplains and  wetlands) x
  (cost to close) +  (number of facilities to  be upgraded for the access
  component of the safety criteria) x  (cost to upgrade).

            (2)  Federally Induced Cost vs. State- Standardlnduced Cost

                In  order to assess   cost distributions.   State  solid
  waste regulations were analyzed;   if the State's floodplains, surface
  water (wetlands),  ground-water,  and access component  of the  safety
  criteria  regulations were as stringent as the Federal  criteria, then
  costs were considered to be State-induced.    All others are Federally
  induced.

  3.   Methodology and Assumptions for the Landspreading Analysis

     The   cost  methodology used to  develop  the  national  costs of   the
regulation for landspreading  is  a step-by-step  analysis which:    screens
for  what  categories  of  costs  should  be  considered  (e.g.,  going to
alternative  disposal  methods,   increased monitoring  and  surveillance);
estimates,  nationally,  the  number of  facilities which  landspread and  the
amount of sludge which  these  facilities landspread;  and finally,  factors
these  estimates  to assess the  incremental  national  costs  (i.e.,  beyond
current  practice)   which   can   be  expected   if  either the  proposed or
selected  alternative regulations  are  applied  on a  national  scale.
NOTE:  For simplicity, all final and  interim  final  rules promulgated in
the  Federal Register  on  September 13, 1979   (44  Federal Reg.  53438)
are  identified in this EIS as "final"   regulations.       However,   it
should  be noted  that  the  criteria for Application to Land for  the
Production  of  Food-Chain Crops and Disease—Sewage  Sludge and Septic
Tank   Pumpings  (under  Section  257.3-5 and 257.3-6(b), respectively)
are of an interim final status.
                                   B-39

-------
     As Figure B-l indicates,  the methodology is organized  into five

activities.   Within each activity,  simplifying assumptions have been

made.   An effort was made,  however, to avoid assumptions which would
understate nationwide costs.   These five activities can be summarized

as follows:


     •    Defining Cost Considerations.  Segments of the environ-
          ment were reviewed to see  where the  regulations would
          have cost  impacts:   environmentally  sensitive  areas
          (floodplains), surface water,  ground water, air, land,
          safety,  and health (disease).    Only the costs of (1)
          protecting  surface  and  ground  water from  excessive
          nitrogen  contamination,  and (2) protecting humans and
          grazing  animals  from  excessive  ingestion  of  heavy
          metals  (cadmium)  and organics (PCB's) were determined
          to  have the potential  to contribute  significantly to
          the national cost of regulation.

     •    Developing Regulatory Alternatives.   The final regula-
          tion  and three alternatives  were proposed to  control
          sludge to food-chain land.    Each alternative was  de-
          signed to achieve a different  degree of protection for
          the  segments of  the environment discussed above;  the
          final  regulations, a  less restrictive alternative,  a
          more  restrictive alternative,  and a most  restrictive
          alternative.   The requirements of the final regulation
          and the  three alternatives are discussed  in detail in
          Chapter III.

     •    Estimating Sludge Quantities and Qualities.    For each
          regulatory  alternative  and the final regulation,  the
          following parameters were calculated for publicly owned
          treatment  works  (POTW's)  where data is  available and
          where landspreading is currently practiced:

               Total  annual  metric  tons  of  sludge  which are
               currently landspread

               Total  annual metric tons  which are/are not land-
               spreadable under the annual cadmium limitations of
               the alternative regulations

               Projected  life  of  disposal  facilities used  by
               POTW's  under  a  worst-case  cumulative   cadmium
               limitation.

          Appendix F  lists  these POTW's.

     •    Estimating Unit Costs.    The unit costs to comply with
          the regulations   in order that  landspreading may  con-
          tinue  and  the   unit costs  to  select an  alternative
                                  B-40

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    0

    03

    cn
    0
   O

    0)
   A •
H  G  3
 I
W
 H  
D 0) -H
O Q T3
H    (13
fc 5^ (U
   O 5-1
   in a
      03
   x:
   4-J
    0)
   S
                        ,      .
                      ,!  sliSlMI    O-J  =  i = = !
                      ii  n'-iSiH    -i <  =  3-i=;
                                         1  i  '
                                           B-41

-------
          method where landspreading cannot continue were estima-
          ted.    All unit costs were  based on a cost per ton of
          disposed sludge or a cost per facility.
     •    Estimating National Costs.   The final component of the
          cost methodology tied together the  previous four comp-
          onents.    Unit costs  of disposal were applied  to the
          quantities  of sludge which  could/could not  be  land-
          spread under the mandates of each of the  four alterna-
          tives.    The results,   a cost of  regulation for  the
          sample  set  of POTW's,   was then extrapolated  to the
          national level to produce national cost estimates.  The
          national costs were  further analyzed for their impacts
          on residential sewer charges.
     The following discussion focuses on these five activities in se-
quence.  For each activity, all assumptions are discussed in detail.
     a.   Defining Cost Considerations

          Seven segments of the environment were screened to determine
the relative cost impact of the landspreading regulations: environmen-
tally sensitive areas (floodplains), surface water, ground water, air,
land, safety, and disease.    Only in the protection of surface water,
ground water, and land were  the costs of regulation nationally signi-
ficant and quantifiable.  Since the regulations do require measures to
protect air quality and environmentally sensitive areas and to control
pathogens, the result may  be additional  treatment costs  incurred by
certain facilities.   However,  in most cases no additional costs will
be incurred,  and thus their  national impact will   be insignificant.
The  regulations  which protect  human safety  are being addressed  in
other  sections of this  environmental impact  statement and  are  not
included in the cost methodology.

     In the second step of the screening, three  subcomponents of sur-
face and  ground-water protection were evaluated for expected cost im-
pacts:  monitoring the sludge  for nitrogen prior to land application,
monitoring  the surface and  ground water after application,  and con-
trolling  the movement  of pollutants after  application.   Where high
water tables  or topographical features  make adverse effects  likely.
                                  B-42

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the criteria  require that best agricultural  management practices are
to be used to prevent ground- and surface water contamination.   Faci-
lity  operators  in such cases  will incur moderate  additional costs.
However,  because the sludge is assumed  to be applied at a rate nece-
ssary to satisfy  the nitrogen demands of the crops,  and because this
application rate is generally quite low,  water pollution from  sludge
application  is unlikely.   Therefore, costs for pollution control and
water  quality monitoring are assumed to be neglible    nationwide and
are not included in the analysis.  However, the cost of monitoring the
nitrogen  in the sludge prior  to application  will be incurred by all
municipalities  and is quantifiable.    This cost  is included in  the
analysis.

     Two subcomponents  of land protection were also  evaluated in the
second screening;  heavy metals and organics application.  The method-
ology includes  the costs associated with regulating cadmium additions
to the  soil and the costs  for monitoring sludge  for polychlorinated
biphenyls (PCB's).

     b.   Developing Regulatory Alternatives

          The final  regulation  and three alternatives  were examined
for  regulating  the application of sludge to food-chain land.    Each
alternative  was designed to achieve  a different degree of protection
for the segments of the environment discussed above.  The requirements
of the  final regulation and the  three alternatives are  discussed at
length in Chapter III.

     c.   Estimating Sludge Quantities and Qualities

          The estimation  of sludge  quantities and qualities is based
on EPA  case study data on sludge handling  practices by POTW's across
the nation.  This methodology assumes that the sample set is represen-
tative of all POTW's landspreading sludge in the nation.    The POTW's
included in the sample set are listed in Appendix F.
                                 B-43

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     For each regulatory alternative, for each POTW in the sample set,
the following estimates were made:

     •    Tons  of  sludge which  are currently  being  spread to
          food-chain land
     •    Tons of sludge which could/could not be spread to food-
          chain land under the annual cadmium  limitations of the
          final regulation
     •    Tons of sludge which could/could not be spread to food-
          chain land under the annual  cadmium limitations of the
          alternative regulations.
In order to reflect different operating characteristics and economics of
scale, the sludge data were disaggregated according to POTW size:
     •    Small POTWs « 1 mgd)
     •    Medium POTWs (>1 mgd, < 25 mgd)
     •    Large POTWs (> 25 mgd)
Five key assumptions made  in the analysis are discussed below:
      (1)  Accounting for Changes in the Quantity and Quality of Sludge

          The methodology assumes  that  the quantity of  sludge being
generated remains  constant  throughout the planning period.  Further-
more,  the methodology assumes that,  except for the effects  of  pre-
treatment,  the amount of cadmium  in the POTW influent  remains  con-
stant.    Both assumptions are not necessarily valid for all POTWs  in
the nation.    As more  secondary  treatment is  brought on line,  and
removal  efficiency  increases  at a given POTW,  more sludge will  be
generated.  As process changes take place within an industry,  the use
of cadmium may decrease and a given POTW may experience  a decrease in
the  amount of cadmium in its influent.   The pending U.S. EPA-Depart-
ment of  Defense  agreement  for  reviewing defense  specifications on
cadmium is an  example of how the demand  for cadmium  may decrease in
the planning period.   At the present time,  the net effect of changes
in sludge generation and influent characteristics is difficult, if not
impossible, to predict.  Thus, the methodology made these two assumpt-
ions.
                                 B-44

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     (2)  Estimating the Effects of Pretreatment Guidelines


          The analysis makes two key assumptions concerning  the effec-
tiveness of pretreatment in reducing cadmium in municipal sludge:


          In POTW sludge where cadmium levels are high,
          the cadium is assumed to be approximately 60%
          industrial in origin. Estimates of industrial
          cadmium origin  reach  as high as 90  percent,
          with  the remainder attributed to residential
          and commercial discharges, urban  runoff, and
          natural background concentrations. (Ref. 195)
          However, the data are limited and suggest   a
          wide variance between sites.  For the purpose
          of  this analysis, a conservative estimate of
          60  percent  is employed to minimize the pro-
          jected  effects  of industrial  pretreatment,
          thereby  maximizing  the  cost of the   land-
          spreading regulations.
          Pretreatment guidelines will reduce the indus-
          trial  contribution  by  80 percent beginning
          July 1, 1984. Pretreatment guidelines for the
          electroplating industry are expected to reduce
          cadmium from that industry by as much as 85
          percent by July 1, 1984.  While pretreatment
          guidelines for other key industries have not
          yet  been  developed,  removal  efficiencies
          could be in this same range for most industries
          and most metals (Ref. 196).


     Assuming  that   a one  percent   reduction in influent    cadmium

corresponds to a one percent reduction in sludge cadmium content, these

assumptions translate into approximately a 50 percent average reduction
in cadmium in municipal sludge after industrial pretreatment (80% x 60%
   50%).


     (3)  Selecting Appropriate Sludge Application Rates


          The analysis was  based  on  a sludge application rate of  10
metric tons  per  hectare (mt/ha) on the conservative assumption   that

this is the lowest economically viable rate.  Should some POTW's spread

at a higher rate, this assumption would overstate the cost of regulation.
                              B-45

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     (4)  Estimating the Impacts of Cumulative Cadmium Limitations

          This  analysis  assumed that  the quantity of  sludge  being
landspread  would be unaffected  by the cumulative  limitations in the
regulation.   Rather,  when the cumulative limit is reached at a given
disposal facility, the methodology assumes that the POTW will continue
disposing of sludge  at an alternative facility at no additional cost.
The validity of this  assumption is supported in the results presented
by the economic impact analysis.

     (5)  Defining Practical Alternate Methods of Disposal

          The  final  regulation  and the  less and  more  restrictive
alternatives  permit POTW's to select either of  two optional  schemes
for the application of sludge to food-chain land.   (The most restric-
tive  alternative requires  the  elimination  of all food-chain  land-
spreading. )    The cost methodology assumes  that if a  large POTW  is
precluded from option 1  landspreading due to the high cadmium content
of its sludge, it will elect to continue landspreading under option 2.
The methodology assumes,   however,   that small and medium facilities
will abandon landspreading altogether and select an alternative method
of disposal.   These assumptions  are made because  the option 2 land-
spreading regulations are tailored to large POTW's capable of develop-
ing and administering a responsible plan, and would be prohibitive for
most small and medium facilities.  Nevertheless, some of these smaller
facilities  may select option 2,   and to this extent the cost  of the
regulation  is overstated.    For the purpose of  this analysis,   the
sludge which can no  longer be landspread is distributed  among alter-
native disposal methods according to the proportions currently devoted
to those methods by each plant size category.   These percentages were
derived  from the data presented in Figure D-l in Appendix D, and  are
presented in Table B-5.

     d.   Estimating Unit Costs

          Unit costs are developed in Table B6 for two mutually exclu-
sive costs incurred by a POTW because of the regulations:
                                  B-46

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                                                          B-46

-------
                       TABLE  B-6 (Continued)

1.    Unit Costs are based on:
         Small plant - 3 days/month for 6 months, 8 hours/day, $9/hr.
         Medium plant - 4 days/month for 6 months, 8 hours/day, $9/hr.
         Large plant - 10 days/month for 6 months, 8 hours/day, $9/hr.

2.    Cadmium, lead, nitrogen, pesticides and persistant organics are
      to be monitored at each  facility.   Monitoring requirements and
      associated unit costs for large and small and medium facilities
      are summarized in the following table.    he frequency of monitor-
      ing for organics (PCB's) by large cities is assumed to be 1 sample
      every 5 years.  (Monitoring for organics (PCB's)  if only required
      under Option 2 of the regulations and only large  cities select
      Option 2.)

                        SLUDGE MONITORING COST

                           Unit Cost                Frequency of Sampling
    Analysis              ($/Sample              	#1 Year	
                                                  Large Cities  Small  and
                                                                Medium Cities

Cadmium                       10                       82

Lead                          10                       82

Nitrogen                      40                       82

Organics (PCBs)               250                       1            N/A

3.    Lime addition for pH adjustment based on 1.0 ton/acre of lime
      to raise pH from 6.0 to  6.5.  (This is equivalent to 2.25 mt/ha.)
      Agricultural lime cost was assumed to be S49/mt,  thus a cost of
      $87.70/ha.   At a sludge  application rate of 10 mt/ha,  this is
      S8.77/mt of sludge.   This value was increased to  SlO/mt to cover
      miscellaneous realted testing and sampling costs.   The less
      restrictive requirement  (pH from 6.0 to 6.2)  was  assumed as being
      .5 tons lime/acre or using the same procedure as  above $5/mt.
      Similarly,  the more  restrictive pH adjustment (from 6.0 to 7.0)
      was assumed to cost  $15/mt.

4.    Land costs  vary widely across the nation,  and estimating an
      average cost per hectare is extremely difficult.   However,  for
      the purposes of this analysis,  an  average unit cost of 55000 per
      hectare was selected. Assuming that an average of 225 kg/ha
      of nitrogen can be used  as fertilizer,  and assuming one third
      of the nitrogen applied  to the land is lost either to the atmos-
      phere or elsewhere,  an average of  336 kg/ha of nitrogen must be
      applied to  the land  to meet the needs of an average crop.
      Assuming that sludge is  1 percent  plant available nitrogen,  1
                                B-49

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                      TABLE  B-6  (Continued)

      hectare requires 33.6 mt of sludge to fulfill its nitrogen
      needs.   Combining  this requirement with the cost of $5000 per
      hectare,  the annualized cost of land is $24/mt.   Only cities
      selecting Option 2 of the regulations are assumed to purchase
      the land prior to  the spreading of sludge.   Since it was assumed
      that only large cities select Option 2, no land  cost is presented
      for small cities.

5.    Landfill estimates include transportation costs, and are based
      on the  best available data,  which  is rpesented in Process Design
      Manual  Municipal Sludge Landfill,  U.S.  EPA Technology Transfer,
      October,  1978, EPA 625/1-78-010.   Errors in this document have
      been noted and compensations have  been  made in this cost methodology.

6.    These estimates include the average cost of incineration and heat
      treatment.  For incineration,  the  estimates assume a 20% filter
      cake, and do not include ash disposal.   For heat treatment, recycle
      treatment and odor control are included.   The estimates are
      based on the best  available data presented in Effects of
      Thermal Treatment  of  Sludge on Municipal Wastewater Treatment
      Costs,  Ewing,  L. J.,  et.  al-,  for  the U.S.  EPA Municipal Environ-
      mental  Research Laboratory,  Cincinnati, June, 1978, EPA 600/2-073.

7.    For composting, no hauling costs are included.  This data was
      taken from "Sewage Sludge Composting,"  Sludge Treatjnent_and
      Disjposaj^.  Chapter  8,  by G.  M.  Wesner, for U.S. EPA Technology
      Transfer,  October,  1978,  EPA 625/4-78-012.

8.    Non-food-chain landspreading costs were assumed  to be equal
      to food-chain landspreading costs  with  surface application with
      subsequent incorporation into the  soil.  See footnote 9.

9.    Due to  the large number of system  variables and  the wide range of
      values  possible for each of these  variables,  single unit costs
      for land application  of sludge are extremely difficult to obtain.
      Or rather, they are difficult  to transfer from one system to
      another.   These variables are  as follows:

        Climate:  Temperature,  rainfall  patterns
        Soils:   Clay, loam,  sand
        Type  of Transport:   Truck, pipeline,  rail,  barge
        Application Method:   Injection,  liquid spray (truck or
                             sprinkler), dewatered
        Incorporation Method.-   None,  disking, plowing, infection
        Distance from Plant to Site:   Less than 5 miles to 100 miles
        Local Health Requirements:   Restrictive loading rates,  con-
                                    straints  on incorporation methods,
                                    treatment requirements prior to
                                    land spreading, etc,
                                B-50

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                 TABLE B-6  (Continued)

      Most equipment or processes used in wastewater and  sludge
treatment are mechanical and are not as susceptible to  local
conditions as transport and disposal systems.

      For this study three types of land application systems were
chosen:   injection,  surface spreading with incorporation  into
the soil, and surface spreading without incorporation into the
soil.  The unit costs presented in Table V-6 are a weighted
average of the unit costs for these three systems, based  on the
following assumptions regarding current practices:

         20% injection
         40% surface application with incorporation into  the
           soil
         40% surface application without incorporation  into the
           soil

The unit costs for a liquid injection system assume one-way
transport distances of 5, 10, and 20 miles for the three  size
ranges of treatment plants.  The small facilities' costs  were
based on using the same truck for hauling and injecting.  The
medium and large facilities costs were estimated with pipelines
used for transport.   The second set of unit costs are based on
surface spreading liquid sludge at a high rate with incorporation
by disking or plowing at a later time.  The same assumptions
are used for haul distances and modes of transportation.  The
third set of limit costs are based on surface spreading liquid
sludge at a high rate without incorporation into the soil.  Again,
the same assumptions discussed above are used for haul distances
and modes of transport.  All costs are based on 1,  10,  25 mgd
facilities to represent the three sizes of POTW's,  under  consi-
deration :

         In jectj-on

               Small Facility:  $38/mt injection plus $24/mt
                                hauling = 562/mt (same  truck to
                                haul and inject, 6% solids "Big
                                Wheels" type injection system)
               Medium Facility:  $16/mt injection plus $39/mt
                                pipeline = $55/mt (6% solids,
                                "Big Wheels" type injection
                                system)
               Large Facility:  $16/mt injection plus S29/mt
                                pipeline = $45/mt (6% solids,
                                tractor-towed injection system)
                          B-51

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                       TABLE  B-6  (Continued)
                Surface  Landspreading  with  Plowing or  Disking AJrtej:
                Spread
                      Small  Facility:   $50/mt  haul and spread with same
                                       truck

                      Medium Facility:  $5/mt spread/disk-in plus S39/mt
                                       pipeline

                      Large  Facility:   $5/mt spread/disk-in plus $29/mt
                                       pipeline

                   Surface Landspreading  Without Plowing or Disking After
                   Spread
                   -   Small  Facility:   $47/mt haul  and spread with same
                                       truck

                      Medium Facility:  $3/mt  spread plus $39/mt
                                       pipeline

                      Large  Facility:   $3/mt  spread plus S29/mt
                                       pipeline

       Transport costs are  from:   Transport of Sewage Sludge, U.S. EPA
       Office of Research and Development,  Cincinnati, December,  1977,
       EPA 600/2-77-2/6.
10.     Dewatering Costs assume vacuum filtration.   Estimates are based
       on data presented in Municipal Wastewater Sludge Alternatives ,
       Prepared by G.  L. Gulp and D.  J.  Hinrichs,  for the U.S. EPA
       Technology Transfer, National  Conference on 208 Planning and
       Implementation,  January,  1977 ,  (1.25 multiplier used to convert
       to current dollars) .

-------
     •    Costs  to  comply with  the  regulations   in order  that
          landspreading  activities  may continue   under Option  1

     •    Costs  to utilize an alternate method of disposal if  the
          annual  cadmium  limitations preclude  continued   land-
          spreading under Option  1.

All values are based on 1978 dollars,  and capital  investments are in-

cluded by  assuming a ten year planning period and  a ten percent inte-
rest rate.


     The goal of the  economic analysis  is to define  the incremental

unit  costs  associated with the  regulations.    The incremental  unit

costs  can be developed from Table  B-6 for the three cases   of concern
as follows:


     •    Option 1 Landspreaders.    The  incremental unit   costs
          incurred  by a POTW which continues  to landspread   are
          those unit costs listed in TableB-6.

     •    Option 2 Landspreaders.    The incremental unit    costs
          incurred  by a POTW  which switches to  Option 2   land-
          spreading  are those  unit costs listed   in  Table B-6.

     •    Landfill, Thermal Processing, Other.    The incremental
          costs incurred by a POTW which switches to an alternate
          method  of disposal can be derived from the unit   costs
          listed in Table B-6.   The incremental  unit cost  asso-
          ciated  with each alternative  is the sura  of the  unit
          cost of the new  disposal method plus  the unit cost of
          dewatering  minus the unit  cost of  the  current   land-
          spreading practice.     (The fact  that a  given POTW  is
          forced  to  stop  an  existing practice   results   in an
          effective cost savings to that POTW.   Hence,  the cost
          of the  current  landspreading  practice  must be  sub-
          tracted from the cost of the new disposal method.)

     e.   Estimating National Costs


          The  final component of the cost  methodology ties   together
the previous four components and results in an estimate of the nation-

al  costs of the  final landspreading regulations  and three alternate

regulations.  Figure B-2 illustrates the sequence in which these costs
were developed.
                                  B-53

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     The methodology assumes that,   because the data base used in the
analysis accounts  for only 38 percent  of all sludge estimated to  be
landspread,  a national projection of costs could be derived by multi-
plying the cost  to the sample set by a factor of 2.6 (100/38).    Na-
tional projections  include a fixed  cost per facility/  multiplied by
the  number of facilities  in the  sample set,  multiplied by  the 2.6
scale-up  factor. Although the numbers  of large and medium facilities
are fairly  representative of their proportion  of the national total,
the projected number of small  facilities currently food-chain landsp-
reading is  understated.     Hence,   while   an  attempt  has  been
made  throughout  the analysis  to forecast  the maximum  cost of  the
regulations,  the cost to small  facilities and  to the nation  may in
this  regard be understated  by several hundred thousand  dollars on a
nationwide basis.

     Dnlike surface  impoundments and landfills,  landspreading is not
yet subject to formal regulations  in most States.  For the purpose of
this analysis,  State-standard-induced costs were  assumed  to account
for 10 percent of the total regulatory cost.  The remaining 90 percent
was assumed to be induced by the federal  regulations, i.e., Federally
induced.

     The projected nationwide  costs of the  four regulatory  alterna-
tives were further analyzed for impacts  on residential sewer charges.
The results are based on a telephone survey of all POTWs in the sample
set  which  are currently  spreading sludge  to food-chain land.   The
survey determined, for each POTW contacted:

     •    the existing residential sewage treatment charge
     •    the number of residential users
     •    the proportion of total wastewater influent generated by
          residential users.

For each regulatory alternative,   the incremental costs  to  the POTW
were  calculated  according  to the  post-regulatory disposal  option,
based  on whether the POTW  could continue landspreading  under Option
1,  or must adopt an alternative disposal method.    Several  critical
assumptions were made in this analysis:
                                  B-55

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     •    If  not precluded  from Option 1 landspreading,  a POTW
          will continue  landspreading,  but must bear additional
          administrative,  monitoring,  and soil pH control costs.
          If  precluded  from  Option 1,  the POTW  must bear  the
          additional costs of an alternate disposal method.

     •    The incremental unit costs  presented  in Table B-6  are
          applicable to the POTW1s surveyed.  Case studies of the
          incremental costs  of disposal  were not made  for each
          POTW surveyed.   The  methodology  assumes  that  case-
          by-case divergences will  be offsetting  in the  aggre-
          gate.

     •    Incremental costs to a POTW  are paid by households  in
          proportion  to the quantity of wastewater  generated by
          all  residential users served by that POTW.    In prac-
          tice,  because utility rate structures often favor large
          industrial  users  by  charging  a lower  average  fee,
          residential  users are  likely  to pay more  than  this
          proportion.   The assumption of proportional payment is
          made here to simplify the analysis by avoiding detailed
          studies of industrial  cost recovery systems on a case-
          by-case basis.


     Based on the number of residential users supporting a given POTW,

the proportion  of wastewater generated by them,   and the incremental
unit  cost data,   a projected incremental cost per  household was com-
puted and  compared to the existing charge  per household to determine
the percent increase.
     4.   Methodology and Assumptions for the Industry-by-Industry

          Analysis for the Manufacturing Industries


     a.   Data Source


          The Fred C. Hart Associates,  Inc.  study,  "The Technology,

Prevalence  and Economics  of Landfill  Disposal of Solid Waste",  was

used  as the base source of data for industrial on-site landfills.  In

addition,   the 19T2. Census of Manufacturers,   compiled  by the  U.S.

Bureau  of the Census,  provided data on numbers of  industrial estab-

lishments  by  two-digit SIC code.   For  data on  industrial  surface

impoundments,  the Geraghty & Miller report,  Surface Impoundments and

Their  Effect cm Ground Water Quality in the United States  (Ref. 107)

was used.

                                  B-56

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     b.   Assumptions and Other Data Considerations

          (1)  Impact Receptors

               For purposes of this analysis,  the following manufactur-
ing industrial groups were considered:
                                             On-site
                                             Landfills
          Surface
         Impoundments
SIC 20 - Food Processing
SIC 21 - Tobacco
SIC 22 - Textile Mill Production
SIC 23 - Apparel
SIC 24 - Wood Products
SIC 25 - Furniture
SIC 26 - Paper Products
SIC 28 - Chemicals Products
SIC 29 - Petroleum
SIC 30 - Rubber & Plastics
SIC 31 - Leather
SIC 32 - Stone, Clay
SIC 33 - Primary Metals
SIC 34 - Fabricated Metals
SIC 35 - NonElectrical Machinery
SIC 36 - Electrical Machinery
SIC 37 - Transportation Equipment
SIC 38 - Instruments
SIC 39 - Miscellaneous Manufacturing
X
X
X
X
X
X
X
X
X

X
X
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
     This information was obtained from the above referenced reports.
                                  B-57

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          (2)  Applicable Criteria

               The criteria which were determined to have economic im-
pacts were the same as those considered relevant  for the landfill and
surface impoundment assessments discussed above.   The assumptions for
these  criteria remain the same as well.    For the  ground-water cri-
teria,    because it affects disposal facilities  differently based on
the rate of  infiltration in individual States, the  following method-
ology was applied:

          The number of establishments of each relevant  industry
          segment  in  each  of the  net  infiltration States was
          totaled,  as were  those in the  negative  infiltration
          States.

     -    Each of these groups  was expressed  as a percentage of
          the national population.

          These  percentages were  applied  to the  landfills for
          each  industry  to determine  the number  of facilities
          affected  by  the   ground-water  compliance   scenario.

          (3)  Technologies and Cost Considerations

               For purposes  of assessing  the costs  to the  manufac-
turing industries, the following assumptions were made:

     •    All onsite industrial landfills required  upgrading for
          compliance  with each  of the criteria,  except for the
          disease criterion, the toxic  and explosive gases  com-
          ponents  of the  safety criteria,  and the ground-water
          criteria.

     •    10  percent  of the on-site  industrial landfills  were
          upgraded for  the disease  vectors  criterion  and  the
          gas components of the safety criteria.
                                  B-58

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     •    All wetlands facilities were upgraded  for  the ground-
          water criteria.    Fifty percent of  those landfills in
          net  infiltration areas were upgraded; fifty percent of
          the total surface impoundments were upgraded.

     •    No  on-site  industrial  landfills were  considered for
          closure.

     •    Two-thirds  of the  industrial surface  impoundments in
          floodplains  and wetlands  required upgrading  or clos-
          ure.   Five percent of the total located in these areas
          were closed.

     •    Twenty-five percent of the  industrial surface impound-
          ments were upgraded  for the access  component  of  the
          safety criteria.

     c.   Data Base and Costs

          (1)  On-Site Industrial Landfills

               The following  methodology  was used  to determine  the
costs  of upgrading  all on-site  industrial landfills  on an industry-
by-industry basis to meet the Federal criteria.

     The Fred C. Hart Associates, Inc.  study (Ref. 141)  provides the
number  of  on-site  industrial  landfills  by size category for  each
relevant  (as determined  by  the  Fred C. Hart Study)  two-digit  SIC
manufacturing industry.

     Based on the assumption  that all  on-site  industrial  landfills
need  upgrading,  the compliance  costs for each industry may be found
using the following calculation:

Costs for Industry X = (number of facilities10TpD x upgrading costs10TpD)

                     + (number of facilities100TpD x upgrading costs100TpD)

                     + (number of facilities 3QOTpD x Upgrading costs300TpD)
                                  B-59

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          (2)  Surface Impoundments

               The Geraghty  &  Miller report (Ref. 107)  provides, by
industry,  the total number  of surface impoundments  for each relevant
industry.    The percentage of the  total number of industrial  surface
impoundments  provided by this  report was applied  to the total number
of industrial surface impoundments obtained through State revisions to
provide a revised number of surface impoundments for each industry.

     These impoundments were  divided into the two size categories for
each industry.    Ninety-five percent were in the  2.5 acre size cate-
gory, and five percent were in the 50 acre size category.

     Costs were assessed based  on the following,  for  each  relevant
criterion:

Cost for Industry X = (number of impoundments needing upgrading x cost
                       to upgrade) +
                      (number of impoundments needing closure x cost to
                       close)

          (3)  Total Costs

               Total costs were assessed  by adding the cost for land-
fills  and  surface impoundments  for each industry.    Further, these
costs were expressed as a  percentage  of total annual sales  for each
industry, based on Bureau of Census (Ref. 150) data.
                                  B-60

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       APPENDIX  C







SELECTED INDUSTRIAL STUDIES
        C-l

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                    TABLE OF  CONTENTS
INDUSTRIAL STUDIES                                        Page
A.   SUMMARY
     1.   Background and Methodology                     C-9
     2.   Mining Industry                                 c-13
     3.   Coal-Fired Utility  Industry                    c-25
     A.   Iron and Steelmaking  Industry                  c-30
B.   A STUDY OF THE COST IMPACTS  OF SECTION 4004 OF
     THE RESOURCE CONSERVATION  AND RECOVERY ACT (RCRA)
     ON THE DISPOSAL OF NON-HAZARDOUS WASTES FROM
     MINING.
                                                          f-^4
     1.   Summary                                         ^
     2.   Development of Model  Plants                    c-40
     3.   Baseline and Criteria-Induced Control          c-42
          Technologies for  Tailings and Mine Wastes
          at Model Plant
          a.   Ground Water                              C-52
          b.   Surface Water                              C-53
          c.   Wetlands                                   C-59
          d.   Floodplains                                C-62
          e.   Air Quality                                C-63
          f.   Closure                                    C-64
     4.   Costs and Cost Methodology                     C-65
          a.   Baseline and Above-Baseline Costs         C-56
          b.   Costs per Unit of  Waste and Product       C-67
          c.   Cost Methodology                          C-67
               (1)  Capital Costs                        C-67
               (2)  Annualized  Capital Costs and         C-69
                    Trust Funds                          C-71
               (3)  Other Annual  Costs                   C-71
          d.   Configuration  and  Costs of Control        C-71
               Methods
               (1)  Tailings  Ponds                       C-72
               (2)  Ground-Water  Evaluation              C-73
               (3)  Site Evaluation                      C-74
                   C-2

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                                                               Page

           (4)  Leachate  Collection System                    C-74
           (5)  Monitoring  Wells                              C-74
           (6)  Diversion Ditches                             c~74
           (7)  Dike  Formation,  Soil Coverage,                C-74
               Revegetation                                  C-76
           (8)  Waste Transportation                          C-78
           (9)  Dewatering  Tailings Ponds for                 C-79
               Closure                                        C-79
5.   References                                               C-79
THE COST IMPACT OF SECTION 4004 OF THE RESOURCE              C-80
CONSERVATION AND  RECOVERY  ACT ON THE COAL-FIRED
INDUSTRY                                                      C-80
1.   Summary                                                  C-84
2.   Development  of  Model  Plant                              C-84
3.   Solid Waste  Costs  for New Facilities                    C-89
     a.   Ground  Water                                        C-91
     b.   Wetlands                                            C-93
     c.   Floodplains                                        C-96
4.   Costs of 4004 on Existing Facilities                    C-99
     a.   Ground  Water                                       C-100
     b.   Wetlands                                           C-102
     c.   Floodplains                                       C-104
5.   References                                              C-107
6.   Appendix                                                C-109
COST OF IRON AND  STEELMAKING NON-HAZARDOUS SOLID            C-155
WASTE DISPOSAL TO MEET  THE 4004 CRITERIA                    C-155
1.   Summary                                                 C-156
2.   Major Assumptions                                       C-156
     a.   Off-Site  (Lining Material Insitu)                 C-162
     b.   Off-Site  (Lining Material Non-Insitu)             C-163
     c.   On-Site (In Floodplain,  Lining Material Non-InsitC-164
     d.   On-Site (Not  in  Floodplain, Lining Material       C-164
          Non-Insitu)
4.   Steel Industry  National Costs in Complying             C-165
     with the Criteria
5.   Costs Directly  Attributable to 4004 Criteria           C-166
     a.   Ground  Water                                       C-166
     b.   Floodplains                                       C-168
     c.   Section 4004  Induced Costs                        C-169
6.   Calculations                                           C-170
                        C-3

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TABLE                   LIST OF TABLES                            PAGE

 0-1        ESTIMATED NON-HAZARDOUS WASTE  QUANTITIES             C-J.O

 0-2        ESTIMATED COMBINED COST OF COMPLIANCE COST OF        °~15
           COMPLIANCE WITH STATE AND OTHER  FEDERAL REGULA-
           TIONS AND SECTION 4004

 C-3        TOTAL COMPLIANCE COSTS AS ATTRIBUTABLE TO STATE      C~16
           AND  OTHER FEDERAL REGULATIONS  AND SECTION 4004
           CRITERIA

 C-4        ESTIMATED COMPLIANCE COST PER  UNIT BASIS             C-16a

 0-5        ESTIMATED MINING INDUSTRY PRODUCTION AND NON-        C-18
           HAZARDOUS WASTE QUANTITIES

 0-6        ESTIMATED TOTAL BASELINE AND GOVERNMENT-INDUCED      C-21
           COSTS BY INDUSTRY AND BY CRITERION

 0-7        ESTIMATED ANNUAL QUANTITIES OF NON-HAZARDOUS SOLID   C-32
           WASTES GENERATED BY THE IRON AND STEELMAKING IN-
           DUSTRY IN 1977

 C-8        ESTIMATED MINING INDUSTRY PRODUCTION AND NON-        c-36
           HAZARDOUS WASTE QUANTITIES

 C-9        ESTIMATED NATIONAL BASELINE AND  REGULATORY COSTS     C-3 8
           FOR  NON-HAZARDOUS MINING WASTE CONTROLS

 C-10       ESTIMATED REGIONAL PERCENTAGES OF LOW OR HIGH        c-52
           WATER TABLE USED IN ANALYSIS OF  GROUND WATER
           CRITERION

 C-ll       ESTIMATED TOTAL BASELINE AND GOVERNMENT-INDUCED      C~54
           COSTS BY INDUSTRY AND BY CRITERION

 012       ESTIMATED BASELINE AND REGULATORY COSTS PER UNIT     C~55
           BASIS

 O13       ANNUITY FACTORS FOR MAJOR MINING INDUSTRIES WITH     C-70
           NON-HAZARDOUS WASTES

 C-14       EQUATION FOR TRUST FUNDS                              C~71

 0-15       SURFACE AREAS OF NON-HAZARDOUS MINING WASTES BY      c-77
           INDUSTRY MODEL PLANT

 C-16       COSTS FOR SOLID WASTE DISPOSAL,  MODEL 1000 MW PLAN'.  c-87
                             C-4

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TABLE                                                          PAGE


 C-17      COST OF UPGRADING AND CLOSURE, MODEL  1000 MW      C-103
          PLANT

 C-1F      ESTIMATED COST OF FLYASH POND                      C-112

 C-19      FLYASH POND- ANNUAL  0 & M COSTS                    C-llP

 C-20      ESTIMATED COST OF FLYASH LANDFILL                  C-117

 C-21      FLYASH LANDFILL - ANNUAL O & M COSTS               C-120

 C-22      ESTIMATED COST FOR CO-DISPOSAL OF FLYASH AND      C-121
          SLUDGE POND

 C-23      ESTIMATED FLYASH/SLUDGE POND - ANNUAL 0 & M       C-125

 C-24      ESTIMATED COST FOR CO-DISPOSAL OF FLYASH AND      C-126
          SLUDGE LANDFILL

 C-25      FLYASH/SLUDGE LANDFILL - ANNUAL 0 & M             C-128

 C-26      NATIONAL SOLID WASTE COSTS - NEW FACILITIES       C-132

 C-27      CRITERIA-INDUCED COSTS - NEW FACILITIES           C-133

 C-23      CAPITAL COST - CLAY  LINER                          C-134

 C-29      MONITORING COSTS                                    C-135

 C-30      LEACHATE TREATMENT AND COLLECTION                  C-136

 C-31      COST OF DIKING                                      C-137

 C-32      CORRECTION FOR DIFFERENT DIKING ASSUMPTIONS       C-138

 C-33      CAPITAL COST - DIKING                              C-140
 C-34     CRITERIA-INDUCED COST - EXISTING FACILITIES       C-144

 C-35     ASSUMPTIONS FOR EXISTING SITES                     C-145

 C-36     COST OF CLOSURE                                     C-146

 C-37     COST OF REPLACEMENT  FACILITY                       C-147

 C-38     COST OF UPGRADING                                   C-148

 C-39     COST OF FLOOD PROTECTION                           C-149


                              C-5

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TABLE                                                          PAGE

 C-40      EXISTING SITES:  STATES AND CORRESPONDING         C-150
          CAPACITIES FLOODPLAIN CRITERIA

 C-41      EXISTING SITES:  STATES AND CORRESPONDING         C-151
          CAPACITIES GROUND WATER CRITERIA

 C-42      MEGAWATT CAPACITIES IN STATES WITH WETLANDS       C-152

 C-43      DRY  AND  WET BULK DENSITIES OF FGD WASTE PRODUCTS  C-154

 C-44      ESTIMATED ANNUAL QUANTITIES OF  NON-HAZARDOUS
          SOLID  WASTE GENERATED BY THE IRON AND STEELMAKIN  C-157
          INDUSTRY IN 1977

 C-45      PRODUCTION DATA FOR TYPICAL INTEGRATED PLANT      C-15S

 C-46      ESTIMATED ANNUAL QUANTITY OF PROCESS SOLID WASTE  C-159
          GENERATED BY A TYPICAL IRON AND STEELMAKING PLAN'.

 C-47      ANNUAL VOLUME OF WASTES FROM A  TYPICAL PLANT      C-160
 C-43      CALCULATIONS FOR COSTS OF MODEL  IRON AND STEEL-  C-171
          MAKING DISPOSAL FACILITIES

 C-49      NATIONAL STEEL INDUSTRY COST                      C-174

 C-50      LEACHATE COLLECTION POND                          C-176

 C-51      COSTS  DUE TO CRITERIA                             C-177

 C-52      ADDITIONAL AVERAGE UNIT COST  ATTRIBUTABLE TO THE C-179
          CRITERIA
 C-53      COSTS  TO COMPLY WITH THE  CRITERIA

 C-54      ESTIMATED AVERAGE UNIT DISPOSAL COSTS             C-181

 C-5F      ESTIMATED ANNUAL COST TO  THE  STEEL INDUSTRY FOR   C-182
          DISPOSAL OF NON-HAZARDOUS SOLID WASTE IN COMPLIANCE
          WITH CRITERIA
                             C-6

-------
                          FIGURES

FIGURE                                                        PAGE

 C-l      COPPER MINING AND BENEFICIATING MODEL PLANT       C-43

 C-2      IRON ORE MINING AND BENEFICIATING MODEL PLANT     C-44

 C-3      MOLYBDENUM MINING AND BENEFICIATING MODEL PLANT   C-45

 C-4      GOLD MINING AND BENEFICIATING  MODEL PLANT         C-46

 C-5      LEAD/ZINC MINING AND BENEFICIATING MODEL PLANT    C-47

 C-5      PHOSPHATE MINING AND BENEFICIATING MODEL PLANT    C-48

 C-7      CLAY MINING AND BENEFICIATING  MODEL PLANT         C-49

 C-S      CRUSHED, BROKEN, AND DIMENSION STONE MINING       C-50
          MODEL PLANT

 C-9      SAND AND GRAVEL MINING MODEL PLANT                C-51

 C-10     CONTROLS INDUCED BY RCRA  GROUND WATER CRITERIA    C-53
          COVERING NON-HAZARDOUS WASTES  FROM THE MINING
          INDUSTRY

 C-ll     CONTROLS INDUCED BY RCRA  SURFACE-WATER CRITERIA   C-59
          COVERING NON-HAZARDOUS WASTES  FROM THE MINING
          INDUSTRY

 C-12     CONTROLS INDUCED BY RCRA  WETLANDS CRITERIA        C-61
          COVERING NON-HAZARDOUS WASTES  FROM THE MINING
          INDUSTRY.

 C-13     CONTROLS INDUCED BY RCRA  FLOODPLAIN CRITERIA      C-62
          COVERING NON-HAZARDOUS WASTES  FROM THE MINING
          INDUSTRY

 C-14     CONTROLS INDUCED BY RCRA  AIR QUALITY CRITERIA     C-54
          COVERING NON-HAZARDOUS WASTES  FROM THE MINING
          INDUSTRY

 C-15     CONTROLS INDUCED BY RCRA  CLOSURE CRITERIA         c-65
          COVERING NON-HAZARDOUS WASTES  FROM THE MINING
          INDUSTRY

 C-16     TOTAL NATIONAL SOLID WASTE  COSTS - NEW FACILITIES c-129
          SCENARIO I

 C-17     TOTAL NATIONAL SOLID WASTE  COSTS - NEW FACILITIES c-130
          SCENARIO II
                             C-7

-------
FIGURE                                                         PAGE
 C-18      TOTAL NATIONAL SOLID WASTE COSTS  - NEW FACILITII   C-131
          SCENARIO  III

 C-19      UPGRADING COSTS FOR EXISTING  FACILITIES -          C-141
          SCENARIO  I

 C-20      UPGRADING COSTS FOR EXISTING  FACILITIES -          C-142
          SCENARIO  II

 C-21      UPGRADING COSTS FOR EXISTING  FACILITIES -          C-143
          SCENARIO  III

 C-22      NATURAL WETLANDS MAP                                C-153

 C-23      DIAGRAM OF A SANITARY LANDFILL WITH LEACHATE       C-167
          COLLECTION

-------
                          EXECUTIVE SUMMARY

                   C.   INDUSTRY SPECIFIC STUDIES

     The following chapter examines the cost impact of Section 4004 of
the Resource  Conservation  and Recovery Act   (RCRA) on three selected
industries:   1) mining;   2)  coal-fired utilities;  and 3)  iron and
steel.   These three sections were independently researched as part of
ongoing EPA inhouse and contract efforts concerning nonhazardous waste
generation  by specific  industry  sectors.    Major  characterization
efforts began in 1978 to provide the Office of Solid Waste with infor-
mation on industry characterization,  waste characterization,  current
and  future  treatment/disposal  practices,  and  the  cost  impact of
Section 4004.

     These three industries  are the  largest  volume waste  producing
industries.   Table  C-l   shows the  most  currently  available  non-
hazardous waste quantities for these industries.  A detailed breakdown
by industry segment  and type  of waste is available  in each specific
industry section.

     The inclusion  of this chapter in the economic impact analysis is
intended to give the reader more detailed information on the impact of
RCRA Section 4004 on these three industries.  The assumptions and unit
costs used are based  on specific industry  considerations,  including
knowledge  of current and planned disposal  practices  and alternative
control technologies available to meet specific 4004 criteria.   Where
practical,  assumptions and unit costs agree  with those utilized else-
where in this economic impact analysis.  However, certain instances do
occur where major assumptions regarding the impact of the Criteria and
unit costs for compliance  differ based on specific industry  informa-
tion.   These differences vary with each industry  and are outlined in
each industry section.

     It  should be noted that the control technologies in each chapter
which are assumed to meet the  Section 4004  criteria are not required
technologies  rather a set of alternative disposal options which would
meet the performance standards set forth.
                             C-9

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                            TABLE  C-I

             ESTIMATED NON-HAZARDOUS WASTE QUANTITIES
                       (million metric tons)
                              No. of Plants
                                                    Total Annual
                                                  Waste Generation
MINING
                                 14,187
1,295
COAL-FIRED UTILITIES
                                    399
                                                           65
IRON AND STEEL
                                    150
                                                           50

-------
     Those costs are maximum costs based on  immediate full compliance
of industrial open dumps.  It has been concluded that States will move
in a voluntary manner  utilizing available Federal funds  to implement
the criteria.   Because the total amount of Federal funds a State will
receive  will be small  compared to  the total financial  requirements
necessary  to implement the criteria,  and because most States  do not
currently  have the legislative  or regulatory authority  to permit or
classify  industrial  solid waste  disposal  facilities,  it  has been
concluded most States will focus first  on landfill facilities receiv-
ing general municipal waste.  It appears that States will need approx-
imately 3 years  to make classification determinations  on  just these
facilities.   Based on this trend it is difficult to predict the exact
year of compliance  and the number of industrial facilities which will
upgrade or close.

     The annualized  solid  waste  disposal  costs  are shown  in 1978
dollars.   Annualized solid waste costs  include the amortized portion
of capital expenses plus annual operation and maintenance costs.   The
annuity factor used to amortize the capital for each industry segment
may vary  due to different costs  of capital and life  of the disposal
facility.  For example, while the economic impact analysis has assumed
a 10 percent cost of capital and 10 year life for a disposal facility,
a 16 percent cost  of capital  and 30 year life  for  a new coal-fired
utility disposal facility is more realistic for this analysis.

     It currently costs  the coal-fired utility industry approximately
16 percent to raise capital through common stock, preferred stock, and
public bonds.   The life of a utility plant  is approximately 30 years
and  it is assumed  capital costs  for the disposal  facility  will be
amortized over this life.
                             C-ll

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     These costs  have been  broken down  by each  criterion  for each
industry  and total costs have been further analyzed  to show the cost
of compliance  with existing state solid waste,  other Federal regula-
tions,  and the criteria.   As stated previously,  state-induced costs
represent estimated costs  of complying with  existing state standards?
for the control of non-hazardous wastes. Other Federally induced costs
represent costs of complying  with existing Federal regulations  other
than Section 4004.   Criteria-induced costs are those costs of comply-
ing with Section 4004  that exceed  the compliance cost  for state and
other  Federal standards.   The individual capital  as well as  annual
operating  and maintenance costs  which comprise  the annualized solid
waste cost are shown  in each specific section.   The results of these
studies are summarized in Tables VII-2 through 4.

     Table  C-2  shows the cost impact of Section 4004  on these three
industries by criteria.   A range of costs  may appear because in some
cases,  two  scenarios  were  costed out  for wetlands.   One scenario
assumed all facilities currently disposing of their wastes in wetlands
would not be issued NPDES permits.   In this case, closure of existing
facilities and the establishment of new sites outside the wetland area
were costed out.   The second scenario assumed all facilities would be
granted NPDES permits.   Here,  additional technical requirements were
considered necessary to meet the ground-water and surface water crite-
ria,  but no costs were attributed directly  to the wetlands criteria.
It should be noted  here that the approach utilized in  these selected
industry studies varies from that previously employed in this document.
Because two of the three industries affected by the wetlands criteria,
—  mining  and  coal-fired  utilities  —  handle  their own disposal
operations  and cannot  depend on municipal or  private facilities for
disposal, denial  of  a NPDES  permit   would  require  closure of the
existing  facility  and  establishment  of a new facility outside  the
wetlands area.   The economic  impact analysis,  however,  covered all
national  disposal  and assumed,  if sites  in wetlands  were  closed,
wastes could be diverted to existing facilities  meeting the criteria.
It was not possible to predict either the alternative disposal options
available  to these facilities  or the number  of new facilities  that
would be required.
                              C-12

-------
     Table C-3   breaks these total national costs down  and indicates
what portion of the total costs are attributable to existing state and
other  Federal regulations,  and  what portion  are  Federally induced
costs.

     Table  C-4   indicates the increase  in disposal cost  per metric
ton of waste along with the increase in cost per unit of product.

MINING INDUSTRY

     The mining industry  produced  an estimated total  of 1.3 billion
metric tons of non-hazardous waste in 1975.   Ten industries generated
91%  of all non-hazardous  mining solid wastes  (excluding coal mining
wastes).   These ten industries are:   copper,  iron ore,  molybdenum,
gold,  lead, zinc,  phosphate, clay, stone,  sand, and gravel.   Table
VII-5 indicates non-hazardous waste quantities from each industry.

     It is estimated that it will cost the ten largest waste producing
mining  industries  between  a total  of 467  million  and 928  million
dollars  in annualized costs  to meet the combined state.  Federal and
Section 4004 criteria.  Between 183  and 635  million of these costs are
attributable  to existing state  and other Federal  regulations.   The
Federally induced  portion  of these costs  range between 284  and 293
million.   These are costs which will be incurred by the mining indus-
try beyond their current solid waste  expenditures  to meet the flood-
plains,  wetlands,  closure,  surface and ground-water requirements of
Section 4004 for all facilities.  The major assumptions used to derive
these costs are listed below according to criteria.
                              C-13

-------
     Table   C-3   shows these total national costs down  and indicates
what portion of the total costs are attributable to existing state and
other  Federal regulations,  and  what portion  are  Federally  induced
costs.

     Table   C-4   indicates the increase  in disposal cost  per metric
ton of waste along with the increase in cost per unit of product.

MINING INDUSTRY

     The mining industry  produced  an estimated total  of 1.3 billion
metric tons of non-hazardous waste in 1975.   Ten industries generated
91%  of all non-hazardous  mining solid wastes  (excluding coal mining
wastes).   These ten industries are:   copper,  iron ore,  molybdenum,
gold,  lead, zinc,  phosphate, clay, stone,  sand, and gravel.   Table
VII-5 indicates non-hazardous waste quantities from each industry.

     It is estimated that it will cost the ten largest waste producing
mining  industries  between  a total  of  467 million  and 928 million
dollars  in annualized costs  to meet the combined state.  Federal and
Section 4004 criteria.  Between 183 and 635 million of these costs are
attributable  to existing state  and other Federal  regulations.   The
Federally induced  portion  of these costs  range between  284 and 293
million.   These are costs which will be incurred by the mining indus-
try beyond their current solid waste  expenditures  to meet the flood-
plains,  wetlands,  closure,  surface and ground-water requirements of
Section 4004 for all facilities.  The major assumptions used to derive
these costs are listed below according to criteria.
                                    C-14

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     Costs attributable  to Section 4004 Criteria  and other state and
Federal legislation  were determined  by using the concept  of a model
plant because, a detailed  site—by-site study was not possible.   It is
recognized  that many mines  will not meet  the model plant specifica-
tions;  however, the costs derived through the methodology are assumed
to be reasonable averages.   Model plants  were developed  for each of
the  10 major mineral  industries.  These plants  represent  a typical
production level,  with typical quantities of tailings and mine wastes
generated.   Model plants also reflect  any current control methods to
the extent that they are practiced  within the industry.   Most mining
industries are now using some control technologies to satisfy at least
some portion of the Section 4004 criteria.

     The copper, iron ore, gold, lead/zinc, clay, and stone industries
have minimal diversion ditching  to prevent surface waters  from reac-
ting with overburden piles.   These industries  also have minimal clo-
sure practices for overburden, usually involving grading and revegeta-
tion.  Twenty percent of the facilities in these mining industries are
assumed to use diversion ditching  and ten percent  are assumed to use
closure practices.   It is assumed 80 percent of the molybdenum indus-
try makes use  of diversion ditches  and 80 percent  of the molybdenum
and 80 percent of the phosphate industry commonly grade and revegetate
their overburden.   Unlined ponds are assumed to be  the baseline con-
trols  used by clay,  sand and gravel  tailings.   Minimal closure  of
tailings  ponds  is practiced  by 10 percent  of the clay,  sand,  and
gravel industry.

     The additional control technologies necessary to meet the Section
4004 Criteria  were formulated and are discussed below  along with the
corresponding costs.
                              C-17

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                             TABLE   C-5

 ESTIMATED MINING INDUSTRY  PRODUCTION  AND NONHAZARDOUS
        WASTE  QUANTITIES  (1,000  metric  tons/year)
Mining
industry
Copper
Iron ore
Molybdenum
Gold
Lead/zinc
Phosphate
Clay
Stone
Sand and
gravel
Coal
Other ^ '
Total
No. Of
mines
61
68
3
99
33/36
47
1,249
5,584
7,007
6,459


H
Product
4,
80,

0.
16,
44,
39,
815,
718,
573,
829,

237
160
55
021
840
600
770
400
000
300
000

Nonhazardous wastes**
Tailings Mine wastes
627
234
10
2,740 8
4
62,500™ 150
2,275 33
Negligible 66
,900
,800
,740
,408
,778
,200S
,760
,160
35,900 Negligible

21,840' 97
125,255 ^^
i;
,730S
,476
Total
627,
234,
10,
11,
4,
212,
36,
66,
35,
'
119,
1.359,
900
800
740
148
778
700
035
160
900

570
731
      Represents  tailings  from gold placer mining.  Other gold
mining tailings are  considered hazardous.
      Fifty percent  of  tailings  from other mining industries are
considered to be  nonhazardous.
      Thirty percent of all phosphate mine waste in Florida is
considered hazardous (i.e., thought to contain radium 226 that
emits radioactivity  in  excess of a proposed 5 picocurie per gram
standard)  and thus is not  included in this number.
     *Coal mine wastes  are regulated by the Surface Mining Control
and Reclamation Act  and were not considered in this study.  The
March 13,  1979, Federal Register contains the Permanent Regulatory
Program of Surface Coal Mining and Reclamation Operations.  Esti-
mated costs of control  methods for nonhazardous wastes from coal
mining are presented in a  report entitled "Permanent Regulatory
Program of the Surface  Mining Control and Reclamation Act of 1977,
Final Regulatory  Analysis  (OSM-RA-1), March 1979."

      All  mine wastes from other mining industries are considered
to be nonhazardous.
       The quantities shown were taken from "Study of Adverse
Effects of Solid  Wastes from All Mining Activities on the
Environment."  The quantities represent 1975 Btatisties based on
Tables 2 and 11 of  the  preprint  from the 1975 Bureau of Mines
Minerals Yearbook.
     ^Includes more than  20 industries.

       These quantities represent  the final products from the
mining industries (e.g., concentrate from beneficiation plants)
with the exception of gold which represents the pure product.

       Represents sand  tailings.
                               C-13

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Ground Water

     It was  assumed  the construction  of diversion  ditches would be
sufficient to direct water away from overburden and waste rock dispos-
al areas and protect the ground water.

     In order  to  determine  the control  technologies  required  for
industries which generate non-hazardous tailings, an evaluation of the
water table  is necessary to determine  whether leachate from existing
unlined  tailings  ponds  would adversely  affect  the quality  of the
ground water.   Regional percentages were calculated which reflect the
percentage  of land  with high  and low  water tables.   The degree to
which a tailings pond will have an adverse impact  on the ground water
was determined by the region in which the industry is located.   Tail-
ings ponds  located  in geographical  regions  with  low  ground-water
tables were assumed  to need no additional controls  to protect ground
water.

     A site evaluation consisting of a hydrogeological survey, permea-
bility tests,  evaluation and report  would be necessary  to determine
the actual impact  on ground water  for tailings ponds  in areas  with
high water tables.  It is estimated that 80 percent of the site evalu-
ations  would  show  an insignificant  impact,  with the  accompanying
recommendation  that monitoring  wells  should be  installed  and data
collected quarterly at these sites.  These wells would be installed as
a precautionary measure  to insure  that no contamination occurs  at a
later time.  It is assumed the remaining 20 percent of the evaluations
would indicate significant  ground-water impact,  with the result that
these sites  would be  required  to install  collection wells  for the
leachate to prevent ground-water contamination, and install monitoring
wells  in appropriate  locations  to perform  quarterly checks  of the
leachate collection system.
                              C-19

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     It is estimated the total annualized cost for the raining industry
to meet the  state  and criteria  ground-water  requirements  is  116-
123 million dollars.  The distribution of the costs among the 10 major
mineral industries can be seen in Table  C-6.

Surface Water

     It is assumed  that the  same construction  of diversion  ditches
around mine waste piles  used to protect  ground water would also pre-
vent surface runoff from interacting with the wastes and carrying them
as suspended solids into surface water.  These costs have been equally
divided between the two criteria.

     An unlined tailings pond  is the current  control technology  for
all mining industries producing non-hazardous tailings with the excep-
tion of gold placer mines located primarily in California and Alaska.

     The cost of complying with  the surface water criterion  includes
the construction  of tailings ponds  for the  placer mine industry  as
well as  the construction of diversion ditches  around  existing ponds
and  the upgrading  of the  existing pond  dikes  by compaction,  soil
coverage, and revegetation.  The diversion ditches would direct waters
away from tailings ponds  to prevent the dikes  from being weakened or
washed out and reduce the chances of overflow.

     It is estimated  that the total  annualized cost  for the  mining
industry  to meet  the  surface water  criterion  is approximately  35
million dollars.  All these costs are attributable  to the Clean Water
Act.   The distribution of the costs among the 10 major mineral indus-
tries is shown in Table  C-6.
                              C-20

-------
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Wetlands Portion of the Surface Water Criteria

     Two scenarios  are considered for  tailings and other mine wastes
located in wetlands.   One scenario assumes that NPDES permits will be
granted to all mining industries  located in wetlands,  allowing solid
wastes to be disposed of within the area.   The second assumes that no
NPDES permits will be granted  and that all mining wastes generated in
wetlands will have to be transported out of the area.

     The specific industries located in wetlands  were calculated from
the percentages presented in  Table IV-27 (Volume I)  of this Environ-
mental Impact Analysis.   If additional information  was available re-
garding the locations of these mineral industry facilities relative to
the  wetlands,  it was used.    For example,   although 46 percent  of
Florida is wetlands, the majority of the Florida phosphate industry is
located in these wetlands;  therefore, it was assumed 90 percent would
be affected by the wetlands portion of the surface water criteria.

     It was assumed that if facilities were permitted to remain in the
wetlands (Scenario 1),  additional monitoring wells would be installed
around mining waste piles  as a  precautionary measure.   Dikes around
tailings ponds permitted to stay  in the wetland  would upgrade into a
3:1 slope structure.   It is estimated Scenario 1 will cost the mining
industry  approximately 13 million dollars  in annualized costs to in-
stall these additional control technologies.

     If the NPDES permit  was denied   (Scenario 2),  the mine would be
required  to close the existing site,  and purchase land  for the con-
struction of disposal facilities  for  tailings and mine wastes outside
the wetlands.  It is assumed wastes from all mining industries located
in wetlands would be trucked a distance of 16 km.  A distance of 32 km
was assumed for wastes from the Florida phosphate industry.

     Due to the distance involved,  the tailings slurry  would require
thickening to a 70 percent solid before it is transported by truck.
                              C-22

-------
     The estimated cost  to the mining industry for Scenario 2  is 500
million dollars in annualized solid waste costs.

Floodplains

     Diking is the principal method  selected to protect both tailings
ponds and mine wastes  from washout  by the 100 year flood.   For mine
wastes,  a 3 meter high,  3:1  slope dike  would be constructed around
accumulated plus newly generated waste.   Based on a national average,
it was assumed  that three sides  of a mine waste  pile  would require
diking with the fourth side of the pile located against a natural bar-
rier.

     Dikes  are the current  control  technology  for tailings  ponds.
Measures necessary  to prevent washout  by the 100 year flood  include
upgrading of existing pond dikes to a 3:1 slope,  compacting, covering
these dikes  with 0.6 meters  of soil  and seeding  and fertilizing to
prevent erosion.

     It was assumed  that 5 percent  of all mining industries  are lo-
cated in floodplains.    This is based  on the estimated average  per-
centage of land in the United States that is within floodplains.  This
average percentage figure is considered adequate since the location of
mining operations  is based  solely  on mineral deposits  rather  than
proximity  to the population,  transportation  or process requirements
(such as large sources of water).

     It is estimated that it will cost the mining industry 133 million
dollars in annualized solid waste costs  to comply with the floodplain
criteria.

Air Quality

     Current disposal practices  were assessed for their impact on air
quality.   It was assumed  that no additional  controls  would be nec-
essary to protect air quality.
                              C-23

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     Mine wastes  are not likely  to pose  an air quality problem  and
closure requirements would satisfy  long-term protection against fugi-
tive dust.

     Tailings from clay,  phosphate,  sand,  and gravel industries and
newly  built gold  placer mine  tailings ponds  are  or will  be  con-
tained in small ponds and are nearly all located  in non-arid regions.
As a result, the pond surface remains wet  a majority of the time  due
to the addition of  new tailings  and  the fact that the precipitation
rate  exceeds  the  evapotranspiration  rate for these  areas.   Other
tailings  ponds  containing hazardous waste  may have  a fugitive dust
problem  but are not addressed in this report.

Closure

     It is assumed that accumulated  and newly generated non-hazardous
mine waste will be closed  with 15 cm of soil cover  and that the soil
will  be  revegetated.   Regrading,  compaction,  soil coverage,  soil
amelioration and seeding would be required  for the accumulated mining
waste.   Newly generated waste would be spread out, compacted, covered
with soil,  and revegetated  on a continual basis.   It  is recognized
that arid,  barren areas of the country would not require top soil and
full revegetation.   Sand  or similar cover and scrub brush would   be
sufficient.   It is assumed the 15 cm of soil  is a reasonable average
cost.

     Closure of tailings ponds  includes dewatering of the pond,  soil
coverage, compaction and revegetation.

     The estimated cost of closure is 226 million dollars on an annua-
lized basis.  This cost is high due to the large number of accumulated
mining waste piles.

Combined Cost of Criteria

     As previously stated,  the range  of costs  for the entire mining
industry  to meet the combined State,  Federal,  and Section 4004 cri-
teria  is 523 million  to 1.0 billion dollars.   These costs  are con-
sidered to be the maximum costs of compliance with Section 4004.
                             C-24

-------
     Certain  costs  could be  reduced  depending  on the  enforcement
approach  taken by  the States  and the adopted  compliance  schedule.
Approximately  120 million  dollars  was  included  in the  floodplain
criteria costs  for protection  of clay,  stone,  and sand  and gravel
wastes against the 100 year flood.   Because these wastes  are present
as natural constituents of riverbeds, these costs may not be incurred.
In  addition,  closure costs,  one of the highest  individual criteria
costs  could be  reduced  if certain mine waste  piles were allowed to
remain as is in isolated and barren areas.

COAL-FIRED UTILITIES

     The coal-fired  utility industry  produces  two major  streams of
waste:    ash and flue gas  desulfurization  (FGD) sludge.    In 1977,
approximately  62 million  metric tons  of ash  and 2.5 million metric
tons of FGD sludge were produced by approximately 400 plants producing
approximately 200,000 MW of power.   It is estimated  by 1985 that the
350 new plants  coming on line will increase this national total to 70
million metric tons of ash and 10 million metric tons of FGD sludge.

     It was  estimated  that the  utility  industry  will incur  costs
between 159 and 246 million dollars in annualized solid waste costs to
upgrade existing facilities  and build new facilities  to comply  with
combined state, Federal and Section 4004 standards.   The three crite-
ria  having the  greatest impact  on this industry  are  ground water,
floodplains,  and the wetlands portion  of the surface water criteria.
It is assumed  that the  industry  is currently practicing  closure of
existing disposal facilities  which comply  with the Section 4004 clo-
sure requirements.
                              C-25

-------
     These national estimates  were extrapolated  from  unit costs de-
rived  from a model plant approach.   A 1000 MW capacity  was used for
this purpose.    Average dollar  per kw capital  investment  costs for
solid waste disposal  and dollar per ton  annual operating costs  from
these model plants were developed  based on average annual quantity of
187,000 metric tons of ash and 162,000 metric tons of sludge.

     A power-rating-size cost adjustment factor was used to offset any
economies  of scale which  may exist for new 1000 MW plants coming  on
line  but not for existing plants with an average capacity  of 500 MW.
It  was assumed a capital  cost of $1.00/MW for a 1000  MW plant would
equal $1.32 and an annual  operating cost of $1.00/ton of waste  would
equal $1.39 for a 500 MW plant.    An average of $1.35  was applied to
annualized costs to more accurately reflect costs.

     Utility wastes  are ultimately disposed of  in ponds or landfills
which can be lined or unlined.   Four disposal methods  are assumed to
be representative of current disposal practices for disposition of ash
alone  and ash in combination with FGD sludge.   For utilities genera-
ting only ash,  it is assumed  35 percent pond the ash  and 51 percent
landfill it.   The remaining 14 percent of the industry incurs no cost
for ash disposal since resource recovery is practiced.   For utilities
generating ash  and FGD sludge,  54 percent  are assumed  to pond  the
combination and 46 percent are assumed to landfill it.

     National solid waste disposal costs for new plants coming on line
through 1985 are broken down  to show cost of disposal attributable to
current practices,  costs attributable  to existing state  solid waste
and other Federal regulations, and compliance costs with the Criteria.
It is assumed the new plant's disposal facility  will be built for the
entire 30 year life of the utility.
                              C-26

-------
     Existing facilities are examined  based on available data regard-
ing current disposal practices.   Estimates are made for the number of
facilities  failing  the  Section 4004  criteria.   Average costs  for
closing and upgrading are  developed.  It is assumed existing disposal
facilities are built in 10-year cells and that utilities have utilized
5 years of this 10 year life.

Ground Water

     The control technologies  assumed  necessary  to meet  the ground
water criteria  are  clay lining  (.6 meters),  monitoring  wells  and
leachate collection  and treatment facilities.   It is assumed that 67
percent of all new facilities  will require liners while the remaining
33 percent will locate land  where natural conditions provide suffici-
ent protection.    It was assumed  existing  facilities  lining  their
disposal sites  or chemically fixing  their FGD sludge  will meet  the
ground water criteria.   The remaining facilities  were subject to the
same 67 percent failure, 33 percent compliance probability.

     It is assumed that monitoring wells  will be installed at all new
and existing facilities.  Due to the large volume capacity and area of
utility disposal facilities seven sampling wells are assumed per site.
Quarterly  sampling costs  are included  as are  annual operating  and
maintenance cost.

     Upgrading  these  existing  facilities  failing  the ground-water
criteria entails removal  and temporary storage  of existing waste  as
well as the purchase and placement of liner materials.
                               C-27

-------
     Annualized ground-water costs for the coal-fired utility industry
were assumed to be  $48 to $53 million  for new facilities  and$37  to
$52 million for existing facilities.

     The range exists for ground-water criteria  because three scenar-
ios were tested  for compliance  with wetlands portion  of the surface
water criteria.  All facilities located in wetlands were assumed to be
a total subset  of the sites  affected by  the ground water  criteria;
therefore,  assumptions concerning different closure options  affected
ground-water costs.   As the distance  from the plant  to the disposal
facility  increases,  capital  and operating  expenses  increase.   In
addition,  it is assumed the farther the facility is located  from the
plant,  the higher the probability  is for locating  impermeable soil.
It is assumed  that  for facilities  moving  8 km  from the plant,  50
percent will locate land with indigenous clay soil and 50 percent will
require lining.  For plants moving 16 km from the plant, it is assumed
only one  out of three  will  require  lining.   The various  wetlands
options  also affect  the floodplain  criteria  costs.   It is assumed
sites five to ten miles from the facility  will not require protection
against washout.

Wetlands

     The degree to which coal-fired utility disposal facilities  would
be likely to locate  disposal facilities  in wetlands and violate sur-
face water criterion was determined  by using the Wetlands Map by U.S.
Water Resources Council.   Based on sample testing, it was assumed all
facilities  located in Arkansas,  Florida,  Georgia,  Louisiana, North
Carolina,  North  Dakota,  South  Carolina,  South Dakota,  Texas  and
Wisconsin would be affected  by the wetlands provision  and facilities
in the remaining  states  would not.   Approximately  60 plants  or 20
percent (25,500 MW) of capacity coming on line by 1985 were determined
to be located in these twelve wetlands states.  It was estimated  that
approximately  115  utilities  or  25 percent (50,000  MW) of existing
sites were in these twelve states.
                             C-28

-------
     The distances  from the plant   these  disposal  facilities  must
move are unknown and will vary.   Where wetlands are highly dense,  it
is assumed  the disposal  facility  will be  relocated 16 km  from the
plant; other sites in less dense wetlands areas are assumed to be able
to locate disposal sites 8 km.

     Three scenarios were examined for wetlands.

     The first case assumed all-facilities in wetlands would be denied
NPDES permits  and forced to move  their disposal facility  outside of
the wetland,  with 50 percent of these facilities moving 8 km from the
plant and 50 percent moving 16 km.

     The second scenario  assumed sites  located in Louisiana,  Texas,
Florida,  North and South Carolina  would be granted NPDES permits due
to the ubiquitous nature  of wetlands in these states.   In this case,
35 of the 60 new facilities  and 30 of the 115 existing sites  will be
granted  NPDES permits.   The remaining  facilities  in each case  are
assumed to move 8 km.

     The last scenario examines the costs  were all facilities granted
NPDES permits.   In this case  no costs are incurred  for the wetlands
criteria.   Technical costs for upgrading facilities  remaining in the
wetlands appear under the ground water criterion.

     The total annualized cost  for compliance  with the wetlands por-
tion of the surface water wetlands criteria  ranges  between 14 and 39
million dollars for new facilities  and  30 and 62 million dollars  for
existing facilities.   These are all costs  attributable  to the Clean
Water Act.

Floodplains

     It is assumed that 100 percent of all coal-fired utility disposal
sites will be  or are located  in floodplains.   A 3 meter dike is as-
sumed to be a sufficient average height  to protect against the flood-
waters.
                              C-29

-------
     It is assumed that landfill disposal sites do not employ any con-
trols against wash out  by the 100 year flood;  therefore,  the entire
cost of the dike will be a compliance cost  assigned to the floodplain
criterion.

     Surface impoundments,  on the other hand, are normally built with
2:1 sloped dikes  to contain wastes.   It is assumed  that these dikes
will be upgraded  to a 3:1 slope  to prevent weakening  and erosion of
the dike.   This incremental cost is attributable  to  the  floodplain
criteria.

     Total floodplain compliance costs for new and existing facilities
are $ 30 to $40million.

Combined Cost of the Criteria

     As previously stated, the combined cost for the coal-fired utili-
ty industry will be between $159 and $246 million dollars  in annualized
solid waste costs.   These are  reasonable maximum costs  based on the
assumptions regarding the technologies necessary to bring existing and
new sites into compliance with the criteria.  These costs are based on
full compliance  of all  open dumps  and may be  reduced  depending on
State  action  and compliance  schedules.    No unusual  circumstances
exist,   such as  the accumulated waste piles  in the  mining industry,
whose costs could be eliminated to reduce these estimated any further.

IRON AND STEEL INDUSTRY

     The iron and steelmaking  industry produces  an estimated 50 mil-
lion metric tons of non-hazardous solid waste per year.   However, due
to commercial sale  and/or  in-plant  recovery of  over 60 percent  of
these solid wastes  the industry disposes  of only 16.5 million metric
tons.   Table c-7    shows the estimated  quantities of  non-hazardous
solid waste  generated  and disposed of  by the  iron  and steelmaking
industry.
                              C-30

-------
     There are currently over 150  iron and steelmaking plants  in the
United States.   It is estimated  that it will cost  this industry ap-
proximately  $36 million  in annualized  costs  to comply  with state,
Federal and Section 4004 criteria.   The two criteria  responsible for
these costs are the ground water  and—to a much lesser extent—flood-
plain criteria.

     These costs were estimated  by using a model plant with an annual
raw steel  production  of 2.5  million  metric tons  and  annual waste
generation  of approximately 305,000  metric tons.   A landfill design
life  of 5 years  was chosen  to provide  a representative basis  from
which  to extrapolate  steel industry  disposal  costs  on a  national
basis.

     The most common disposal practice in current use is to dump/land-
fill the various wastes.  It was assumed that sites will not be closed
and relocated as a result of the criteria.  Existing sites failing the
criteria will be upgraded  as necessary.   It is also assumed  that 50
percent of the sites  will remain onsite  (on or adjacent to the plant
ground) and 50 percent offsite.

     It was assumed that approximately 15 percent  of offsite iron and
steel  disposal sites  (or 8 percent  of all iron  and steel  disposal
sites) are presently designed and operated in a manner which meets the
Section 4004 criteria.   The remainder  will require upgrading to meet
the ground water and floodplain criteria as discussed below.

Ground Water

     The ground-water  criteria will have  the greatest impact  on the
iron and steel industry.   It was assumed 100 percent of onsite and 85
percent  of offsite disposal areas  will require  additional site con-
trols to provide for ground water protection.   Site preparation, land
clearing, surface runoff, ditching, clay lining,  leachate collection,
monitoring wells, closure and revegetation are the additional costs to
prevent ground water contamination.

     The annualized costs  for the steel industry  to meet  the ground
water criterion are $36 million.
                              C-31

-------



















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Floodplains

     The floodplain criteria  is assumed to affect  15% of onsite dis-
posal areas  <8% of the entire industry).   The control technology re-
quired  to protect  against inundation  by the  100 year flood  is a 3
meter dike.

     National  annualized costs  for the  steel industry  to meet  the
floodplain criterion are $274,000.

Closure

     The iron and steelmaking  industry  does not  currently  practice
closure and revegetation.   However,  this practice was assumed  to be
necessary  for land reclamation  as well as final ground water protec-
tion.  Of the $36 million shown for annualized ground-water protection
costs, $5.3 million covers closure and revegetation requirements.

Combined Cost of the Criteria

     The total costs of $36 million  in annualized costs is a reasona-
ble maximum cost  based on the stated assumptions  regarding technolo-
gies necessary  to bring iron and steel disposal facilities  into com-
pliance with the Criteria.   The $36 million assumes immediate upgrad-
ing of disposal sites  and is subject to change  based on State action
and compliance schedules.
                             C-33

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B.   A STUDY OF THE COST IMPACTS OF SECTION 4004 OF THE RESOURCE
     CONSERVATION AND RECOVERY ACT (RCRA) ON THE DISPOSAL OF NON-
     HAZARDOUS WASTES FROM MINING
1.
     The main objective  of this study  is to present  estimated tota,l
capital and annual operating costs  of solid waste disposal  technolo-
gies for mining industries that will satisfy the criteria set forth in
Section 4004  of the  Resource Conservation  and Recovery Act   (RCRA).
This study partially satisfies  Section 8002(f) of RCRA,  the require-
ments of which  are delineated in  the following excerpt  from Section
8002(f) :

     The Administrator, in consultation with the Secretary of the
     Interior,  shall conduct a detailed  and comprehensive study
     on the  adverse  effects  of  solid wastes  from active  and
     abandoned surface and underground mines  on the environment,
     including, but not limited to, the effects of such wastes on
     humans, water, air, health, welfare,  and natural resources,
     and on the adequacy of means and measures currently employed
     by the mining industry,  Government agencies,  and others to
     dispose of and utilize  such solid wastes  and to prevent or
     substantially  mitigate  such adverse  effects.   Such study
     shall include an analysis of -
           (1)  the sources and volume of discarded material  gen-
               erated per year from mining;
           (2)  present disposal practices;
           (3)  potential dangers to human health and the environ-
               ment from surface runoff of leachate  and air pol-
               lution by dust;
           (4)  alternatives to current disposal methods;
           (5)  the cost of those alternatives in terms of the im-
               pact on mine product costs; and
           (6)  potential for use of discarded material  as a sec-
               ondary source of the mine product.
                              C-34

-------
This  study  essentially fulfills analyses  (2),  (4),  and (5)  above
and  completes  the  requirements  of Section 8002(f)  by augmenting a
recently  completed  comparison  study,   currently  under  final  EPA
review,   entitled  "Study  of Adverse  Effects  of Solid  Wastes from
All Mining Activities on the Environment," prepared under EPA Contract
No. 68-01-4700.

     The author of this report used professional judgment to determine
the split between hazardous and non-hazardous wastes.  Any assumptions
and estimates made  were not intended to reflect EPA decisions regard-
ing final classification of these mining wastes but were made for cos-
ting purposes.    In addition,  the author asserts  that these  mining
wastes which it judges  would fail the proposed hazardous characteris-
tics,  or which were included in the proposed hazardous wastes  in the
December 18, 1978, proposed hazardous waste regulations, were excluded
from consideration in this study addressing the cost impact of Section
4004.   The disposal technologies used in this report were not assumed
to be the  only design standards  which meet the performance  criteria
for disposal of non-hazardous wastes under Section 4004,  but were one
set of alternative technologies which would meet the criteria.

     This  study  focuses  on  the  following  10  mining  industries:
copper,  iron ore,  molybdenum,  gold,  lead,  zinc,  phosphate, clay,
stone,  and sand and gravel.    These 10  industries  contribute about
91 percent of all  the mining solid wastes assumed to be non-hazardous
(excluding coal mining wastes),  as shown in Table   C-S.    This table
exhibits the quantities of non-hazardous  wastes from  each  industry.
All  mine wastes (overburden and waste rock) from these industries are
considered  non-hazardous,  with the exception of about  30 percent of
the  phosphate overburden  generated in Florida,  which is  considered
hazardous.   (The hazardous designation is based  on the criteria that
the overburden contains radium that emits levels of radioactivity that
exceed a proposed standard of 5 picocuries per gram.  The value of  30
percent was estimated  by the author based on information and a report
entitled  "Radioactivity of Lands and Associated Structures"  from the
University of Florida for the Florida Phosphate Council.)   Only  four
                              C-35

-------
                             TABLE  C-8

 ESTIMATED MINING INDUSTRY  PRODUCTION AND  MONHAZARDOUS
        HASTE  QUANTITIES  (1,000  notric tons/year)
Mining
industry
Copper
Iron ore
Molybdenum
Gold
Lead/zinc
Phosphate
Clay
Stone
Sand and
gravel
Coal
Other1"1'
No. Of
mines
61
68
3
99
33/36
47
1,249
5,584
7,007
6,459

It
Product
4,
80,

0.
16,
44,
39,
815,
718,
573,
829,
237
160
55
021
840
600
770
400
000
300
000
Nonhazardous wastes**
Tailings


2

62
2


,740*

,500™
,275
Negligible
35

21
,900

,840t
Mine wastes
627
234
10
8
4
150
33
66
,900
,800
,740
,408
,778
,200!
,760
,160
Negligible

97
11
.730*
Total
627
234
10
11
4
212
36
66
35

119
,900
,800
,740
,148
,778
,700
,035
,160
,900
U
,570
 Total
                                125,255
                                            1-234,476
                                                          1^359,731
      Represents  tailings from gold placer mining.   Other gold
mining tailings are considered hazardous.

      Fifty percent of tailings from other mining  industries are
considered to be  nonhazardous.
     ^Thirty percent of all phosphate mine waste in Florida is
considered hazardous  (i.e., thought to contain radium 226 that
emits radioactivity in excess of a proposed 5 picocurie  per gram
standard)  and thus is not included in this number.
     'coal mine wastes are regulated by the Surface Mining Control
and Reclamation Act and were not considered in this study.  The
March 13,  1979, Federal Register contains the Permanent  Regulatory
Program of Surface Coal Mining and Reclamation Operations.  Esti-
mated costs of control methods for nonhazardous wastes from coal
mining are presented in a report entitled "Permanent Regulatory
Program of the Surface Mining Control and Reclamation Act of 1977,
Final Regulatory  Analysis (OSM-RA-1), March 1979."
     9A11  mine wastes from other mining industries are considered
to be nonhazardous.

       The quantities shown were taken from "Study of Adverse
Effects of Solid  Wastes from All Mining Activities on the
Environment." The quantities represent 1975 statistics based on
Tables 2 and 11 of the preprint from the 1975 Bureau of  Mines
Minerals Yearbook.
     ^includes more than 20 industries.

     55These quantities represent the final products from the
mining industries (e.g., concentrate from beneficiation plants)
with the exception of gold which represents the pure product.

       Represents sand tailings.
                               C-36

-------
of the industries — clay, sand and gravel,  gold (placer mines only),
and phosphate (sand tailings) — generate non-hazardous tailings (ben-
eficiation wastes).     Non-hazardous wastes from all  other  domestic
mining  industries,  constituting  the  remaining   9 percent of  non-
hazardous mining wastes,  are shown in various tables in this study as
"other  industries,"     No  hazardous wastes  are  addressed  in this
report.

     The  costs  are  divided,   for  each  criterion,  into  national
baseline costs;   national state-  and other  Federally induced costs;
and national 4004  (criteria induced) costs (Table VII-9).  The  base-
line  costs  represent  estimated  costs  of control  methods  already
in use by the industry — tailings ponds,  diversion ditches,  closure
practices — that satisfy  or partially  satisfy  any of the  six 4004
criteria.   State-induced costs represent estimated costs of complying
with existing state standards for the control of non-hazardous wastes;
other Federally induced costs represent those of complying with Feder-
al regulations other than RCRA.   For example, the  Clean Water Act of
1977 covers surface waters and the issuing of  National Pollutant Dis-
charge Elimination System (NPDES) permits to disposal sites located in
wetlands;  therefore,  the costs of relocating a facility outside of a
wetland  area or  protecting  surface water  are attributable  to this
Federal  regulation.    It should  be noted that the  costs of control
methods for non-hazardous wastes from coal mining are regulated by the
Surface Mining Control and Reclamation Act of 1977 (SMCRA); therefore,
these costs are not included.   Estimates of these costs are presented
in a report entitled "Permanent Regulatory Program of the Surface Min-
ing  Control and Reclamation  Act of 1977,  Final Regulatory  Analysis
(OSM-RA-1)"; this report was  prepared to  support the final SMCRA re-
gulations (Federal Register, March  13, 1979).  Criteria-induced costs
are those costs of complying with Section 4004 that exceed the compli-
ance costs for state and other Federal standards.
                             C-37

-------
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     The  three cost  categories  presented in  this report  are total
capital,  annual operation and maintenance, and total annualized solid
waste disposal costs.    The last is the sum of annualized capital and
annual operation and maintenance costs.

     As shown in Table  C-9,  baseline costs for ground water are mini-
mal when compared with the costs  induced by state and Federal regula-
tions.  Baseline costs  for surface water,  however,  are considerably
greater because of the  surface water  protection afforded by existing
tailings ponds at mine sites.  There are no baseline costs  for flood-
plains and air quality  because practically  no controls  are specifi-
cally in use to satisfy these criteria.    Some  industries  do employ
measures that satisfy the Section 4004 closure requirements;  however,
it is estimated an  additional capital cost  of $829  million would be
required to meet the Section 4004 closure criterion. (Closure  in this
study includes  soil coverage of a depth of 0.15 meter.   If 0.6 meter
of soil material is used,  total closure costs are  estimated at $1.84
billion.)

     National  baseline capital costs  of non-hazardous  waste control
for all mining industries are estimated at $474 million.   The annual-
ized baseline control costs are an estimated $120 million.    National
state-  and  other  Federally induced  capital costs  are estimated at
$667 million  if NPDES permits  are granted  for facilities located in
wetlands and $891  million if these permits are not granted.   Respect-
ive annualized costs are $209 million and $698 million. The total Sec-
tion 4004  or Criteria-induced  costs are  estimated at  $1.101 billion
(NPDES  permits granted)  and $1.097  billion  (NPDES permits denied).
Respective annualized costs are $314  million and $312  million.

     The  NPDES permit  granted scenario  exhibits a  higher Criteria-
induced cost  than the NPDES permit denied scenario  due to additional
environmental  controls required in a wetland.   The state-  and other
Federally  induced costs, however, reflect the true costs of relocating
outside of a wetland.
                             C-39

-------
2.   Development of Model Plants

     Costs attributable  to Section 4004  criteria and other state and
Federal  legislation were determined  by using the  concept of a model
plant, because a detailed,  site-by-site study was beyond the scope of
this report.    For each of the  10 major mineral industries,  a model
plant was  developed that  represented a typical  production level and
the quantities of tailings and mine wastes generated.  Production lev-
els were obtained from the Minerals Yearbook, and solid waste tonnages
were obtained  from available sources  and contacts  within th'e mining
industries.   '

     Figures  C-l  through  C-9  display the model plant sizes used in
the study. These model plants include various steps within the process
that generate significant quantities of solid wastes.   The horizontal
arrows show the flow  from mine site to usable product (e.g., concent-
rate for a smelter);vertical arrows show mine waste and tailings waste
streams.   The figures also reflect any current control methods to the
extent that they  are practiced within the industry.    Each state was
allocated a number of model plants  based on the production levels for
that industry within the state.    These estimates were  later used to
allocate state-induced costs.

     The model  plant size for  the copper industry (Figure  C-l)   was
determined on the basis of the total solid wastes generated within the
industry and from the fact that  25 out of 61 mines produce 93 percent
of the Nation's copper.  '"  The model plant,  therefore, is a typical
mine within the group of 25 major producing mines.
     The iron ore model plant size   (Figure  C-2)    was determined by
the same method,  but with only 68 mines producing all of the Nation's
iron ore.

     All of the primary molybdenum ore is produced at three mines, and
a model plant size was thus developed  from information on actual ton-
nages obtained from the respective mining companies.   The tonnages in
Figure  c-3  represent  a  molybdenum mine  that uses both surface and
underground mining methods.

                              C-40

-------
     The gold  ore  model  plant size  (Figure  C-4)   was based on the
production figures  for only  those sites  that mine gold as the prin-
cipal ore:  i.e., actual gold mines.

     The lead/zinc industry model plant size  (Figure  C-5)   was based
on combined production levels for the two industries. It is an average
of the model plant sizes for lead and zinc,  as determined separately.
The  ore to product ratios  for the lead and zinc industries shown  in
this model  plant diagram are  not meant to depict  these ratios at an
actual mine site;  an average of a range of ratios for the  two indus-
tries was chosen.   The lead model plant size  was  based on  25 mines
producing  99 percent of the Nation's lead,  and the zinc model  plant
size  was based on 25  mines producing 89 percent of the Nation's zinc
ore.

     The clay  model  plant size (Figure  C-7)  was  determined by two
methods.   Mine waste tonnage was calculated as the average of the to-
tal mine wastes produced at all clay mines.  Tailings tonnage was cal-
culated  as the average  from  the production  of kaolin  and fuller's
earth only, because these are  the only  clay processes  that generate
                                   4
significant quantities of tailings.

     The model plant  sizes for  the remaining industries — phosphate
rock (Figure   C-6;    crushed,  broken, and  dimension stone  (Figure
C-8;   sand and gravel (Figure  C-9   — were calculated as an average
production size  based on  the total number  of mine sites  within the
respective industries.
                              C-41

-------
3.   Baseline and Criteria-Induced Control Technologies for
     Tailings and Mine Wastes at Model Plants

     Most mining industries are now using certain control technologies
that satisfy at least some portion of the  Federal Section 4004 crite-
ria.   These baseline controls are indicated  on the model plant block
diagrams for each industry (Figures  C-l   through  C-9).    The copper,
iron ore,  gold,  lead/zinc,  clay,  and stone industries have minimal
diversion ditching  to prevent  surface waters  from interacting  with
overburden piles.   These industries  also have minimal  closure prac-
tices  for overburden,  usually  involving  grading  and revegetation.
"Minimal"  diversion ditching  and closure  means that 20 percent (for
ditching) and 10 percent  (for closure)  of the  individual facilities
within the industry are using these practices.  Diversion ditching and
closure of overburden  primarily protect surface water  from pollution
by suspended solids.

     The molybdenum industry makes extensive use of diversion ditches,
which  are present in  about 80 percent  of the industry.    Both  the
molybdenum  and  phosphate  industries  commonly  grade and revegetate;
their overburden.   Phosphate mining companies in Florida  reclaim all
or nearly all of their overburden.

     Unlined  ponds are  the  baseline  controls used   in  the (clay,
phosphate, and sand and gravel industries.   In addition to the ponds,
the  clay industry practices minimal closure for tailings.   The stone
industry  produces negligible quantities  of tailings and has not been
considered in this study.

     The additional control  technologies necessary to meet the crite-
ria of Section 4004  have  been  formulated  and are shown  in Figures
C-10   through  c-15.    These various controls  are discussed below in
terms of the criterion to which they apply.
                             C-42

-------
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C-51

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     a.   Ground Water

     A control technology  that would  meet the  Section 4004  ground-
water criterion for overburden  and waste rock  (Figure  C-10)  is the
construction of diversion ditches  to direct water  away from the dis-
posal areas.    This control  reduces the leaching  of materials  from
these areas  and subsequent pollution of the ground water by diverting
rainwater from prolonged contact with the waste.

     In  order  to determine  the control  technologies  required  for
industries that generate non-hazardous tailings,  an evaluation of the
water  table is necessary to determine whether leachate from  existing
unlined  tailings  ponds  could adversely  affect  the quality  of the
ground water.    A high/low water table  has been delineated  for this
purpose.    In a particular industry, the degree to which the tailings
ponds will have an adverse impact  on the ground water  was determined
by the region in which the industry is located.    This study assumes,
for example,  that in the southeastern section  of the country 25 per-
cent of the land  has  a low water  table and 75  percent a high water
table;   these percentages are assumed to be reversed in states in the
Southwest.  A national summary of these estimated high/low water-table
percentages  was prepared  for the  Northwest,  Southeast,  Southwest,
Northeast, and Midwest (Table  C-10) .
                           TABLE  C-10
     ESTIMATED REGIONAL PERCENTAGE OF LOW OR HIGH WATER TABLE
            USED IN ANALYSIS OF GROUND-WATER CRITERION

Region
Northeast
Southeast
Southwest
Northwest
Midwest

Low water
table (%)
50
25
75
75
25

High water
table (%)
50
75
25
25
75
*These estimates are based on engineering judgment; they were not ob-
 tained from referenced material of actual measurements.
                             052

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     Non-hazardous tailings  ponds  located  in areas  with  low water
tables  are assumed  to need  no additional  controls  to satisfy  the
ground-water criterion  because of the natural filtration of suspended
solids  as the leachate  perculates  through the soil.  Ponds in areas
with high water tables  could be subjected  to a site evaluation (con-
sisting of a hydrogeological survey,  permeability tests,  evaluation,
and report) to determine the actual impact on the ground water.  It is
estimated that 80 percent of the site evaluations would show an insig-
nificant impact,  with the accompanying recommendation that monitoring
wells should be installed and data collected quarterly at these sites.
The remaining 20 percent of the evaluations would indicate significant
ground-water impact,  with the recommendation that these sites install
further control technologies  consisting of  collection wells  for the
leachate to prevent ground-water contamination.  In addition, monitor-
ing wells  would be  installed  in  appropriate  locations  to perform
quarterly checks of the leachate collection system.

     b.   Surface Water

          Control technologies  to meet the Section 4004 surface-water
criterion are shown in Figure   C-ll.     Diversion ditches around mine
waste piles  would prevent  surface runoff  from interacting  with the
waste  and carrying it,  primarily  as suspended solids,  into surface
waters.    The tailings pond is a baseline control technology  for all
mining industries  producing  beneficiation wastes.    It contains the
tailings and prevents surface-water contamination.    One exception is
gold placer mining operations,  located primarily  in Alaska and Cali-
fornia.   Sluiced wastes (tailings) from these operations are the only
nonhazardous tailings within the gold mining  and beneficiating indus-
try.    These wastes are currently pumped directly to streams and riv-
ers.  Control of the tailings  from gold sluicing operations  could be
accomplished by construction of tailings ponds.

     For industries  having tailings ponds,  further  controls to meet
the  surface-water criterion  include diversion ditches and  upgrading
of the pond dikes by compaction, soil coverage, and revegetation.  The
diversion ditches would direct waters away from tailings ponds to pre-
vent  the dikes  from being weakened  or washed out and  to reduce the
chances  of pond overflow.     Either situation  could cause  suspended
solids to contaminate surface waters.
                            C-53

-------
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                        C-57

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                                           NONHAZARDOUS  WASTES
                                      TAILINGS             MINE WASTES
                                      /                  - DIVERSION DITCHES
                                GROUND-WATER
                                   TABLE
                                 EVALUATION
                        HIGH                     LOW
                    GROUND-WATER             GROUND-WATER
                       TABLE                    TABLE

                    [                                 NOTHING ADDITIONAL
                    I                               TO  SATISFY RCRA CRITERIA
                   SITE
                EVALUATION
         INSIGNIFICANT
            IMPACT     SIGNIFICANT
                         IMPACT
 •MONITORING
     WEUS                    - UPGRADE WITH
                               LEACHATE COLLEC-
                               TION SYSTEMS

                             - MONITORING WELLS
Figure   C-ll   Controls induced by  RCRA ground-water criterion covering
                nonhazardous wastes  from the  mining  industry.
                                 C-58

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                           NON-HAZARDOUS
                              WASTES
          TAILINGS-
                                              INE WASTES
- DIVERSION DITCHES                               - DIVERSION DITCHES
- COMPACTION OF DIKE
- SOIL COVERAGE OF DIKE
- REVEGETATION OF DIKE
Figure   C-10     Controls  induced by  RCRA  surface-water  criterion
covering non-hazardous wastes from the mining industry.

     c.   Wetlands

          Control technologies to meet the Section 4004 wetland crite-
rion are shown  in Figure  C-12.     TWO scenarios  are considered for
tailings and other mine wastes.   One scenario assumes that NPDES per-
mits will be granted  to all  mining industries  located  in wetlands,
allowing solid wastes to be disposed of within the area.    The second
scenario assumes  that no NPDES permits  will be granted  and that all
mining wastes generated in wetlands will have to be transported out of
the area.   Control technologies for the two scenarios are outlined in
the following paragraphs.

     NPDES permits granted.    It is assumed  that  monitoring  wells,
checked  on a quarterly basis,  would be  installed around  mine waste
piles as a precautionary measure  to insure protection of the well and
that the dikes around tailings ponds permitted  to stay in the wetland
would be upgraded  into a 3:1 sloped structure (3 horizontal, I verti-
cal).  This control would also include dike compaction, soil coverage,
and revegetation (similar to the controls for the surface-water crite-
rion) .
                             C-59

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     NPDES permits denied.  This scenario would entail the purchase of
land outside the wetlands  to construct disposal facilities  for tail-
ings and mine wastes.    The additional costs would include the trans-
portation of these non-hazardous wastes to the new sites.    It is as-
sumed that the wastes  from all mining industries  located in wetlands
would have to be trucked a distance of 16 kilometers one way, with the
exception  of wastes  from the  Florida  phosphate industry,  which is
located in areas of extensive wetlands.  The assumed trucking distance
in this case is 32 kilometers one way.

     Because  of the distances  involved,  pumping the tailings to the
new facility is not considered feasible.  The control method described
here includes  thickening the  tailings slurry to a  70 percent solids
sludge before  it is transported by truck.   Overflow from the centri-
fuge would be pumped to storage tanks as recycle water.

     In  addition to  trucking  the newly  generated  tailings  to new
disposal facilities  that  meet Section  4004 criteria,   the scenario
includes closing the existing tailings ponds   (pond free water pumped
off,  pond allowed to drain, 0.15 meters of soil uniformly graded over
the pond,  and revegetation).    Closure measures  for  the  relocated
disposal  facilities at the  end of its life  are  described under the
closure criterion.
                             C-60

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     The percentages  of the specific  industries located  in wetlands
were calculated from the percentages presented in Table c-27.  (Volume
I) of the EIS;  and adjustments to the percentage  were based on know-
ledge of locations  of these minerals industry facilities  relative to
wetlands when this information was available.   For example,  although
46 percent of Florida is wetlands,  the majority  of the Florida phos-
phate industry  is located  within these wetlands;  therefore,  it was
assumed 90 percent would be affected by the wetlands criterion.

     d.   Floodplains

          Control  technologies to meet  the Section 4004  floodplains
criterion are shown in Figure  C-13. .    Diking is the principal method
selected, for both tailings and mine wastes,to satisfy this criterion.
For mine wastes, this entails construction, compaction, soil coverage,
and revegetation  of dikes 3 meters  high at a 3:1 slope.    The dikes
would  be built around  accumulated plus  newly generated  mine waste.
Based on a national average,   it was assumed three sides of the  mine
waste piles (assuming roughly rectangular shapes)would require diking.
In actuality,  some waste piles  are located against a ridge or ridges
bordering the floodplains; these piles may be protected from floods on
one, two, or three sides.  Other waste piles are located in the middle
of floodplains,   and dikes would have to be built around their entire
periphery.
                    NON-HAZARDOUS WASTES
                 (TAILINGS AND MINE WASTES)
                    -  DIKE CONSTRDCTION
                    -  COMPACTION OF DIKE
                    -  SOIL COVERAGE OF DIKE
                    -  REVEGETATION OF DIKE

Figure  c-13.-  Control technologies to meet the Section 4004 flood-
plains criterion.
                             C-62

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     For tailings ponds,the floodplain criterion would require upgrad-
ing the existing pond dikes to a 3:1 slope, compacting, covering these
dikes with 0.6 meters of soil,  and seeding and fertilizing to prevent
erosion.

     The percentage of industries  located in  floodplains  were esti-
mated  on a state-by-state basis.    Most of  the states were assigned
a value of 5 percent,   which is  the estimated average percentage  of
land in the  United States  that is within  floodplains.    Deviations
from  this value were based  on knowledge of  specific mine  locations
with respect to floodplains.

     It is noted that the strategy of upgrading tailings ponds in wet-
lands and floodplains is the same.   Based on the general  location of
the applicable  mine sites and small percentages of  mines in wetlands
and floodplains, it was assumed for cost purposes that  the industries
located  in  wetlands are mutually   exclusive from those  located  in
floodplains.

     e.   Air Quality

          Control methods  to prevent adverse  impacts on  air quality
are shown in Figure  C-14.   No controls are needed on an annual basis
during the active life  of the  mine waste disposal site.    Long-term
protection  of the air quality  after the site is retired would result
from revegetating  the piles.    This method  is discussed  under  the
closure section.

     Fugitive dust can also be generated by winds blowing across dried
areas of tailings ponds,  particularly in arid regions of the West and
Southwest.   Tailings from the clay and sand and gravel industries are
contained in small ponds and are nearly all located in nonarid regions.
As a result,   the pond surfaces remain wet a majority of the time due
to the addition of new tailings water and the fact that the precipita-
tion rates exceeds the evapotranspiration rate for these areas.    Be-
cause the ponds do not dry out and create dust problems, no additional
controls to protect air quality standards are considered necessary.
                             C-63

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                       NON-HAZARDODS WASTES
  KEEPING FREE WATER
  ON THE ENTIRE PORTION
  OF THE TAILINGS POND
     TAILINGS	—S        ^	MINE WASTES

                                             - NO CONTROLS NEEDED DOPING
                                               ACTIVE DISPOSAL OF MINE
                                               WASTES.  CLOSURE CRITERIA-
                                               INDUCED CONTROLS PROVIDE
                                               FOR LONG-TERM PROTECTION
                                               OF AIR QUALITY

Figure  C-14      Controls induced by RCRA air quality criterion cover-
  ing non-hazardous wastes from the mining industry.
     £.
          Closure
          Control  technologies necessary to meet the 4004 closure re-
quirements are shown in Figure  c-15.    It is assumed that accumulated
and newly generated non-hazardous mine wastes will be closed with 0.15
meters of soil cover  and that the soil  be revegetated to restore the
land similar to its original condition.    With a few exceptions, such
as Florida phosphate, most of the mineral industries have allowed mine
wastes  to accumulate in piles  since the startup  of the mines.   The
quantity  of these wastes  is considerable,  depending on the type  of
industry  and length of time  the mines have been in  operation;   the
copper model plant,  for example,  has been operating for an estimated
15-year period. (These estimated periods of other industries are shown
later in Table  C-13).     The  control  method  for  stabilizing these
accumulated  mine  waste  piles  would  involve  regrading  to provide
adequately  contoured slopes;  compaction  of this material;  coverage
with 0.15 meters of soil; soil amelioration; and seeding to revegetate.
                             C-64

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                       NON-HAZARDOUS WASTES
     TAILINGS-
                                             MINE WASTES
  DEWATERING
  SOIL COVERAGE
  REVEGETATION
- GRADING AND SURFACE COMPACTION
- SOIL COVERAGE
- REVEGETATION
Figure   C-15     Controls industed by RCRA closure criterion covering
  non-hazardous wastes from the mining industry.

     The newly generated  mine wastes would be spread out,  compacted,
covered with soil, and revegetated on a continual basis.    These pro-
cedures  are similar to the reclamation that is practiced in  some  in-
dustries.    Closure would  thus occur  regularly,  so that the wastes
would be "closed" on a weekly, monthly, or even an annual basis rather
than be allowed to accumulated through the remainder of the mine life.

     Procedures  for closure  of a tailings pond  when it is full   are
also shown in Figure   C-15.     Pond free water  would be pumped  to a
pressurized filtering system to remove solids, and the clarified water
would be  discharged to  a surface stream or river  or used for opera-
tional purposes at the mine or mill.    When the drained area was sta-
ble,  0.6 meter of soil would be used to cover the tailings,  followed
by compaction and revegetation.

4.   Costs and Cost Methodology

     This section  presents  and discusses baseline costs.  State-  and
other Federal-induced costs,   and Criteria-induced costs  on a capital
and an annualized basis.  All the costs are given in 1978 dollars.
                            C-65

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The methodology used to  determine these costs is also discussed.  The
two principal sources of cost data were Richardson and Means; '   other
                                            Q Q
sources were used for additional unit costs. '

     a.   Baseline and Above-Baseline Costs

          For each of the 10 mining industries, costs have been calcu-
lated for  the baseline case and  for the control methods attributable
to government regulations (Table  C-ll).     Baseline costs include all
control technologies the industries are currently implementing  in the
absence of Federal solid waste regulations which meet the Section 4004
criteria.    Costs above baseline are figured and shown separately for
each  criterion.    In the copper industry, for example,  the 61 mines
have  a total baseline  capital cost  (for all criteria)  of  $94,000;
annual  operating  and  maintenance  costs  are $2,239,000;  and total
annualized costs are $2,250,000.  Capital costs above baseline to meet
the  ground-water  criterion  (NPDES  permits granted  or denied)  are
estimated  at $185,000,  and total  annualized costs  are estimated at
$37,000.    Additional costs are shown for surface-water criterion and
closure.  Within this industry, the sum of the costs above baseline to
meet these  criteria is  estimated at  capital costs  of $182 million,
annual operation  and maintenance costs of 21 million,   and total an-
nualized costs of  $48 million.  It is noted that the capital costs oE
satisfying  the  floodplains  and closure  criteria  for the  sand and
gravel industry are considerable for several reasons.    Fifty percent
of  the  disposal  facilities  in this industry  are assumed to  be in
floodplain areas;   thus costs of  upgrading tailings  pond dikes  are
great.    As shown in Table  C-8),  the sand and gravel industry has by
far  the  greatest  amount  of non-hazardous tailings produced by over
7000 mines.    The cost of  closing this number of ponds at the end of
their lives also is great compared with other industries.  (Closure of
ponds  is a capital expense because the  money for this purpose is set
up in a trust fund.)
                            C-66

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     For  costs above baseline,   each column total represents  the es-
timated  cost of all raining industries to meet a criterion.   The grand
total  shown in the bottom right hand corner of Table csil   represents
the  estimated  total cost  that all  mining  industries  would have to
incur  to satisfy the  Section  4004 criteria.    Two grand totals  are
shown to represent  two situations.    It will cost  an estimated $1.77
billion  in capital costs to meet Section 4004  criteria if  NPDES per-
mits  are  granted to  disposal facilities  located  in wetlands  or an
estimated $1.99 billion  if  NPDES permits are denied  to those facili-
ties in wetlands.

     b.   Costs per Unit of Waste and Product

          The  control  method  costs  have  also  been calculated  per
metric  ton  of waste and  of product,   based  on the total annualized
costs for each industry (Table  C-12).    For example, for the baseline
case, the annualized cost  in the copper industry is estimated at $2.25
million;   this figure  equals additional  disposal costs of $0.004 per
metric ton of waste and if prices  were passed directly on to consumers
an  additional  $0.53 per metric ton of product.    (Tons of waste  and
product were  shown in Table  C-8).     For State-  and  other Federal-
induced  annualized costs   (NPDES permit granted),   the  estimate  is
$69,000;  this figure equals $0.0001  per metric ton of waste and $0.02
per  metric ton of  product.    For  Criteria-induced annualized  costs
(NPDES permit granted),   the  estimate  is  $48 million;  this  figure
equals  $0.08  per  metric ton  of waste  and $11.30  per metric ton of
product.

     c.   Cost Methodology

          (1)  Capital Costs

               National baseline  and above-baseline  capital costs for
=ach mining  industry were based on the size of the model plant and the
:ontrol methods chosen  to meet the Section 4004 criteria.   Unit costs
?ere    determined   for  components  of  control  methods   that   are
                             C-67

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current  or baseline  and those that are above baseline to provide com-
pliance with Section  4004.    The baseline  and above-baseline control
method  component  costs  were subsequently  calculated  for the  model
plants.    The sum of the control costs to meet a criterion for a model
plant was then calculated, as applicable, for tailings and mine wastes;.
These  costs  were  determined  for each  of the six criteria  for each
model plant.  When one control strategy satisfied two criteria, such as
surface water and ground water, the costs for the strategy were divided
equally between them.

     In each industry,  the baseline costs  to  meet all criteria  were
determined  from the multiplication  of the  number  of model plants by
the  sum of the model plant control costs for all criteria.   The total
baseline costs  per criterion  were determined  from the multiplication
of the  number  of model plants in the industry by the model plant cost
of meeting that criterion.    The individual  industry  criterion costs
were summed to get the total mining industry criterion costs.

     The criterion  costs were  used to develop the baseline and above-
baseline  costs by State.   The number of model plants in each State by
industry  and by type  of waste  (tailings and mine wastes) were deter-
mined by proportioning  total tailings  and mine waste quantities among
that States,  based on industry production figures. '   For each State,
the cost increment  was determined from the multiplication of number of
model plants  per industry by  model plant  control costs for a criter-
ion.    The sum of these incremental costs  for all industries within a
particular  State  is that  State's  total  industry  cost  to meet one
Section 4004 criterion.    The sum of these costs for all States in the
United States is the national  mining industry's cost to meet a criter-
ion;  and the sum of these costs for all  criteria is the national cost
impact  on the mining industry  of meeting Section  4004-level controls
for non-hazardous wastes.

     A  contingency factor  of 20  percent is included  with the capital
costs shown in the tables.
                             C-i

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     Costs of Section 4004-level controls were calculated  by State  to
determine that total State-induced costs.   Control costs in each State
having regulations equivalent  to the Section  4004 criteria were added
together,  then deducted from the national total costs of Section 4004-
level controls.   The matrix shown in another appendix (Economic Impact
Analysis)  to this document lists the States that have regulations with
provisions equivalent to Section 4004 criteria.   Other Federal-induced
costs (in Table   C-9.,  and included  in above-baseline costs in Tables
C-ll    and   C-12J   are those  attributable to  the Clean  Water Act.
They  represent the  controls installed  to meet  the surface water and
wetlands  criteria  (NPDES permit denied).    State  and other Federal-
induced  costs  are combined  and deducted from  the costs  of  meeting
Section 4004-level controls to yield the actual Criteria-induced cost.

          (2)  Annualized Capital Costs and Trust Funds

               Annualized  capital  costs were determined  for each in-
dustry by amortizing  the capital  at 12 percent  interest over the re-
maining  life of the model plant.    The  equation for  determining the
annuity or capital recovery factor is:

                                   [1(1 + i)"]	,
                                    [(1 + i)n - 1]

where i is the  interest  rate and n is the number of years.    Annuity
factors for  the main  industries considered in this study are shown in
Table  C-13.
                              C-69

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                           TABLE  C-13

            ANNUITY FACTORS FOR MAJOR MINING INDUSTRIES

                     WITH NON-HAZARDOUS WASTES
Industry
Copper, gold
Iron ore
Molybdenum
Lead/zinc, phosphate
Clay, stone
Sand and gravel
Assumed remaining life of
model plant (years)
15*
20*
30
10*
7.5*
5*
Annuity
factor
0.1468
0.1339
0.1241
0.1770
0.2096
0.2774
* These remaining lives are assumed to Be half of the full~lives7

     Another  annualized  capital cost  is the  establishment of  trust
funds to pay for the closure  of tailings ponds at the end of a  mining
operation and  the operation and maintenance of  monitoring wells after
closure. A closure period of 1 year was assumed for non-hazardous tail-
ings  ponds for costing purposes.   During the closure period, the pond
free water would be pumped from the pond to quicken the time that natu-
ral evaporation and drainage would take, adequate drainage then allowed
to occur,  soil material added on top of the drained tailings,  and the
soil material seeded and fertilized.

     The trust fund for  the monitoring wells  is based on the assumpt-
ion  that they will be operated  and maintained for 5 years  after clo-
sure.   (This 5-year period is not a requirement stated in Section 4004,
but  is a period of time  in  which collected  monitoring  data  should
be  indicative  of  whether leachate  from  a closed pond  is impacting
ground  water and to what degree.)  Equations were derived to determine
the  trust funds for  closure and for  the monitoring wells (Table   e-
14).   The equations  take  into account  variations in remaining  life
among  the  model plants, and they include  a 2 percent  return  (above
inflation)  on capital.    In  the equations,  T is the capital cost of
the trust fund;  and S is the cost of closure and of well operation and
maintenance for 1 year.

                             C-70

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                           TABLE   C-14
                     EQUATION FOR TRUST FUNDS
Tailings pond
Industry closure
Iron ore
Lead/zinc, phosphate
Clay, stone T = 0.853 S
Sand and gravel T = 0.897 S
Monitoring
well upkeep
T =
T =
T =
T =
3.202 S
3.903 S
4.101 S
4.309 S
          (3)  Other Annual Costs

               In  addition  to  annualized  capital costs,   the other
annual  costs  include  maintenance  of  the  various  control  systems
(assumed  to  be 5 percent  of the  applicable  total  capital  costs);
electricity to operate pumps,   as during pond  dewatering (assumed  to
cost 30 mills/kwh);   labor to operate equipment, such as the front-end
loader  (costed at $26.60 per man-hour, including supervision and over-
head);  trucking of trailings and mine wastes  from wetlands when NPDES
permits are denied  (assumed to be done  by a contractor);   and annual
costs of continuous overburden grading,  soil spreading,  and revegeta-
ting (also assumed to be done by a contractor).  These latter costs and
trucking costs are discussed further in the following subsection.

     d.   Configuration and Costs of Control Methods

          The flow diagrams (Figures  C-l   through   c-9)  and  "tree"
diagrams   (Figures  C-10   through  C-15)    presented  the  different
baseline  controls  and those  that would  meet Section  4004 criteria,
respectively.   This section discusses design parameters and components
of the control methods.   Unit costs are listed, where appropriate,  in
parentheses.
                             C-71

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          (1)  Tailings Pond

               The tailings pond  is the principal method  used to con-
trol  mining beneficiation  wastes.    Most mines have  tailings ponds;
some,  such as gold placer mines,  discharge their waste sluicing water
to streams and rivers.    To determine the cost of constructing a tail-
ings pond for non-hazardous  beneficiation  wastes,  this study assumed
the following  design parameters:    rectangular-shaped pond;  depth of
about 11  meters from the top  of the dike  to the  bottom of the pond;
dike around three sides of the pond  (assuming a natural barrier on one
side);  and a slope of 2:1  (horizontal:vertical) except in floodplains
or wetlands, where dikes are sloped 3:1.   The dikes are constructed to
have a 6-meter-wide  horizontal section along the top so that machinery
can  be driven  and maneuvered there.   Ponds are designed  with a 1.5-
meter freeboard above the water  and an allowance of 1.2 meters of free
water  above the settled solids.   Incoming slurry is assumed  to be 30
percent solids,  by weight;  and settled tailings are  assumed to be 65
percent solids,   with an average  specific gravity of 1.8.    The  ex-
cavated  depth of a pond  is based on the amount  of material needed to
construct the dike.  The length-to-width ratio of the pond is 2:1.

     With  the exception of the sand and gravel  industry and the phos-
phate industry,  it is assumed  that  one   pond will  accommodate  the
beneficiation  (tailings)  wastes from the other subject mineral indus-
tries over the entire life of each model plant.    Sand and gravel  and
phosphate operations typically  construct a small settling pond at  the
startup  of a mine  to receive beneficiation wastes during  the initial
two or three years  of operation,  with subsequent employment of one or
more excavated areas from the mining operation for this purpose; conse
quently, baseline control costs  for tailings from the sand  and gravel
and  phosphate industry  are based   on this  configuration, i.e., con-
struction  of a 3-year settling  pond and operation and  maintenance of
this  pond  and the ponds created   by the mining  operation   over the
life of the mine.   Nearly all of the cost of building  a disposal pond
for the phosphate industry is for the slimes since the pond is sized to
handle a five percent slime slurry.    The  only cost for sand tailings
                             C-72

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disposal  assumed  in this report  is for the  transportation  of these
wastes outside a wetlands area if an NPDES permit is denied.  All other
costs are assumed attributable to slime disposal,  which is not covered
in this report.

       In  a case  where a new pond  must  be built  (e.g., gold placer
mining)  the cost is  calculated  for   a capacity adequate  to  handle
tailings  for half  the  duration of a mine life;   it is assumed  that
the mines on the average  are halfway through their useful lives.  (The
life of  a  mine cannot  accurately be estimated   because  it  depends
on  many  factors;  two,   for  example,  are  market  conditions   and
technological  breakthroughs that  can reduce ore  recovery and  treat-
ment costs.)   For both baseline case ponds and new ponds,  assumptions
about  the annual  quanities of tailings  received were  shown in Table
C-8.

     The  capital  cost of  constructing a  tailings pond  includes the
following components:    land (rural undeveloped, $2,400  per hectare);
land  clearing  ($1,300 per hectare);   survey ($925 per hectare);  ex-
cavation  of pond area  ($0.47 per cubic meter);   hauling  and dumping
overburden  at the dike area  ($0.47 per cubic meter);   dike formation
and compaction   ($1.88 per cubic meter);   and fine grading ($0.69 per
square meter).

          (2)  Ground-Water Evaluation

               This  evaluation is the determination of the water table
level.    The main costs are for drilling temporary test wells,   which
in this  study are  assumed to  be 6.35  centimeters in diameter.   The
cost of a 15-meter-deep well is $475,   and each linear meter exceeding
that depth is $25.
                            C-73

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          (3)   Site Evaluation

               The detailed  site evaluation  considered in this report
includes a  hydrogeological survey  to determine  ground-water movement
and  flow nets   ($5,000 per site)  and tests of   borings to determine
leachability  and permeability  ($3,000 per site).  The capital cost of
such an evaluation,  including engineering appraisal and  a report,  is
estimated at $15,000.

          (4)   Leachate Collection System

               The  system considered  here  is a group  of  collection
wells  spaced at a density of one per hectare.    Each well is equipped
with piping and a pump located above ground level.    The wells collect
the leachate  and pump it back to the tailings  pond.   Cost of a well,
with pump and piping, is estimated at $4,500.

          (5)   Monitoring Wells

               The  monitoring  wells  are costed  according to  depth.
The wells include casing 10 centimeters in diameter,  piping 3.8 centi-
meters in diameter,   and pumps rated  at 5,700 liters per hour.    The
installed  cost of a  15-meter-deep  monitoring  well  is estimated  at
$3,000;   and a 30-meter-deep well,  at $4,000.    The shallower  wells
would be used to measure  ground water in wetlands;   and deeper wells,
in all other areas.

          (6)   Diversion Ditches

               Cost  of construction of  diversion ditches  (1.8 meters
deep by 0.6 meters wide at the top)   with a trencher is  approximately
$2.10 per linear meter.

          (7)   Dike Formation, Soil Coverage, Revegetation

               Dikes  are  the principal  control  method used  in this
study for protecting overburden in floodplains.   They are also part of
                            C-74

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the  construction  of a tailings pond,   when no  natural barriers  are
available.  In this study,  tailings pond costs normally  include dikes
with  2:1 slopes  (which are  assumed to  exist at  all  baseline  case
ponds).   Costs of dikes for  new ponds to replace ponds closed because
of wetlands  criterion  are attributable  to Section 4004,   as are the
costs of new dikes  (3:1 slopes)  around  overburden in floodplains and
the costs for modifying existing pond dikes in wetlands and floodplains
to 3:1 slopes.

     Unit  construction  costs  used  for  dike  construction  and com-
paction were:    $1.25 per  cubic meter  of dike material  to  build  a
floodplain  dike around mine wastes  (3:1 slopes,   3 meters high, con-
structed of overburden)  and $1.88 per  cubic meter to build a tailings
pond dike (2:1 slopes).

     Costs of $0.51 per  cubic meter (above the $1.26 value) are needed
to modify pond dikes in floodplains  from a 2:1 to a 3:1 slopes;  these
costs are for  loading trucks and hauling  overburden from the piles to
the dike areas.

     The revegetation  costs for  dikes or for  closing tailings  ponds
and mine waste piles include the cost of fill soil,  top soil, seeding,
and fertilizing.    It was assumed  that all of the soil  would have to
be purchased.  When mine wastes are revegetated as an ongoing procedure
(e.g.,  in the Florida phosphate industry),  it is assumed that  usable
soil  material could  be segregated  during mining  operations  so that
only 50 percent of the soil would need to be purchased.

     Unit  costs  of soils  and revegetation used  in this study are as
follows:    purchased fill soil  is $3.40 per cubic meter  delivered to
dike areas  and $23,500  per hectare delivered  to overburden piles and
tailings  ponds  for closure; purchased  top  soil  is $4.12 per  cubic
meter  delivered to  dike areas  and  $8,800 per  hectare delivered  to
the site  for closure  purposes.  The   surface areas  used to determine
costs,   by industry,  are shown in Table   C-15.
                             C-75

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     Where only  the  outer  slope and  horizontal portion  of the dike
are  covered  with fill  soil and  top soil  (i.e.,   for tailings pond
dikes),   costs of spreading and compacting the two soils are $1.26 and
$1.53  per cubic meter.    The  costs increase  by 50 percent  if  both
slopes (as on floodplain dikes)  are covered with soil.     Fine grading
of  the soil on dikes is  costed at $0.69 per square meter.   Revegeta-
ting,  including seed and fertilizer,  is costed at $2,500 per hectare.
This revegetation cost applies to dikes and the closure of tailings and
mine wastes.

          (8)  Waste Transportation

               If  NPDES permits are not  granted to mines in wetlands,
costs  must be included for transporting  newly generated mining wastes
out of  those areas.    Capital costs  include  purchasing  a front-end
loader  to load the newly generated mine  waste from the piles onto 30-
ton trucks.    If  the front-end loader is used full time for 8 hours a
day,   5 days a week,  50 weeks a year,   the cost of the equipment per
hour is estimated at $52.    Trucking of  the waste from the  mine site
to  the  disposal  facility  is assumed  to  be done  by a  contractor,
which makes it an operating cost.    The unit cost of trucking is $1.05
per metric ton of waste,  including fuel and labor and based on a round
trip of 32 kilometers.    This distance  was assumed  for all  mines in
wetlands  except  the Florida phosphate industry,   which is located in
extensive wetlands areas.    A round trip distance of 64 kilometers was
assumed there, bringing the unit cost of trucking to an estimated $1.96
per metric ton of waste.

     Other operating costs include labor and fuel to operate the front-
end loader.    Direct labor  plus overhead  is estimated at  $26.60 per
man-hour, and fuel is estimated at $6.00 per hour per loader (38 liters
of fuel per hour at $0.16 per liter).
                            C-76

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                           TABLE  c-15




                   SURFACE AREAS OF NONHAZARDOUS




               MINING WASTES BY INDUSTRY MODEL PLANT

Industry
Copper
Iron
Molybdenum
Gold
Lead/zinc
Phosphate
Clay
Stone
Sand and Gravel

Mine
wastes
(hectares)
716
355
5.28
153
7.73
171
1.67
1.42
Negligible
Full life*
Tailings
pond
(hectares)
NA+
NA
NA
**
0.5
NA
NA
2.3
Negligible
0.8
*    For model plant half life, values are half the number shown.



+    Not applicable, wastes are considered hazardous.



**   Only tailings wastes from mining of placer deposits.
                             C-77

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     The capital  costs  of transporting  tailings wastes  include such
major  items  as purchase  of a  centrifuge  (to concentrate the slurry
from  30 percent solids to 70 percent solids),   a slurry feed pump plus
spare, a sludge conveying system/hopper, and recycle wacer tanks.   The
sum of these items for the clay industry model  plant,  for example,  is
about $205,000.

          (9)  Dewatering Tailings Pond for Closure

               In this study,   dewatering consists of pumping the free
water off the tailings pond and allowing  the retained surface water to
drain  until the ground is  stable enough for  machinery to work on it.
The costs  include pumping  the water from  the pond  surface and  pur-
chasing a fine-mesh,  backwash filter to remove suspended solids.   The
capital cost of the filtering unit,  with pumps and piping, is $25,000.
The main operating cost  is for electricity (30 mills per kilowatthourI
to run the centrifugal feed and backwash pumps.
                             C-78

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                       REFERENCES
U.S. Bureau of Mines.  Minerals yearbook 1974.  v. 1. Metals,
minerals, and fuels.  U.S. Department of the Interior, 1976.

PEDCo Environmental, Inc.  Study of adverse effects of solid
wastes from all mining activity on the environment.  U.S. En-
vironmental Protection Agency.  Contract Number 68-01-4700.
Cincinnati, 1979.  303 p.

U.S. Bureau of Mines.  Mineral commodity summaries 1978.  U.S.
Department of the Interior, 1978.  200 p.

U.S. Bureau of Mines.  Mineral facts and problems.  Bulletin
667.  U.S. Department of the Interior, 1975.  1,266 p.

Unpublished data provided by the Federal Emergency Management
Agency, Office of Federal Insurance and Hazardous Mitigation,
Washington, D.C.

Richard Engineering Services, Inc.  The Richardson rapid
system.  1978-79 ed. v. 1, 3, 4.  Solano Beach, Calif., 1978.

Robert Snow Means Company, Inc.  Building construction cost data,
1978.  Duxbury, Mass., 1977.

U.S. Environmental Protection Agency.  Assessment of industrial
hazardous waste practices in the metal smelting and refining
industry.  SW-145c. 2.  Washington, D.C., 1977.

Midwest Research Institute.  A study of waste generation, treat-
ment and disposal in the metals mining industry.  PB-261052.
Environmental Protection Agency, Washington, D.C., October 1976.
                       C-79

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C.   THE COST IMPACT OF SECTION 4004 OF THE RESOURCE CONSERVATION
     AND RECOVERY ACT ON THE COAL-FIRED UTILITY INDUSTRY
     1.
          The  purpose of this section   is to  define  the cost impact
of the proposed 4004 criteria on the coal-fired utility industry.

     The coal-fired utility industry  is currently  the  largest volume
producer of non-hazardous industrial waste, producing two major streams
of waste:    ash (flyash, bottom ash and boiler slag)  and flue gas de-
sulfurization (PGD) sludge.    In 1977, approximately 62 million metric
tons of ash  and approximately  2.5 million  metric  tons of FGD sludge
              2
were produced.  (A variety of other wastes are generated by the utility
industry.   Although it was  not in the scope  of this report  to cover
these wastes,  it is recognized costs for controlling these wastes will
increase the impact of Section 4004.)

     Ultimate  disposal of any of  these wastes  is in a  pond or land-
fill, either lined or unlined.

     Flyash  collected in a flue  gas cleaning device  can be pumped to
disposal  as a slurry to a  settling pond  or transported dry via pneu-
matic handling  to a storage  silo and subsequent  trucking to a  land-
fill.    The choice of disposal  is highly site specific and highly de-
pendent  upon the method  of collection.    Most dry  material  leaving
coal-fired  utility plants ends up in landfills.    These landfills are
rarely lined.   Where ponds are used for disposal liners, which include
clay and synthetic liners, are sometimes used.

     Disposal options  for sludge involve direct ponding or dewatering.
In  either  case the sludge  can be mixed with  (1) flyash or flyash and
lime or  (2)  a number of  other materials  used for commercial fixation
processes, depending on the chemical nature of the sludge.

     If  dewatering is  not used  the sludges  are commonly  pumped  as
10-15 percent solids.    Sludge can undergo  partial dewatering  and be
pumped   to ponds  as 20-35  percent solids.    The sludge can be vacuum
filtered  to 50-60  percent solids  and trucked  or otherwise hauled to
the landfill.
                            C-80

-------
     In every case where ponding is used,  either for dewatered sludges
or the slurry pumped directly to ponds,  the solids can be  removed and
landfilled after settling.

     The three criteria  which will have the greatest impact on utility
disposal sites are:  1) surface water  (concerning disposal in wetlands)
2) floodplains and 3) ground-water criteria.  In order to determine the
national cost impact of  these three criteria on the coal-fired utility
industry, new and existing disposal facilities are examined separately.

     The total  national solid waste disposal costs for  new plants ex-
pected to  come on line through  1985 are broken  down to show costs of
disposal assuming current practices, costs for compliance with existing
State solid waste and Federal regulations, and the additional costs for
compliance with Section 4004 criteria.

     Existing  sites are examined  based  on  available  data regarding
current disposal practices.  Estimates are made for the number of sites
failing the three  (wetlands,  floodplains and ground-water)  criteria.
Average costs for closing and upgrading are developed.

     Based on this study,   the costs for solid  waste disposal for the
coal-fired utility industry are shown below.

     The range  of cost reflects difference  scenarios for granting and
denying  of NPDES permits for  disposal in wetlands.    These scenarios
in turn affect ground-water  and flood protection costs,   depending on
the number of sites required to move outside the wetlands area.

     As the distance from the plant to the disposal site increases,  it
is assumed the probability of locating impermeable soils increases.  It
is also assumed sites five  to ten miles from the site will not require
protection against washout.    A further explanation of these scenarios
and the range of costs follows in the text.
                             C-81

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a.   Cost for New Facilities

     Total  national  solid waste  costs for the  approximately 250 new
plants  (135,000 MW) expected to  come on line by 1985 are estimated to
fall within the following ranges:

     Capital Investment Costs      Average Operating Costs
     $1.4-$1.5 billion             $100-140 million

     This amounts to $340-370 million in annualized costs.   Annualized
costs are calculated  by amortizing capital investments over the thirty
year life  of the site assuming a pre-tax cost of capital of 16%.   The
amortized capital is added  to annual operating and maintenance charges
to obtain  the annualized  solid waste disposal cost.    The annualized
cost must  be recovered  from consumers  and for  the case of  electric
utilities, increases in the price of electricity are shown in mills per
                    4
kilowatt hour (kwh).

     The portion of these cost assignable to existing State solid wasste
and Federal regulations range from:

     Capital Investment Costs      Annual Operating Costs
     $240-275 million              $24.5-40.5 million

These  account  for  between  $54  and  $84  million  of  the  national
annualized solid waste and .09  and .14 mills per kwh  for the consumer
charge.

     The portion attributable to Section 4004 range from:

     Capital Investment Cost       Annual Operating Cost
     $165-195 million              $.8 million

The annualized cost  of Section 4004 ranges between $27 and $32 and the
charge to consumers will be between .04 and .05 mills per kwh.
                            C-82

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b.   Cost for Existing Facilities

     The  current  cost for  the utility  industry to dispose  of their
65 million metric  tons of solid waste  is estimated to be $195 million
annually.    This is based  on an  average disposal  cost  of $3.00 per
metric ton.

     Total  national  solid waste  costs associated  with bringing  the
disposal sites at the current 400 plants  (200,000 MW)  into compliance
with the criteria are:

     Capital Investment Costs      Annual Operating Costs
     $198-$268 million             $2.5-50 million

This would increase total annualized costs between $85 and 110 million.

     The total  costs required to comply  with existing Federal regula-
tions and state solid  waste regulations for the coal-fired utility in-
dustry are:

     Capital Investment Costs      Annual Operating Costs
     $162-211 million              $2.2-50 million

     This amounts to 67 to 112 million in annualized costs.   These ex-
penses will increase electricity costs by .11-.19  mills per kwh.

     The 4004-induced costs amount to:

     Capital Investment            Annual 0 & M
     $36-57 million                $.16-.30 million

     These costs  amount to between $12  and 18  million  in annualized
solid  waste costs.    Based on the estimated  134,000  MW of  capacity
assumed  to be affected,  electricity  costs will  increase between 0.02
and 0.03 mills per kwh.
                            C-83

-------
     Explanations of the criteria,  assumptions,   methodology and pro-
cedures for cost development  are shown in detail in the following sec-
tions.

2.   Development of Model Plant

     In order  to develop the base  number from which  average national
costs for future utilities can be extrapolated,  a model plant approach
is utilized.    The typical plant characterized  for the purpose of de-
veloping  national  average  costs is  based on  a 1000  MW "nameplate"
capacity.    Average dollar per kw capital  investment costs and dollar
per  ton  annual operating  costs are generated  using published  data.
Cost data for  model plant disposal options are  taken from EPRI FP-671
"State-of-the-Art of  FGD Sludge Fixation."    Additional  sources  are
utilized and will be referenced.

     The annual  quantities of ash and  sludge a utility plant produces
is a function of several variables including the ash and sulfur content
of the coal.    Because several Eastern  and Western coals with varying
range of ash and sulfur are utilized,  one Eastern and one Western coal
is assumed with the specific ash and sulfur content shown below:

     Eastern Coal:       14% ash, 3.5% sulfur, 12,000 BTU/lb.
     Western Coal:        8% ash, 0.8% sulfur,  9,000 BTU/lb.

     Based  on Federal  Energy Administration  projections for  Eastern
and Western coal use in 1985,   it is assumed the model plant burns 77%
Eastern coal and 23% Western coal.    The average capacity of the power
plant  over  its thirty  year life is  assumed to  be  4380  hours (50%
capacity) per year.   This is based on an average of 7000 hours for the
first ten years, 5000 hours for the next five,  3500 for the next five,
and 1500 for the last ten.     This average is used to estimate average
quantities  of  flyash  and sludge  generated over  the lifetime of the
plant.    Density figures  were used  to estimate  the volume  of solid
waste  to determine  the required  size of the disposal  facility  (see
appendix).
                            C-34

-------
     Current  emission  standards  for  coal-fired utilities  limit SO,,
                              c                                       *•
emissions  to  1.2  Ib  SO-/10   Btu and  require  99% flyash  removal.
Announced  new source performance standards  (ANSPS)  would require 85%
removal of  SO.  from all coals.    Promulgation  of these  regulations
will  affect  all coal-fired  utilities coming on  line beginning 1983.
The dominant impact of the proposed  regulations is for scrubber sludge
at plants burning low sulfur coal.   The impact of these regulations on
solid  waste production  will be significant  in the 1990's.    The EPA
Office of Air Quality Planning and Standards projects that the megawatt
capacity  of coal-fired  utilities scrubbing  in 1985 will  increase by
approximately 4,800 MW due to the ANSPS  and sludge generation will in-
crease by approximately 2 million metric tons per year.

     This report  examines planned facilities  expected to come on line
through 1985.   The majority of these facilities operating scrubbers by
1985 will be complying with current emission standards.  Therefore, for
the purpose of developing solid waste costs, annual quantities of solid
waste produced by the typical plant are based on current emission stan-
dards.

                                 3 8
     The quantities of waste are: '

          ASH            187,000 MT
          SLUDGE*        162,000 MT

     The ANSPS  is taken into account by  increasing the megawatt capa-
city disposing of both flyash and sludge by 4,800 MW.

     Bottom ash,  or boiler slag,  generated in smaller quantities  can
be  disposed in  separated ponds  or together with flyash and  scrubber
sludge.    Alternatives  for bottom ash  disposal are more  limited and
less complicated  in terms of disposal alternatives.    Although bottom
ash is not separately treated in this report, ash quantities do reflect
*Limestone is assumed to be the scrubber reagent, based on current
 industry practice.
                            C-35

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                                                C-87

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both flyash  and bottom ash.    Co-disposal  of bottom ash  with flyash
and scrubber sludge is assumed;   therefore,  costs  accurately reflect
total disposal costs for all coal-fired utility wastes, although bottom
ash  is not  specifically  mentioned throughout  the remainder  of this
       9
report.

     There are four  basic disposal practices used for the calculations
in this study.  They are ponding of ash, landfilling of ash, ponding of
FGD sludge and ash, and landfilling of FGD sludge and ash.   These four
practices  are assumed to be  representative  of current industry so Lid
waste disposal.

     Disposal costs for these four scenarios are shown in Table VII-.L6.
These costs  include all expenses considered necessary to meet the 4004
criteria.    Costs for varying distances to the disposal sites are also
shown.    By comparing capital  investment requirements for  a pond and
landfill, ponding is more expensive due to pumping and piping expenses.
Landfilling, on the other hand, tends to incur greater annual operating
costs resulting from operation and maintenance  of moving equipment and
labor.    Where ash and sludge are disposed,  operating costs for land-
fills show  a sharp increase due to  additional maintenance of the pro-
cessing facility utilized for dewatering.

     Construction designs for the four  disposal sites along with comp-
onent costs are shown in the appendix.

     All national cost estimates in this report are  derived  utilizing
the  average  kilowatt capital  investment  costs  and annual operating
costs.    Projections are made  regarding the future  megawatt capacity
employing  the various  disposal  scenarios and  the  existing megawatt
capacity failing the three criteria.    These projections are explained
in the following sections.    Solid waste disposal costs  and costs for
upgrading  and closure are derived by  multiplying these megawatt capa-
cities by average dollar per kilowatt costs.  In order to derive annual
operating  costs,    these  megawatt  capacities   are  converted  into
                             C-88

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equivalent 1000 MW plants and multiplied by the annual operating  costs
shown.    The cost figures represent average cost figures to the extent
that the 1000 MW plant is representative of a typical plant.  It is re-
cognized  the average existing utility is  approximately 500 MW; there-
fore, a power-rating-size cost adjustment factor was  used for existing
plants.

     Ponds  are assumed to be approximately 9 meters deep,  rectangular
in shape  and contained  by dikes with a two to one slope.    In actual
practice,   the depth and shape of the pond will be determined by local
conditions.  The ponds provide a thirty-year lifetime.   Ash and sludge
are assumed to settled to 65% solids.

     Landfills  are assumed to be  approximately 12 meters  at the mean
depth and  provide a thirty-year lifetime.    Flyash  is collected  dry
and mixed  with water to be landfilled  at 20% moisture content and ash
and sludge are dewatered to approximately 50% moisture content.    Land
requirements for the four scenarios are as follows:

     ASH POND                            92 hectares (230 acres)
     ASH LANDFILL                        62 hectares (155 acres)
     ASH/SLUDGE POND                    168 hectares (420 acres)
     ASH/SLUDGE LANDFILL                107 hectares (268 acres)

Land requirements  needed for  ultimate disposal  depends on water con-
tent.

     Distance  from  the plant  to the disposal  site  is  assumed to be
approximately 3 km (2 miles).

3.   Solid Waste Costs for New Facilities

     New plants  coming on  line by 1986  are projected to  add 135,000
MW  of generating capacity.     Of these 135,000 MW,   70,000 MW will be
operating scrubber units,   based on current and proposed NSPS.    Coal-
fired  sites will be  located in forty  out of the fifty States,   with
major capacity generated in EPA Regions 4, 5, and 6.    The current mix
of  disposal  practices  at  coal-fired  utilities  is  based  on  data

                            C-89

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collected  from  the most current  Federal Power Commission  (FPC) tape
for their  Form 67 data  for the year ending  31 December 1974,   and a
survey of 64 coal-fired utility plants,   most of which began operation
in  the period 1970-1978.     The latter data are more  up-to-date  and
more accurate  than the  FPC data.    Based on this  survey determining
disposal practices by quantities of ash,  it is assumed,  of the 65,000
MW of capacity coming on line and producing ash only,   51% (33,000 MW)
will  landfill their wastes,  35% (23,000) will pond them,  and the re-
maining 14%  (9,000 MW) are assumed  to incur no costs due to.  resource
recovery  practices  for  their ash.      This 14% reflects 1977 flyash
utilization figures produced by the National Ash Association.*

     The data  obtained from  the 1974 Form  67 or  additional  contact
with 64 plants were not sufficient  to cover solid wastes from flue gas
desulfurization processes.    Additional data was gathered on 38 plants
contracted for  SO_  removal systems or under letter of intent to do so
                 3
by April 1, 1978.    These plants should begin operation by 1986.    Of
36 plants  (25,000 MW) which have decided on disposal options,  19 units
(11,500 MW)  46% will  utilize landfill  and 17 units   (13,700 MW)  54%
will use ponding.    Based on this survey,  for the 70,000 MW producing
both ash and sludge,  54% are assumed to  pond their waste and 46%  are
assumed to landfill it.     (Although some  of this  scrubbing  capacity
refers to  retrofitting  existing facilities,   disposal costs  for new
scrubbing capacity will be handled under new facilities.)

     Solid  waste  capital  investment  costs  for  new facilities  are
estimated  to range from $1.4 billion to $1.5 billion.    Annual opera-
ting  costs are estimated  to range from  $100 to $140  million.   This
amounts to between  $340 and $370  in annualized solid waste costs,  of
which  consumers will pay  between  .5 and   .6 mills  per kwh  for solid
waste disposal.
*NOTE:  In this case   14%  approximately reflects the national utiliza-
tion  rate for flyash.    Bottom ash, due to its higher carbon content,
has a higher  economic value and was  utilized at a higher rate of 33%.
                             C-90

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     The  majority  of these  national solid waste  disposal costs  in-
clude  base solid waste costs incurred  for disposal of waste according
to current practices.    The remainder of  the costs are assignable  to
existing  Federal  regulations,    (specifically,   section  404 of  the
Federal Water Pollution Control Act) and State solid waste regulations,
and Section  4004  (which have comparable  provisions  for wetlands and
floodplains  protection).    In order  to  develop the  cost impact  of
Section 4004,  projections are made regarding future disposal practices
based on compliance with the ground-water, wetlands and floodplain pro-
visions.    Costs  to  comply with these  three criteria  are isolated.
State  solid waste  regulations and  existing  Federal regulations  are
assessed  for corresponding criteria  and the assignment of State-stan-
dards costs  is performed.    The grid prepared for the Economic Impact
Analysis for the Criteria was utilized  for this operation.   The final
cost for  Section 4004  is the difference  between the  costs to comply
with the criteria and federal and state-standard induced costs.

a.   Ground Water

     The first criteria  requiring safeguards by the coal-fired utility
industry is the ground-water criterion.

     Clay lining,  monitoring wells  and leachate collection and treat-
ment facilities  are considered to be the best available control  tech-
nology  for prevention of ground-water  contamination.    The extent to
which these measures are employed  at each site is entirely site speci-
fic.   Certain natural conditions at the disposal site may provide ade-
quate protection  without  a liner.    These  conditions  include  soil
characteristics, hydrogeologic and geologic conditions and climate.

     Very little information  is currently available  to determine what
percentage  of sites will  require liners.    The majority  of  utility
plants  employ  on-site disposal.    Since they  are located relatively
close to their water source,   there is a high probability these  sites
will be located on sandy, alluvial soil which is highly permeable.
                            C-91

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     For  the purpose  of estimating  the cost  to protect ground
water, it is assumed  that two-thirds of all new sites will require
liners and the  remaining one-third  will locate on  land providing an
indigenous liner.  These percentages are based on three data points
available from monitoring at utility disposal sites.  '   '

     It is  assumed a .6m natural clay liner  will prevent endangerment
of the ground water.    The national cost for clay  liners is estimated
to be between $280 and $314 million in capital investment costs.   This
is   based   on  material  and   installation  costs  of  approximately
       3 14
$5.80/m .      These  capital  investment  costs  can be annualized  to
$45-50 million a year.

     Monitoring  costs vary  from site to site,   depending on the data
collected.    Monitoring is costed into each site at a price of $40,000
for capital investment and $16,800 per year for analysis.  This $40,000
capital investment cost reflects 4 3-cluster piezometer wells to deter-
mine direction of ground water, 7 sampling wells, and cost of drilling,
engineering,   mobilization,   equipment and materials.      The annual
operating  costs include quarterly sampling  and a comprehensive annual
sampling.

     Monitoring  costs are assumed at all disposal sites.    Monitoring
costs are  estimated at  $5.4 million  for capital  investment and $2.3
million per year for analysis.    This equals an annualized  cost of $3
million per year.

     Leachate  collection  and treatment  systems  are not included  in
these  total national costs.    A clay-lined pond is assumed to prevent
contamination  and the  supernatant  pump  is  assumed to  maintain the
water balance and eliminate the  need for collection and treatment.  It
is also assumed the landfill  will be constructed  to prevent the prob-
lem of  leachate.  Due to  the unknown nature of leachate,   the amount
occurring and  the degree of treatment,   no exact costs are  available
for  leachate treatment and collection.    If leachate  collection  and
treatment becomes necessary at lined landfills costs will increase.  If
                            C-92

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                                                                     14
annual  treatment costs  per gallon of leachate  average 2C a gallon,
annual solid waste 'costs  for the industry would  increase by approxi-
mately $23 million.

     Thirty-one  of the forty states in which coal-fired  utilities are
projected  are assumed to have  a ground-water criterion  comparable to
the Section 4004 criteria.   Approximately one-third of projected capa-
city  is located in the remaining nine states;   therefore one-third of
the ground-water  projection costs are attributable  to Section 4004.
These costs are estimated to be  $95-105 million in capital investment,
$.8 million in annual operating costs or an  annualized cost of  $16-18
million per year.

b.   Wetlands

     The degree to which new facilities  would be likely to locate dis-
posal facilities  in wetland and violate surface water criterion is un-
known.  There are currently very few detailed  maps available designat-
ing wetland areas.  The U.S. Office of Fisheries and Wildlife has begun
extensive  mapping  of wetland  areas;   however,  this project is only
scheduled for completion in 1983.

     For the purpose of determining to what degree coal-fired utilities
in states with varying concentration of wetland will be affected.  Land
Use Development  maps available at the U.S. Geological Survey were con-
sulted.    The longitude and latitude of utilities in two states, South
Carolina  and Pennsylvania,   were used  to determine  the location  of
plants in relation to wetlands.    South Carolina was chosen as a state
with  high concentration of wetlands and Pennsylvania  as a state where
wetlands are sparser.    The majority of existing  coal-fired utilities
in  South Carolina  are located near  enough to wetlands  to assume all
existing  sites are affected and  future sites will be affected.    The
coal-fired utilities which were plotted in Pennsylvania were not affec-
ted  by the wetlands.    Therefore  it is  assumed  existing  sites and
future sites, in this state, will not be affected.
                             C-93

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     To  apply  these conclusions  to the nation  the Natural  Wetlands
map by the U.S. Water Resources Council,  1968 (see appendix)  was con-
sulted.    The twelve states which contain large concentrations of wet-
land are:   Arkansas, Florida, Georgia, Louisiana, Michigan, Minnesota,
North Carolina,  North Dakota,  South Carolina, South Dakota, Texas and
Wisconsin.  It is assumed sites in these states will be affected by the
wetlands provision and sites in the remaining states will not be affec-
ted.   Approximately 60 plants or twenty percent of the projected coal-
fired generating capacity will be built in these twelve states.

     The  distances from  the plant to which these  disposal sites must
move are unknown and will vary.   Costs were developed for distances of
8 km (5 miles) and 16 km (10 miles) from the site.   Where wetlands are
highly dense,   it is assumed the disposal site  will be located  16 km
from the plant;  other sites in less dense areas are assumed to be able
to locate disposal sites 8 km away.

     Three  scenarios are examined  for the national  costs of wetlands
criterion.    The first  case assumes  that all 60  new facilities  are
denied  NPDES  permits  and will  be forced  to locate  their  disposal
facilities  outside the wetlands.    For this case 50%  MW of the sites
are assumed to  move 8 km from their  plant and 50% are assumed to move
16 km.

     The  second national  cost which is developed  assumes that  sibes
located in Louisiana, Texas, Florida, North Carolina and South Carolina
will be granted NPDES permits.    Due to the ubiquitous  nature of wet-
lands in these states,   it is assumed that no technically or economic-
ally  feasible alternative  exists for disposal.    Twenty-five  of the
sixty sites  are located  in wetlands in  states other than  these five
states.    The 25 sites represent 8 percent of the projected coal-fired
generating (10,600 MW)   capacity.  Because these states are those with
sparser wetlands it is assumed all these sites will only be required to
move a maximum of 8 km.
                            C-94

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     The third scenario  assumes all sites applying for an NPDES permit
will be granted one.    In this case, no additional costs are incurred.

     The costs of increasing the distance from a coal-fired utility and
its disposal  pond include additional capital expenses for larger pump-
ing  facilities  and  piping  installations to  the disposal  site  and
additional operating costs resulting from greater  transportation  dis-
tances.    For the purposes of this study,  it is assumed that moving a
pond  8 km from the plant increased capital costs 56% and annual opera-
ting costs 69% from the base case. Moving a pond 16 km from the site is
assumed  to  increase  capital  investment  117%  and  annual operating
costs 129%.

     Landfill costs  increase due to costs  of additional equipment for
transporting  the wastes and increased operation  and maintenance costs
due  to increased distances.    For the purpose  of this study,   it is
assumed  moving a landfill 8 km will  increase capital investment costs
6% and annual  operating costs 23%.    Moving a landfill 16 km will in-
crease capital costs 11%  and annual operating  costs 41%.   These per-
centage  figures are taken from EPA  Report 600/7-78-023A "Economics of
Disposal  of  Lime/Limestone  Scrubbing  Wastes;   Untreated and Chemi-
cally Treated Wastes."  Corresponding annual operating costs are extra-
polated and shown in Table VII-16.

     In order  to develop the cost incurred due to increased  transpor-
tation, two assumptions come into play.  It is assumed a plant will use
the cheapest disposal method at the new site.    It is also assumed for
plants  requiring  to site  their disposal  sites 8 or 16  km  from the
plant, a higher probability exists for locating impermeable sites.  For
those sites forced to move 8 km from the site,  50% will be required to
line.    For those sites 16 km away,  only one out of three will be re-
quired to line.  What would normally account for an increase of capital
cost due to increased distance to the disposal site is off-set by these
two assumptions.  The first is sites which would have previously ponded
                             C-95

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will convert to landfilling.   This assumption results in a substantial
decrease in capital costs.    Secondly, because it is assumed the prob-
ability  of  finding sites with  indigenous  clay liners increases, the
increase  in  capital costs caused by  the  additional distance  to the
site is off-set by the decrease in liner expense.

     The  majority of the cost  impact of the wetlands criteria is seen
in increasing operating costs.

     The  additional solid  waste disposal  costs incurred  if all  new
facilities  are denied NPDES permits and 10%  of new facilities are re-
quired to move 8 km and 10% of new facilities  are required  to move 16
km amounts to $39 million in annual operating costs.

     Under the second scenario,   additional annual operating and main-
tenance charges amount to $14 million.

     The wetlands  criterion is a  direct attempt  to coordinate  solid
waste regulation with the Clean Water Act.    The issuance or denial of
these  permits and the resulting requirement  to move are costs assign-
able  to the  Clean Water  Act of 1972  and are not  charged to Section
4004.

c.   Floodplains

     The total cost impact  of this criterion consists of costs to pro-
tect sites against washout by the 100-year flood.

     Based on the  assumption that 100 percent of these facilities will
be located in the floodplain,  costs to protect against washout are the
costs  of flood protection  dikes for all  new facilities.    Since the
levels  and velocity of  each flood are  site  specific, the height and
material  requirements for  each dike will vary.    A  3  meter dike is
assumed to be a sufficient average height to protect against the flood-
waters.    A cost of $2.60/m  for fill material is assumed to cover the
                            , C-96

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cost  of building  a dike on  dry land.    This price  includes  avail-
ability  and compactability  of the material  as well  as leveling  and
digging expenses.

     The capital  costs of the  pond discussed earlier  already include
embankments approximately 9 meters high.    It is assumed these embank-
ments can  and will be built  to protect against the floodwaters.   Be-
cause these  embankments are  constructed in the absence  of flood pro-
tection requirements,   only the portion of the costs incurred for pro-
tection  against erosion are charged to the criterion.    It is assumed
       •5                                                             1 p
$1.40/m   is the base price for building the embankment for the pond.
Therefore, the remaining $1.20/m  required for protection against wash-
out is attributed to the criterion.

     The  cost of flood  protection for  landfills includes  the entire
cost of the 3 meter dike.

[NOTE:  In  the previous chapters of this EIA,   costs for flood proof-
ing  were assumed  to be based  on a 3:1  sloped  dike and material and
placement costs of $2.00/m .   Separate calculations  were performed to
determine  the  dollar value  by  which  these  estimated  costs  would
change based on these two varying assumptions.

     Because  the dike surrounding the landfill  is only 3 meters high,
a 2:1 slope is technically feasible.

     The higher  cost for  material of  a dike used for this coal-fired
utility report with a 2:1  slope off-sets the lower estimate for volume
of material required  for a dike with a 2:1 slope surrounding the land-
fills in this report.    Costs to protect  against washout would be re-
duced  by approximately  $17,000 for flyash landfill sites  and $26,000
for flyash/sludge landfills,   which accounts for less than .2% and .4%
of total  capital investment costs  respectively.    Due to  the insig-
nificant  amount of these costs,   this difference is not accounted for
in the total flood protection figure.
                             C-97

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     For  the 9 meter dike which  is currently built to surround a sur-
face impoundment, a 3:1 slope may be  the most technically and economi-
cally feasible  option to protect  against washout  and insure that the
dike will not erode with the 100-year flood.    The difference in costs
between  the assumptions made in this report  and those previously men-
tioned is an additional capital  investment cost of $221,000 in capital
costs  for  the flyash pond  and $272,000  for the flyash/sludge  pond.
These  costs represent an increase  of 1.7% and 1% of capital costs re-
spectively.    This difference has been included in the following esti-
mates  for the  cost of  flood protection  and has  been added to total
national  solid waste costs  for new  facilities to  insure consistency
and accuracy.]

     Total  costs for flood protection  are calculated  to be $120-$150
million for capital investment,which translate to an annualized cost of
$19-24 million.

     Only  fifteen  states are  assumed to  have  comparable floodplain
criteria in their solid waste regulations.   These states are estimated
to include  approximately 40%  (57,000 MW)  of the projected 135,000 MW
                    19
generating capacity.      Assigning  the corresponding  cost of  $48-60
million  to states for floodplain protection decreases the Section 4004
criterion costs to $72-$90 million in capital investments.

     The total costs for new facilities to meet the ground-water,  wet-
lands  and floodplain  criteria is estimated to  range between $405 and
$470 for  capital investments  and $15.7 and $40.9 for annual operating
costs.  The annualized costs range from  $81 to $116 million which will
increase  the price of electricity  between .14 and .20 mills per kilo-
watt hour.  The total costs assignable to Section 4004 are between $165
and  $195 million  for capital  investment  and $.8 million  for annual
operating cost.   Annualized Section 4004 criteria induced costs amount
to $27 to 32 million  or an increased consumer  charge of .04-.05 mills
per kilowatt hour.

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4.   Costs of 4004 on Existing Facilities

     In  order to assess  the cost impact  of Section 4004  on existing
facilities,  the basic methodology employed  for new facilities is uti-
lized with adaptations to account for additional knowledge.

     Any  site which fails  the criteria and  is listed as an open dump
will be closed  or upgraded according  to a  state compliance schedule.
Although  the  average life  of a utility plant is thirty years,   many
existing  sites are built for five or  ten year portions  of this life.
Information is not  available concerning the age and remaining capacity
of existing sites.    For the purposes of determining  the costs of up-
grading and  closure, all existing sites are assumed to have a ten year
life and to have been in operation for five years.    Capital costs in-
curred  for upgrading or closure  are annualized for the  five years of
the remaining life of the site.    Therefore a different annuity factor
is used.

     A power-rating-size cost adjustment factor was used to offset  any
economies  of scale which  may exist for  new 1000 MW  plants coming on
line but not  for existing plants  with an average capacity  of 500 MW.
It  was assumed a capital  cost of $1.00/MW  for a 1000  MW plant would
equal $1.32  and an annual operating cost  of $1.00/ton of waste  would
equal $1.39 for a 500 MW plant.  An average of $1.35 was applied to an-
                                                o
nualized costs to more accurately reflect costs.

     Current utility  waste disposal  practices are considered to be as
c T n    20
follows:
                            C-99

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     DISPOSAL PRACTICE                            ft OF PLANTS
ASH:
  Lined Pond                                            25
  Unlined Pond                                         225
  Unlined Landfill                                     175
ASH/SLUDGE:
  Untreated/Unlined Pond                                14
  Untreated Lined Pond                                   2
  Treated Unlined Pond                                   1
  Treated Unlined Landfill                               4
  Untreated Unlined Landfill                             4
SLUDGE ONLY:
  Untreated Lined Pond                                   3

     Of  the  approximate 200,000  MW of current  coal-fired  capacity,
12,000 MW  are producing flyash and sludge.    The distribution of  the
megawatt capacity  utilizing  each disposal  practice  is based  on the
previous chart.  It is assumed 72 percent pond their sludge and 28 per-
cent landfill.

     Of the  188,000 MW  producing flyash,   51% (96,000  MW) are land-
filling,  35% (66,000 MW) are ponding and 14% (26,000 MW) are utilizing
their ash.    Sludge/flyash disposal  is distributed as follows:    72%
(8,700 MW) are ponding and 28% (3,400 MW) landfilling.

     In  the preceding  disposal practice table,   treatment  refers to
chemical/commercial fixation of flyash and sludge.    Clarifier, vacuum
filtration  and centrifuge treatment  are not included in this category
because they are   not considered to change the  chemical properties of
the  water to  eliminate leaching  or decrease  permeability  of  waste
material.

2.   Ground Water

     Current  flyash  disposal  sites which  are lined   (6,600 MT)  and
flyash/sludge  sites  using liners  or chemical  fixation   (5,500 MW)
are assumed to meet sanitary landfill criteria.   Of the remaining four

                            C-100

-------
hundred sites  (155,400 MW) disposing of ash at unlined sites, approxi-
mately two-thirds  (103,800 MW)  are assumed  to  leach  and  one-third
(51,600 MW) are assumed to be located in soils which provide indigenous
liners.    These percentages  are based on  the three data  points pre-
                , 11, 12, 13
viously mentioned.

     The same  assumption is  applied to  the eighteen  sludge disposal
sites  which neither  line nor  chemically fix the waste.    Two-thirds
(4,400 MW)  are assumed to  leach and one-third  (2,100 MW) are assumed
to meet the ground-water criteria.

     Costs for upgrading sites are shown in Table  C-17.  It is assumed
existing  sites  are  one-third the  size of  the  new facility  with a
thirty year lifetime.    Liner costs of  $5.80/m   are assumed for mat-
erial  and  installation.    The cost  of liner  required for  existing
facilities  is one-third of the cost for new facilities.    The cost of
removal of the waste is  estimated to be approximately $.75/m .    Once
again,  very little cost information for removing  wastes and upgrading
the site is available.     One case in Buffalo,  New York cites the re-
moval  of 1.4 million cubic meters  of waste and  the construction of a
sump to  collect leachate for ten million dollars.    A cost of $.75/m
was assumed to be reasonable for removal of waste.    Temporary storage
is not included in these costs.

     It  is assumed  monitoring will  be established  at  all  existing
sites failing the criteria and new replacement facilities.   Monitoring
expenses include capital costs of $40,000 for sinking wells and $16,800
per year for analysis.

     It  is  assumed that all  sites failing  the ground-water criteria
will  be upgraded unless they  are located in a wetland area,  in which
case closure is a possibility.

     Due  to the additional expense  to build a facility to replace the
open dump, upgrading costs shown for the model plant are less expensive
than  closure costs for all cases except flyash landfills.    The ulti-
                             0101

-------
mate decision  to close or  upgrade will be made by the operator of the
site based  on the remaining life of the   site, land availability  and
comparative costs of options for compliance.

     The  cost  for  utilities  to  upgrade  existing  sites (including
power-rating-size cost adjustment factor) ranges  from $114 million  to
$216  million for capital investment  and $1.3  to $2.5 million for op-
erating costs  depending on the number  of sites required to close  due
to  location in wetlands.   This equals an  annualized cost of approxi-
mately $37 to 52 million for ground-water protection.

     Thirty-seven  of the fifty states  are assumed to  have comparable
ground-water  regulations.    The  Section 4004  criteria-induced  cost
for those  thirteen states are  12% of total costs  to correspond  with
the approximate  percentage of existing  generating capacity located in
the thirteen states where state solid  waste regulations do not account
for ground water (see appendix).    Costs assignable to upgrading these
sites are between  $13 and $26 million for capital investment cost, .16
and .30 in annual  operating costs or annualized  costs of $4.5 to $8.5
million.

b.   Wetlands

     It is estimated  that approximately 25% of existing sites,  or 115
utilities (50,000 MW)  of capacity  are located  in  twelve  "wetlands"
states previously determined.    (The background for this assumption is
discussed in the wetland portion of the new facility section.)    Since
wetlands  are generally located  in shallow  ground-water areas,  it is
assumed that these  50,000 MW are a  total subset of the sites affected
by the  ground-water criterion.    Costs are  developed for three scen-
arios.    The first scenario assumes that NPDES permits would be denied
to all existing sites  currently  located  in  wetlands.    The  second
scenario  assumes that  NPDES permits  will be  granted to the 30 sites
(20,000 MW) in Texas,  Louisiana,  North Carolina,  South Carolina, and
Florida because of the lack of technical and economical disposal alter-
natives.   These 30 sites will upgrade to meet the ground-water criter-
ion.
                            C-102

-------
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-------
     The  last scenario  assumes  that all  sites will  apply for NPDES
permits and receive them,  depending upon compliance with the technical
requirements  of Section 4004.    These costs are  shown as the highest
ground-water costs previously discussed.

     The  cost components  of this  criterion include  costs of closing
open dumps,  capital costs  of establishing  a new site and  additional
annual operating costs due to increased distances.

     Closure of an  open dump is assumed to require application of  .6 m
of final  permeable cover at  .65/m  and revegetation at $2,500/hectare.
The $2,500/hectare  includes  $500 for  seeding  and $2,000  for ferti-
lizer.22

     The criteria-related  capital cost of  the replacement facility is
assumed  to be  equal to  one-sixth  of the  cost  of the  thirty  year
facility,   based on a five year   life, since only  five years  of the
existing disposal facility capacity is retired.    Additional operating
costs  are those incurred based  on increased distances to the site and
monitoring analysis.

     The costs for these three options are:

                                                       Annualized
                                                          Costs
                                                       62,200,000
                                                       30,500,000
                                                           -0-

     No  information  is  available regarding  the  enforcement  action
which will occur for these existing sites.   In any case, these will be
costs assignable to the Clean Water Act.

c.   Floodplains

     As with new sites,   it  is assumed that 100%  of existing disposal
sites are  located in floodplains.    Although utility plants, in recent
                             C-104
SCENARIO I
SCENARIO II
SCENARIO III
Capital
Investment
46,600,000
28,200,000
-0-
Annual
Operating Costs
49,100,000
22,400,000
-0-

-------
years,   have protected  their generating  facilities against  the 100-
year flood,   it is assumed  very little protection  has  been provided
for  their disposal facilities.    Compliance costs for  the floodplain
criterion  are the costs are  flood protection dikes.    Costs for  the
flood  protection dikes for  landfills are based on  the same cost com-
ponents used for new facilities.   The perimeter of these sites is cal-
culated by  reducing the area of  fill for the thirty year site to one-
third and calculating a new perimeter.   An operator may elect to build
an embankment around land set aside for future disposal;  however,  for
the purpose of this report,   it is assumed only the remaining disposal
area will be diked.

     The costs  for  upgrading existing  surface  impoundment  dikes to
protect  against washout  includes application  of 3 meters of rip-rap.
This assumption  is based on  current practices  for upgrading existing
                                                rap
                                                 23
dikes  for protection  against floods.    A rip-rap cost  of  $43/m  is
utilized to reflect material and placement costs.

     The  capital cost  for all existing  sites to building  flood pro-
tection dikes is approximately $37-51 million.  The $51  million assumes
that no existing site is moved.   If sites are closed based on the wet-
land criterion  and moved outside the  wetlands area,  it is assumed no
floodplain  protection costs  will be  incurred for  sites 8 and  16 km
from the plant and  this criterion induced cost  will decrease by $9-14
million.  The annualized cost is between $11 and 16 million.

     The  twenty-three  states  shown  to  have  comparable  floodplain
criteria  constitute approximately  78,000 MW or  40% of existing capa-
city.   The cost of upgrading the remaining 60% is assumed to be attri-
butable to Section 4004.   The corresponding portion of the diking cost
is  $22-32  million  in capital  investments  or  an annualized cost of
$7.0 to 9.9 million.

     The  entire costs  of upgrading  existing facilities  to  meet the
ground-water, wetlands, and floodplain  criteria will vary depending on
the amount of closure required in wetlands.   Up to sixty-seven percent
                             C-105

-------
of existing capacity  (134,000 MW)   may be affected  by these criteria.
Approximately  $200 million in  capital investment will be necessary to
close,   upgrade and establish new   sites if no existing facilities are
permitted  to continue  in wetlands  and  $50   million  in  additional
operating expenses would be required.    For the least stringent wetland
scenario  —  no closure  —  the cost of  these criteria  will be $270
million for capital investment and  $2.5 million annual operating costs.

     The  annualized solid  waste cost  for existing  facilities to up-
grade to meet the criteria are  estimated to range between $78 and $130
million.    The consumer  charge associated  with these increased costs
is between .13 and .22 mills per kwh.

     The Section  4004 costs are  between  $36 and $57 million in capi-
tal investments, $.16 and $.30 million in annual operating costs.   The
increased annualized solid waste cost is $12-18 million  and the assoc-
iated consumer charge is .02 to 0.03 mills per kwh.
                              C-106

-------
                       5.   References

 1.   National Ash Association and Edison Electric Institute.

 2.   Rosoff,  J.,  et.  al.  Disposal of By-Products from Nonregenerable
     Flue Gas Desulfurization Systems:   Second Program Report,
     Aerospace Corp.,  USEPA,  May, 1977.

 3.   Jones,  B.F., et.  al,  Study of Non-Hazardous Wastes from Coal-
     Fired Electric Utilities:  Draft Final Report,  Radian Corp.,
     USEPA,  December 15,  1978.

 4.   Temple,  Barker and Sloane, Inc., Review and Financial Analysis
     of Best Available Technology, NSPS  and Pretreatment Standards
     for the Steam-Electric Utility Industry,  USEPA, December 27,  1977.

 5.   Federal Energy Administration 1976  Energy Outlook.

 6.   Barrier, J.W., et. al.,  Economics of Disposal of Lime/Limestone
     Scrubbing Wastes  Untreated and Chemically Treated Wastes,  USEPA,
     February, 1978.

 7.   ICF Incorporated, Summary of Forecasted Effects of Alternative
     New Source Performance Standards for Coal-Fired Powerplants,
     USEPA,  December 12,  1978.

 8.   Rosoff,  J. ,  et.  al..  Controlling SO,, Emissions from Coal-Fired
     Steam - Electric  Generators:  Solid Waste Impact (Volume II:
     Technical Discussion), Aerospace Corp., USEPA,  March, 1978.

 9.   Jones

10.   Jones

11.   Fling,  R.B., et.  al,  Disposal of Flue Gas Cleaning Wastes:   EPA
     Shawnee Field Evaluation - Second Annual  Report, Aerospace
     Corp.,  USEPA, February,  1978.

12.   Theis,  T.L., et.  al., "Field Investigation of Trace Metals in
     Ground Water from Fly Ash Disposal", Dept. of Civil Engineering,
     University of Notre  Dame, 1977.

13.   U.S. EPA Region VII,  Report of Groundwater Investigation Iowa
     Public Service -  Port Neal Units 1, 2, and 3 Salix Iowa,
     Surveillance and  Analysis Division.

14.   Fred C.  Hart Associates, Inc., Overview of Landfilling
     Technology Task IV Economic Analysis, USEPA, October 12, 1978.

15.   Duvel,  et.  al.,  Michael  Baker, Jr., Inc., State-of-the-Art of
     FGD, Sludge Fixation, EPRI, January, 1978.
                            C-107

-------
16.   U.S.  Department of Energy,  Inventory of Power Plants in the
     United States,  Office of Utility Project Operation,  December,
     1977.

17.   Personal communication with Jack Thompson,  U.S.  Army Corps
     of Engineers.

18.   Duvel.

19.   U.S.  Department of Energy.

20.   SCS Engineers,  Data Base for Standards/Regulations Development
     for Land Disposal of Flue Gas Cleaning Sludges,  USEPA,
     July, 1977.

21.   Geswein, A.J.,  Liners for Land Disposal Sites:   An Assessment,
     USEPA, 1975.

22.   Fred C. Hart Associates

23.   Personal communication with E. Dodson, U.S. Army Corps  of
     Engineers.
                             C-108

-------
6.   Appendix

-------
     This appendix contains  the charts and calculations which form the
basis  for extrapolating  national  solid waste  costs  and  associated
costs of compliance with the discussed criteria.

     It  is not possible  to take the reader  through each step of each
calculation.    What is shown are the unit costs and the flow charts of
the models used to determine national costs.

     Costs are initially  calculated for new facilities having a thirty
year life.    Design and cost data for model plant disposal options are
taken  from EPRI  FP-671  "State-of-the-Art  of FGD  Sludge  Fixation."
Changes are made where necessary to reflect costs of the criteria.

     These charts take the reader step by step through the calculations
for  determining the size and costs of the disposal site.    The flyash
pond and flyash landfill  show formulas as well as calculations.    The
20% contingency fee added to the disposal site is a safety factor built
into the costs which allows for increases in  costs or forgotten items.
The 50%  added on as the owner's expense includes engineering, account-
ing, interest during construction, allowance for start up and modifica-
tion, and miscellaneous expenses such as road installation, preparation
of the area,  installation of drainage facilities,  findings,  posting,
guard duty and covering.

     Separate costs  are developed for unlined disposal sites and sites
8 km and 16 km from the plant.

     All  national cost  estimates are  derived  utilizing the  average
kilowatt capital investment costs and annual operating costs.  The pro-
jected megawatt  capacity  employing the  various disposal  options are
multiplied by dollar per  kilowatt costs to estimate capital investment
required for disposal.    Annual operating and maintenance expenses are
estimated  by coverting these megawatt  capacities into equivalent 1000
MW plants and multiplying by annual operating costs shown.
                             C-110

-------
     The criteria induced  costs are derived utilizing the same method-
ology.    Unit costs  ($/KW)  for capital  investment  requirements  or
annual operating  costs are  applied  to  the megawatt capacities shown
in the flow charts for the three scenarios.    This applies to both new
and existing sites.

     Other information in this appendix is self-explanatory. The power-
rating-size  cost adjustment factor was applied  to the totals shown in
this appendix for inclusion  in the text.    No multiplication for this
adjustment is shown.
                             C-lll

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                                  Table   C-27

                            CRITERIA-INDUCED COSTS
                                NEW FACILITIES

                             CAPITAL INVESTMENT


SCENARIO                 I              II                 III

Wetlands               -0-              -0-                -0-


Floodplains         121,690,000      139,570,000           152,110,000


Groundwater:

   Liners           279,880,000      302,480,000           313,540,000

   Monitoring         5,400,000        5,400,000            5,400,000	
TOTAL              406,970,000       447,450,000           471,050,000
TOTAL

Annualized for 30 year life of site at approximately 16% cost of  capital


                                 ANNUAL 0 & M



Wetlands               38,587,400      13,431,600          -0-


Floodplains             -0-               -0-              -0-
Oroundwater :
Liners
Monitoring
Total
-0-
2,270,000
40,857,400
-0-
2,270,000
15, 701,600
-0-
2,270,000
2,270,000
                                  C-133

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SCENARIO

Wetlands:

  Closure

  New Facilities


Floodplains

Ground Water
             TOTAL
                           TABLE  C-34

                       CRITERIA INDUCED COST
                        EXISTING FACILITIES
                        CAPITAL INVESTMENT
                                               II
  6,211,600

 29,100,000
 35,311,600

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150,000,000
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 21,353,000

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116,360,000
170,451,000
                                                               III
 39,475,000

164,092,000
203,567,000
Annualized for five years at approximately 16% cost of capital.
Annuity factor = .305
                           ANNUAL 0 & M
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  Closure

  New Facilities

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Ground Water
             TOTAL

35


36
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1,818,096
                         ANNUALIZED COSTS
                          82,020,016
                  69,395,341
                  63,906,031
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                                       C-149

-------
                             Table  C-40
      EXISTING  SITES:   STATES AND CORRESPONDING CAPACITIES

      FLOODPLAIN  CRITERIA


EPA With Coal- Capacity
State Region Fired Units (MW)
nUbaia IV 10 7991.02
i izona IX 3 2534
! k,i3as VI 0 0
r Hrbrala t
p^prado VI.
• pnacticur. 	
9 0
I 8 2519.75
0 0
Delaware III 2 459.5
(lacrlct of Columbia III 0 0
Georgia IV 10 8133.9
•£abo X 0 0
Illinois V 26 17,131.46
Indiana V 27 11.790.21
leva VII 22 3200.58
Kentucky IV 16 6555.1
Louisiana .VI 0 0
«jin« 10 0
Uirylard Tjt 5 4345.3
'afpachuseets _ _ 	
4 ^692.12
fichlgan V 27 1Z.2S3.U3
^m.sota V 1 fi 5771 01
iiaaissiDOl r
liusMTi . Jl.
•tontana VI
0 0
16 8735.19
I J IfjW.y.
Sevada IX 2 1910
Rev Jiacoshlra I 1 506
•few Jersey It 6 4470.94
lev Mexico VI 3 2872.2
Se» York II 10 2967.15
forrS rjrnMn, IV 1} U,7\\
North Dakota VIII 6 1205.5
Ohio V 35 23.692.61
Oklahoma, VI 0 0
Oregon X 0 0
'enajvlvmia ff
32 20,133.82
South Carolina IV 9 3870.94
South DakotA VTTI 6 542.9
ennessee IV . 8 10.090.4
Ctah VIII 5 923.65
feraont 10 0
Vlrgiaia III 9 6613.12
•ishlnzton X 1 1329.8
fcest Virginia III 1J JU.U.U.4b
Ul^consin V 20 5510.55
•lyoaln? VIII 5 3046.36
U. S. TOTAL
Inventoried
for 1976
399 216,349 02

Fired Capacity
(MW)
7975.74
2441
0
5
2514.25
g
459.5
0
?5?";!!
0
16.033.56
11,553.85
3077.32
/lb/ .4
6431.1
0
0
3353
2642-19
11,038.45
37i7 Q^
0
809^.64
11 TO V 3*1 	
?iijl
1910
459
337i.7l
2872.2
2960.25
10.905
f205.5
22,203.34
0
0
18,027 . 62
	 •- i?!.1:! 	
2983.46
542.9
10.090 4
923.55
5629.82
1329.8
n. uuu. 8 b '•"•-—
5250.45
3045.36
202.379.89
Average Coal-
Fired Capacity
per Plant
(MO
797.57
813.67
p__
0
314. J4
9 ILJ
229.75
0
fifiS.^7
777.52
0
616.6;
423.11
139.88
ifn~94
0
0
670 6
Sfin f.
408.63
m 75^ ._
0
505.75
	 ttH* —
955
459
562.29
957.4
296.03
838.85
	 	 ZDOJ 	
634.38
0
0
563.36
	 77773 	
90.5
158! 3
184.73
0
625.54
1329.8
	 •"TBtrB'.'Hl'
262.52
609.07
507.22
Total MW Capacity
in States with
comparable floodplain
regulations
78,400 MW approx. 40%
                           C-150

-------
                       Table  C-41

  EXISTING  SITES:   STATES AND CORRESPONDING CAPACITIES

  GROUNDWATER CRITERIA
No. Plants Total Plant Total Caal-
EPA With Coal- Capacity Fired Capacity
State Refiion Fired Units (MW) (MW)
.„!,«* IV
!-i"2L -vi
Colorado VIII
Connecticut I
x.1 aware III
,«.nriee of Columbia III
n™.(,U *V
r.-,r,(a IV
M.hn X
IlijLcois V
"ladltua V
lova VII
&nsas VII

"alra I
»»r7la:id TTT
"fr-Ms-in V

Sisslssiopi IV
mfl.m^-t VTT


s!iw ht=^>shi'-e I
Hew Jersey I :

Jew York II
Sorth Dakota VIII
OhJ,o V
Oklahoma VI
Pena»vlvani» TTT
ISld. IsLanrf I .
South Dakoca VIII
Tennessee IV
•leiaa VT
Utah VIII
Vtrzin-'a TTT
jlaahi.iirnn V
•eat Virginia III
jyoflirl " TOt '
U. S. TOTAL
Inventoried
for 1976
10 7991.02 7975.74
5 U 0
8 2519. /3 2514. O
00 0
2 459.5 459.5
— B 	 o 	 a 	
10 8133.9 lin.i
0 0 0
?fi 17.131 46 16.033.56
27 11.790.21 11.553.85
22 3200.58 3077.32
8 2631.4 2157.4
16 6555.1 6431.1
on o
00 0
•i 41"-1 - -3353
4 2692.12 2642.39
,7 12.299.03 11.038 45
16 2771. 9S 2747.95
00 0
16 8735.19 8092.04
1 Q1Q Si 119 54
3 938 93.8
1 506 459 !
6 4470.94 3373.71
5 2372.2 VK/2.Z

6 1205.5 1205.5
15 21 692.61 72 201 14
00 0
Q 0 0
32 50.111.8-1 18 0?7-fi2
2 242 88 194.5
6 ^S^.'l^ ^j|j.'?^
8 10 090.4 10 ,}?0.4
2 2300 2300
? (J^.tS ' ' ' SJJ.tl
00 0
9 6613.12 5629.82
1 152?'? i13f?'Si
12 12625.45 12.u!l!So 	

399 216.349 02 202.379 89
Average Coal-
Fired Capacity
per Plant
(MO
	 HHJ-
0
314.28
0
229.7.
	 o 	
005.47
111 ,5'L
P

428.11
139.88
269.68
401.94
A
670-6
408.33.
171-75
0
505.75
313.18
!l5.67
459
5 62 .^'9
957.4
296.03
200.92
614 1ft
0
p
563-36
9? 155
m) _<,
1261.3
1150
1B4. /J
0
6^,54
1329 8
'iJ^S'Li)

507.22
Total MW Capacity in
States with comparable
groundwater regulations
178,300 MW  approx.
                         C-151

-------
                      Table  C-42
   MEGAWATT CAPACITIES  IN STATES WITH WETLANDS
State
Alabama
Arizona
Arkansaq
California
Colorado
Connecticut
Delaware
District: of Columbia
* Florida
Georzia
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Ha ins
Maryland
Massachusetts

Mississippi
Missouri
Montana
Nebraska
Nevada
Sew Hampshire
Hew Jersey
Sew Mexico
L Hew York
n* Horth Carolina
No-rrh naknr*
Ohio
Oklahoma
Oregon
Pennsylvania
^ Rhode Island
** South Carolina
Soucn Dakota
Tennessee
Utah
Venaonc
Virginia
Washington
West Virginia
Wyoming
U. S. TOTAL
Inventoried
for 1976


EPA With Coal- Capacity Fired Capacity
Res-ion Fired Units (MW) (HW)
IV 10 7991.02 7975.74
IX 3 2534 2441
VI p 0 0
ix 3 So
Vlll 8 2519.75 2514.25
100 0
III 2 459.5 459.5
III 0 0 0
IV 6 4705 7 3992.8
IV .„ ,JJ, ,,. 	 ,„
138.9 7775.2
X 0 0 0
V 26 17.131.46 16,033.56
V 27 11.790.21 11,558.85
VII 22 3200.58 3077.32
VII 8 2631.4 2157.4
IV 16 6555.1 6431.1
. VT 0 0 ft
100 0
HI 5 4345.3 3353
I 4 2692.12 2642.39
v 57 12.299.03 11.038.45
V 16
1773.95 2747.95
IV 0 0 0
VII 16 8735.19 6092.04
VIII 3 939.54 939.54
VII 3 938 938
IX 2 1910 1910
I 1 506 459
II 6 4470.94 3373.71
VI 3 2872.2 2372.2
II 10 2967.15 2960.25
IV 13 i; 711 10,905
VTTT 6 	 	
205.5 1205.5
V 35 23,692.61 22,203.34
VI 0 0 0
X 0 0 0
III 32 20,133.82 18.027.62
I 2 242.88 194.5
IV 
-------
C-153

-------
                 TABLE   C-43
DRY AND'WET BULK DENSITIES OF FGD  WASTE  PRODUCTS'











Oi
Dry

jtiaum
Bulk Density
a
70S

65%

50Z
Wet Bulk Density

Optimum
Solids
9
70%

65Z

50%
Solids
Specific
Gravity
Fly Ash

Bottom Ash
Scrubber
Fly Ash
Sludge
and
Scrubber Sludge
2.
2.
2.

Z.
55
55
55

55
Kqs.
1520
1440
1280

1520
Dry Solids/m3
1220
1220
1220

1220
1070
1070
1070

1070
720
720
720

720
Ks;s
1790.
1760
1670

1790
. Total/m3
1730
1730
1730

1730
1650
1650
1650

1650
1430
1430
1430

1430
  x MT
              =  MT
   1000 kg
                         C-154

-------
D.   COST OF IRON AND STEELMAKING NON-HAZARDOUS SOLID WASTE DISPOSAL
     TO MEET THE 4004 CRITERIA

1.   Summary

     The iron and steelmaking industry generates about 50 million met-
ric tons of non-hazardous solid waste per year.   However, due to com-
mercial  sale  and/or in-plant  recovery  of  over 60% of these  solid
wastes,  about 16.5 million  metric  tons  (excluding rubble) of solid
wastes remain to be disposed.   Table C-44   shows the estimated quan-
tities of non-hazardous  solid wastes generated and disposed of by the
iron and steelmaking industry.    The most common disposal practice in
current use is to dump/landfill  the various wastes.   All assumptions
in this report  regarding  the percentage of current sites not meeting
the Section 4004 criteria,  the control technologies available for up-
grading and  the estimated costs of current and future disposal  costs
were made based on the author's best judgment.

     Present disposal costs are estimated to be:

     1)   on-site - $1.20 to $2.00/MT waste (avg of $1.60/MT)
     2)   off-site- $2.00 to $3.00/MT waste (avg of $2.50/MT)

These disposal costs take into account the costs of land,  labor,  and
transportation.  In addition to these costs, it is estimated that cur-
rent site  operation and maintenance  costs are approximately an addi-
tional 50%.

     Assuming that the  current practice is to landfill 50% (8.25 MMT)
or iron  and steelmaking  non-hazardous solid  waste on-site and   50%
8.25 MMT) off-site, the total current estimated disposal cost is $50.7
million.   Of this $50.7 million, land, labor and transportation costs
account for $33.8 million  while an additional $16.9 million is incur-
red for  site operation  and  maintenance.   The costs assume that  no
costs for hydrogeologic surveys, land clearing, and other similar land
preparation costs are currently being incurred.
                              C-155

-------
     The purpose  of this  assessment is  to determine the cost impact
of  the final  4004 criteria  on the  iron and  steelmaking  industry.
Estimated unit  costs were derived from several sources  (Fred C. Hart
Assoc. Inc.,  Calspan, Draft  4004 EIS).    The landfilling design and
methods used  in making  the assessment were assumed merely to provide
a basis  for estimating various landfilling costs.   They were not in-
tended to be considered as guidelines for leachate control.   The pri-
mary  cost  involved  is the  cost  of providing  protection of ground
water from contamination due to leachate.

2.   Major Assumptions

     The  cost of  landfilling  of  these  wastes is developed by  con-
sidering  the costs  involved for a typical  iron and steelmaking plaint
to provide  a solid waste disposal  facility which  meets the 4004 cri-
teria.   A typical plant  is considered  as having an  annual raw steel
production of 2.5 million metric  tons.    The production data for such
a typical plant is  listed in Table   C-45.   The concept  of a typical
plant  was utilized in   order to  develop a base cost from which   the
national  disposal costs could  be extrapolated.   The derived disposal
costs  (expressed in $/MT waste)  are expected to  be representative of
the overall industry.

     Table   C-46   shows the  quantities of non-hazardous solid wastes
generated and disposed of by the typical plant.    Over 305,000  metric
tons of  waste are  disposed of annually  by this typical plant.   This
quantity of solid waste corresponds to a volume of over 173,000  m   of
waste,  using an average density of 1.76 Mt/m  .  Table  C-47  lists the
volumes assumed for each of the wastes.

     It is  assumed that  all non-hazardous  solid wastes  will be dis-
posed in a  manner which meets the criteria requirements.    Only those
                             0156

-------




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C-157

-------
                           TABLE  C-45

        PRODUCTION DATA FOR TYPICAL INTEGRATED STEEL PLANT
Facility

Coke Ovens

Blast Furnaces

Basic Oxygen Furnaces

Electric Furnaces

Soaking Pits

Primary Mills

Continuous Caster

Hot Rolling Mills


Cold Rolling Mills

Tin Plating Mills

Galvanizing Mills
Product

Coke

Iron

Steel

Steel

Steel Ingots

Billets, Blooms, Slabs

Billets, Blooms, Slabs

Sheet Steel, Bars, Rods
Structural Shapes, etc.

Sheet Steel

Tin Plated Sheets

Zinc Coated Sheets
Annual Amounts
(Metric Tons)

1,120,000

1,600,000

2,000,000

  500,000

1,560,000

1,350,000

  790,000

1,800,000


  700,000

  100,000

  125,000
                            C-153

-------

























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-------
                           TABLE  C-47
Annual Volume of Wastes from a Typical Plant
Slags
BF
EOF
EF
Soaking Pit
Scales
Sludges
Dusts
BF
EOF
Quantity (Mt)
22,560
145,000
48,000
Slag 15,600
20,095
34,340
2,590
11,200
Volume/MT
(M3/MT)
0.62
0.60
0.45
0.15
0.63
0.63
0.80
0.77
Volume (M3)
13,990
87,000
21,600
2,340
12,660
21,634
2,072
8,624
                305,785 MT
173,440 M
  Density =    MT/M




               305,785 MT





               173,440 M3  = 1.76 MT/m3
                             0160

-------
blast furnaces and steelmaking slags and also those other  wastes which
are processed and/or  stored with the purpose of utilizing them through
commercial sale and/or in-plant recovery within 90 days are excepted.

     Those  criteria which will  have the greatest impact on the indus-
try  are the   ground-water  criterion and  to a much less extent,  the
floodplains criterion.    It is assumed that no present or future  dis-
posal sites  are  or  will be located in wetlands.   The total national
annual  cost  to the industry for compliance with the 4004 criteria was
developed with that portion which  is specifically  attributable to the
criteria, and which would  not have  been incurred  to operate disposal
sites according  to current practices or in compliance with State solid
waste regulations, isolated.  Average disposal costs/MT waste are  also
calculated.

     It is assumed that facilities will not be relocated as a result of
the criteria:  instead, existing  facilities will be upgraded as neces-
sary.    Fifty percent of the disposal facilities are assumed to be on-
site, 50% off-site.  On-site is defined as a facility being located  on
or adjacent  to the  plant grounds.    No differentiation is made as to
whether the facility is company, contractor,  or otherwise owned.   On-
site  disposal areas  typically involve  the landfilling  of relatively
shallow ravines or simply onto flat, open land.  Offsite disposal areas
typically involve the landfilling of abandoned stripmines, deep ravines
or valleys.

     The costs were developed using four scenarios:
     I    off-site (lining material insitu)
     II   off-site (lining material non-insitu)
     III  on-site  (in floodplain, lining material non-insitu)
     IV   on-site  (not in floodplain, lining material non-insitu)

Ground-water  protection is considered to be required in all four scen-
arios .

     These costs represent  the total criteria and comparable State re-
gulation induced costs.    That portion which is attributable to either
comparable State  regulations or to the 4004  criteria directly will be
identified later.
                             C-1S1

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     For  each scenario,  using as  a basis  a landfill design life  of
5 years in conjunction  with the annual  volume of wastes  (173,000 rn )
disposed  of  by the  typical plant,  a landfill area  of (450m x 225m)
100,000m   (25 acres)  is utilized  in which the solid wastes are land-
filled  to a depth of 10m.    This landfill design life of  5 years  is
expected  to provide  a representative basis  from which to extrapolate
costs for steel industry disposal facilities nationwide.

3.   Costs for each scenario

     Costs generated for each of the four scenarios are as follows:

     a.   Scenario I:  Off-site (Lining Material Insitu)

          Those items  for which costs were included are:  site prepar-
ation,  land  clearing,  grading  and placement  of clay liner, surface
runoff ditching,  leachate collection pond, leachate treatment, closure
revegetation,  monitoring,  and analyses of samples from the monitoring
wells.  None of these items is considered to be current practice.

     It  is  assumed that  85% of the  off-site disposal areas will re-
quire additional controls to provide for ground-water protection.   50%
of the off-site  disposal areas  contain  suitable clay  such that only
sloping of  the area  will  insure ground-water protection and leachate
collection.   The leachate collection  pond is sized based on a maximum
10"  monthly rainfall with a landfill infiltration  rate of 25%.    The
leachate collected will be treated,  with treatment consisting of  per-
haps heavy metal removal,  cyanide and phenol removal,  removal of dis-
solved solids,  pH control,  and oil  skimming, prior to its being dis-
charged.    Treatment  of the  leachate  will be  based upon  an annual
average rainfall   of 32" with a  landfill  infiltration  rate  of 25%.
This  corresponds  to about 15,000 GPD.   Leachate  monitoring/analysis
is  assumed to be implemented at each site with a minimum of four wells
utilized.    Sampling/analysis of indicator  parameters is performed on
a quarterly basis along with an annual comprehensive analysis.
                             C-162

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Closure of the site involves the placement of a  15cm layer of suitable
clay and a 30cm  layer of natural soil over the landfilled area follow-
ed by revegetation.

     Other factors included in the estimates are a 20% contingency fac-
tor and 12% annual cost of capital factor:

               Total Capital Cost	- $248,200
               Annualized Capital Cost     - $ 68,850
                    0 & M Cost	- $ 26,000
                    Total Annual Cost      - $ 94,850

     The average cost of disposal/MT waste is $0.31/MT
     The average cost of disposal/m  waste is $0.55/m
     The average cost of waste disposal/MT raw steel production
          is $.04/MT

     b.   Scenario II:  Off-site (lining material non-insitu)

          A minimum  of 0.6m  of natural  clay will be  utilized as the
lining  material,  which is  assumed  to  be  obtained from  an outside
source.  The costed items are the same as for scenario I.

               Total Capital Cost	- $712,700
               Annualized Capital Cost     - $197,000
                    0 & M	- $ 26,700
                    Total Annual Cost      - $223,700

     The average cost of disposal/MT waste is $0.73/MT
     The average cost of disposal/m  waste is $1.29/m
     The average cost of waste disposal/MT raw steel production
          is $0.09/MT
                            C-163

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     c.   Scenario III;  On-site (in floodplain, lining material non-
            insitu) - see Figure C-23

          It is  assumed that 15% of the on-site disposal areas are lo-
cated in floodplains, thereby necessitating the   construction of a  3m
dike  around the disposal area. 100% of the on-site disposal areas will
require  additional  controls  to  provide for ground-water protection.
All on-site  disposal areas  are assumed to obtain clay lining material
from an  outside source  as in scenario II.    In addition, due to dif-
ferences  in the  physical and  hydrogeological characteristics of  on-
site  vs. off-site disposal areas, it is assumed that additional leach-
ate  collection capability will  be needed.    Therefore, 4" perforated
PVC  pipe spaced at 15m  intervals the length  of the landfill site are
utilized.  Other items costed remain as in scenario I.

               Total Capital Cost	- $944,600
               Annualized Capital Cost    - $262,000
                    0 & M	- $ 26,000
                    Total Annual Cost     - $288,000

     The average cost of disposal/MT waste is $0.94/MT
     The average cost of disposal/m  waste is $1.66/m
     The average cost of waste disposal/MT raw steel production
          is $0.12/MT

     d.   Scenario IV:  On-site  (not in floodplain, lining material)
            non-insitu)

          Item  costs  for this scenario  are the same as for  scenario
III, except for deletion of the diking.

               Total Capital Cost	- $878,200
               Annualized Capital Cost    - $243,600
                    0 & H	- $ 26,000
                    Total Annual Cost     - $269,900
                              C-164

-------
     The average cost of disposal/MT waste is $0.88/MT
     The average cost of disposal/ra  waste is $1.55/m
     The average cost of waste disposal/MT raw steel production
          is $0.11/MT

4.    Steel Industry National Costs In Complying with the Criteria

     The  national  cost to  the industry  was developed  by using  the
four  previously  outlined scenarios  in combination with the following
assumptions  as  to  the  quantities  of waste to be disposed  at  each
scenario:
     a)   Quantity of Non-Hazardous Solid Wastes to be
          Disposed - 16.5 MMT

     b)   Off-site - 50%  	   8.25 MMT
          On-site  - 50%	   8.25 MMT

     c)   Floodplains - 15% of on-site	     1<25 MMT
          Non-Floodplains - 85% of on-site 	     7.0  MMT

     d)   Ground Water Protection
          On-site - 100% 	   8.25 MMT  (clay from outside source)
          Off-site-  85%	   7.0  MMT
            a)  50% clay lining material insitu   	  3.5 MMT
            b)  50% clay lining material non-insitu	  3.5 MMT

     e)   Off-site - 15%	 1.25 MMT are assumed to be presently
          landfilled at a site or in a manner which requires no addi-
          tional upgrading.
                             C-165

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Scenario

I   - Offsite (lining material insitu)  3.5 MMT @   $0.31/MT      = $1,085,000
II  - Off-site (lining material non-insitu) 3.5 MMT @ $0.73/MT  = $2,555,000
III - On-site (in floodplain) 1.25 MMT @  $0.94/MT               = $6,160,000
IV  - On-site (not in floodplain)  7.0 MMT % $0.88/MT            = $1,175,000
          Total Annual Cost                                     =$10,975,000

     This total  national annual cost  is comprised of $9,500,000 capi-
tal costs,  the remainder as  operating and maintenance costs for samp-
ling and analysis, well maintenance and leachate treatment.

     In  addition to these expenses,  it is estimated  site maintenance
and operation costs will increase.    A cost of $2.70/MT is assumed for
site maintenance and operation at a sanitary landfill. This constitutes
a $1.90/MT increase for on-site disposal and $1.45/MT increase for off-
site disposal.  This  increases the total national cost of the criteria
by $25.3 million to approximately $36.3 million.

5.   Cost Directly Attributable to 4004 Criteria

     Although the  annual cost  to the  industry of complying with  the
criteria  is estimated at approximately $36.3 million,  that cost which
is directly attributable  to the Federal  criteria compared to existing
State regulations, must be developed.

a.   Ground Water

     The  ground-water criterion  has the greatest  impact on the  iron
and steelmaking industry.    It is assumed that 100% of on-site and 85%
of  off-site  disposal  areas will require additional site controls  to
provide   for  ground-water  protection.    Clay  lining,   leachate col-
lection   and treatment,   and monitoring wells  are considered the best
available  technology  for  prevention  of  ground-water contamination.
Some sites will require just sloping, compacting,  etc. of insitu clay.
                              C-166

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                                                   E-i
                                                   «
                                                   I
                                              a
                                             4J
                                              rt
                                             .C
                                              U
                                              IS
                                              0)
                                             M-l
                                              0
                                              I
                                              O
C-167

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Others  will  require the procurement of clay from outside sources with
subsequent placement, grading, compacting, etc.  Still other sites will
require additional leachate collection capability and thus utilize pip-
ing to perform this function.

     Twenty-nine  of  the 37 States in which  iron and steelmaking dis-
posal  facilities are located  are assumed to have ground-water regula-
tions comparable to the Section 4004 criteria. Approximately 80% of the
costs of complying  with these criteria are assumed State attributable,
the  remaining 20% to Section  4004.   This annual cost attributable to
the  Federal criteria  is $2.2 million  for control technology  and  an
additional $5.1 million for site operation and maintenance.

     Final  closure of the site consists of cover and revegetation  and
was assumed by the author to be performed as an on-going process neces-
sary for ground-water  protection.   Of the $2.2 million  assignable to
the Federal  criteria for control technology,  .3 million  is for final
closure  and of the 5.1 million  for site operation and maintenance  .8
million is assumed attributable to closure.

b.   Floodplains

     The second criterion  having impact  on  the  disposal of  iron and
steelmaking non-hazardous  solid wastes is that of floodplains.   It is
assumed that 15%  of on-site disposal  areas  are located in floodplains
and that  all of  these sites will  be upgraded to prevent  inundation of
the disposal facility.

     Twenty  of   the thirty-seven States in   which iron and steelmaking
disposal  facilities  are located  are  assumed  to  have  a floodplain
criterion  comparable to the Section  40o1 criteria.     Ninety percent
of  these  disposal  areas situated in  floodplains are assumed  to  be
located  in States  which do not have floodplain criteria  at least com-
parable to Section  4004.     The national annual costs attributable to
the 4004  criteria is estimated  to  be $67,500 for diking and  $159,150
for additional site operation and maintenance costs.
                             C-168

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c.   Section 4004 Induced Costs

     The combined criteria-induced  costs (ground water, including clo-
sure, and floodplains) is estimated to be $7.52 million.

     Using as  a  basis the  national  quantity of 15.25 million metric
tons  of  solid waste to be disposed in upgraded sites,  the additional
cost  attributable to Section 4004  is estimated to  be $0.49/MT waste.
The  additional  cost of  disposal induced  by Section 4004 per  ton of
raw steel  production,  based on  an annual  production of  114 MMT, is
$0.07/MT of raw steel.

     The current  estimated disposal  cost when  added to the estimated
costs of complying with  the criteria   (State reg. comparable -  $29.0
million  +  4004 attributable - $7.52 million) results in an annual ex-
pected steel industry disposal  cost of $87.0 million.  This represents
a 72% increase  in disposal  costs, with  80% of  the increase  due  to
comparable State regulations  and the remaining 20% attributable to the
criteria.
                           C-169

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CALCULATIONS
 C-170

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6.
     CALCULATIONS
                             TABLE  C-48

                  CALCULATION FOR COSTS OF MODEL IRON
                  AND STEELMAKING DISPOSAL FACILITIES

                             Cost Estimate

          Landfill AREA             - 100,000 m2 (25 acres)
          Landfill Depth            -      10 ra
          Landfill Area Dimensions  -     450 m long x 225 m wide
     I.    Off-site (clay lining material insitus)

     Site Preparation                   Capital Costs
     Survey
     Test Drilling
     Sampling
     Engineering Eval.
     Land Clearing
     Grading
     Compacting,  Dist.
          of Clay
     Surface Runoff
          Ditching
     Leachate Collection
          Pond
     Leachate Treatment
     Monitoring
    -Analysis/Sampling
     Closure

     Revegetation



               Total Capital

               Annualized Ca;

                             0 and M Costs
$275/acre
$ 25/m for 10 ra holes
$ 65/sample 2 samples/hole


$850/acre? ~
$ 0.04/m 1000,000 m
$ 0.08/m3 60,000 m3
$7. 25/m 1,500 m

15,000 GPD
$1000/well 4 wells
$ 400/qtly 4 samples/well
sample
$ 750/annual
sample , ,
Clay - $1.00/m, 15,000 m, clay
Soil - $0.60/m 30,000 m soil
$240/acre
Capital Cost =
.1 Cost + 20% contingency =
!apital Cost (12% at 5 yr. ) =
$6875
500
260
2000
$9635
$21,250
40,000
48,000
10,875
14,080
20,000
4,000
6,40(3]

3,OOOJ O&M

15,000
18,000
6,000
$206,840
$248,208
$ 68,851
             "^Sampling/Analysis
               Wells Maintenance
               Leachate Treatment
$ 9,400
$ 1,600
$15,000
                                          $26,000

               Total Annual Cost	$94,851
                            C-171

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II.  Off-site (clay lining material non in situ)

     Cost Items same as for I,  except

     Clay liner,  compacting,         ,          -,
          etc.               S6.00/m   60,000 m   $ 360,000
     Closure (clay material) $6.00/m   15,000 m   $
           90,000

        $ 450,000
                         Capital Cost  =
$ 206,840
 -(48,000 + $ 15,000)
  143,840
+ 450,000	

$ 593,840
     Total Capital Cost   + 20% contingency = $712,608

     Annualized Capital Cost (12% over
                              5 years)      = $197,672

                              O&M Costs     = $ 26,000

                         Total Annual Cost    $223,672
III. On-site (in floodplain)

     Cost items same as for II, plus diking construction and
     leachate collection piping.
                         450 m
A 3 m high dike is constructed around the landfill site

               (450 x 2) + (225 x 2) = 1350 m

Diking construction      $41,00/m     1350 m    $55,350
                         C-172

-------
Piping (leachate collection)

     4" PVC piping at 15 m interval the length of landfill plus
     manifold connections at both ends.

     Piping     $23.00/m       6000 m         $138,000


     Capital Costs = $593,840 + $55,350 + $138,000 = $787,190

     Total Capital Costs   + 20% contingency  =  $944,628

     Annualized Capital Cost (12% over
                              5 years)        =  $262,033

                             O&M Costs        =  $ 26,000

                         Total Annual Cost    =  $288,033
IV.   On-site (not in floodplain)

     Same as for III, except delete diking construction


          Capital Cost = $787,190 - $55,350   =  $731,840

     Total Capital Cost   + 20% contingency   =  $878,208

     Annualized Capital Costs (12% over
                               5 years)       =  $243,608

                             O&M Costs        =  $ 26,000

                         Total Annual Cost    =  $269,608
                      C-173

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                          TABLE  C-49

                  NATIONAL STEEL INDUSTRY COST


  Assume:   16.5 MMT of waste disposed

  a.    50% off-site - 8.25 MMT
       50% on-site  - 8.25 MMT

  b.    15% of on-site in floodplain - 1.25 MMT
       85% of on-site not in floodplain - 7.0 MMT

  c.    15% of off-site - requires no additional groundwater
            protection controls - 1.25 MMT
       85% of off-site - additional groundwater protection
            controls - 7.0 MMT
       50% of off-site have dry lining material in situ - 3.5 MMT
       50% of off-site do not have clay lining material
            in situ - 3.5 MMT
       100% of on-site do not have clay lining material
            in situ - 8.25 MMT


  Cost of Four Scenarios:

  I.    3.5 MMT x $0.31/MT        =  $1,085,000

 II.    3.5 MMT x $0.73/MT        =  $2,555,000

III.    1.25 MMT x 50.94/MT       =  $1,175,000

 IV.    7.0 MMT x $0.88/MT        =  $6,160,000

                 Total             $10,975,000 per year

       Of this amount, $9,490,340 is for capital costs and
       $1,484,660 is for operation and maintenance costs.


  Additional site operation and maintenance costs for a sanitary
  landfill.

  I.    3.5 MMT x S1.90/MT        =  $6,650,000

 II.    3.5 MMT x $1.90/MT        =  $6,650,000

III.    1.25 MMT x $1.45/MT       =  $1,812,500

 IV.    7.0 MMT x $1.45/MT        = $10,150,000

                 Total             $25,262,500 per year
                          C-174

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                          TABLE  C-49




                           (CONTINUED)









  Total cost:




  I.   51,085,000  +  6,650,000  =   7,735,000




 II.    2,555,000  +  6,650,000  =   9.205,000




III.    1,175,000  +  1,812,500  =   2,987,500




 IV.    6,160,000  + 10,150,000  =  16,310,000




                                   $36,237,500
                          C-175

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                        TABLE  C-50

                  LEACHATE COLLECTION POND


Assume:

1.   Maximum monthly rainfall of 10 in.

2.   Infiltration rate of 25%  (2.5 in.) or 0.064 m

0.064 m over 100,000 m   =  6400 m  rainfall


Pond Dimensions:  80 m long x 40 m wide x 2 m deep


Costs:

     Excavation and Diking  $2.00/m    3200 m3    $ 6,400

     Grading                $0.40/m2   3200 m2    $ 1,280

     Clay Lining Compac-           .         ,
          tion, etc.        $1.00/m    6400 m
     6400 m3  /  ft3	/  7.5 gal.  =  1.7 million gal/month
             1 0.028 m3 l    ft3
Leachate Treatment

Assume:

1.   32" rainfall/year

2.   25% infiltration rate  =  8"  =  0.20 m


100,000 m2   /  0.20 m  /  ft3   /  7.5 gal	 = 15,000 GPD

                       /0.028 m3'  ft3  360 days
                        C-176

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                             TABLE  C-51

                         COST DUE TO CRITERIA

A)   Floodplains

Capital Cost to Typical Plant - $55,350 f 20% contingency  = $66,420

Annualized Capital Cost (12% over 5 years)  =  $ 66,420 x -  jL	= $18'424
Annual Cost/MT waste = $18,424 4 305,785 MT = $0.60/MT waste

Annual National Cost - 1.25 MMT x $0.60/MT  = $75,000

Assume:   90% of Floodplain site upgrading attributable to criteria.

          1.25 MMT x 0.90 = 1.125 MMT

Annual Cost Attributable to Criteria = 1.125 MMT x $0.60/MT = $67,500


B)    Groundwater Protection

               Total        -  Floodplain   = Groundwater Protection

               $10,975,000  -  $75,000      =  $10,900,000

Annual Cost/MT waste  =  $10,900,000 4 14.5 million MT = $0.75/MT

Assume:   20% of groundwater protection upgrading attributable to
          criteria.

               $10,900,000  x   0.20        =  $ 2,180,000
               Annual Cost Attributable to Criteria.
                             C-177

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          CORRESPONDING SITE OPERATION AND MAINTENANCE COSTS
                     ATTRIBUTABLE TO THE CRITERIA
A)   Floodplains

Annual national cost      $75,OOP    _  _ 7
                       10,975,000    ~

                  .007 x 25,262,500  =  $176,800

Annual Cost Attributable to Criteria = .90 x $172,600  =  $159,150


B)   Groundwater Protection

Annual national cost    $10,900,000     qq ,
                        $10,975,000     »»-J*

                  .993 x 25,262,500  =  $25,090,000

Assume:   20% of groundwater protection attributable to the criteria.

                   25,090,000 x .20  =  $5,018,000
                             C-17S

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                             TABLE  C-52

                     ADDITIONAL AVERAGE UNIT COST
                     ATTRIBUTABLE TO THE CRITERIA


          $7.42 million criteria induced costs  4-  15.25 MMT waste

                                                = 0.49/MT waste

          $7.42 million criteria induced costs  4-  114MMT raw steel
                                                        production

                                                = $0.02/MT raw steel

Current estimated steel industry non-hazardous waste disposal cost.

          bn-site        +         off-site

     8.25 MMT x $1.60/MT + 8.25MMT x $2.50/MT   =  $33,836,000


Site operation and maintenance:  additional 50% = $16,918,000

                            Total disposal cost = $50,754,000
                            C-179

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                             TABLE  C-53

                   COSTS TO COMPLY WITH THE CRITERIA
A)   Total Compliance =  $10,975,000  (100%)
     Scenario I
     Scenario II
     Scenario III
     Scenario IV
$1,085,000
$2,555,000
$1,175,000
$6,160,000
(10%)
(23%)
(11%)
(56%)
$0.31/MT
$0.73/MT
$0.94/MT
$0.88/MT
B)   State Regulation (Comparable to 4004)
Scenario
Scenario
Scenario
Scenario
Scenario
I
II
III
III
IV
=
=
=
=
=
0.
0.
0.
0.
0.
8
8
8
1*
8
x
x
X
X
X
1,
2,
1,

6,
085,
555,
100,
75,
160,
000
000
000
000
000
                                             868,800
                                           2,044,000
                                             880,000
                                               7,500
                                           4,928,000

                                          $8,728,300
                                  0.25/MT
                                  0.58/MT

                                  0.71/MT
                                  0.70/MT
C)   4004 Induced Compliance
Scenario
Scenario
Scenario
Scenario
Scenario
I
II
III
III
IV
= 0.
= 0.
= 0.
= 0.
= 0.
2
2
9*
2
2
x 1,
x 2,
X
x 1,
x 6.
085
555
75
100
160
,000
,000
,000
,000
,000
=
=
=
=
=
217
511
67
220
1,232
,000
,000
,500
,000
,000
0
0

0
0
.06/MT
.15/MT

.23/MT
. 18/MT
                                          $2,247,500
*Separate Floodplain Calculations
                            C-180

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                             TABLE   C-54

                 ESTIMATED AVERAGE  UNIT DISPOSAL COSTS
                     (LAND, LABOR,  TRANSPORTATION)
A)
     Off-site
     1) State
                    Current
                     Cost
               Additional
                  Cost
Total
Cost
% Increase Above
Current Average
 I.  $2.50/MT +  $0.25/MT  = $2.75/MT

II.  $2.50/MT +  $0.58/MT  = $3.08/MT
     2) Federal
        4004     I. $2.50/MT  +   $0.06/MT   =  $2.56/MT

                II. $2.50/MT  +   $0.15/MT   =  $2.65/MT
            10%

            23%


             2%

             6%
B)   On-site

     1) State  III. $1.60/MT  +   $0.71/MT   =  $2.31/MT     44%

                IV. $1.60/MT  +   S0.70/MT   =  $2.30/MT     44%

     2) Federal
        4004   III. $1.60/MT  +   $0.23/MT   =  $1.83/MT     14%

                IV. $1.60/MT  +   $0.18/MT   =  $1.78/MT     11%
                            C-181

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                        TABLE  C-55

 ESTIMATED ANNUAL COST TO THE STEEL INDUSTRY FOR DISPOSAL OF
   NON-HAZARDOUS SOLID WASTE IN COMPLIANCE WITH CRITERIA.
     I.   3.5 MMT   x   $2.81/MT   =   $ 9,835,000

    II.   3.5 MMT   x   $3.23/MT   =   $11,305,000

   III.   1.25 MMT  x   $2.54/MT   =   $ 3,175,000

    IV.   7.0 MMT   x   $2.48/MT   =   $17,360,000

Off-site no upgrading.

          1.25 MMT  x   $2.50/MT   =   $ 3,125,000

                                       $44,800,000

Additional site operation and maintenance, which are assumed
to be $2.70/MT for sanitary landfill:

         15.25 MMT  x   $2.70/MT   =   $41,175,000

          1.25 MMT  x   $ .80/MT   =   $ 1,000,000

                                       $42,175,000


             Total Projected Cost  =   $86,975,000

Projected Cost - Present Cost      =   Increase

$86,975,000    -  $50,700,000      =   $36,275,000


        % increase of disposal     =   l^^ggg  =   72%


        % increase of disposal due to comparable state reg.

                                       $29,020,000      ,,,,
                                       $50,700,000


        % increase of disposal due to 4004 directly.

                                       $ 7,520,000  _   ,„
                                       $50,700,000

        f nnn  =  80%  of increase due to comparable  state
 oeTTg nnn
?36,275,000          regulation
                        C-182

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            APPENDIX D
  CURRENT TYPES, QUANTITIES, AND
CONDITIONS OF DISPOSAL FACILITIES

-------

-------
                               APPENDIX

D.     CURRENT  TYPES,  QUANTITIES,  AND CONDITIONS OF DISPOSAL FACILITIES

A.   LANDFILLS

1.   General Description  of  Practice

     The  term  landfill   is used   in this EIS  to denote open dumps and
solid waste disposal   facilities  where soil   cover is periodically ap-
plied over the wastes.  Operations  range from uncontrolled, polluting,
anaesthetic,   open-burning   dumps  to landfills  which,  when properly
designed  and  operated,   are nonpolluting  and  nuisance-free.    Land-
filling   is a   popular  solid  waste  disposal  method  because of  the
following advantages:

          The  general availability  of land   suitable for disposal
          facilities.

     -    Ability   to  use   otherwise  marginal  or nonproductive
          land  such  as  borrow pits  and quarries  and,  through
          filling,  to increase the  utility  of such land.

          Relatively  low  capital  and operating costs.

     -    Traditional   acceptance  by the  public  and regulatory
          authorities.

     -    The   adaptability    and  flexibility  of  operation  to
          accommodate  fluctuating   quantity,  quality,  and type
          ot waste.

     -    Pretreatment  of waste is  not required.

     Various   landfill  construction  and   operating  procedures  are
used,  depending on the  physical configuration  of the facility.  The
operation may  be referred to as cut and cover,  area fill,   trench and
cover,  and  similar  terminology.    Common   to all  operations   is the
sequence  of dumping  and  compacting the waste  in layers and covering
                                 D -1

-------
the waste  with compacted earth.    Each day's  operation  when covered
with earth  is referred to as a cell.    Refuse is placed and compacted
in layers  until the desired height  of the cell  is reached (normally
6 to 14 feet);  this cell height dimension  is commonly referred to as
a lift.   Succeeding lifts may be  placed until the final grade of the
disposal area is achieved.

     In  recent  years,  concern  for  conservation  of  resources  has
generated  considerable  interest   in  resource  recovery  and  waste
reduction measures.   Even if widely applied,  however, such practices
cannot  eliminate  solid  waste  altogether;    thus,  communities  and
industries  will continue  to require   an  environmentally  acceptable
means  of final disposal.   The largest component  of municipal  waste
is paper,  but substantial food wastes,  yard wastes,  glass,   metals,
plastics, rubber, and liquid wastes are also included.  Many municipal
facilities  also receive  industrial  process  residues  and pollution
control system  sludges  in addition  to septic tank pumpings,   sewage
sludge,  bulky wastes,   street sweepings,  and construction/demolition
wastes.

     The basic  large-scale  environmental  problems  associated  with
landfilling of solid wastes are water  pollution, air pollution, public
health effects,  ecosystem degradation,  and effects on  land quality.
On a  national basis,  land disposal  is a significant  contributor to
ground-water  and surface  water contamination  from landfill leachate
(with large potential  public health impacts),  to fire and explosions
(resulting from improper  waste disposal and landfill gas production),
and to disease vectors such as flies and rats.   Of these effects, the
primary  problem  that  has been  recognized  to date  is ground-water
contamination.

     Additional environmental impacts  are either localized,infrequent,
or they are geographically specific (such as use of wetlands for waste
disposal).   However,  some of these impacts  are potentially of great
concern; therefore, they are being regulated now.
                                  D-2

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     The general thrust  of this EIS  and the criteria  is to identify
and address adverse effects of improper solid waste disposal practices.
Proper solid waste disposal practices,such as true sanitary landfills,
do not have these problems.   It is beyond  the scope  of this report,
however,  to list the positive aspects  of proper solid waste disposal
practices.

2.   Number of Facilities, Distribution

     A national inventory  of landfills  has not been  conducted since
1967-69;  however,  State solid waste management programs  do maintain
various forms  of information  on landfills  within  their  respective
States.   During the latter part of 1976, Waste Age magazine conducted
a National Survey  of Waste Control  Practices.   The survey  was pub-
lished in Jaunary, 1977  and was conducted by the Waste Age staff with
the cooperation of each State's solid waste control agency as a source
of information.   Updated  in January, 1978,  this survey  is the most
current compilation of landfill data  and has been used in this report
as the  national data  base.   Information  on disposal  facilities is
presented by States  and includes total number  in each State;  number
permitted,  or otherwise  recognized  as  sanitary  landfills  in com-
pliance  with  State  regulations;  number  of  authorized  landfills;
ownership;  operation;  and operating  capacity.  The survey  presents
additional  information  on the facilities  and  the  State regulatory
program and is included in its entirety in Appendix G.

     The Fred C. Hart Associates study,  "The Technology,  Prevalence,
and Economics  of Landfill  Disposal  of Solid  Wastes",  provides  an
estimate  of the number  of on-site landfills  for each two-digit  SIC
manufacturing industry group (Ref. 141).   These facilities are appor-
tioned to each State  by using the methodology detailed in Appendix B.
A summary  of the information  contained  in the Waste Age  survey and
derived  from the Hart study  and State revisions  are shown  in Table
D-l.
                                  D -3

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    TABLE  D-l
LANDFILL DATA BASE*


-,„-. O.SAS
CALIFORNIA
COt;\ECTICI T
"LOR I DA
U..AII
ILLP.orS
1 1 i UNA
".,! E
.!"" LV D
'.oS-vrJ -SETTS
":SS:SSIDD:
.E . r-VlfSHIRE
:. JERSEY
"- 1Z U CO
•'iT1- CAROLINA
3RTH DAKOTA
J-IO
•> £ £ i L, , AN H
i1 IDE rSL\M.1
3,-uTH ( ,-p-n :-,A
- ...ESSES:
£.™

HUMCIFU.
| REBUTTED UTHORIZED ILLEGAL
1-2 0 3
123 126 98
0 140 0
9- 0 240
22- 176 0
130 90 0
93 79 0
5 20 0
177 140 0
200 200 80
19 14 2
-.6 46 48
300 0 140
112 23 10
100 1000 225
343 0 0
151 0 2200
65 65 235
-5 192 150
5o 0 11
3 159 161
295 255 150
.j3 126 119
38 68 113
;: o 48
10 98 31
58 400 0
0 20 0
~f> 0 52
:ao 20 o
0 300 300
381 254 0
[70 0 0
80 15 40
228 9 13
202 0 0
261 0 4
150 160 45
13 0 12
211 0 3
0 144 5
520 573 0
11 41 122
55 3 35
234 26 20
oO 300 50
75 6 !80
333 1023 44
68 58 24
n.oiS 6.390 5,272
JfJ-Sl™
r\ni STRtAL
1,150
74
469
652
8,6-8
638
1,580
125
2,213
1,694
151
275
4,580
1,390
305
691
723
843
432
757
2, -97
4.412
1,372
608
1,514
201
332
91
313
3,525
211
7.693
1,985
104
4,488
756
1,093
4,368
660
871
U6
1.236
3.480
300
1,029
1.221
411
1.998
84
75.^05

10 TPD 100 T^T 300 TPD
1,232 55 10
421 2 I
591 12 6
923 52 11
3,871 99 78
340 13 5
1,668 79 5
137 10 3
2,429 67 39
2.115 47 12
i71 11 4
354 58 3
4,729 243 78
1,931 52 52
1,713 342 75
950 76 3
2,948 90 36
1,123 62 25
81- 5 0
737 21 6
2,759 42 16
1,721 252 139
1,648 58 14
377 5 0
1,655 L9 9
419 7 2
811 15 14
109 2 0
404 34 3
3.832 57 42
791 18 2
8,042 261 25
2,000 47 108
226 13 0
-.,561 125 52
894 49 15
1.339 9 10
4.638 79 16
675 6 •*
977 39 68
386 30 0
1,267 102 16
4,404 124 15
384 79 11
284 4 0
1,272 21 16
1,490 117 24
608 64 0
3.185 181 32
227 7 0
39,611 3.262 1,1-0
TOTU
TPD T-Y
20.320 5. -13
4,710 1.225
3,910 2,317
17 , 730 4,610
i:2,010 31,723
11,200 2,912
26,080 6,781
3,2T0 850
42,690 11 ,099
29,^50 7,657
4,010 1,043
10,240 2,662
94 , 990 24,697
40,110 10,429
73.330 19,196
19,500 5,070
49,280 12.813
24,930 6,482
8,640 2,246
11,770 3,060
36,590 9.51]
114,110 29,669
26.480 6,885
9,270 2,410
21,150 5,499
5,490 L.427
13,810 3,591
1,290 335
8, 340 2,168
56,620 14,721
10.310 2.681
114 ,020 29,645
57,100 14,846
3.560 926
73,710 19,165
13,340 4,768
17,290 4.495
59,080 15.361
8,550 2,223
34,070 8,358
6,360 1.784
27,670 7,194
69,940 18, 184
15,040 3.910
3,240 842
19,620 5.101
33,800 9.788
12.480 3,245
59.550 15,483
2.970 772
1 ,5^,310 -06,721

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                      Table   D-l (cont'd)


*LANDFILLS - STATE QUALIFICATIONS TO DATA BASE


 Alabama

    Facility considered illegal  unless permitted.


 Delaware

    Authorized facilities have permits with compliance schedules
    authorized.


 Florida

    Authorized facilities are those  operating under consent order.
    Authorized facilities are those applying for permit, and may or
    may not be in operation.   Illegal facilities are not permittable.
 Iowa

    Number of authorized facilities are only estimates.   Number
    authorized is high because they do not have administrative
    authority over facilities on industrial properties.


 Kentucky

    Number of facilities may include small roadside dumps,  but will
    be evaluated under Open Dump Inventory.  If facilities  are not
    permitted,  then they are illegal.


 Louisiana

    Figures may be low.
    Waste  Age  data not updated since State requires  written requests
    for information on waste  disposal facilities and time constraints
    precluded  this.
                                 D-5

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                      Table   D-l   (cont'd)
Mississippi
   Authorized facilities are those operating with approval or
   consent of local governments but without State permit.
Nebraska
   Number of authorized facilities is only an estimate and may
   be high because the State does not have permitting authority
   for second class facilities and villages.
New York

   Breakdown of facilities in Waste Age survey is not compatible
   with New York State's classifications.
Pennsylvania

   Waste Age data not updated since State requires written requests
   for information on waste disposal facilities and time constraints
   precluded this.


Tennessee

   State registers facilities and does not have permitting authority.
                                D-6

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     The sources  recorded information  of 94,013  disposal facilities
within  the  50 States.   Approximately  35  percent  of the  disposal
facilities reported by Waste Age were recognized as sanitary landfills
in compliance  with existing  State regulations.   These comprise  ap-
proximately 6 percent  of the total known and estimated landfill  dis-
posal facilities.

     Only partial information (34% response)  is available on facility
ownership  and  operation,  but in  the  information  obtained  in the
survey,  publicly owned  and operated  facilities  outnumber privately
owned and operated facilities on a 3:1 basis.

     The number  of landfills  in each State  varies considerably  but
generally reflects  the population  and area  of the State;  thus, the
larger and more populated States have more landfills.  The approximate
total waste tonnage  received by facilities  included in the data base
is 1,564,000 tons per day, at 407 million tons per year, including on-
site industrial landfills.

3.   Facility Conditions

     a.   General

          Improperly controlled disposal  of municipal solid waste  in
landfills  results  in damage  to  public  health  and environment  in
several  forms.   Solid waste  constituents  may  leach  into  surface
streams  and  ground-water  aquifers  and  significantly  impair their
quality.   The migration  of explosive  gases  may result  in injuries
and fatalities,  destruction of buildings,  and damage  to vegetation.
Open burning  of solid wastes  may contribute  to  local air pollution
problems,  interfere  with  aircraft  operations,  and  reduce highway
visibility,  sometimes  causing  automobile accidents.   Facilities at
which solid waste  is  improperly disposed  may provide  harborage and
breeding grounds for disease vectors,vermin and parasites resulting in
public health hazards.   Dust, odor,  litter,  noise, and traffic con-
ditions  associated with  solid waste disposal  at landfills also have
had adverse impacts on the aesthetic quality of the environment.

                                 D-7

-------
     Landfills have frequently been located on land that is considered
to have little or no value for other uses,  for example:   marshlands,
abandoned sand and gravel pits, old strip mines, floodplains, or lime-
stone sinkholes,  all of which are susceptible to ground-water contam-
ination problems.   In one eastern State,  85 percent  of the existing
landfills were originally designed  as "reclamation" projects  to  fill
marshlands and abandoned sand and gravel pits.

     b.   Specific Environmental Impacts

          Wetlands have been used extensively for solid waste disposal
because the land was cheap,  the resistance to disposal facility loca-
tion was small,  the location was close  to major coastal and riverine
cities,  and  filled-in wetlands  could be  used for other more direct
economic activities.    The effect of this practice has been to elimi-
nate some  wetlands and  reduce the  value or productivity of adjacent
wetlands.   Disposal  facilities  in wetlands  often  degrade adjacent
surface  water quality.    The alteration  and destruction of wetlands
through draining,  dredging,  landfilling,  and other  means has had a
cumulative  adverse impact on hydrologic stability  and the ecosystems
involved.   Recent estimates indicate that about 40 percent of the 120
million  acres  in this country's  wetlands that existed 200 years ago
have been destroyed (Ref. 109).

     Disposal of solid wastes in floodplains  (especially along rivers)
may  have several significant adverse impacts:   (1) if not adequately
protected from flooding,  wastes in a disposal facility may be inunda-
ted by water and flow  from the site,  thereby impacting water quality
and  aquatic life  in  downstream waters,  and  also  causing erosion,
siltation,  and flooding;   (2) filling in the floodplain may restrict
the flow of flood waters and/or  reduce the size  and effectiveness of
the floodplain in assimilating flood waters which may result in higher
flood levels and greater flood damages;  downstream or  upstream;  and,
(3) since floodplains generally have hydraulic connection to wetlands,
surface water,  and ground water, improperly  locating disposal facili-
ties in floodplains may result in leachate contamination.

-------
     Solid waste disposal in landfills  has often  led to surface water
contamination  from runoff of leachate,  accidental spills,  and drift
of spray.   One study  cited 162 cases of surface  water contamination
from  industrial waste disposal  of which 49   (30%)  occurred at land-
fills or dumps (Ref. 10).

     The  principal source  of surface water contamination   from land-
fills is leachate,  caused by  water percolating   through  the refuse.
Leachate,  a highly mineralized fluid,  typically  contains  such con-
stituents  as  chloride,  iron,  lead,  copper, sodium, nitrate, and a
variety  of organic chemicals.   Where  manufacturing  wastes  are in-
cluded,  hazardous  constituents  are  often  present in  the leachate
(e.g.,  cyanide,  cadmium,  chromium,  chlorinated  hydrocarbons,  and
PCBs).   The particular makeup  of the leachate  is dependent upon the
city and/or industries using the landfill.   The types  and  concentra-
tions  of contaminants in leachate  are of great importance  in deter-
mining its potential effects on the quality of surface water.

     Leachate  production  is common in the United States because most
facilities are  subjected  to substantial  precipitation  and although
many have  run-off/run-on  controls,  very few  have liners  to prevent
percolation through the wastes.   It is impractical to cover the work-
ing face,  and uneven settlement,  erosion, etc. result in ponding and
percolation.    Furthermore, wastes at many facilities have been placed
directly in contact  with surface or ground waters  (e.g., in streams,
marshes,  and sand and gravel pits).   Once produced, leachate usually
migrates from the disposal area and enters surface or ground waters.

     It may take decades or even centuries for a ground-water resource
to purge  itself even after  a contamination source  has been removed.
The mechanisms  of soil attenuation  (e.g., adsorption,  ion exchange,
precipitation,  or dispersion) have a limited capacity, are  not always
available,  and are reversible since attenuation is  a function of soil
and leachate  characteristics,  thickness  of unsaturated  zone,  soil
homogeneity,  flow rate,  concentration, and pH.  Because of  this, soil
attenuation  alone  is not  always sufficient to  assure prevention of
ground-water contamination from a waste disposal source.

                                 D -9

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B.   LfiNDSPREADING

1.   General Description of the Practice

     Landspreading  of  solid wastes  is currently  practiced  using a
variety  of methods.   The use  of a  particular  method  is dependent
upon such factors  as the characteristics  of the waste,  availability
of  certain land types  (e.g.,  agricultural,  damaged  land) and site
specific  economic considerations.   Three  major categories  of land-
spreading  practices  can  be  identified:    food  and  nonfood-chain
landspreading and use of land as a treatment medium.

     The food-chain  category  includes  the application  of the waste
to crops  that are  for human consumption  or for use  as animal feed.
The  nonfood-chain  category  includes agricultural  practices not re-
lated to the human or animal food chain  and nonagricultural practices
such as  use on recreational land  or in land reclamation.   The third
category, using soil as a treatment medium, is distinct from the other
categories  in that the solid waste,  typically  an industrial sludge,
is applied  for the purpose of achieving effective pollutant disposal,
with soil production essentially sacrificed.

     Thus,  in food-chain  and nonfood-chain landspreading,  the bene-
ficial  properties  of certain  solid  wastes  are  exploited.   These
properties can  enhance the quality of the soil in terms of  fertiliza-
tion,  conditioning and pH neutralization.   Examples  of solid wastes
having these beneficial properties are:
     •    Fertilization
          -    Some municipal wastewater treatment sludges
          -    Animal manures
               Selected textile wastes
          -    Selected food industry residues
                                  D -10

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     •    Soil conditioning
               Shredded municipal solid waste
               Fibrous wastewater sludges  (e.g.,  pulp and paper
               industry)
               Composts derived from wastewater  treatment sludges
               and municipal solid wastes
     •    pH neutralization
          -    Limed sludges from water treatment plants
               Limed sludges  from wastewater treatment disinfec-
               tion processes.
     Although the fertilizer value  of solid waste  is not in the same
order of magnitude  as most commercial fertilizers/  a number of these
wastes can be of significant value as low-grade  fertilizers  with the
added benefit of enhancing the physical condition of the soil.

     Of the  solid wastes  currently landspread,  the most common  are
in the form of  sludges.    The  majority of  municipal and industrial
waste-water  treatment sludges are produced as slurries, which contain
from four to  fifteen percent  solids and  behave either  as solids or
liquids. Available application systems of sewage sludge, both in solid
and  liquid  forms,   are  presented in  Table    D -2.  As shown in the
table,  the application  of solid  or slurry  sludges to land includes
both surface spreading and  soil incorporation.   In a surface system,
the  goal  is  to provide  uniform distribution  on the  land surface.
Sludge  spreaders or other devices are used  to  distribute solid waste
across the surface  ahead of plow blades.   In soil incorporation, the
sludge is sometimes mixed with soil with deep plowing equipment immed-
iately after application.

     Methods of landspreading liquid sludge  also include both surface
and subsurface applications.   To date,  the most commonly used surface
application  methods,   especially  by  smaller   communities,  are tank
trucks and farm tank  wagons.  The  tank truck   can also  be used  for
sludge transport,  but use of either a truck or  a wagon requires suit-
able soil conditions.   Other surface application methods include spray
and ridge and furrow irrigation.
                                 D -11

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      TABLE   D-2
Field Application Methods
          D-12

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     Soil incorporation  of liquid sludge  has a number  of advantages
over surface application.  Odors and pests are not a problem, nitrogen
is conserved  since ammonia volatilization  and runoff  are minimized,
and the public is more receptive.   Liquid sludge  can be incorporated
into the soil  in a number of ways.   The  principal methods  used are
plow-furrow-cover  and  subsurface injection.   Other  tillage methods
which adequately incorporate the sludge may be suitable (e.g., disk or
chisel)  but there have been no  reports to date of the successful use
of these methods.

     The  sludge application rate  for any method  usually  depends on
nutrient needs   (if it is applied  to cropland or vegetative terrain),
sludge composition,  soil characteristics, and local climate (adequate
drying of applied sludge is required so that severe  odor problems and
insect proliferation are avoided).

2.   Number and Distribution of Facilities

     a.   General

          There are seven major  municipal and industrial groups which
produce the majority of wastes suitable for landspreading.  Participa-
tion by other industries  in landspreading is likely to continue to be
quite limited.

     The major groups are:
          Municipal wastewater treatment
          Food processing
          Pulp and paper
          Leather
          Textiles
          Pharmaceuticals
          Petroleum refining.
                                 D -13

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     Table   D-3 summarizes the estimates of  quantities landspread by
each  group.  It is  obvious that the  total quantity  of wastes land-
spread is  dominated by feed-lot  manure.    Among actual municipal or
industrial processes,  the major quantities of landspread solid wastes
are  likely to arise  from municipal  sludge, petroleum  refining, and
food processing residuals such as  whey and grape pomace.   Only small
quantities  of landspread wastes  are expected from the  textile, pulp
and paper, pharmaceutical, and leather industries.

     When one considers  the relative impacts of each of these activi-
ties  in terms  of both  the quantities  of sludge landspread  and the
potential  toxicity of the sludge,  the municipal wastewater treatment
sludges become a prime concern.   For example, some types of municipal
wastewater treatment sludges,  while containing nutrients and organics
of  natural origin,  also contain  trace quantities of chemicals which
are persistent and/or biologically active.  Two examples are the heavy
metals and refractory organic chemicals  (i.e.,  PCB, DDT, PBB, etc.).
The known detrimental impacts of these contaminants on biological sys-
tems can effectively counter the otherwise beneficial aspects from the
addition  of nutrients and organic matter to the soil.   These impacts
include:  direct toxicity to plants; second order toxicity to animals;
third order toxicity to people;  and effects on all food chain compon-
ents.  Obviously, the productivity of soils having such impacts on the
biota is  highly compromised. Thus,  because there is a high potential
for many  municipal sludges  to  be very  toxic  and because municipal
sludge accounts for about  65 percent of the present total landspread-
ing activity  (excluding the nontoxic wastes from feedlots),  this EIS
places  primary  emphasis  upon the  criteria's  impact   upon munici-
pal sludge landspreading.
                                 D -14

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            TABLE  D-3




Landspreading Activity, Dry Weight
Activity
Textiles
Petroleum
Pulp & Paper
Leather
Food Processing
grain mills
dairy products
beet sugar
breweries
wineries
distilleries
- meatpacking
canned & frozen
foods
feedlots
Municipal Wastewater
Treatment
to food chain
non-food chain
giveaway/sale
Total Except Feedlots
TOTAL
Current Volume
(000 metric
tons/year )
5
50
Negligible
24

0
120
0
3
217
0
0
400
62,000

750
250
500
2,319
64,319
                D-15

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     b.   Municipal Wastewater Treatment Sludge

          The removal  of solids  during  the  treatment  of municipal
wastewater  results in a mixture  of  water, grit, screenings and bio-
degradable solids commonly referred to as municipal sludge.   The com-
position and characteristics of municipal sludge  can vary greatly de-
pending upon a number of factors, including:

     •    The origin  of the sludge;  whether  it includes solids
          from domestic,  commercial,  agricultural and/or indus-
          trial wastes.
     •    The type of processing the sludge has undergone,-whether
          the sludge results from primary sedimentation, chemical
          precipitation,  activated sludge  or trickling  filter/
          biodisk treatment,  and its degree  of stabilization by
          either the anaerobic or aerobic digestion process.
     •    The age of the sludge; whether it has been lagooned for
          some time  or whether  it is fresh  from  the digestion
          process.
     Sludges  most commonly applied  to agricultural lands or used for
land restoration purposes  are typically digested  sludges originating
from the primary and secondary treatment processes.

     (1)  Municipal Sludge Disposal Practices

          The major disposal and utilization practices for the approx-
imately  five  million  dry metric tons  of municipal  sludge produced
annually are incineration, landfill, landspreading and ocean disposal.
Minor  but growing disposal  and use practices  within the category of
landspreading  include  nonfood-chain landspreading  and giveaway  and
sale programs.    The current distribution  among the major options is
shown  in Figure   D-l.    Incineration is  clearly an option for only
large communities due to the capital investment required.  Thus,   for
smaller communities other options, especially landspreading, are util-
ized more extensively.  Moreover, since ocean disposal is mandated  to
cease  by 1981 and  air quality regulations  are coming   into force in
many areas,  it seems likely that the use of the landfilling and land-
spreading options will  further increase.
                                  D-16

-------
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                        D-17

-------
     (2)  Municipal Sludge Quality

        Municipal sludge typically contains about 95 percent water  by
weight  (prior to dewatering,  if dewatering is to be utilized).   The
remaining solid portion is made up of soil, grit, organics, nutrients,
and  many trace elements.   A factor  which significantly affects  the
final use or disposal  of municipal  sludge is the  trace element con-
tent.   While the trace element content of sludge can vary greatly de-
pending upon the nature of the wastewater being treated (i.e., whether
it contains domestic and/or industrial wastes) the effect of this var-
iation in trace element composition is not clearly defined due to  the
lack of knowledge about these sludge constituents.

     The  metal content of municipal sludges,  and in particular their
cadmium (Cd) content, have come under particularly close investigation
recently  due to concerns over potential  health and environmental ef-
fects  and the significant  variability in metal  concentrations found

from one  municipal  sludge to  another.   The  sample communities  uses  as
a  data base  in the  EIS  analysis were  examined  for their sludge  cadmium
concentration.This  data base  includes more than  350  POTWs  with  approx-
imately 120  of  these   landspreading 614  dry metric  tons   per  day  on
food-chain  land.    Thus,  the  survey represents about  38 percent  of  the
total sludge presently  being  landspread nationally to  food-chain land.

     The  results of the cadmium survey are shown on  Figure   D-2,  Note
that although  cadmium  concentrations  are   high  in   isolated   cases,
nearly 80 percent of all  current  landspread  sludge has a cadmium con-
concentration  less than  50 mg/kg,  under the limit  implied by   the
final  cadmium  criteria  (as  discussed in Chapter III).  In  fact, not
surprisingly,   that class   of   communities with the  worst   cadmium
problems  are those with  treatment plants  larger than  25 mgd (250,000
equivalent population)   which do not  now   landspread to food-chain
lands.    This may  reflect an implicit knowledge on  the part of  large
urban communities that  sludges that are laden  with industrial contam-
inants such  as cadmium  are not suitable for  landspreading.
                                  D-18

-------
                            FIGURE    D-2
            Distribution  of Cadmium  Concentration  In
   Municipal  Sludge  By  Method of Disposal  and  POTW Site

80-
60-
40-
20-


80-
60-
40-
20-


60-
40-
20-



I1




"1

r~



1
1
1
1
(108.843)



p_p

(110.997)


n

1224.055)


i — i — i — r~

~n
i
1
L.
1
1
I


1
1
I
I
L.
1


r"

4,142)

(207,741)

(1,451,204)
^~H_

(1,663,7871
~H "1— r-
      50  100  150  200   -       50   100   150  200
                          CADMIUM CONCENTRATION (Mg/Kg)
'INCLUDES CHICAGO LANDSPREADING OPERATION
2INDICATES DRY METRIC TONS OF SLUDGE PER YEAR INCLUDED IN SAMPLE SET
                                                -•1
                                                    50   100  150  200
                                                                     l>25mgd)
                                 D -19

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3.   Conditions at Municipal Sludge Disposal Facilities

     a.   Surface Water

          Because  much prime  agricultural  farmland  is  located  in
floodplain areas,   municipal sludge has commonly been spread in these
locations.   Under such circumstances, the likelihood of surface water
contamination  due to flood or rainfall conditions is considerably in-
creased.   Many instances have occurred where municipal sludge has ei-
ther runoff or been washed into surface waters. However, at most land-
spreading facilities  the risk of  contamination of surface waters has
been mitigated due to precautions  taken during siting and proper man-
agement during the landspreading program.

     It is probably not unreasonable to liken the potentiality of com-
mercial fertilizer  runoff from  farmlands to  that posed by the land-
spreading of municipal sludge.  Although with surface water contamina-
tion  due to  municipal sludge,  an additional  potential  for adverse
environmental effects is created by the presence of, for example,heavy
metals and toxic organics, exceeding the problems posed by too great a
supply of nutrients in the water.

     b.   Ground Water

          It is believed that current municipal  sludge  landspreading
practices do not generally endanger the quality of ground waters. How-
ever,very few landspreading facilities are monitored for their effects
on ground water.

     Chemical contamination of ground water can, to a great extent, be
controlled by proper siting.   The depth to ground water at a facility
is a vital factor to be considered.

     The potential  for nitrate contamination  of ground water  can be
considerable  if conditions such as a coarse soil and excessive nitro-
                                 D-20

-------
gen application  from sludge exist.   Generally,   the nitrogen  applied
should not exceed the nitrogen needs of the crop grown.  Any  amount  of
excess nitrogen increases the risk  of nitrate contamination  of ground
water.

     Of the heavy metals,  zinc has been found to  migrate  down  through
the surface  soils at some municipal sludge landspreading   facilities,
but only under undesirable conditions.   Nearly all movement  of metals
toward ground water can be prevented by proper siting,   including  con-
sideration of the depth to ground water, the soil  texture  and soil pH,
and control over contaminant application rates.

     c.   Soil

          Excessive soil contamination has occurred at a number of mu-
nicipal sludge landspreading facilities,  posing problems  of  plant up-
take of toxic elements  (cadmium), potential phytotoxicity  problems for
sensitive crops, and the direct ingestion by grazing animals  of chemi-
cals such as PCBs.

     A considerable number  of landspreading facility  soils  have  been
found to contain more than 5 mg/kg of cadmium as a result  of  municipal
sludge application. A few facilities have even been found  with  greater
than 10 mg/kg of  cadmium in the soil due to the landspreading  of  mun-
icipal sludge.   The use  of such soils for  the growth  of leafy vege-
tables, tobacco or root crops (including home vegetable  gardens)   may
present unreasonable risk to the consumers of these foods.

     Pesticide  and persistent  organic  residues  in municipal sludge
have received,until now, little attention. Very few landspreading  pro-
grams have monitored  these contaminants.   However,  the  Bloomington,
Indiana case of the ingestion of the PCB contaminated municipal sludge
by a dairy cow  is well known.   In this circumstance,   the cow's  milk
was excessively contaminated  with PCBs  after  the cow  had  grazed  on
                                 D-21

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sludge treated pasture.   The problem  was not discovered  until after
the milk was being consumed for some time by a single family.

     The potential for pathogen survival in soils  where landspreading
is practiced has received little attention.  The problems posed by the
presence of  fecal coliform  and fecal streptococci  at  landspreading
facilities is probably no greater than those posed by manure resulting
from grazing animals or the spreading of manure on agricultural lands.
From the  scarce data available,  it is believed  that Salmonella sp.,
Shigella  sp. and  ascaris ova  can quite commonly  be found in  soils
where municipal sludge is landspread.  Ascaris survival has been docu-
mented (not on sludge amended soils) as lasting as long as 7 years  in
soil.
     Problems of odor  and fly breeding at  municipal  sludge  landspread-
ing sites have also been recorded.
      d.    Summary

                     In any program for municipal sludge landspreading,
 proper site selection  and facility management can preclude any of the
 potential  adverse impacts identified in  this section.  And,  indeed,
 these  adverse impacts to  public health and  the environment are  not
 present at most current municipal sludge landspreading facilities.

 C.    SURFACE IMPOUNDMENTS

 1.    General Description of Practice

      Surface impoundments,  which include a wide variety of facilities
 referred to as  pits,  ponds,   lagoons, basins, and pools, are another
 major solid waste disposal method that can introduce contaminants into
 ground water.
                                   D-22

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     Surface impoundments for the disposal  of wastes  are us,ed in es-
sentially all processes relating to treatment of community,industrial,
and agricultural water and wastewater, and as well as in processing by
major industries engaged in such activities as manufacturing,food pro-
duction, mining, oil and gas production,and animal feedlot operations.
Because impoundments are often unlined and leak part of their contents
downward into the soil,  ground-water contamination from these sources
is believed to occur throughout the nation; indeed,instances are known
of contamination from surface impoundments in nearly every State. Many
of the bodies of contaminated ground water are localized;  some are so
far removed  from populated  areas that  they constitute  no immediate
threat to the water supply of any community. Others, however, have de-
veloped into extensive  plumes of  contamination that have already de-
graded  or may degrade  the quality  of local  ground-water  supplies.
(Ref. 107).

     Most plumes of contaminated  ground water associated with surface
impoundments have been found to be small and widely scattered through-
out the country.  A major difficulty in identifying the source of con-
tamination  is that the  existence of a  plume may not  be known until
the contaminated water reaches a nearby well or stream and is detected
either by the taste,  color,  or odor of the water or by routine water
sampling and analysis.

     In the most definitive  study on this subject to  date, a surface
impoundment is defined as a "natural topographic depression,artificial
excavation,  or dike arrangement  with the following  characteristics:
(1) it is used primarily for storage, treatment, or disposal of wastes
in the form  of liquids,  semi-solids;  (2)  it is constructed  above,
below,  or partially in the ground,  and  (3) it may or may not have a
permeable bottom and  sides allowing infiltration of its contents into
ground water."  (Ref.  107).

     Omitted from this study,   were fresh-water  impoundments  such as
natural lakes,  reservoirs,  farm ponds used for water supply,  storm.
                                 D -23

-------
water basins, and flood-control and irrigation impoundments, and otner
impoundments,  not designed to store or dispose of wastes.   These im-
poundments  number  several million  and mainly  contain  fresh water;
hence, many States do not recognize them  as potential sources of con-
tamination.

     Concrete-lined  basins and prefabricated tanks, and steel vessels
that are used  in waste treatment  and industrial processing  were not
included  in the definition of impoundments  in the recent preliminary
national inventory of surface impoundments.  (Ref. 107).

2.   Number of Facilities, Distribution

     Few States have actually counted impoundments or compiled detail-
ed records of  their  construction  and  operation.   The  preliminary
national inventory  (Ref. 107)  and revisions provided by States indi-
cate  the  estimated  number  of  surface  impoundments  in the United
States,  as illustrated  in Table   D-4 .   These  numbers reflect the
judgment  that most impoundment sites, the term most often provided by
the States, are comprised of two to three actual surface impoundments.
Of an estimated  272,000 total impoundments,  approximately 27,000 are
municipal,  198,000 are industrial, and 46,000 are agricultural.   The
majority  of the impoundments are at facilities related to oil and gas
extraction, coal and other raining, and animal feedlots.

     For purposes  of analysis,  each of  these impoundment groups was
considered  for classification  into size categories.   All of the im-
poundments were put into a 2.5 acre size category,except for five per-
cent of the industrial impoundments,which were assumed to be 50 acres.
The rationale and background assumptions  for these groupings are pro-
vided in Appendix C.

3.   Facility Conditions

     The national survey  of impoundments   (Ref. 107)  found that most
impoundments are unlined and built on permeable earth materials,with  a
                                  D 24

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                      TABLE   0-4
ESTIMATE OP  NUMBERS OF IMPOUNDMENTS,  FOR ALL CATEGORIES,
                        BY STATES
State
Alabama
Alaska
Arizona
Arkansas
Call fornia
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
11 linois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
No.
2,763
325
387
2,233
6,566
12,756
1,537
209
5,350
2,836
300
1,385
6,430
5,899
2,918
15,020
8,620
24,493
1,437
1,213
325
7,707
3,673
3,300
4,037
1,352
7,298
231
State
New Hampshire
New Jersey
New Mexico
New Yo rk
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming

Grand Total




No.
398
631
16,190
2,026
4,265
6,923
32,616
5,500
1,798
14,585
129
2,068
1,713
1,831
19,841
1,642
1,251
4,971
2,546
4,855
2,311
12,897

271,567




                               D -25

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                    TABLE   D-4 (cont'd)

*SURFACE IMPOUNDMENTS - STATE QUALIFICATIONS TO DATA BASE
     State has not yet started work on SIA  survey

Maryland, Pennsylvania

     Waste Age data not updated since  States require written requests
     for  information  on  waste  disposal  facilities  and time  con-
     straints precluded this.

New York

     Efforts to establish an impoundment data base are currently under-
     way through the State Health Department.

Tennessee

     SIA survey not started, estimate of total only.

West Virginia

     All private/commercial/institutional  facilities  are included  in
     the industrial category.

 SIA is Surface Impoundment Assessment
                                   D-26

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high potential for leakage.   In regions where rainfall exceeds poten-
tial evapotranspiration, the dominant mechanism for wastewater loss  is
through seepage into ground water.

     It is likely  that  at least  some  leakage into  ground water  is
taking place  from most unlined impoundments  (Ref.  Chapter III  ) .   In
many places,  impoundments could  not function  at all if  leakage were
prevented.    In  those instances,  the owners would  have to turn   to
costly alternatives such as treatment,  liners, or recycling of wastes
in order to remain in operation.  Moreover, the cost for correcting  an
individual leaky  impoundment might  range from  several tens of  thou-
sands to several hundreds of thousands of dollars and, in  some places,
the  remedial action would cost in the millions.   Many States require
permits or have  some other type of regulations concerning impoundment
construction and operation, but many of these regulations  are not very
specific  in regard  to contamination  prevention  or are  not enforced
because financial resources are limited.

     In  addition,  impoundments were  found  to  contain  fluids with
almost every  known chemical substance,  and many  of these substances
were also identified  in ground  water contaminated  by leaky impound-
ments.   Nearly all States  have reported cases of significant ground-
water contamination from impoundments.

     Thus far,  it is primarily  water  in shallow  aquifers which has
been adversely  affected by leakage from impoundments,  but the poten-
tial for contamination  of deeper  waters could exist  in  some ground-
water recharge areas.

     Numerous EPA-documented case studies attest to air,   ground-water
and surface water pollution as a result of land disposal of industrial
wastes.  EPA's Office of Solid Waste has documented 30 case studies  of
industrial land  disposal facilities  that  have created public health
and  environmental hazards.    Also,  through contract  efforts,  fifty
randomly chosen  industrial land disposal facilities were  investigated
and ground-water contamination was observed at 47 of these facilities.
                                  D -27

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     Case studies  on the different  industrial waste disposal methods
have shown different mechanisms for causing environmental, economic or
health damage,  as shown in  Table   D-5.    This information suggests
that  the  waste stream  has often  been shifted between impoundments,
landfills,  and other  disposal methods,  making it more productive to
focus on protecting  the particular resource from all disposal methods
than focusing only on particular industrial waste disposal methods.

     As previously stated,  most impoundments  are unlined and, there-
fore,  may leak part of their  contents down into the soil (leachate).
In many areas,  any contamination of  ground  water also threatens the
quality of surface water.  It has been estimated that over 380 million
cubic  meters (100 billion gallons) per year  of industrial  effluents
enter the ground-water system,  based on standard leakage coefficients
and on the estimated  6.4 billion cubic meters (1,700 billion gallons)
of industrial wastewater pumped annually to oxidation ponds or lagoons
for  treatment (or as a step in the treatment process).   Contaminants
documented  as having degraded  ground-water quality  include phenols,
acids,  heavy metals, and cyanide.  The potential ground-water conteim-
inants for  several  selected  industries  are  shown in  Table   D-6.
(Ref. 7).
                                  D -28

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                          TABLE   D-5

  MECHANISMS INVOLVED IN INCIDENTS OF  DAMAGE  BY  DISPOSAL  METHOD

                     FOR INDUSTRIAL WASTES*
Disposal Method

Damage Mechanisms
(no. of cases)
Ground water (248)
Surface water (162)
Air (17)
Fire, Explosions
(14)
Direct Contact
Poisoning (52)
Wells Affected (138)
Surface
Impoundments
89
57
42
3
-
1
32
Landf il Is
Dumps
99
64
49
5
11
6
28
(No. of Cases)
Other Land
Disposal* *
203
117
71
9
3
40
74

Storage
of Wastes
15
10
-
-
-
5
4
 *The tabulation refers to 406 cases  studies  thus  far.   The  numbers  in
  the matrix add up to more than 406  because  several  damage  incidents
  involved more than one damage mechanism.

**Haphazard disposal on vacant properties, on farmland,  spray irrigation,
  etc.

+ Not included as a damage mechanism.

Note:  The data presented in this table have  been  derived  solely  from
       case studies associated with land disposal  of  industrial wastes.
Source:   House Committee Print No. 20.
                                   D-29

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                          TABLE   D-6

      INDUSTRIAL WASTEWATER PARAMETERS HAVING OR INDICATING

        SIGNIFICANT GROUND-WATER CONTAMINATION POTENTIAL
PAPER AND ALLIED PRODUCTS
                         Pulp and Paper Industry

COD                           Phenols
TOC                           Sulfite
pH                            Color
Ammonia                       Heavy metals

PETROLEUM AND COAT PRODUCTS
                         Nutrients (nitrogen
                           and phosphorus)
                         Total Dissolved Solids
                         Petroleum Refining Industry
Ammonia
Chromium
COD
pH
Phenols
Sulfide
Total Dissolved Solids

PRIMARY METALS
     Chloride
     Color
     Copper
     Cyanide
     Iron
     Lead
     Mercaptans
                         Steel Industries
pH                            Cyanide
Chloride                      Phenols
Sulfate                       Iron
Ammonia

CHEMICALS AND ALLIED PRODUCTS
Nitrogen
Odor
Total Phosphorus
Sulfate
TOC
Turbidity
Zinc
                         Tin
                         Chromium
                         Zinc
                         Organic Chemicals Industry
COD
PH
Total Dissolved Solids
Acidity/Aklalinity
Total Dissolved Solids
Chloride
Sulfate
COD
TOC
     TOC
     Total Phosphorus
     Heavy metals
Phenols
Cyanide
Total Nitrogen
Inorganic Chemicals, Alkalies and Chlorine Industry

     Chlorinated Benze-  Chromium
      noids and Poly-    Lead
      nuclear Aromatics  Titanium
     Phenols             Iron
     Fluoride            Aluminum
     Total Phosphorus    Boron
     Cyanide             Arsenic
     Mercury
                                  D-30

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                     TABLE   D-6 (Cont'd.)

      INDUSTRIAL WASTEWATER PARAMETERS HAVING OR INDICATING

         SIGNIFICANT GROUND-WATER CONTAMINATION POTENTIAL
CHEMICALS AND ALLIED PRODUCTS (Cont'd.)

                         Plastic Materials and Synthetics Industry
COD
pH
Phenols
Total Dissolved Solids
Sulfate
Ammonia
Chloride
Chromium
Total Dissolved Solids
Nitrate
Calcium
Dissolved Solids
Fluoride
pH
Phosphorus
Phosphorus
Nitrate
Organic Nitrogen
Chlorinated Benze-
  noids and Poly-
  nuclear Aromatics
Ammonia
Cyanide
Zinc
Mercaptans
                         Nitrogen Fertilizer Industry
Sulfate
Organic Nitrogen
  Compounds
Zinc
Calcium
COD
Iron, Total
pH
Phosphate
Sodium
                         Phosphate Fertilizer Industry
Acidity
Aluminum
Arsenic
Iron
Mercury
Nitrogen
Sulfate
Uranium
                                 D-31

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         APPENDIX E
 STATE ADMINISTRATIVE COST
ASSOCIATED WITH THE CONDUCT
      OF THE INVENTORY

-------

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                               APPENDIX
          E.   STATE ADMINISTRATIVE COST  ASSOCIATED  WITH
                   THE CONDDCT OF THE  INVENTORY
INTRODUCTION

     The purpose of  this  analysis  is  to  estimate  the  cost  that  will  be
incurred by  the States in classifying solid waste  disposal  facilities
for the Open  Dump Inventory.    The  cost   estimates  pertain to  those
tasks which  the States will  need to  perform  in order  to  (A) review
existing  legislative authority and correct deficiencies,   (B)  develop
phasing schemes for  the inventory,    (C) conduct  on-site  inspections,
(D) analyze  facility data  and present  conclusions  and  (E) hire and
train staff to complete items  (A)-(D).   For the purpose  of this analy-
sis, the inventory work stops  at  the point where the decision  is made
whether  or not to place  a facility on the  Open Dump  Inventory  and be-
fore due process procedures begin.

     In  developing  cost  estimates,   some assumptions had  to be made.
The major assumptions were:

     1.   Data on the number of facilities, their size,  their location
(i.e.  in a floodplain  or wetland) and  their   need to be   upgraded  or
closed is all taken  from  Chapter   I,  or  the methodologies  as presented
in Appendix B.

     2.   All facilities  in need  of  upgrading  for  the ground-water  or
gas criteria will require sampling and analysis work.

     3.   Hourly labor rates were  calculated as:
          Personnel           Annual Rate         Hourly Rate x
                                                  factor of  2.0
          A. Inspector        $12,000                  $11.50
          B. Evaluator/
             Supervisor       $20,000                  $19.25

The 2.0 multiplier is for  factoring  in  overhead  and   fringe benefits.

                                E-l

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A.   STATE LEGISLATIVE AUTHORITIES

     In order  to  conduct the  inventory,  States will need to review
certain legislative authorities and remedy deficiencies.   At minimum,
these  authorities are (1) the right of access to inspect all disposal
facilities  (including  industrial  disposal  facilities)  and  (2) the
ability to require ground-water monitoring.

     After  EPA promulgates  the Criteria for Classiciation  of  Solid
Waste Disposal Facilities, a State would:
     Task
     Review and clarify legislative needs with USEPA regional and
       headquarters offices.
     Review existing authorities against those needed.
     Submit listing of authorities and deficiencies for USEPA re-
       gional office review.
     Timing:  1 week
     Cost:  $19.25 per hour x 40 hours - $770. per State
                                 x 50  = $38,500.

     Once a State received concurrence  from the USEPA regional office
as  to its areas of legislative deficiency,  the State  would begin  to
write new legislation.  The time estimate used to compute the cost per
State to correct  legislative deficiencies consists of the time neces-
sary for the State solid waste management  agency to draft legislation
plus time for participating in the law-making process.  See Table  E  -1
for the costs associated with these activities.
                                 E-2

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                           TABLE  E -1

                  STATE LEGISLATIVE AUTHORITIES
                   SITE ACCESS AND MONITORING
Authority
Site Access
Monitoring


Cost per
State1
$6,737
$6,737


No. of Total
Deficient States Cost
4 $ 26,948
19 $128,000
Grand Total $154,948

     In summary, the costs are estimated to be $38,500 for the identi-
fication  of legislative  deficiencies  and $154,948,  as reported  in
Table VI-1, for correcting legislative deficiencies, for a grand total
of $193,448.

B.   DEVELOPMENT OF THE PHASING OF THE INVENTORY

     In  accordance with the proposed  Guidelines  for the Development
and Implementation of State So lid Waste Management Plans,  the orderly
time phasing of the inventory is to be based on the State's regulatory
and financial abilities,  as well as the expected and  known potential
for health and environmental damage.   It is expected that the process
to determine  priorities  for the  conduct of the  inventory  would be
carried out by existing State personnel.  The process could be divided
into the following parts:
  Based on an assumed 350 hours at $19.25 per hour.
  Based on information gathered as part of EPA Contract No.68-01-4767,
  as of October, 1978.   The statutory right  of access is vested with
  local governments in four States.    Very few State solid waste man-
  agement agencies have been granted  the specific authority "to moni-
  tor" but 31 States have  legislation which calls  for "monitoring as
  deemed necessary by the Agency".
                                  E-3

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Part 1 - Review of State Solid Waste Management Agency Records

     This would involve reviewing permit data  and any inspection data
including gas and ground-water information.

Part 2 - Coordination with Other State and Federal Programs

     Existing information  from  other State and Federal programs will
need to be  assembled and reviewed  to determine if  it is relevant to
making open dump determinations.  The programs include:

     a.   National Flood Insurance Program - defines the
          extent of 100-year interval flood.

     b.   Clean Water Act -
          Section 402 - NPDES permit requirements
          Section 404 - controls  the  discharge  of  dredged and
                        fill materials
          Section 208 - areawide  and statewide wastewater treat-
                        ment plans.

     c.   Safe Drinking Water Act-Surface Impoundment
          Assessment program  to assess the health hazard  of the
          estimated 271,566 surface impoundments.

     d.   Safe Drinking Water Act - National Primary Drinking
          Water Regulations - sets  allowable contaminant  levels
          for drinking water.

     e.   Endangered Species Act, Section 7 - controls the place-
          ment  of disposal facilities  so as not to   "jeopardize
          the continued existence of endangered species."
                                E-4

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     f.   Clean Air Act - Section 110; facility  must comply with
          State Implementation Plans.

     g.   Federal Aviation Administration Order  5200.5 - applies
          to disposal facilities within 10,000 feet of airfields.
          FAA Regulations Part 77  applies to  objects  affecting
          navigable airspace  and is a surface extending  outward
          and upward from a periphery  of a horizontal surface at
          a slope  of 20:1 for  a horizontal  distance  of  4,000
          feet.

     h.   Federal Food,  Drug, and Cosmetic Act establishes maxi-
          mum cadmium and pH limitations for animal feed and milk.

     To accomplish the work under parts 1 and 2 a period  of two hours
per known site is thought to be needed.  The cost is computer as:  Two
hours at $11.50 per hour x [18,500 municipal landfills + 75,505 indus-
trial landfills + 309  landspreading facilities  + 271,566 surface im-
poundments]  = $8,419,840.

Part 3 - Environmental and Health Prioritization

     All criteria have screening  (elimination from further considera-
tion)  techniques.   The most costly of these will be the ground-water
and gas screening techniques.  Based on an estimate of three hours per
site to perform ground-water  screening,  the  total cost  for ground-
  309 is thought to be a "low" estimate.  Indications are there may be
  an additional  several hundred small landspreading facilities across
  the nation.
                                E- 5

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water screening  would be  $12.7  million  ($11.50 x 3 hr. = $34.50  x
[18,500 + 75,705 + 309 + 271,566] = $12,629,760).  It is assumed  that
gas screening will be performed at landfill facilities only.  Based on
an estimate of three  hours per facility to perform gas screening, the
total cost for gas screening would  be $3.25 million ($34.50 x  [18,500
+ 75,705]  = $3,250,072).    The total costs for both  ground-water  and
gas screening are considered to be "high cost" estimates.  In reality,
it probably will not be necessary to screen all facilities as some may
be screened by class or location, or some facilities  may already have
a monitoring program.

Part 4 - Prepare Recommendation for Time-Phasing of the Inventory.

     Typical tasks might be:

     a.   Review of  regulatory program,  staffing  and budgetary
          constraints, and environmental problems.

     b.   Consider additional  site information  such as expected
          life, public awareness and pressure to take action, and
          ability to take corrective action.

     c.   Prepare initial  time-phasing  recommendations and dis-
          cuss with appropriate State and EPA regional officials.

     d.   Revise, finalize, and issue phasing document.

     This activity is estimated to consume four weeks per State at the
supervisory level for a national total cost of $154,000  (160 hours   x
$19.25 x 50 States - $154,000).

     Part 4 would be repeated  in each of the projected 5 years of the
inventory with a review of  the previous year's  progress as the basis
for the next year's  planning.    The inventory  is projected for five
years based  on the announcement  in the President's FY80  Budget that
Subtitle D funds will be phased out over the next five years.

                                 E- 6

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     In summary  the costs for  the development of the  phasing of  the
inventory are:

          Parts 1 and 2       $ 8,419,840
          Part 3              $12,629,760  ground-water screening
                              $ 3,250,072  gas screening
          Part 4              $   154,000 x 4 = 616,000
                              $   616,000
          Grand Total         $25,069,672

C.   ON-SITE INSPECTIONS

     Time estimates are based on the current thinking as to the proce-
dures that could  be used to evaluate disposal facilities  for the Open
Dump Inventory.    In  general, time estimates  refer  to  actual  time
spent  at the site.  It is  assumed that initial site inspections will
be  made in conjunction with routine inspections that are  conducted as
part of on-going State permit programs.

     The time  estimates for  performing on-site inspections at  land-
fills, landspreading facilities, and surface impoundments  follow.

Municipal and Industrial Landfills

257.3-1  Floodplains.

     Determine if the facility is  protected against "wash-out" by  in-
specting the levee and/or other containment structures.
Time estimate:  two hours.

257.3-2  Endangered and Threatened Species.

     If a facility is in a critical location;  then a specialist, pot-
entially  from another State agency,  would be called upon for expert
advice.   Full evaluation could take up to one month per facility (173
hours).
                                  E-7

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257.3-2  Surface Water.

     Determine conformance with wetlands provision.
Time estimate:  one hour.

257.3-4  Ground Water.

     For the purposes of this  study it  is assumed  that ground water
will  have to  be sampled and analyzed  at  all facilities   requiring
monitoring under the scenario presented in Appendix B.
     Municipal Landfills
          Size
           10 TPD
          100 TPD
          300 TPD
                                   Number
                                    2,138
                                      596
                                      164
Wells Per Facility
     3
     4
     7
     Industrial Landfills
          Size
           10 TPD
          100 TPD
          300 TPD
                                   Number
                                   31,865
                                       52
                                        0
Wells Per Facility
     3
     4
     7
                                                         parameters of
                                                                     4
     A ground-water sample  analysis for  the indicator
chloride,  iron, specific conductance and pH.  is estimated to be $18
per 300 ml sample.   Together  with an estimated one hour  to draw the
sample, the cost per sample per well is $18.00 + $11.50 = $29.50.  Thie
sample will be drawn four times  to account for seasonal variations  in
precipitation and temperature.
     To sample  and  analyze ground  water for the  second, third, and
fourth  times would involve costs not included  in the $29.50.   These
  Estimates from the following laboratories:
  KAPPE Associates, Inc., Rockville, Md.
  Penniman and Browne, Inc., Baltimore, Md.

-------
additional  costs would be for an  estimated two hours travel time  for
inspector  and a vehicle mileage charge.  The total additional cost  is
calculated as:

               $23.00    two hours travel time
                16.00    20* per mile for 80 miles
               $39.00    Travel Cost.

     The total ground-water  sampling and analysis costs  are shown  in
Table  E-2.   For the purpose of calculating the total costs shown   in
Table  E-2,  it was assumed  that all  facilities requiring monitoring
under  the scenario presented in  Appendix B would be sampled and ana-
Ized four times.   In reality, all these facilities may not need to   be
sampled four times.   On the other hand, sampling and analysis at some
facilities  may need  to include  parameters in  addition to chloride,
iron,  specific conductance and pH. to test for the other contaminants
specified in the criteria.   There is no reasonable methodology avail-
able  for estimating the number of facilities  that fall  into each  of
these categories.

257.3-5  Application to Land Used for the Production of Food-Chain
         Crops.

     Criteria does not apply to landfill facilities.

257.3-6  Disease.

     Check  for signs of  disease vectors during appropriate  seasons.
Determine  if cover is  adequate  and if  the  facility minimizes  the
availability of food and harborage for disease vectors.
Time estimate:  one-half hour.
  Assumes  that there would be a qualified laboratory within a 40 mile
  radius of most disposal facilities.

                                 E- 9

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                            TABLE  E-2

             GROUND-WATER SAMPLING AND ANALYSIS COSTS
Municipal Landfills
                                           Cost Per       Total Cost  Per
     Facility Size  Number of Facilities  Facility Size   Facility  Size
        10 TPD             2,138              $4716           $ 1,006,998
       100 TPD               596               589                351,044
       300 TPD               164               943                154,652
Industrial Landfills

        10 TPD             31,865               471            $15,008,415
       100 TPD                 52               589                 30,628
       300 TPD                  0               943                      0
                                        TOTAL                $16,551,737
6 $29.50 x 3 wells                  =   $  88.50   1st  visit
   88.50 + 39.00  =  $127.50 x  3      =   $382.50   2nd,  3rd,  and 4th visit.
                                       $471.00   per  facility with 3 wells.
                                 E-10

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257.3-7  Air.

     Check that the facility controls air emissions in accordance with
the State Implementation Plan and that the facility does not open burn
solid waste.
Time estimate:  one-quarter hour.

257.3-8  Safety.

     a.   Explosive gases

     For purposes of this  cost  analysis it is assumed  that gas samp-
ling and analysis will be required at all facilities which  are  estima-
ted  to need  upgrading to meet  the gas criteria.  It is assumed  that
meters will be  used in  testing  for explosive gases  at structures  and
in the field.    The cost for sampling  and analysis is  calculated as
follows.

     Explosive  gases
     Materials:     $0  (it is assumed  that  in   general   States
                        have  meters or will have  access to them
                        as  needed.)
     Labor:             Two hours for sampling structures at each
                        facility.  One-quarter hour per  test lo-
                        cation (in the field).

     All labor  costs are included at the rate of $11.50 per hour.   The
total 
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                            TABLE  E-3
                     GAS SAMPLING  AND ANALYSIS
Municipal Landfills
                                              Cost  Per     Total Cost Per
     Facility Size  Number of Facilities  Facility Size   Facility Size
                                                    ,7
        10 TPD
       100 TPD
       300 TPD
6, 053
1,713
  622
$ 34.50
  46.00
  57. 50
208,829
 78,798
 35,765
Industrial L_andf ills
         10 TPD           7,558
        100 TPD              13
        300 TPD               0
                    $ 34.50
                      46.00
                      57. 50
                  260,751
                      598
                        0
                                                     TOTAL
                                                             $  584,741
  Cost at 10 TPD Facility:
  Explosive Gases  - 2 hrs.
    1/4 hr. x 4 test locations =  3 hrs x  11.50
                                         $34.50
                                 E-12

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     As reported in Table  E-3,   the total cost for   gas  sampling  and
analysis is estimated to be $584,741.

     c.   Fires.

     Determine if the facility poses a hazard to the  safety  of persons
and property from fires.
Time estimate:  one-half hour.

     d.   Bird Hazards.

     If FAA lists a facility as posing a threat to aircraft,  inspector
should review the operating procedures at the facility with  the owner/
operator.  Also, measure the distance to the runway.
Time estimate:  one hour.

     e.   Access.

     Determine  if facility access is  controlled so  as to protect  the
public from on-site  exposure to potential health and safety hazards.
Time estimate:  one-half hour.

     Table  E-4  presents the total cost of conducting on-site assess-
ments for municipal and industrial landfills.
                                 E-l 3

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                         TABLE  E -4

             COST TO CONDUCT ON-SITE ASSESSMENTS

           FOR MUNICIPAL AND INDUSTRIAL LANDFILLS
Hours Per
Criterion Criterion
Floodplains 2
Endangered
Species 173
Surface Water 1
Ground Water
10 TPD 12(+lab+travel)
100 TPD 16(+lab+travel)
300 TPD 28(+lab+travel)
Application
to Land N/A
Disease .5
Air .25
Gases
10 TPD 5+materials
100 TPD 8+materials
300 TPD 11-nnaterials
Fires .5
Bird Hazard 1
Access . 5
Cost
Per Site
$ 23.00
$1,989.00
11.50

471. 00
589.00
943.00

5.75
2.87

34.50
46,00
57.50
5.75
11.50
5.75
Number

of Sites Total Cost
28,445 $
= 508
84,130

34,003 16,
648
164

94,205
94,205

13,611
1,726
622
94,205
2009
94,205
654,235
99,450
967,495

015,413
381,672
154,652

541,678
270,368

469,580
79,396
35,765
541,678
2,300
541,678
GRAND TOTAL $20,755,359
o
No reasonable methodology is available for estimating the number of
facilities affected by this criterion, although the number is expected
to be minimal.
FAA estimates of the total

number of

disposal facilities

throughout
the  country that are near  airports.    It has  not  been estimated how
many  of these facilities are  landfills,   landspreading facilities or
surface impoundments.
                              E-14

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Landspreading Facilities

257.3-1   Floodplains

     This part of the criteria does not apply to  landspreading facili-
ties.

257.3-2   Endangered and Threatened Species

     If the facility is in a critical location, then a specialist, po-
tentially  from another  State agency would  be called upon for expert
advice.   Full evaluation could take up to one month per facility  (173
hours).

257.3-3   Surface Water

     Determine conformance with wetlands provision.
Time estimate:  one hour.

257.3-4   Ground Water

     It  is assumed there  will be minimal  potential for ground-water
contamination  from landspreading  facilities.    If a State  suspected
that a facility  is a source  of  ground-water  pollution  then  it  is
assumed that the following steps would be taken:

     a.   Determine if loading rates exceed the nitrogen require-
ment of the crop (analysis for nitrogen).

     b.   Identify  the source  of the waste material and  assess
the potential for soluble pollutants.

     c.   Calcuate the soil water balance.
Time estimate:  three hours.

257.3-5   Food Chain Crops

     Assess  use of crops grown  at the facility  and note the presence

                                E-15

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of grazing animals.  Check waste handling and methods of  incorporation
and collect samples  of both waste and soil.   Identify the source  of
waste  and assess  the potential for pesticide  and persistant organic
contamination.   Calculate loading rates from operating records, field
inspection reports, and lab analysis results.

     At each  landspreading facility  the following lab costs would be
incurred.

     Laboratory Analysis
          Nitrogen in waste material         $40.00
          Cadmium                            $10.00
          pH and CEC                         $12. OO10
                         Total lab cost      $62.00
Time estimate:  six hours.

257.3-6   Disease.

     Assess the level of stabilization.
Time estimate:  one hour.

257.3-7   Air.

     It is anticipated that  no facility will need to be  evaluated for
compliance with State Implementation Plans.

257.3-8   Safety.

     a.   Explosive gases.

     This part of the criteria does not apply to landspreading facili-
ties because the material is in an aerobic  state and gases will  not be
produced.
   State of Maryland, State Chemists Office.
                                  E-16

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     c.   Fires.

     This part  of the criteria  does not apply to  landspreading since
there should be nothing to support combustion.

     d.   Bird Hazards.

     If FAA lists a facility as posing a threat to  aircraft, inspector
should review the operating procedures at the facility with the owner/
operator.  Also, measure the distance to the runway.
Time estimate:  one hour.

     e.   Access.

     Determine  if facility access is controlled so  as to protect  the
public from on-site exposure  to potential health   and safety hazards.
Time estimate:  one-half hour.

     Table  E-5 presents the total cost of  conducting on-site assess-
ments for landspreading facilities.
                                 E-l 7

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                            TABLE  3-5

                COST TO CONDUCT ON-SITE ASSESSMENTS

                   FOR LAHDSPREADING FACILITIES
Criterion
Floodplains
Endangered
Species
Surface Water
Ground Water
Application to Land
Disease
Air
Gases
Fires
Bird Hazard
Access

Hours Per Cost
Criterion Per Site
NA
173 $1,989.
1 11.50
3 34.50
6(+lab fee) 131.00
1 11.50
NA
NA
NA
1 11.50
0.5 5.75

Number Total
of Sites Cost

11 $ -
309 3,554
o
Minimal
309 40,479
309 3,554



11
309 _ 1^777
TOTAL $49,364
11
No  reasonable methodology is available   for estimating  the  number of
facilities affected by this criterion, although the  number is  expect-
ed to be minimal.

Number included in Table  E-4.
                                 E-I :

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Surface Impoundments

257.3-1   Floodplains.

     Determine if the facility is  protected against  "wash-out" by in-
specting levees and/or other containment structures.
Time estimate:  two hours.

257.3-2   Endangered and Threatened Species

     If the facility is in a critical location, then  a specialist, po-
tentially  from another State agency, would  be called upon for expert
advice.  Full evaluation could take up to one month per  facility  (173
hours).

257.3-3   Surface Water.

     Determine conformance with wetlands provision.
Time estimate:  one hour.

257.3-4   Ground Water.

     For  the purposes of  this study it is assumed   that ground water
will have to be sampled and analyzed at all facilities requiring moni-
toring under the scenario presented in Appendix B.

     Surface Impoundments

          Size                Number              Wells Per Facility
          2.5 acres           156,162                    3
           50 acres             5,894                     7

     A ground-water sample  analysis  for the indicator  parameters of
chloride,   iron,  specific conductance and pH.  is estimated to be $18
per 300 ml sample.  Together  with an  estimated one hour to draw  the
sample, the cost per sample per well is $18.00 + $11.50 = $29.50.  The
sample will be drawn  four times to account for seasonal variations in
precipitation and temperature.
                                  E-19

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     To sample  and analyze  ground water  for the second,  third, and
fourth tines would  involve costs not  included in the $29.50.   These
additional costs would  be for an estimated two hours  travel time for
the inspector and a vehicle mileage charge.  The total additional cost
is calculated as:
                    $23.00         two hours travel time
                    $16.00         20C per mile for 80 miles
                    $39.00         Travel Cost

     The total  ground-water sampling and analysis costs  are shown  in
Table  E-6.  For the purpose  of calculating the total costs shown   in
Table  E-6,  it was assumed  that all facilities requiring  monitoring
under the scenario presented in Vol. II, Chapter  D   would be sampled
(and analyzed) four times.   In reality,  all these facilities may not
need to be sampled four times.  On the other hand, sampling and  analy-
sis at  some facilities  may need to include parameters in addition  to
chloride, iron,  specific conductance and  pH. to  test for other con-
taminants specified in the criteria.   There is no reasonable methodo-
logy available  for estimating the number of facilities that fall into
each of these categories.

                            TABLE  E-6
                           GROUND WATER
                     SAMPLE AND ANALYSIS COST
                       SURFACE IMPOUNDMENTS

Size
2. 5 acres
50 acres



Number of Sites
156, 162
5, 894



Cost Per
Site Size
$471
$943
Total


Total Cost Per
Site Size
$73, 552, 302
5, 558,042
$79,110, 344

                                 E-20

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257.3-5   Application to Land Used for  the Production of Food-Chain
          Crops.

     Criteria does not apply to surface impoundments.

257.3-6   Disease.

     The  disease  vectors  under  consideration  in  the criteria  are
assune3 not to be a problem at surface  impoundments.

257.3-7   Air.

     Check  for hydrocarbon  emissions  fron  evaporation   of   certain
waste types with Colormetric Indicator  Tubes.
Time estimate:  one hour.

257.3-8   Safety.

     a.   Explosive gases.

     It is assuned that  the  gas criteria will apply at only a  limited
number of surface impoundments.   Since the assessment for  gas  is  site
specific and the number of facilities is expected to be small,  no  cost
estimate was developed.

     b.   Fires.

     Determine if the facility poses a  hazard to  the safety of  persons
and property from fires.
Time estimate:  one-half hour.

c.   Bird Hazards.

     If FAA lists a facility as posing  a threat to aircraft, inspector
should review the operating procedures  at the facility with the owner/
operator.   Also, measure the distance to the runway.
Time estimate:  one hour.

                                 E-21

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d.
     Access.
     Determine  if facility access  is controlled so as to protect the
public  from on-site exposure to potential health and safety  hazards.
Time estimate:  one-half hour.

     Table  E -7 presents  the total cost of conducting on-site  inspec-
tions for surface impoundments.
                            TABLE  E -7

                COST TO CONDUCT ON-SITE ASSESSMENT
                     FOR SURFACE IMPOUNDMENTS
Criterion
Floodplains
Endangered
Species
Surface Water
Ground Water
2.5 acres
50 acres
Application
to Land
Disease
Air
Gases
Fires
Bird Hazard
Access
Hours Per
Criterion
2
173
1

12(+lab+travel)
28 (+lab+travel)
NA
NA
1 l+materials)
Site Specific
5
1
.5
Cost Number of
Per Site Sites
$ 23.
00 55,436
Total Cost
$ 1,275,028
1,989. U
11.

471.
943.


Site
Site
Site
11.
5.
50 26,272

00 156,162
00 5,894


g
Specific
Q
Specific
o
Specific
50 1X
75 271,566
GRAND TOTAL
302,128

73,552,302
5,558,042


-
-
-
-
1,561,504
$82,249,004
   No reasonable  methodology is available  for estimating  the  number  of
   facilities affected by this criteria,  although  the  number is  expect-
   ed to be minimal.
 11 Number included  in Table   E-4.
                                  E-2 2

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D.   FACILITY EVALUATIONS

     After the field work has been completed, the  facility  evaluations
must be made.  The steps involved are assumed to be:

                                      Hours12      Rate    Unit Cost
     a.  Written evaluation             4         $11.50     $46.00
     b.  Meeting with owner             2          11.50      23.00
     c.  Prepare final report           1          11.50      11.50
     d.  Decision on intention to
         place on "open dump" list      1          19.25      19.25
                                     Cost Per Facility      $99.75

     Nationally the cost would be:
     $99.75 x  [18,500 + 75,705 + 309 + 271,566]  = $36,516,480.

E.   HIRING AND TRAINING INSPECTORS

     In order to estimate  the cost for hiring and training  inspectors
a comparison was made between the total number of inspectors  needed to
conduct  the inventory and  the number of inspectors currently  avail-
able.   Table  E -8 indicates the total number  of inspectors  that will
be needed to conduct the inventory.  (Assuming that  the  inventory will
be conducted  over a five-year period,   total hours were divided first
by five and then by 2,080 hours per year to arrive at the total annual
need for inspectors.)

     Information  in the January  1979 edition of Waste Age Survey was
used  as the basis  for estimating the number  of inspectors  that are
currently  working  in the  States.    The Survey lists personnel  by
different  categories.    It is assumed  that inspectors  are included
under the category entitled "enforcement".    The Survey estimates the
   More extensive evaluations, deliberations, etc., are anticipated at
   facilities  ranked as open dumps than as sanitary  landfills.  These
   estimates are averages.
                                 E-23

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the number  of personnel  in enforcement to be 356.    If it is assumed
that two-thirds  of the current inspectors  (235)  will be assigned  to
work on the inventory,  there is a  need for 520 additional inspectors.
(755 - 235 = 520)

     Hiring and training  these inspectors could cost as much as $3,000
each.    One thousand  dollars is estimated for the cost of advertising
positions,  interviewing personnel and processing paperwork involved in
hiring  a new employee.   Two thousand dollars  is estimated for a two-
week  training  period consisting of classes,   closely-supervised field
work,  and orientation to the site classification manual.  It is recog-
nized  that training  of existing personnel will be needed and thus, in
computing the cost  nationally,  the training cost is multiplied by the
total  number of inspectors.  Total national cost for hiring and train-
ing inspectors is:

          Hiring         $1,000 per inspector  x 520 = $  520,000
          Training       $2,000 per inspector  x 755 = $1,510,OOP
                                        TOTAL          $2,030,000

     Table E -9  presents  the estimate  of the total number  of super-
visors  that will be needed to conduct the inventory.  No reliable data
was  readily available  regarding  the number of  existing  supervisory
personnel  in the States,  although one supervisor per State is thought
to be reasonable.

     In  a review  of the cost  estimates  pertaining  to  tasks  which
States will  need to perform  in order to  (A) review existing legisla-
tive  authority and correcb  deficiencies, (B) develop  phasing schemes
for the  inventory, (C) conduct  on-site inspections,  (D) analyze site
data and present conclusions and   (E)  hire and train staff to complete
items (A) - (D) the total cost is reported as $168 million.

     Given  that it is not feasible to evaluate all solid waste dispos-
al sites in the  United States (and in light of the announcement in the
President's FY80 Budget that Subtitle  D funds will be phased out  over
the next 5 years),  the  importance of  the phasing  process cannot  be
underestimated.   It is here that States will make the decision concer-
ning which sites will be evaluated.
                                 E-24

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                            TABLE  E-9
                    NEED FOR SUPERVISORS IN THE
                        OPEN DUMP INVENTORY
Task
A.
B.
D.

State
regulatory
authorities
Phasing of the
Inventory
Part 4
Facility
evaluations

Hours Per Number of
Task Tasks
40 50 (States)
350 23 (States)
160 50 States x
5 years
1 366,080
Total Supervisors
Total
Hours
2,000
8,050
40,000
366,080
416,130 = 40 persons/yr

F.   SUMMARY
     A summary of all State administrative costs to conduct the  inven-
tory is presented in Table  E- 10.

                            TABLE  E-10
                       CLASSIFICATION CRITERIA
        EIS-STATE ADMINISTRATIVE COST SUMMARY  (in thousands)
     Element of Cost
    Legislative Authority
    Phasing the Inventory
    On-Site Inspections
     Landfills
     Landspreading
     Surface Impoundments
    Facility Evaluations
    Hiring and Training Inspectors
National Total Cost
$    193.4
  25,069.7

  20,755.4
      49.4
  82,249.0
  36,516.5
   2, 030. 0
                                   Total
                                             $166,863. 3
                           E-2 7

-------
                         APPENDIX F
                SLUDGE DATA FOR POTWs IN THE
                   RCRA 4004 SAMPLE SET
Note:     1.   Footnotes for disposal practices include:

               a-   Food-chain landspreading
               b-   Non-food-chain landspreading
               c-   Unknown landspreading practice
               d-   Giveaway/sale

          2.   It is assumed that industrial pretreatment
               will result in a 50% reduction in cadmium
               concentration in the POTW influent

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-------
               APPENDIX  G




1977 UPDATE TO THE 1976 WASTE AGE SURVEY

-------

-------
DISPOSAL SUES DOWN 24%  IN THREE  YEARS
                           1977  update  for  land
                     disposal  practices  survey
  State officials seemed anxious to talk to us in late
1976 when we did the last disposal practices survey
update.  This  year, however,  many waste control
agency administrators were anything but delighted to
see our  new inquiries. "I want to work with you on
this," we heard again and again "But I don't have the
time any more So many forms, polls, surveys, re-
quests for information .. ." the voice always trailing
off,  disheartened  Fortunately we were able to  per-
suade, cajol, or flatter every state agency into lending
us some of its valuable time to complete  this survey.
  We've thanked state officials before for their gener-
ous help in completing these  time-devouring surveys,
but  those thanks bear repeating  That top state
agency personnel  are willing to volunteer their  ser-
vices to  help generate a  national data  base demon-
strates, we think,  the solid waste control profession-
als'  continuing commitment to improving public under-
standing of solid waste handling
  In addition to complaints about pressures on  their
time, many  state agency officials offered this com-
ment "I don't know anymore." Many items specifically
answered one year ago now list as N/As
  It doesn't take  a degree in government  affairs to
deduce that we have entered the RCRA (Resource
Conservation and Recovery Act) world  RCRA's de-
mands (and the increasing public interest in disposal
practices) have caused  heavier workloads  on state
agencies  More, anticipation of or confusion about the
definitions RCRA will use for  key concepts like "sani-
tary landfill"  has thrown many  state agencies  into
doubt about the significance of their information
  Hence, we are  reluctant to make  any claims about
the  comprehensiveness of this year's figures As you
will  see from the following pages, there  are too many
N/As to allow the 1977 survey to be  thought  of as the
complete national picture  In these cases, N/A is
literal—"not available " It's not that we  didn't get the
information, it's that the information isn't  there
  We'd planned this survey for 1977 (previously, up-
dates were done only in even-numbered years) hop-
ing to grab a "last look" at the state of waste control,
as it is conceived now, because the concepts certainly
will be altered by RCRA  What we discovered is that,
as far as statistics are concerned, waste  control is in a
 bit  of disarray. Considering the pervasive impact of
 RCRA, perhaps that should not have come as a sur-
 prise
  Despite this, it is useful to make some general ob-
 servations about the  new lines of figures First, the
 total for "known land disposal sites," perhaps the sur-
 vey's key item, declined from  15,821 in 1976 to
 14,126,  a 10.7 per cent drop. Our last survey showed
 the 1976 figure declined from the 1974 total of 18,539
 sites, a decrease of 146 per cent. But  since this
 year's decline took place over one year rather  than
 two, it seems reasonable to conclude that the number
 of land disposal sites is shrinking ever more rapidly
 (Or at least that statistical recognition of them is drop-
 ping. If, as is possible, RCRA defines every "pit, pond,
 and lagoon"  as a "land disposal site," then this total
 will inflate to  many times its present size.) In sum, the
 surveys  show a 23 8 per cent decrease in the number
 of "known" land disposal sites in just three years
SURVEY begins on page 36
  Another anticipated trend borne out by the new fig-
ures is that toward larger, more expensive state waste
control agencies. The number of reported state solid
waste employees increased from 858 to 1,000 in one
year, a 165 per cent jump  Since 1974, state solid
waste employees have  increased in number 34 9 per
cent, an  astounding figure  even  by  government's
ever-inflating  standards  It seems clear that state
budgets have  jumped, too, although we did not total
that column because three N/As there dilute  the fig-
ures We  estimate the total to be $28 million, a whop-
ping 45 per cent above last year's $19 million
  Also of interest is that seven states switched their
position to "supports" as regards interstate transfer of
wastes, while two shifted to "discourages " Thirty-four
states now are listed as supporting the controversial
interstate  transfer, 12 as discouraging  it and the  rest
taking neutral  positions  (Among the unconcerned is
Alaska, of course Hawaii, perhaps  playfully, changed
its position from neutral to "discourages ")
  A continuing hangup for this survey is the states'
various legal  (or regulatory) definitions We asked
again the  number of "authorized" landfills and the
                   (Notes, continued on page 42)

                       WASTE AGE January 197S   35

-------
      EXCLUSIVE WASTE ACE SURVEY




REGION #1
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont

REGION #2
Delaware
New Jersey
New York

REGION #3
Maryland
Pennsylvania
Virginia
West Virginia

REGION #4
Alabama
Florida
Georgia
Kentucky
Mtssisspp-
No Carolina
So Carolina
Tennessee

REGION ts
Illinois
Indiana
Michigan
Oh»
Minnesota
Wisconsin

REGION #e
Arkansas
Louisiana
New Mexico
Texas
Oklahoma

REGION #7
Iowa
Kansas
Missouri
Nebraska

REGION *8
Colorado
Montana
Utafi
Wyoming
No Dakota
So Dakota

REGION #9
Anzona
California
Hawaii
Nevada

REGION #10
Alaska
Idaho
Oregon
Washington

District ol Columbia
GRAND TOTAL
State
Population
1 Provisional \
( 1975 Data '

3.095,000
1 059,000
5828,000
618000
927.000
471.000
12,198000

579,000
7,316000
18,120,000
26,015,000

4098,000
11 827000
4,967,000
1 803000
22695000

3,614000
8357000
4 926,000
3,396 000
2,3*6,000
5451 000
2818000
4,188.000
35 096,000

11,145,000
5311,000
9,157,000
10 759,000
3,926,000
4 607 OOO
44,905,000

2,116000
3791 000
1 U70OO
12,237 000
2,712000
22,003.000

2870000
2267000
4,763,000
1,546000
11,446000

2534000
748000
1 206000
374000
635000
663000
6180000

2224000
21 185,000
865000
592000
24866000

352000
820,000
22B8000
3544000
7004 000
716200
213 124200
Metropolitan
Population
, Provisional >
i 1974 Data !

2,849200
322 100
5.610.900
399.100
854,400
_
10,035.700

395300
6.799,800
16057,900
23 253,000

3,495.400
9545600
3,228,300
659500
16,929.000

2204600
6778200
2760300
1 563700
604,700
2,436,400
1 338.700
2,600,200
20.286 800

9,064,700
3,507,400
7,442,100
8.600.500
2,473,200
2 752 500
33.840.400

793,000
2,370 900
376,900
9,418800
1 507,300
14,468,900

1,055,100
976300
3,050,100
685,100
5,766,600

2,030,200
178800
928500
	
79000
98,400
3314900

1,598000
19,448800
691,200
462200
22,201 000

148800
131 500
1 368 700
2 495 500
4 144500
716200
154 957 200

Number
at Cities
(her SHOD

42
27
93
15
15
12
204

5
206
210
421

45
271
46
29
391

56
100
62
43
39
66
41
55
462

199
83
116
193
77
SO
746

37
56
23
183
52
351

58
46
61
24
209

34
14
24
16
12
12
104

19
266
9
7
301

5
18
35
45
103
1
3295

Square
Mdes of
Area

5,009
33215
8257
9.304
1,214
9,609
66606

2057
7836
47939
57832

10,577
45,333
39838
24 181
119,929

51 609
58560
58,876
40395
47 716
52,712
31 055
42244
383,167

55,930
36.291
58.216
41,222
64,068
56 154
331,881

53,104
45,106
121 666
267338
68,867
556,101

56,032
82264
69,686
77227
265,209

104,247
147 138
84916
97281
70,665
77047
581294

113909
158,693
6,424
109786
388,614

586400
83557
96248
68 192
834397
€9
834466
State Solid
Waste
Legislation
Since 1916'

Yes
Yes
No
No
No
Yes


No
No
YBS


No
No
No
Yes


No
Yes
No
No
No
No
No
NO


No
No
NO
No
Yes
No


NO
No
No
Yes
No


Yes
Yes
No
Yes


No
Yes
No
No
No
Yes


NO
Yes
NO
Yes


No
No
Yes
No

Yes


Stai

1976

320,000
1 30.000*
425.000
75.000
349.000
90,000
1.389.000

100.000
560.000
871.548
1.531,548
1
218,445
1,333,000
200,000
-128.000
1.877.445

67,180
361.000
2,716,627
501 000
120.000
238,000
307,042*
314,400
; 4,625,249

801,000
, 278.200
• 524.000
' 535,000
£ 420.000
500000
3.056,200

' 100,000
70,000
! 136.460
713,560
, 120,000
1,140.040

285.000
118,000
' 197,000
132334
732,334

150,000
750,000
61 000
53,592
65.000
117000
t 1.218,592

156,758
2,000.000
50000
96,392
2.305.150

312.000
134.000
387953
550000
1 383953

19 257 51 1

te Siltd Waste
Budiet— $
1977
	 „ _ „
NMV
r 120,000
662.825
. 112.000
1 385.000
I 122.500


310.000
907,000
1 .475,638


" 257,525
. 1 573,315
, 250,000
192,000


' 105,000
906.754
1,778.095
501,100
150,000
=300000
NMV
2.817,500


1.000.000
300.000
966,700
354.000
I 651.907
i 950,000
I

273.350
1 263,000 .
<• 250,000
!, 020.000
275.000
,

200000
244.000
' 430,000
224,000


200000
1 203 flT*
139 B43
99 ,324
84,000
126720


117.000
• ;',800.ooo
70,000
124.264


NMV
156,271
725000
550000

150000

36 WASTE AGE January 1978

-------
                OF  U.S.  DISPOSAL  PRACTICES
                                                                                Number     Number of    Number of
  Number of                                                         Slate     State     of Sites     Landfill     Sites With
   State                             1977                         Attitude   Attitude    With Im-    Impermeable   Leachate
  Solid Waste                       Utilization of State                     Toward    Toward   permeable    Linings     Tteatment
  Employees	Solid Waste Personnel	    Regional   Interstate    Linings     Installed    Facilities
1976     1977      A       B     " C      D      E "   "  F      G      Authority   Transfer    In 1974     Since 1976     In 1974
                     -A Plannmg               f Enforc
                     B Training               T Admin.
                     C Reseatch              G Other
                                                                Encg      Sup
                                                                Encg      Disc
                                                                Encg      Sup
1 0
1 0
1 0
2 1
2 0
1 0
2 0
2 2
12 3
0 0
NiA N/A
0 0
0 3
0 0
3 1
2 3 1
253
2 20 8
1 12 5
1 5 2
24 2
1744
16 2 7
43 55 32
0313
N'A N,A NiA
796
1 5 2
026
1166
0
2
5
0
0
0
0
15 5
32
N,A
5
4
9
6
Encg
Encg
Encg
Encq
All
Encg
Encg

All
Encg
Encg
All
Eocg
Encg
Sup
Sup
Sup
Sup
Disc
Sup
Sup
Sup

Sup
Sup
Sup
Sop
Dsc
All
                                                               Encg
                                                               Encg

                                                               Encg
                                                                        Sup
                                                                        Sup
                                                                        Sup
                                                                        Sup
                                                                        Sup
                                                                        Sup
                                                                        Sup
                                                                        Sup
                                                                        Sup
                                                                              WASTE AGE January 1978  37

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       EXCLUSIVE WASTE AGE SURVEY
40 WASTE AGE January 1978
                Cover Dm
               Milled Refuse

-------
        OF  U.S. DISPOSAL  PRACTICES
Publicly
G*ned
 Und
Oprated
Number of landfills
With Daily Operating
 Capacities of"
                                              0 200 500
                                              E 500 1 000
                                              F i 000 or mn
-------
SURVEY NOTES  . . .
(Continued from page 35)

number of "licensed, permitted, and otherwise recog-
nized" sites This comparison is meaningful to some
state officials and  causes ;others to scratch their
heads in bewilderment  With the expectation  of
RCRA's definitions brooding over  this  year's survey,
these numbers became confused  Therefore,  we did
not attempt to total  columns beyond number (17)  In
the latter columns,  particularly question (21),  some
states could  supply only figures  for acknowledged
"sanitary" landfills,  some for all  landfills,  some for
permitted landfills,  and so on, and these different
categories were impossible to correlate We suggest
readers will find these latter columns  most useful if
regarded as significant only within states or regions.
Anyone wishing to project a national trend from the
latter columns should remember the doctrine  of
caveat emptor
  We hope this update will provide a helpful informa-
tion base for all professionals in  the  waste control
field  For good or ill, it probably is the last "pre-RCRA"
statistical look at our nation's land  disposal  practices.
The  next look—RCRA's open-dump  inventory—will
tell us everything we  always wanted  to know about
solid waste but couldn't afford to ask  We realize the
open-dump inventory may put our  survey out of busi-
ness  But then, considering the $50 million pncetag
put on the inventory by EPA officials, it ought to.


NOTES ABOUT THE QUESTIONS

COLUMN (5)
  Several states reported legislation pending

COLUMN (6)
  States were asked to supply total figures, including
one-time state or federal grants, without listing source.
Several reported federal grants pending.

COLUMN (8)
  Most states have  other employee support not indi-
cated by these figures—county,  regional,  and local
health and  environmental control personnel Several
states reported new positions expected soon, and
these were  included in the figures  New York and In-
diana reported tthat their workers have no "formal as-
signments " Their entries as N/As  mean that employ-
ees are not  tied to any given slot—not that the agency
heads don't know what their people are doing

COLUMN (12)
  Reprinted from earlier survey

COLUMN (13)
  The 1974 to 1976 figure showed 82 new  liners; the
new one-year figure shows 44, so the pace  should be
considered  unchanged Some reponses included arti-
ficial  linings, asphalt,  rubber,  etc, but  never recom-
pacted on-site soils

COLUMN (14)
  Reprinted from earlier survey
                                                                      Abbreviations
                   D,'N A = Did Not Apply
                 No Upd  - Nol Updated
                   Footnotes

 (1)  Editor supplied number based on typical responses
     from similar programs
 (2)  1974 number utilized where new data was  not
     supplied
 (3)  Surveillance
 (4)  Inspection and Permits
 (5)  Hazardous waste
 (6)  Clay liners only
 (7)  Program development
 (8)  11 permits—3 hazardous waste
 (9)  Financial assistance
(10)  Includes 5 sites privately owned and publicly operated
(11)  Abandoned auto program
(12)  Data management and demonstration studies
(13)  Spray irrigation
(14)  Recirculation method not reported
(15)  Number reported here by state was total for all sites
     which editor proportioned to equal answer in question
     #14
COLUMN (16)
  Eight states changed to determining cover require-
ments on a case-by-case basis, while six made daily
cover mandatory  Two dropped cover requirements
In Region Six, four of  the five states changed proce-
dures. We would be pleased to hear readers' theories
on what this signifies.

COLUMN (17)
  This column includes whatever the  sampled slates
classified as  a  "land  disposal site." It is  bound  to
change because of  new definitions being considered
in many quarters Many of the entries are estimates


COLUMN (20)
  Many of  these numbers  are estimates  In many
cases, we were told, far more was known about sites
either publicly owned and operated or privately owned
and operated  than of the public-private hybrids
  In  some cases, the  total sites  listed in the break-
down is greater than  the total for "known sites"  in
column (17) This is because (20) often represents the
respondent's best estimate, and the round numbers
are intended to represent  proportions rather than
exact guesses  In the  last survey, we corrected this
column (on a  proportional basis) to match the tolal in
(17)  This year, we reproduce  the  state's  listing.
Perhaps a contrast  between the two approachs will
benefit the user                                 •
42  WASTE AGE January 1978

-------
      APPENDIX H

LANDFILL GAS INCIDENTS:
  BACKGROUND MATERIAL
          H-l

-------
                        City of Richmond
                Department of Public Works
900 F. Broad Street, Richmond, Virginia 23219
804 • 649 4664
  'Mtf 1 ? 1979

EMCON ASSUCWIEi
                                      March 5, 1979
               Mr.  David H.f Armstrong
               Emcon  Associates
               1420 Koll  Circle
               San  Jose,  California  95112

               Re:   Landfill  Gas Control  System Costs

               Dear Mr. Armstrong:

                   As  discussed in our phone conversation of March 1, 1979, I
               am enclosing a report outlining our experiences in the early
               phases of  our  gas control  work.  I  hope it will be of some use
               to you.

                    I have  made  marginal  notes to  indicate the costs of various
               items  that we  know.   Also  the  cost  breakdown  of the project we
               now  have under bids  is  attached for your use.

                   Please  note  that some of  the comments made concerning
               communications are peculiar to our  case and should not be taken
               as general statements.

                   If we can help  you further, please advise.

                                               Sincerely,
              DN/st
              Enclosure
                                                Of 0. NuttaU,  Sr.  CE
                                                Division  of Sewers

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              REPORT SUMMARIZING THE LANDFILL GAS
                  CONTROL PROGRAM OF THE CITY
                     OF RICHMOND, VIRGINIA
                          PREPARED BY
                THE CITY OF RICHMOND DEPARTMENT
                        OF PUBLIC WORKS
                              FOR
              THE NATIONAL ASSOCIATION OF COUNTIES'
                 TECHNICAL ASSISTANCE SEMINAR IN
                  DENVER, COLORADO ON SEPTEMBER
                        27, 28 and 29, 1977
  I.   HISTORY/BACKGROUND
 II.   PROBLEMS ENCOUNTERED/RECOMMENDATIONS
III.   APPENDIX

-------
                          I.  HISTORY/BACKGROUND
The City of Richmond, Virginia first became aware of the potential hazards
of sanitary landfill-produced methane gas in early January of 1975 when
an explosion in an apartment building inflicted minor burns on a resident
and blew doors and windows from the apartment.  The building, which is
located within a matter of feet of the edge of the City-operated Fells
Street Landfill, was all-electric and was not served by natural or bottled
gas.  Fire personnel detected combustible gas in the first floor walls and
exterior weep holes of the building.  This combination of circumstances led
the City to investigate the landfill as a potential source of the explosive
gas.  Test borings revealed subsurface gas concentrations well in excess of
the lower explosive limit (L.E.L) immediately surrounding the building.
As roughly two-thirds of the landfill perimeter bordered fully developed
residential and commercial neighborhoods, the potential magnitude of
hazardous exposure to the areas became evident.

Recognizing that the scope and the complexity of this problem exceeded the
expertise of City and other local engineers, EPA was contacted for the names
of consultants with experience in dealing with landfill gas problems.  EPA
offered the names of two firms, although the City has since become aware of
others (see Appendix).   The City interviewed and accepted work proposals
from the two firms who both proposed to evaluate the problem in a similar
manner.  A contract was entered into with the consultant agreeing to accept
professional services liability as a contract provision (also see Problems
Encountered).  The consultant conducted on-site studies in mid-1975.

Although the City has identified and is dealing with landfill gas problems
at five sites, major emphasis has been placed on two of them:  the Whitcomb
and the previously discussed Fells landfills.  The Whitcomb landfill covers
approximately 14 acres with a maximum 40 foot depth.  Less than half of its
perimeter fronts on developed land and a City school is located on one
developed side.   The landfill was closed out in the late 1950's and the land
is now used primarily for recreational purposes.  The Fells landfill covers
approximately 39 acres to a maximum 80 foot depth.  Approximately two thirds
of its perimeter fronts on developed land and, as at Whitcomb, a City school
is located on one developed side.  A portion of the landfill has been closed
and is now used for school and recreational facilities.  The active portion
is scheduled to be closed within several years.

The tests which the consultant performed consisted primarily of sampling sub-
surface gases through plastic tubing buried generally to depths of 5, 10 and
20 feet (see sketch in Appendix).  These samples were collected in plastic
bottles and analyzed in the consultant's lab for methane, carbon dioxide,
nitrogen and oxygen by gas chromatography.  After several rounds of sampling,
the methane concentrations were plotted on a site plan and used to construct
"isogas" lines,  or contours showing the trend of methane generation/migration
around the landfills.  Methane, the consultant determined, had been migrat-
ing several blocks outside of the landfill limits through natural ground.

-------
Included in the consultant's report to the City were the following recommenda-
tions:  1) residents and businesses in the affected areas should be advised
of the potential hazard and asked to keep buildings well ventilated, 2) con-
tinuous, automatic methane detection systems should be installed in the
school buildings, 3) building permits should not be issued in the affected
areas until the applicant demonstrates that there is either no methane
problem on the site or that the problem will be addressed by the inclusion
of protective features in the building design, and 4) the City should begin
a two-phase program to eliminate the movement of methane outside of the
landfills using a subsurface vacuum barrier induced by electric blowers
through transmission headers to gas extraction wells.

The City implemented the first recommendation with the door-to-door distri-
bution by Fire inspectors of notices advising residents of the problem and
precautions which they should take.  (Sample notices included in the Appendix.)
An emergency telephone number was provided should residents detect unusual
odors or have any questions.  Fire inspectors began, and are continuing, to
"spot check" homes with portable meters on a regulator basis or on request.
The border of these activities was generally along the "zero" methane gas
contour.

The City began implementation of the second recommendation by authorizing
it's consultant to design the proposed automatic detection systems for the
school buildings.  Sensing heads were installed in virtually every room of
the buildings.   Changes in combustible gas concentrations at the sensors
induce a voltage variation in the control wires which tie the sensors to a
central control panel in the buildings.  Visual alarms are set at a 5% L.E.L.
threshold and audible alarms at 10% L.E.L.  Both systems, which operate con-
tinuously , are linked to the School Board's radio room for remote monitoring
at night and on week-ends.

The City's Building Commissioner's office was advised of the methane-affected
areas as a first step in implementing the consultant's third recommendation.
Building permit applicants inside the established "zero" gas contour are now
required to engage the services of a certified professional engineer to
first determine whether a methane problem exists on the site of the proposed
work.  Should methane in concentrations less than 2% L.E.L.  be detected, a
permit is issued without further requirements.   This limit of allowable
methane concentration was recommended by the City's consultant.   Should this
limit be exceeded, the following three features must be included in the
building design:  1) adequate ventilation, 2) automatic methane detection,
and 3) sealing of ground-level or basement floors.  When these requirements
have been addressed, the permit is issued.  Two such permits have been
issued.   In both cases, the special features were required.   (Also see
Problems Encountered).

The City initiated implementation of the gas migration control program by
entering into a contract with it's consultant for the design of two "pilot'1
control systems.  The primary purpose of these small scale systems was to
provide a means for evaluting the performance of a gas collection system
in local soil,  groundwater  and climatic conditions.   These systems have
been constructed on the grounds of the two schools in order to afford pro-
tection to the buildings at the earliest possible date.   This considera-

-------
tion, however, was secondary to the primary purpose of collecting performance
data to be used in the design of full-scale control systems around the
landfills.

The pilot control systems were constructed during the winter of 1976-77 and
were tested by the consultant during May and June of 1977.  The systems con-
sist of four major components:  1) gas extraction wells, 2) gas collection
headers, 3) vacuum blowers, and 4) waste gas burners.  The gas extraction
wells, of which five were constructed at each site, were drilled with a
30 inch auger to groundwater or natural ground (typically 15 feet to ground-
water at the two sites).   Perforated PVC pipe was installed generally below
the ten foot level and tied to nonperforated PVC pipe above the ten foot
level.  The wells were then backfilled with large ballast stone around the
perforated pipe and compacted soil around the nonperforated pipe.  In this
manner, gas is drawn from the lower depths in an effort to prevent atmospheric
air from being drawn through the ground surface into the system.  (Also see
sketch in Appendix.)

The gas collection headers are polyethylene pipe ranging in diameter from
8 to 24 inches.  Polythylene pipe was selected by the consultant because of
its flexibility, a necessity in settlement-ridden landfill areas, and its
high resistance to chemical attack, needed because of the acids which
condense in the pipe from the moist landfill gas.  The consultant also made
provision to remove the condensate by specifying overflow traps at low points*
in the headers.  Each gas collection well is connected to the header by
branch tees and individual control valves.

Centrifugal blowers create vacuum through the collection headers and wells
to the ground surrounding the wells.  (Subsurface negative pressures were
measured by the consultant in the previously mentioned sampling probes
during the pilot systems  testing.)  A fiberglass blower housing was speci-
fied to the resist chemical attack.

Waste gas burners are used to flare the extracted gas, when combustible mix-
tures are present.  This  feature is solely for aesthetic purposes as odor
problems have been reported at sites where the landfill gases are released
to the air.

The City's consultant's report on the pilot systems testing revealed that
the Whitcomb system had adequately controlled the methane migration to
provide full protection to the school.  It was determined, however, that
the Fells system required modification in order to provide a continuous
barrier to gas movement.   A relatively nonproductive well has been aban-
doned and replaced with two additional wells which appear to be adequately
protecting the school.   Six wells are now in service in the Fells system.
In addition to other design and operating criteria, the consultant has deter-
mined that the optimum well spacing for the sites under study is approximately
200 feet.

The City's consultant is  currently (September, 1977) designing the full-scale
control systems which will fully control methane gas migration from both
landfill sites.  The City expects to advertise for competitive construction
bids around the latter part of 1977.

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p
                 II.  PROBLEMS ENCOUNTERED/RECOMMENDATIONS


The City of Richmond has experienced many peculiar problems since it began
its landfill gas control program in early 1975.   Most of these problems are
directly or indirectly related to the City government's responsibility to
protect the public's health and safety.  However, this responsibility has
also become a matter of liability in Richmond's case as the landfills are
owned and operated by the City.  (In Virginia, cities and counties are
independent corporations.  Although some regional authorities and com-
missions exist, Richmond has found little cooperation from it's less
densely populated neighboring counties in establishing refuse disposal
sites outside of the City limits.  As a result, Richmond has landfilled
areas in developed neighborhoods and development has spread to and, in at
least one case, directly over landfills which were once in relatively iso-
lated areas.  This practice, of course, was well established long before the
potential hazards of landfill gas were appreciated).

A problem which the City encountered early in its gas control program was
the question of the consultant's professional liability.  As was previously
mentioned, the City's consultant was selected, in part, as a result of the
second prospect's refusal to accept a standard hold harmless clause in his
contract.  An article by Myron Nosanov and Robert White (see Appendix)
addresses the issue from one consultant's point of view.  (The City later
discovered that it's consultant did not carry adequate liability insurance
and is now reimbursing him for his annual policy premium).   Potential con-
tracting authorities may find this issue to be an obstacle in selecting a
consultant.

It could be argued that placing liability on the consultant dealing with a
problem as hazardous, inexact and relatively new in technological terms as
methane gas migration would encourage the consultant to be unduly conserva-
tive in his design and recommendations.  This would place additional burden
on the contracting authority in implementing the consultant's recommended
programs.  In any case,  the contracting authority must be prepared to accept
the consultant's judgment.   To refuse acceptance would shift the liable
exposure to the contracting authority.   It is recommended that such possibili-
ties be weighed when selecting a consultant.

As was previously discussed, the City distributed notices of precaution to
residents in the migration-affected areas.   Although this was considered a
responsible action to take, it was not  without disadvantages.   Some misunder-
standing resulted as a few residents believed methane to be poisonous or
that it was traveling from the landfills through the air into residential
areas.  Also,  public calls  were made for the City to provide relief to
residents having incurred excessive heating costs resulting from following
ventilation precautions  advised by the  City.   Richmond has  learned that
insuring that  the affected  people receive correct information is an impor-
tant facet of  conducting it's gas control program.

-------
The conditional issuance of building permits near landfill areas has caused
several Richmond property owners to incur excessive building costs through
no fault of their own.  Two owners have requested reimbursement by the City
for added expenses.  One case has been settled out of court while the other
remains unresolved.  This potential exposure should be considered by the
appropriate authority prior to restriction of development.  The County of
Los Angeles has adopted an ordinance addressing such development (see
Appendix).

As several thousand miles separate the City of Richmond and the consultant,
there have been occasions when communication and expediency could have been
better served had a local consultant been retained.  Ready accessibility of
the consultant and his staff, as in any business association, is highly desirable.
The use of local consultants may not always be possible, but is advantageous
and should be considered.

In summary, many sensitive administrative and legal problems may be encountered
in dealing with landfill gas migration.  As discussed above, the City of
Richmond has experienced several in spite of the benefit of the guidance of
an experienced consulting engineer.  This points to the importance of employ-
ing the services of experienced individuals or firms as some problems may be
found to be inherent to methane hazards and could be anticipated with exper-
ience.  Still other problems, it will likely be found, are peculiar to local
social and political conditions and may not be so readily predicted, even
with the benefit of expert guidance.

-------
        n   ,   ,'7n ki'^T",   ^VTv:ik    SOI North 9lh Street, Richmond.!
        Department of Public S,ifety    A.  V\
             orr  ra n   ,     i^-,A    703 • 049-5G21
             OffiLc of the Director .   *t •? JSf
                          \%&%y!
                           •s^Gi^y
                            ^»v_  ,,X
                         December 5, 1975
 Dear Resident:

 As  you are aware,  notices were distributed in your neighborhood
 in  July and August advising residents to take precautions
 against the possible accumulation of methane gas.  Although we
 know of no change  in the general migration of methane gas  in
 the area,  this is  to remind you that the need for ventilation
 is  even greater during cold weather.  Accordingly, you are
 again advised to take the following precautions:

    1.   All basements and crawl spaces should be opened for
        natural ventilation.

    2.   All living  areas should be ventilated.  Where forced air
        ventilation is not provided,  our consultant's staff
        advises that windows should be opened at least one inch,
        preferably  from the top.  Storm windows should also be
        opened at least one inch.   Closet doors should be left
        open as well.

    3.   Should you  have any questions concerning methane gas in
        your building,  or should you note any unusual odors,
        please  call 649-1111 immediately.

Concentrations of  methane  gas  may be odorless and are not
usually dangerous  in a well vented area.  According to the
independent  consultant,  it is  most important that your home,
apartment,  dwelling  or other structure  be  kept well ventilated
at all  times.

As a step to alleviate the problem,  City Council has authorized
initial funding  for  the  establishment of a gas control system.
In the meantime, we  sincerely  appreciate your cooperation in
the following  the  above  safety precautions.
                              Jack M.  Fulton
                              Director of  Public Safety

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                                                           M.AR
                                                                5 ,97g
                 louisville and Jefferson county planning conittilssiv&i/U Ei
                 900 fiscal courl building  •   louisville, keiilucky 40202    •   581-6230
 March 1,  1979
 Mr.  David H.  Armstrong
 EMCON  Associates
 1420 Knoll Circle
 San  Jose,  California  95112

 Dear Mr.  Armstrong:

 In reply  to your letter of February 21,  1979, I have compiled some
 specific  costs  related to resolution of  the Lee's Lane landfill gas
 migration problem.   Information with regard to property value
 deterioration is not available at this time.   Also,  it is impossible
 to assess legal costs because of the potential for further legal
 action.

 A study to determine the extent of the gas migration,  the composition
 of the gas, and the  depth to which it extended was done at a cost
 of $60,000.   An environmental review necessary to receive funding
 for  the gas ventilation system costs an  additional $5,000.  The
 contract  for  designing a gas ventilation system was  performed for
 $29,370.   Actual cnstruction of the gas  ventilating  system is
 costing approximately $250,000.   Operation and maintenance of the
 system is  expected to cost about $5,000  per year for the next ten
 years.  To date,  five families have been relocated and a sixth
 family will be  relocated soon.  The total cost of the  relocation
 effort is  about $175,000.

 Costs to  date are therefore:

     1.   Study  to determine composition  and migration  -  $60,000
     2.   Environmental review -                            5,000
     3.  Design contract price -                          29,370
     4.  Estimated construction costs -                   250,000
     5.  Operation and maintenance (10 years)  -           50,000
     6.  Approximate relocation cost (including
         property acquisition,  replacement housing
         payment, and moving  expense)  -
     7.  TOTAL -
 175,000
$569,370
This information was gathered  from  the  Housing Authority of Jefferson
County and the Jefferson County Public  Works  Department.  If property
value deterioration or legal fees information becomes  available,  we
will forward the information to EMCON.   Hopefully,  the ventilation

-------
Mr. David H. Armstrong
Page Two
March 1, 1979


system will resolve the gas migration problem.  A similar system is
working well at another landfill in Jefferson County.  If the
system does not resolve the problem, however, more extensive costs
may well be incurred.

VJe are glad to be able to assist in this study of the landfill gas
problem.  Please contact me if you require further assistance.

Sincerely,
David J. Mansen
Deputy Director
DJM/tb
     Ed Robinson, Jefferson County Public Works Department
     Dave Ripple, Director of Advance Planning, Planning Commission
     Jude Clark, Planner I, Planning Commission

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                    CITY OF  NASHUA,  NEW HAMPSHIRE

                          OFFICE  OF CITY ENGINEER
                                                 February 16,  1?66
 Mr. Jar.es I. Waller
 Director of Safety
 Winston-Sales,  Korth Carolina

 Dear Sir:

         The land fill that has been built  on in Nashua is the only one that
 has developed a gas problem.   The  other areas without buildings, although
 they are generating gas,  difuse the gas into the open air and no dangerous
 density has been noted.

         At our  shopping  center area, the gas problem was noted early in the
 construction stage  arid the  following additional precautions were required.

         (1)   A  peraanent  gas  sensing devise was installed in the only basement
 area.   Perforated pipes were  laid under the concrete floor and the trenches
 for the pipes were  backfilled  with pea stone.  This pipe grid was vented through
 the roof.

         (2)   The greatest part  of the building was slab construction and in
 the concrete  sideualk, self-closing  test tubes were constructed every fifteen
 feet the full length  of the building so that periodic checks could be made
 of  the  gas density.

         (3)  The parking lot,  which is located over the area of  the  land fill
 that was the deepest., was vented by storm drainage  system,  backfilled with
 crushed  stone.  The underground electrical cable to the parking  area light
 standard was also backfilled with crushed stone, and a hole  was  left in the
 center of the light standard bases and the standards were  topped with a
 ventilating cap  which allowed any gasses trapped in the area by  the  asphalt
 surfacing to have a way out.

        For the  first year the test spots were  checked monthly by the Fire
 Prevention Bureau.  The owner of the shopping center was required to have
periodic tests made by qualified "Leakage Control"  consultants.

        During the first year no dangerous concentrations  of gasses  were
 noted, although  gas was detected and the venting systems were doing  what  they
vere supposed to do.
             New  Hampshire $ Most Progressive City

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                   CITY OF NASHUA, NEW  HAMPSHIRE


                         OFFICE OF CITY  ENGINEER
 Mr.  James I. Waller              -2-               February 16,  1966
        I hope that this information vd.ll help you with your problem.
 I'm  sura that there is some consultant for leakage control in your area
 who  could help you with your specific problem.


                                             Very truly yours,
                                                -

                                          //Joel B. Hill
                                          V  City Engineer
JBE/ac
            New Hampshire's Most Progressive City

-------
PORTABLE GAS DETECTION EQUIPMENT
SUPPLIER
MSA1









Lumidor
Products
JW2





Enmet

Bio Marine ,
Industries


MODEL PRICE
Spotter Methane $255.00
Detector
502 460.00
53 310.00

250

Combustible Gas
Indicator Models
20,21,30,40
Explosimeter (model
24) Indicator
Gas - Pro
No. LP-PGA-9
H
HPK 788.55
G
HPK 728.00
L
GPK 671.00
CGS 10 395.00
CGS 8 295.00
911 (combustible 225.00
gas detector)
901 (combination 515.00
combustible gas/0,,
detector) *•
922 (combination 495.00
combustible gas/0,
detector '
COMMENTS
0-5% methane
Dual Scale: 0-2% and 1.5-5%
0-100% 87 volume
0-100% LEL
0-100% LEL
0-25% Oxygen

4 Models



CH4







Factory preset for alarm at 100%
of LEL - can be modified, however






Gas kit with case & assessories

With integral pump (special
scale)

With case and accessories
20% LEL methane
20% LEL methane
0-100% LEL, 0-5% CH4
0-100% LEL, 0-5% CH4
0-100 LEL, 0-5% CH4, 0-4% DZ

LEL








-------
                        PORTABLE GAS DETECTION EQUIPMENT
     SUPPLIER         MODEL              PRICE                  COMMENTS
                  900 (Combination       $615.00    0-100? LEL,  0-5% CH4>  0-42  02
                  conbustible gas/0.
                  detector with alarms)

                  902 (combination        995.00    0-100% IEL,  0-« CH4,  0-25% 02
                  combustible gas/0.
                  detector)


 Carle 4          9704 (Basic 645
                  chromatograph)

 Southern Cross   Pin Pointer Model  SCC              0-1 LEL natural  gas, 0-100% natural
 Corporation                                         gas


 Gastech4         GX-3                    845.00    Simaltaneous CH./O- detection
                                                    0-100% LEL
FOOTNOTES:

1.  Prices current as of January 1979
2.  Prices current as of 1978
3.  Prices current as of August 1977
4.  Prices current as of December 1978

-------
                        PERMANENT GAS DETECTION EQUIPMENT
SUPPLIER
Dictaphone




Gastech, Inc.1

General Moniotors



MSA1




Scott

Enmet2



MODEL
810

820

880
1220
1220
1620
180
520

160
510
510
510
510
510
Series
9000
ISA-330D

ISA-44-5

CHANNELS
1

2

8
1
2
4
1
2

10
1
2
3
4
5
1





PRICE
$ 715.00
\
990.00 j:
/
4,230.00
585.00
690.00 /
1,500.00
876. 00 x
1,280.00 ^
/
6.378.00/
955.00
1,660.00
2,365.00
3,070.00
3,775.00


795. 00 \
j>
3, 785. 00 /

COMMENTS

Without cabinet and alarms


_
> remote calibration, 2 levels
plus "trouble"

One level with cabinet
2 levels with cabinet

>2 yr. guarantee, reliable,
draft, only product






0-100% LEL

Scale on methane indicating
meter ranges from 10-60%;





less











0-20% LEL available for more
sensitive work

FOOTNOTES:

1.  Prices current as of January 1979
2.  Prices current as of August 1978

-------
           APPENDIX I




ACRONYMS  AND GLOSSARY OF  TERMS

-------

-------
                             ACRONYMS
BNA        Bure'au of National Affairs
BOD        Biochemical Oxygen Demand
CEC        Cation Exchange Capacity
CFR        Congressional Federal Register
CPE        Chlorinated polyethylene
CWA        Clean Water Act
DDT        Dichloro-diphenyl-trichloroethane
DOE        Department of Energy
DOI        Department of the Interior
EIA        Economic Impact Analysis
EIS        Environmental Impact Statement
EPA        Environmental Protection Agency
EPDM       Ethylene propylene rubber
ESA        Endangered Species Act
FAA        Federal Aviation Administration
FDA        Food and Drug Administration
FFDCA      Federal Food, Drug and Cosmetic Act
FIFRA      Federal Insecticide, Fungicide and Rodenticide Act (of 1947)
FR         Federal Register
FWPCA      Federal Water Pollution Control Act
HUD        Housing and Urban Development
MCL        Maximum Contaminant Levels
NPDES      National Pollutant Discharge Elimination System
NPDWR      National Primary Drinking Water Regulation
NTIS       National Technical Information Service
O&M        Operation and maintenance
PCB        Polychlorinated biphenols
PE         Polyethylene
POTW       Publicly Operated Treatment Works
ppb        Parts per billion
ppm        Parts per million
PVC        Polyvinyl chloride
RCRA       Resource Conservation and Recovery Act
                              1-1

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SDWA       Safe Drinking Water Act
SMSA       Standard Metropolitan Statistical Area
STP        Sewage Treatment Plant
tpd        Tons per day
TDS        Total Dissolved Solids
UICP       Underground Injection Control Program
USEPA      United States Environmental Protection Agency
USGS       United States Geological Survey
                               1-2

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                    GLOSSARY  OF  TERMS  AND  PHRASES
Agricultural Surface Impoundment  -  An  impoundment  used  in  the
    treatment  of wastes  from  feedlots  and  other  agricultural
    operations (Pef. 141).

Animal Feed  -  Any  crop grown  for  consumption  by animals,  such
    as pasture crops, forage, and grain.

Approved State Solid Waste Management Plan   -  A  plan  developed
    according   to   guidelines  promulgated  pursuant   to  Sec-
    tion 4002(b) of  the Act  and  approved  by  the Administrator
    pursuant to Section 4007 of the Act.

Aquifer   -  "A  geologic  formation,  group of   formations,  or
    portion of a formation capable of yielding usable quantities
    of around water to wells or springs."

Attenuation -  The  ability of  soil  to remove  or  transform  ions
    passing throuah the soil by a variety of physical,  chemical,
    and biological  mechanisms.

Pase Flood  - A  flood  that  has a one percent  or  greater chance
    of recurring in any year, or a flood of a magnitude egualled
    or exceeded once in 100  years, on the average, over a signi-
    ficantly long period.  In any given  100-year interval such a
    flood may not occur, or  more than one such flood may occur.

Beneficial Utilization - The  application  of solid waste to  land
    for the  purpose  of utilizing nutrients or  conditioning  the
    soil .
  The sources of definitions designated with an asterisk (*)  are
  subsections 157.2 and 257.3 of the criteria  for Classification
  of Solid Waste Disposal Facilities and Practices  (40  CFR  Part
  257)  .  The text  of the criteria is presented in Appendix A.
                               T-l

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Pird Hazard -  As  used in  reference  to a  facility,  this means:
    (1)  attracts  birds  that  feed  on  putrescible  waste,  or
    (2)  disrupts normal bird flight patterns,  or (3)  alters bird
    roosting  and  watering  sites;  thereby causing  bird  popula-
    tions to develop such that approaching or departing aircraft
    are  placed in a position where bird/aircraft collisions that
    may  cause  damage  to  the aircraft and/or injury to its occu-
    pants are likely.

Cadmium  Concentration - The total cadmium in mg/kg dry weight of
    solid waste.

                              *
Cation Exchange Capacity (CEC) - The sum of exchangeable cations
    a soil  can absorb,  exoressed  in  mi]1iequivalents  per  100
    arams  of  soil,  as  determined by  sampling  the soil  to the
    depth of  cultivation  or solid  waste placement, whichever is
    greater,  and   analyzing  by  the  summation  method for  dis-
    tinctly acid soils or the sodium acetate method for neutral,
    calcareous or  saline  soils  ("Method of Soil Analysis, Agro-
    nomy Monoaraph No. 9," C. A. Elack, ed.;  American Society of
    Aaronomy, Madison, Vlisconsin, 1965, pp. 891-901).

Contaminate   - "Contaminate"  means  introduce  a  substance  that
    would cause:
        (!) the concentration  of  that  substance  in  the ground
    water  to  exceed  the maximum  contaminant  level specified in
    Appendix I of the criteria, or
        (2) an  increase  in the  concentration  of  that substance
    in the ground water where the existing concentration of that
    substance exceeds the maximum contaminant level specified in
    Appendix I of the criteria.

Contiguous Zone   -   The   entire   zone  established   or   to  be
    established by the  United  States  under  Article 24  of  the
    Convention  of the Territorial  Sea and the  Contiguous  Zone
    (Clean Water  Act,  Public Law  92-500,  as amended  by Public
    Law  95-217) (Pef. 125) .

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Destruction or Adverse Modification   -  A  direct  or  indirect
    alteration of  critical  habitat which appreciably diminishes
    the  value  of  that  habitat  for  survival  and recovery  of a
    listed species.

Discharge of Dredged Material - Any addition of dredged material
    into  the  waters of the  United States.   The term includes,
    without  limitation,  the addition  of dredged material  to a
    specified  disposal  site  located  in  waters  of  the  United
    States, and  the  runoff  or  overflow from a contained land or
    water  disposal  area.   Discharges  of  pollutants into waters
    of  the  United  States resulting  from  the  onshore subsequent
    processing of  dredged material  that  is  extracted  for any
    commercial use  (other  than  fill)   are not  included  within
    this  term  and  are  not subject to Section 402 of the Federal
    Water Pollution Control Act,  even  though  the extraction and
    deposit of such material may require a permit from the Corps
    of  Engineers.    The  term  does not  include  plowing,  culti-
    vating, seeding, and  harvesting  for the production of food,
    fiber, and forest products (33 CFR Part 323).

Disease Vector   -  Any  organism  that is  capable  of  transmitting
    disease, including  birds,  rodents,  flies,  and tnosquitos.

Disposal    -   The    discharge,   deposit,   injection,   dumping,
    spilling,  leaking,  or  placing   of   any  solid  waste  or
    hazardous  waste  into  or on  any  land  or  water  so  that  such
    solid waste  or  hazardous waste,  or any constituent thereof,
    may enter the environment or be emitted into the air or dis-
    charged  into any waters,  including ground  waters  (Fef. 6,
    Public Law 94-580,  90  Stat. 2799, 42 U.S.C. 6903).

Dredged Material  -  Material  that  is  excavated or  dredged  from
    waters of the United  States (33 CFP Part 323).
                                1-5

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Facil i ty   - Any  land  and  appurtenances  thereto used  for the
    disposal of solid wastes.

Fill Material  - A  material  used  for  the  primary  purpose  of
    replacing  an  aquatic area with dry land  or  of changing the
    bottom  elevation  of  a  waterbody.   The term does not include
    any pollutant discharged into the water primarily to dispose
    of waste, as that activity is regulated under Section 402 of
    the Federal  Water Pollution  Control  Act  Amendments of 1972
    (33 CFR Part 323).

Floodplain   -  The  lowland  and relatively flat  areas adjoining
    inland  and  coastal  waters,   including flood-prone  areas  of
    offshore islands which are inundated by the base flood.

Food-Chain Crops  - Tobacco, crops  grown  for human consumption,
    and animal  feed for animals  whose  products  are consumed  by
    humans.

Ground Water   -  Water  below  the  land  surface  in  the  zone  of
    saturation.
Impoundment - See Surface Impoundment

Incorporate into the Soil*  -  The injection of solid waste beneath
     the surface of  the  soil  or  the  mixing of solid waste with
     surface soil,
Industrial  Surface Impoundment - An  impoundment  used  for  tempo-
    rary storage, settling,  aeration, or disposal by evaporation
    or seepage of industrial  process and non-process wastes.
                                1-6

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"Jeopardize the Continued Existence of"  - To engage  in an acti-
    vity or program which reasonably would be expected to reduce
    the reproduction, numbers, or distribution of endangered and
    threatened  species  to  such  an  extent  as  to  appreciably
    reduce  the  likelihood of  the  survival  and  recovery of that
    species in the wild.

Lower Explosive Limit (LEL)  - Niinimum  concentration  which will
    explode due to a spark or  flame.

Municipal Landfill -  A  site  for  disposal  of  solid wastes which
    is operated under municipal funding  (Pef.  141).

Municipal Surface Impoundment  -  fin  impoundment  used  in primary,
    secondary, and  advanced  municipal  wastewater  treatment  for
    temporary storage,  settling, aeration, or  disposal  by per-
    colation or evaporation (Pef. 141).

Maviaable Waters  -  The waters of the  United  States, including
    the  territorial  seas  (as defined  in  the Clean  Water Act,
    Public Law 92-500, as amended by Public Law 95-217).

Non-Point Source  - Any  origin  from which  pollutants  emanate in
    an  unconfined and  unchannelled  manner,  including  but  not
    limited to leachate seeps.

Cn-Site Industrial Landfill -  A disposal site  for solid indus-
    trial process  wastes  which  is  owned by  the waste-producing
    plant (Pef.  141).

Open Burning  - The  combustion of  solid waste  without (1) con-
    trol of combustion  air to maintain adequate temperature  for
    efficient  combustion,  (2) containment  of  the  combustion
    reaction  in an  enclosed   device to  provide  sufficient resi-
    dence time  and  mixing for  complete combustion, or (3) con-
    trol of the  emission of the combustor products.
                                1-7

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  Open Dump -  A facility  for the disposal  of  solid waste  which
      does  not  comply  with  the  Criteria   published  under  Sec-
      tion 4004 of PCPA.   Typically,  such  facilities are  disposal
      sites where discarded materials  are  deposited  with  little  or
      no  regard  for pollution  control  or  aesthetics,  where  the
      wastes are  left  uncovered,  and  where  freauently the  use  of
      the site  for waste disposal  is neither authorized  nor  super-
      vised.

  Pasture Crops  -  Crops  such as legumes, grasses,  grain  stubble
      and stover which  are consumed  by animals  while grazing.

  Periodic Application  of  Cover    -  The  application  of  soil  or
      other suitable material over  disposed solid  wastes at  such
      frequencies and  in  such a  manner  as  to  impede vectors and
      infiltration  of  precipitation;   reduce and  contain  odors,
      fires, and litter;  and enhance the  facility's  appearance and
      future utilization.

  Permeability  - The capacity of  a  medium to conduct or  transmit
      fluids .

pH* - The logarithm of  the reciprocal  of  hydrogen  ion concentra-
     tion.
  Plume -  "A body  of contaminated.  .  .water  originating from  a
      soecific source and  influenced  by such  factors as the  local
      around-water flow  pattern,  density of contaminant, and  dura-
      tion of the aauifer"  (Pef.  7,  p. 500).
                                 1-8

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Point Source  -  Any  discernible,  confined  and  discrete convey-
    ance, including but not limited to any pipe, ditch, channel,
    tunnel, conduit,  well,  discrete fissure,  container, rolling
    stock,  concentrated  animal feeding  operation,  or vessel or
    other  floating  craft,  from which  pollutants are  or  may be
    discharged.    This term does  not  include return  flows from
    irrigated agriculture  (Clean  Water  Act,  Public Law 92-500,
    as amended by Public Law 95-217).

Pollutant - Any dredged soil,  solid waste, incineration residue,
    sewaae, garbage,  sewage sludge, munitions,  chemical wastes,
    bioloaical materials,  radioactive materials,  heat, wrecked
    or discarded  equipment, rock,  sand,  cellar dirt, and  indus-
    trial,  municipal  and   agricultural   waste  discharged  into
    water  (Kef.  125,  Public  Law  92-500,  as  amended  by  Public
    Law 95-217) .

Practices - The act of disposal of solid waste.

Putrescible Wastes -  Solid  wastes  which  contain organic matter
    capable of being decomposed by microorganisms,  and of such a
    character and  proportion  as to be capable  of  attracting or
    providing food for birds .
Recharge - "The  addition  of  water to the ground-water system by
    natural or artificial processes" (Ref 7, p. 501).

Pecharge Zone - An area through which water enters an aguifer.

Root Crops   -  Plants  whose  edible  parts  are  grown  below  the
    surface  of the soil.

Runoff - "Direct  or  overland  runoff is that portion of rainfall
    which  is  not  absorbed by  soil,  evaporated  or transpired by
    slants,  but   finds  its way  into  streams  as surface  flow.
                               1-9

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    That  portion  which  is absorbed by soil and later discharged
    to surface streams is ground-water runoff" (Ref. 7, p. 501).

Sanitary  Landfill  -  A facility  for  the  disposal  of solid waste
    which meets  the  "Criteria  for Classification of Solid Waste
    Disposal  Facilities  and Practices"  (Ref. 62,  RCRA,  Public
    Law 94-580).

Sludge  - Any solid, semisolid, or liquid waste generated from a
    municipal,  commercial,  or   industrial  wastewater  treatment
    plant, water  supply treatment plant, or air pollution control
    facility, or  any  other  such waste having similar character-
    istics and effects.
Soil pH*   -  The value obtained by sampling the soil to the depth
     of  cultivation  or  solid waste placement,   whichever    is
     greater, and analyzing  by  the electrometric  method.("Methods
     of Soil  Analysis,  Agronomy Monograph No,  9,"C.A.  Black,  ed.,
     American Society  of   Agronomy,  Madison,  Wisconsin,  pp.  914-
     926,  1965).
Sole Source Aquifer - A water-bearing geologic formation that is
    the principal source of drinking water for the population of
    a  given  area.   The  contamination  of  such  a  water  source
    would create a significant  hazard to public health.

Solid Waste  - Any garbage, refuse, sludge from  a  waste  treat-
    ment  plan,  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 agricul-
    tural  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  discharqes 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  byproduct  material,  as defined  by the  Atomic
    Energy Act  of  1954,  as  amended (68  Stat.   923)  (Ref.  62,
    RCRA, Public Law 94-580).
                              1-10

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State  -  Any of  the  several  States,  the  District of Columbia,
    the Commonwealth  of Puerto Rico,  the  Virgin Islands, Guam,
    American Samoa, and the Commonwealth of the Northern Mariana
    Islands (Ref. 62, RCRA, Public Law 94-580, 90 Stat. 2801, 42
    U.S.C. 6903).

Surface Impoundment - "A natural topographic depression, artifi-
    cial  excavation,  or  dike  arrangement  having  the following
    characteristics:    (1)  it   is  used  primarily   for  storage,
    treatment,  or disposal of  wastes  in  the form  of liquids,
    semi-solids,  or  solids; (2) it  is constructed  on, below, or
    partly in the ground;  and  (3)  it is generally wider than it
    is deep.  Excluded  from this  definition are:  (1) concrete-
    lined basins  and  prefabricated  above-ground  tanks and steel
    vessels that  are used in waste treatment and industrial pro-
    cesses,  and  (2)  fresh-water  impoundments  such  as  natural
    lakes, reservoirs,  and farm ponds  that are used  for water
    supply, collection of storm-water runoff,  flood control, and
    irrigation"   (Ref. 107, p.  7).

Underground Drinking Water Source    -  (1)  An  aquifer  supplying
    drinking water  for  human  consumption,  or  (2)  an aquifer in
    which the ground  water  contains  less than 10,000 mg/1 total
    dissolved solids.

Variance - A  license  to pollute for a limited time, typically a
    year,   usually with  the agreement  that  the  polluter  will
    institute procedures to clean  up (Fef.  140,  p.  372).

Waters of the United States comprise  (1)  the  territorial  seas
    with respect  to  the  discharge  of fill material; (2) coastal
    and  inland   waters,   lakes,  rivers,  and   streams   that  are
    navigable waters  of  the  United  States,  including  adjacent
    wetlands; (3) tributaries  to navigable  waters  of the United
    States,  including adjacent  wetlands (manmade nontidal drain-
    age and  irrigation  ditches  excavated  on  dry  land  are not
                               1-11

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    considered waters  of the United  States under  this  defini-
    tion);    (4)  interstate   waters   and   their   tributaries,
    including adjacent wetlands;  and  (5)  all other waters of the
    United  States  not  identified in  paragraphs  (1)  through (4)
    above,   such  as  isolated wetlands  and lakes,  intermittent
    streams,  prairie  potholes,   and  other  waters  that  are  not
    part of  a   tributary  system  to  interstate  waters or  to
    navigable waters  of the United  States, the  degradation  or
    destruction  of  which   could  affect   interstate   commerce
    (33 CFR Part 323).

Wetlands -  Those  areas  that  are  inundated  or saturated  by
    surface or  ground  water at a frequency and  duration suffi-
    cient  to  support,   and  that  under  normal  circumstances  do
    support,  a  prevalence of  vegetation  typically  adapted  for
    life  in  saturated  soil  condition.     Wetlands  generally
    include  swamps,  marshes, bogs,  and similar  areas  (33  CFR
    323 -  Permits  for  Discharges  of Dredged  or  Fill  Material
    into Waters of  the United States,  Ref.  116).
                              1-12

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APPENDIX J






REFERENCES

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                       J.  REFERENCES*
     Strategic environmental assessment  system:   residuals fore-
     caoting.  International Research and Technology Corporation,
     February 1976.   59p.   (Distributed  by NTIS, Springfield, VA
     as PB-252041.)

     Comparing   conventionally  landfilled   solid   waste   with
     processed  landfilled  solid  waste.    Floyd  G.  Brown  and
     Associates,  Ltd.    Prepared  for  Environmental  Protection
     Agency  1973.    136p.   (Distributed  by National  Technical
     Information Service, Springfield, VA, as PB-253 304).

     Effluent  limitations guidelines  for  existing   sources  and
     standards  of performance  for  new  sources,  National  Field
     Investigation  Center,    Environmental  Protection  Agency.
     August  1974  (Distributed  by  NTIS,  Springfield,  VA.  as
     PB-257 300).

     Disposal  of  wastewater  residuals,  Environmental  Quality
     Systems, Vol. 1.  March 1976,  1031p.  (Distributed by NTIS,
     Springfield, VA. as PB-251 371-01).

     Disposal  of  wastewater  residuals,  Environmental  Quality
     Systems, Vol. 2.  March 1976.   548p.  (Distributed by NTIS,
     Springfield, VA. as PB-251 371-02).

     Resource conservation  and recovery  act of  1976;  Public Law
     94-580,  94th  Congress  5.2150,  Oct. 21, 1976.   Washington,
     U.S. Government Printing Office, 1976.  44p.

     Office of  Solid Waste Management Programs.   The  report to
     Congress;  waste  disposal practices  and  their  effects  on
     ground  water.     U.S.   Environmental   Protection  Agency.
     Washington, D.C., January  1977.   512p.  (Distributed by NTIS
     as PB-265 081) .

     Coe, Jack J.  Effect of solid waste  disposal on ground water
     quality.     Journal,  American  Water  Works   Association
     776-782p. Dec. 1970.

     Proceedings; Kentucky  Coal  Refuse  Disposal  and  Utilization
     Seminar  (1st)  Held  at  Cumberland,   Kentucky, May  22,  1975.
     47p.
 References cited in the text by number correspond to numbered refer-
ences in this list.   Appendix XII(Volume II) presents a bibliography
organized according  to subject matter.
                               J-l

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10.   Shuster,   Kenneth   A.      Leachate   damage:     a   national
     assessment.       U.S.    Environmental   Protection    Agency,
     Washington,  D.C.  September 1976 (Unpublished  Report).

11.   Procedures manual for  monitoring solid waste  disposal  sites.
     (Office  of   Solid  Waste   Management  Programs),   Wehran
     Engineering   Corporation  and  Geraghty &  Miller,  Inc.  U.S.
     Environmental Protection Agency, 1976.  287p.

12.   Garland,  George  A.  &  Dale  C.  Mosher.   Leachate effects  of
     improper   land  disposal.    Waste Age,  March  1975,  pgs  42,
     44-48.

13.   Feldsman,  Jim.   Ground  water pollution standards  chapter.
     March 21,  1977.   30p.

14.   Geswein,   Allen   J.    Liners  for  land  disposal  sites;  an
     assessment.     EPA  publication  SW-137.     U.S.  Government
     Printing  Office  1975.   66p.

15.   Shuster,  Kenneth A.   Leachate  damage assessment; Case study
     of  the  Fox  Valley solid  waste  disposal  site  in  Aurora,
     Illinois.     Environmental   Protection   Agency   publication
     SW-514.  U.S. Government Printing Office, 1976.   34p.

16.   Shuster,   Kenneth  A.     Environmental  impact  of  leachate.
     Outline of  presentation;  gas  and  leachate  generation  and
     control  in   landfills.    Presented   at  Madison, Wisconsin,
     March 29-31,  1976.   14p.

17.   Office  of Solid Waste  Management  Programs.    Decision
     Makers   guide  in  solid  waste  management.    Environmental
     Protection Publication SW-500.  Washington,  U.S. Government
     Printing  Office,  1976.   158p.

18.   Proceedings;   Conference  on   Geotechnical   Practice   for
     Disposal  of  Solid  Waste Materials,  University  of  Michigan,
     Ann Arbor, Michigan,  June-13 15,  1977,  American Society  of
     Civil Engineers,  1977.   885p.

19.   Proceedings;  Fourth  National  Congress  on  Waste Management
     Technology  and  Resource   &   Energy  Recovery.     Atlanta,
     Georgia,    November 12-14,   1975.       U.S.    Environmental
     Protection  Agency,  Washington,  U.S.  Government   Printing
     Office, 1976.  382p.

20.   Soil Conservation   Society of  America,  Land  application  of
     waste materials.   Ankeny, Iowa, 1976.  313p.

21.   Land  Application   of   Residual  Material;  Proceedings
     Selected  Papers; Engineering  Foundation  Conference,  Easton,
     Maryland,  September 25 -  October 1,  1976.   American Society
     of Civil  Engineers.  183p.
                               .1-2

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22.  Smith, F.A.  Quantity and Composition of post-consumer solid
     waste:  material  flow  estimate  for 1973 and baseline future
     projections.  Waste Age, 2-10,  April 1976.

23.  Boyd,  G.B.  and  M.B. Hawkins.   Methods of  predicting  solid
     waste  characteristics.   Environmental Protection Publication
     SW-23C Washington,  U.S. Government  Printing Office,  1971,
     28p.

24.  American  Chemical Society.   Solid  wastes.  An Environmental
     Science and Technology  reprint  book. 87p.  CA., 1971.

25.  National   Environmental Research  Center.    Municipal  solid
     waste   generated   gas  and   leachate.      United   States
     Environmental Protection  Agency,   Cincinnati,  Ohio.    1974.
     119p.

26.  Environmental Protection Agency.   Water Programs.   National
     interim  primary   drinking   water  regulations.     Federal
     Register,  Vol. 40, No.  248,  December 24, 1975, 2p.

27.  Sommers,   L.E.   Chemical composition  of  sewage  sludges  and
     analysis    of   their   potential    use   as    fertilizers.
     J. Environ. Qual. 6(2):  225-231.   1977.

28.  Jelinck,  C.F. and  G.L.  Brande.   Management of sludge use on
     land,  F.D.A. Considerations.  35-37.

29.  Municipal  Sludge:  what shall we do with it?  Current Focus.
     League of  Women  Voters  of the United States.  5p.

30.  U.S.  Environmental  Protection  Agency.    Office  of  Solid
     Waste.  Proposed  criteria for  classification  of solid waste
     disposal  facilities.   (40  CFR  Part 257).   Docket  No.  4004.
     43 Fed.  Reg. 4942-4955, February 6, 1978.

31.  Jones,  R.L.,  T.D.  Hinesly, R.J.  Johnson.    Selenium  in
     agricultural ecosystems; a  bibliography  of  the  literature.
     The  Metropolitan  Sanitary   District  of  Greater   Chicago,
     August,  1973.  79p.

32.  Landspreading of  municipal sludges   (Draft),  USEPA,  1977
     (unpublished report).

33.  The  Water  Pollution  Control   Act of  1972:    Enforcement
     Vol. 1,  October,  1975.    479p.     (Distributed  by  NTIS,
     Springfield, Va. as PB-246  321).

34.  Chian, E.S.K.,  &  F.B.  Dewalle.   Compilation  of  methodology
     for measuring  pollution  parameters  of  landfill  leachate.
     U.S. Environmental Protection Agency.   October,  1975.  164p.
                               ,1-3

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35.   Office  of  Water   Supply.    U.S.  Environmental  Protection
     Agency.      Draft   Environmental  Impact   Statement;   State
     underground    injection    control   program.       Proposed
     regulations.  40 CFR,  Part 146.   Washington,  U.S.  Government
     Printing Office, 1976.   207p.

36.   Brunner, D.R. and  D.j.  Keller.  Sanitary landfill  design and
     operation.    Environmental  Protection  Agency  Publication
     SW-65ts. Washington, U.S.  Government Printing  Office,  1972.
     59p.

37.   Subsurface  application  solves   community  sludge  disposal
     problems.  Public Works 67-68.   December 1976.

39.   Issue Paper:    Proposed  regulations  for  classification  of
     solid waste disposal facilities,  40 CFR,  Part  257,  July 20,
     1977, lip.

40.   Protection of Wetlands, Executive Order 11990,  May 24,  1977.

41.   Floodplain   Management,    Executive   Order 11988,   Federal
     Register, Vol. 42,  No.  101.  May 25,  1977, 7p.

42.   Background  document.  Land criteria.    (Unpublished  Draft).
     June  24, 1977, 121pp.   Docket 4004.

43.   Environmental Protection  Agency.   Environmental  impacts  of
     land   disposal.   (Unpublished  Draft).   26pp.   Docket  4004.
     1977.

44.   Sanitary landfill criteria, Issue No.  3, 15p.  EPA, 1977.

45.   Gray, Donald H.,  Environmental  concerns related to disposal
     fills.   Department of Civil Engineering,  the  University of
     Michigan.  January 1976.  20p.

46.   Pohland,  F.G.  and R.S.   Engelbrecht,  Impact  of  Sanitary
     Landfills:  An Overview of Environmental Factors and Control
     Alternatives.    Prepared  for   American   paper  Institute.
     February 1976.  82p.

47.   RCRA   land  disposal criteria:    coverage of surface  impound-
     ments, July 15, 1977,  7p.

48.   Personal   Communications.  Joseph  Hile,   Acting   Associate
     Commissioner for Compliance,  Food and  Drug Administration to
     Dr.  Andrew W.  Breadenbach,  U.S.  Environmental  Protection
     Agency,  September 22,  1976.

49.   Anderson,  R.  Kent.  Case  studies of  the cost of landspread-
     ing  and  hauling sludge from municipal  wastewater treatment
     plants (unpublished document)  U.S.E.P.A.
                               J-4

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50.   Emcon  Associates,   Evaluation   of  clay   liner   materials
     following in-field exposure to  landfill  leachate.   Prepared
     for USEPA, July 1977.

51.   Shuster,   K.A.   Leachate damage  assessment:   Case  study  of
     the  Peoples  Avenue  solid  waste  disposal site  in  Rockford,
     Illinois, Report EPA/530/SW-517,  USEPA,  1976.

52.   Stewart,   W.S.   State-of-the-art study of  landfill  impound-
     ment techniques.  Prepared by  Exxon Research and Engineering
     Co.,  Linden,  N.J.,   for  USEPA,  Office  of  Research  and
     Development,  Cincinnati.  Project R-803585.

53.   USEPA,   Industrial   waste  management:     seven  conference
     papers.   EPA/530/SW-156, January 1975,  lllp.

54.   American   Society  of  Civil   Engineers,   Sanitary  landfill
     manuals   and   reports  of  engineering  practice  -  No.  39.
     Revised  1976.

55.   World  Health  Organization.    Evaluation  of  certain  food
     additives and  the  contaminants mercury, lead,  and  cadmium.
     Sixteenth Report  of  the  Joint  FAO/WHO Expert  Committee  on
     Food Additives.  FAO  and WHO,  Geneva, 1972.   32p.

56.   The City  of  Scottsdale,  Arizona.   A handbook for  initiating
     or  improving  commercial  refuse  collection.   Environmental
     Protection Agency  Publication.    SW-85d,  Washington,  U.S.
     Government Printing Office, August 1975,  68p.

57.   Herman,   E.B.   WRAP.    A model  for regional  solid  waste
     management   planning.      User's   Guide.      Environmental
     Protection Agency  Publication.    SW-574.   Washington,  U.S.
     Government Printing Office, 1977.  124p.

58.   Environmental  Protection  Agency  - Solid waste  planning and
     disposal    advance notice  of  proposed  rulemaking.   Federal
     Register, Vol. 42,   No.  128.   Washington,   U.S.  Government
     Printing  Office, 1977.   124p.

59.   Environmental Protection Agency.   Materials recovery.   Solid
     waste management guidelines for  source  separation.   Federal
     Register, Vol. 41,   No.  80.    Washington,   U.S.  Government
     Printing  Office, April  23, 1976.   8p.

60.   Environmental   Protection  Agency.      Resource   recovery
     facilities.      Guidelines.     Federal   Register,   Vol. 41,
     No. 184.    Washington,  U.S.   Government  Printing   Office,
     September 21, 1976.   4p.

61.   Environmental Protection Agency.   Polychlorinated  biphenyl -
     containing wastes.     Federal  Register,  Vol.  41,   No. 64.
     Washington,  U.S. Government Printing Office, April  1,  1976.
     3p.
                                J-5

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62.   Environmental  Protection Agency.   Resource  Conservation  and
     Recovery Act  of 1976.   Federal Register,  Vol.  42,  No.  23.
     Washington,  U.S.  Government  Printing Office,  February  17,
     1977.   Ip.

63.   Environmental  Protection Agency.   Identification  of  regions
     and   agencies   for   solid  waste   management.      Interim
     Guidelines.   Federal  Register,  Vol. 42,  No.  94.   Washington,
     U.S.  Government Printing Office, May 16,  1977.   5p.

64.   Environmental    Protection   Agency.      Vinyl    chloride.
     Recommended  procedure for disposal  of aerosol  cans.   Federal
     Register,  Vol.  41,  No. 112.    Washington,  U.S.  Government
     Printing Office, June 9, 1976.   2p.

65.   Terry, Jr.  R.C.  and  J.B. Berkowitz, A.D. Little,  Inc. C.H.
     Porter.   Waste  clearing  houses  and  exchanges.   Chemical
     Engineering  Progress, 58-62.  December 1976.

66.   Ghassemi,  M.,   S.C.  Quinlivon and  H.R.  Day.  Landfills  for
     pesticide   waste  disposal.     Environmental  Science   and
     Technology,  10.  1209-1214.  December 1976.

67.   Anderson,  K.  and  M.  Cowart.   Don't walk away from  an open
     dump.   The American  City and County.  February 1976.   2p.

68.   Hatte,  S.J. Anaerobic digestion of solid waste  and  sewage
     sludge  into methane.   Compost Science  ^_ Journal of  Waste
     Recycling,  17(1):   January - February 1976.   5p.

69.   Environmental   Protection  Agency.    Winter  sewage  treatment
     plant performance study report.  1977.

70.   Emcon  Associates  -   City  and  County  of Honolulu.   Liners.
     July,  1977.   5p.

71.   Geswein, Allen J.   Liners for disposal sites,  an assessment.
     Environmental    Protection   Agency   Publication   SW-137.
     Washington,  U.S. Government Printing Office, 1975.  66p.

72.   Wolcott, R.M.   and  B.W. Vincent.   The  relationship  of  solid
     waste  storage  practices in the inner city  to  the incidence
     of  rat infestation  and  fires.    Environmental  Protection
     Agency  Publication   SW-150.    Washington,  U.S.   Government
     Printing Office, May 1975.  14p.

73.   Smith,  F.A.     Comparative  estimates  of  post-consumer  solid
     waste.  Environmental  Protection Agency  Publication  SW-148.
     Washington,  U.S. Government Printing Office, May 1975.   8p.

74.   Smith,  F.L.,   Jr.    A  solid  waste  estimation  procedure:
     material  flows  approach.   Environmental Protection  Agency
     Publication SW-147.    Washington,  U.S.  Government  Printing
     Office, May 1975.   55p.
                               J-6

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75.   Stanton,  W.S.  and   J.G.  Langerton.    Pesticide  container
     processing    in   commercial    reconditioning    facilities.
     Environmental   Protection    Agency    Publication    SW-88d.
     Washington, U.S. Government Printing  Office,  November  1976.
     20p.

76.   Waste Age survey of  the nation's disposal  sites.   Waste Age.
     21-28.  January 1977.

77.   Cost of solid waste  management  facilities.   Board  of County
     Commissioners.  Johnson County,  Kansas, March 1975.

78.   Inglehart, Cecil.  How  do  you measure the costs  of landfill
     design and operation?  (unpublished report).

79.   U.S.  House  of Representatives.   Report of  the Committee  on
     Interstate  and   Foreign Commerce  on  H.R.  14496,  Resource
     Conservation and Recovery Act of  1976.  Report No. 94-1491,
     94th Congress, Second Session, September 9,  1976.  136pp.

80.   FAA   "Bird   Hazards   to  Aircraft"   Advisory  Circular   AC
     150/5200-3A, 1972.

81.   FAA Advisory  Circular. Use  of  chemical  controls  to  repel
     flocks of birds at  airports (AC  150/5200-8,  May 2,  1968).

82.   FAA Advisory  Circular, Bird  reactions to  scaring  devices.
     {AC 150/5200-9,  June  26,1968).

83.   FAA Advisory  Circular, Announcing  the availability of  the
     international civil  aviation organization  airport  services
     manual, DOC-9137-AN/898, Part 3, Bird control and reduction.
     (AC 150/5200-22).

84.   FAA Order 5200.5 FAA  guidance concerning sanitary landfills.
     October 16, 1974.

85.   EPA  Noise  emissions  standards  for  (new)  transportation
     equipment:    medium   and   heavy  trucks.   (40 CFR  Part 205)
     Federal Register,  V.  41, N72,  April 13, 1976.  p.15538-58.

86.   EPA Noise regulations for  new wheel and crawler tractors  and
     other heavy equipment.

87.   U.S.  Water  Resources Council.   A Unified  National  Program
     for Floodplain Management.   Washington, D.C., July  1976.

88.   James, Stephen C.,  Metals  in Municipal Landfill Leachate  and
     Their  Health  Effects.   Am. J.  of Public Health 67,  5,  May
     1977,  429-432.
                               J-7

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89.  Environmental  Protection   Agency,  Bird/airport  hazards  at
     airports near solid waste  disposal  sites,  SW-116,  1974.

90.  Environmental   Protection    Agency    Technical    Bulletin:
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91.  Geraghty  &  Miller, Inc.   Development  of  a  data base  for
     determining  the   prevalence   of  migration   of   hazardous
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92.  Council  on  Environmental  Quality.   Environmental  Quality
     1976,   Seventh   Annual  Report, Washington,  .D.C.,  September
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93.  Cogswell,  Howard  L.   Proceedings  on the  Conference  on  the
     Biological Aspects of  the Bird/Aircraft  Collision Program,
     Clemson University, South  Carolina, February 1974.

94.  Hinesly, Thomas D.  Agricultural benefits and  environmental
     changes  resulting  from  the use of digested sludge on field
     crops.   Metropolitan  Sanitary District of  Greater Chicago,
     prepared  for Environmental  Protection Agency, 1974.   375p,.
     (Distributed by NTIS,  Springfield,  VA. as  PB-236  402).

95.  Recycling  sludge  and   sewage effluent  by  land  disposal;
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96.  Walker,  John,  Sewage  sludges - management  aspects for  land
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97.  Bjornson,  B.F.,  Pratt,  H.D.  and  Littig,  K.S.   Control  of
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98.  Ham.  Robert  K.    Vectors.     Conference  of  Engineering
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99.  Manson,  Robert  and Merritt,   Clifford.  Land  application of
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100. Singh, R.N., Reefer,  R.F., and  Hovath,  D.J.,  Can  soils be
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     March-April 1975.
                               J-8

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101. U.S.  Senate   Report   No. 94-988,  94th   Congress,   Second
     Session, 1976.

102. LA/OMA  Project,  Sludge  management activities  for  the  Los
     Angeles/Orange  County  metropolitan  area,  Whittier,  CA.,
     May 1977.

103. The  Metropolitan  Sanitary  District  of  Greater  Chicago,
     Working  Draft—proposed   regulations  for  classification  of
     solid waste disposal facilities.  July 12, 1977.

104, SCS  Engineers.   Municipal  sludge  agricultural  utilization
     practices—an environmental assessment.  Volume I.  Prepared
     for Office of Solid Waste, USEPA.  1977.  151p.

105. Impact  assessment  of annual   cadmium  limitations  on  the
     agricultural utilization  of municipal sludge. (Draft)

106. Municipal  sludge  management:     EPa   construction   grants
     program.   An overview of the  sludge  management  situation.
     U.S.  Environmental   Protection   Agency,   Office   of  Water
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107. Geraghty  & Miller,  Inc.   Surface  impoundments  and  their
     effects  on  ground-water quality  in  the United  States—A
     preliminary  survey.    Prepared  for the  Office of  Drinking
     Water, U.S. Environmental  Protection Agency.   EPA 570/9-78-
     004.  June 1978.   275p.

108. U.S.  Environmental  Protection  Agency.    Office of Research
     and   Development.      Environmental  Protection  Technology
     Series.  Movement of  selected  metals,  asbestos, and  cyanide
     in  soil:    applications   to  waste  disposal  problems.   EPA
     600/2-77-020.  Cincinnati, Ohio.  April 1977.  242p.

109. U.S.  Water  Resources Council.    A Uniform Technique  for
     Determining   Flood    Flow   Frequencies,   Bulletin   No.  15.
     Washington, D.C., December, 1976.

110. The  carcinogen   assessment  group's assessment  of  cadmium.
     1977 26p. (unpublished report)

111. Dotson, G.  Kenneth,  e t.   al.   An appraisal  of  the relative
     health risks  associated  with land  application  of municipal
     sludge.    50th   Annual   Conference  of   the Water  Pollution
     Control  Federation,   Philadelphia,  PA,   October  2-6,  1977.
     22p.

112. Bruade,  G.L. and Jelinck,  C.F.   Management of sludge use on
     land,  FDA  considerations.   Food  and   Drug  Administration,
     Washington, D.C.
                               J-9

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113. Troast,  Richard,  et.  al.,  Cadmium.   (Position  Document  1).
     Office  of  Special  Pesticide  Reviews.  U.S.  Environmental
     Protection Agency.

114. Otte,  A.D.  and  K.Z.  LaConde,  Environmental assessment  of
     municipal  sludge  utilization at  nine  locations  in the U.S.,
     Ninth  Annual   Food,  Fertilizer  and  Agricultural  Residues
     Conference.   Syracuse,  New  York.   April 27,  1977.

115. U.S.   Environmental   Protection  Agency.    Office  of  Water
     Program    Operations.     Municipal  Construction   Division.
     Municipal    sludge  management:     environmental   factors.
     EPA 430/9-77-004.  Washington D.C.   October   1977.  31p.

116. Department  of  Defense,  Department  of  the  Army,  Engineer
     Corps. Regulatory program  of  the  Corps  of  Engineers.   (42
     Fed.  Reg.  37122-37164,  July,  19,  1977).

117. Emcon  Associates.   Methane  gas  hazard.   In-house  report.
     1977  6p.

118. Riggs, James  L.   Economic  decision models for engineers  and
     managers.   New York:   McGraw Hill,  Inc. 1968.

119. U.S.  Department of Commerce, Bureau  of the  Census.  General-
     Summary,   1972  Census  of  Manufacturers,  Washington:  U.S.
     Government Printing  Office, 1975.

120. U.S.   Environmental  Protection  Agency,  Office of  Water  anc3
     Hazardous  Materials,  RCRA  solid  waste  disposal  criteria,
     (unpublished memorandum from Thomas C.  Jorling  to Assistant
     Administrators).  December  1977.

121. Federal   Insecticide,   Fungicide,  and  Rodenticide  Act   as
     amended.   Public Law 94-140.

122. The Bureau  of National  Affairs,  Inc.  Environment Reporter:
     State  Solid  Waste -  Land  Use  (Washington:   The  Bureau  of
     National Affairs,  Inc.  1976).

123. U.S.  Bureau of  the  Census.   1970  Census of  the Population:
     Number  of  Inhabitants,  Vol.  I.    United  States  Summary,
     Table  II,  Area,  1970,  and  population  per square  mile,  1920
     to 1970  (Washington:   Government  Printing Office,  1972).

124. Gordian  Associates,  Inc.  (draft)  An  economic  analysis  of
     municipal   waste  water   sludge    treatment   and   disposal.
     Washington:   Gordian Associates,  Inc., July 1977.

125. Clean  Water Act.   Public  Law  92-500, as amended by Public
     Law 95-217.
                              J -10

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126. Federal Food, Drug, and Cosmetic Act.  Public Law 95-217.

127. Anderson,  R. Kent. Case studies on the cost of landspreading
     and  hauling  sludge  from  municipal  wastewater  treatment
     plants (unpublished document)  USEPA.

 128.  Endangered  Species Act.   Public  Law  93-205.

 129.  Critical  habitat.   50  CFR Part  17, Subpart  F.

 130.  Safe  Drinking Water Act.   Public  Law 93-523.

 131.  Proposed  procedures  for  sole-source  aquifer designations.
      42  Fed. Reg.  51620.

 132.  Clean Air Act.   Public Law 93-319.

 133.  Shuster,  Kenneth  A.     Leachate damage   assessment:     an
      approach.   (Unpublished  Draft).   December,  1975.

 134.  Shuster,  Kenneth A.   Leachate damage  assessment;  case  study
      of  the Islip  (Long  Island)  New York solid waste  disposal
      site.    Environmental  Protection Agency.    U.S.  Government
      Printing  Office,  1976.

 135.  Brunner,  D.R.,   S.J.  Hubbard  D.J. Keller,  and J.L.  Newton.
      Closing   open  dumps.     Environmental  Protection  Agency
      Publication SW-61ts.  Washington,  U.S. Government  Printing
      Office, 1971, 19p.

 136.  office of Solid  Waste  Management  Programs.   Second Report  to
      Congress;    resource   recovery   and   source    reduction.
      Environmental  Protection  Publication  SW-122.   Washington,
      U.S.  Government  Printing  Office,  1974.   112p.

 137.  Office of Solid  Waste Management Programs.   Third Report  to
      Congress;    resource    recovery    and   waste    reduction.
      Environmental    Protection   Agency    Publication   SW-161.
      Washington,  U.S.  Government Printing Office,  1975.

 138.  Thermal   processing  and  land   disposal  of  solid waste;
      guidelines.   40  CFR Part 241.    39  Federal Register 29327-
      29338, August 14,  1974.

 139.  Perkins,  Henry   C.    Air  pollution.    New  York,  McGraw  Hill
      Book  Company, 1974,  407p.
                               J -11

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141. Fred C.  Hart Associates,  Inc.  Overview of Landfilling Tech-
     nology (Draft).   Prepared for Office  of Solid Waste,  U.S.
     EPA,  September 11,  1978.

142. Transcript^ public  hearing  on  the proposed  classification
     criteria  for  solid  waste  disposal  facilities,    San  Diego,
     California, March  1,  1978.   U.S.  Environmental  Protection
     Agency publication SW-34p.

143. Transcript; public  hearing  on  the proposed  classification
     criteria   for   solid  waste   disposal  facilities,   Portland,
     Oregon,   April  26,   1978.    U.S.  Environmental  Protection
     Agency publication SW-40p.

144. Transcript; public  hearing  on  the proposed  classification
     criteria  for  solid  waste  disposal facilities, Washington,
     D.C., April 21, 1978.  U.S.  Environmental Protection Agency
     publication SW-38p.

145. Transcript; public  hearing  on  the proposed  classification
     criteria  for  solid  waste  disposal  facilities,  Kansas City,
     Missouri,  April 24,  1978.   U.S.  Environmental  Protection
     Agency publication SW-39p.

146. U.S. Environmental Protection Agency,  Office of  Solid Waste.
     Criteria  for  classification  of solid  waste  disposal  facil-
     ities [40 CFR Part 257].   December 1978.

147. Safe Drinking Water  Act.   Public  Law 93-523.

148. Geraghty, J. J.,  et  al.   Water atlas  of  the  United States.
     Port Washington, New York, Water  Information Center, 1973.

149. U.S. Bureau of the  Census.  1970  census  of  the population.
     Numbers  of  inhabitants,   Volume  I  United  States  summary.
     Washington, D.C.,  U.S.  Government Printing Office, 1970.

150. U.S. Bureau of the  Census.   1972 census  of  manufacturers,
     Volume I.    Washington,   D.C.,   U.S.   Government  Printing
     Office,  1972.

151. Schaeffer and  Roland,  Inc.  Evaluation of  the  economics of
     the  social  and environmental effects  of  floodplain regula-
     tion.   Washington,   D.C.,  Federal  Insurance  Administration
     (unpublished study).

152. The National Energy Act.

153. U.S. Environmental Protection Agency,  Office of  Solid Waste.
     Proposed   guidelines  for   the  landfill   disposal  of  solid
     waste.  Washington,  D.C.,  August  7, 1978.
                              J -12

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154. Waste Age,  January  1978.   Survey  of the  nation's  disposal
     sites .

155. Braude,   G.   L.,  et  al.   /flA's  overview  of  the  potential
     hazards   associated  with   the  land  application  of  municipal
     wastewater sludges.   Proceedings of the  Second National Con-
     ference  of Municipal Sludge Management Information Transfer,
     Inc., Rockville,  Maryland, 1975.  pp. 214-217.

156. Shaw, S.  P.,  and  C. G.   Fredine.    Wetlands  of the  United
     States.     U.S.   Fish  and  Wildlife   Service   Circular  39.
     Washington,  U.S.  Government Printing  Office,  1956.

157. Flood  Insurance   Program  Data  Base,  Washington,   Federal
     Insurance Administration, May 1978  (unpublished).

158. Airport  and  Airways  Development Act of 1970.   Public Law 91-
     258.

159. Airport   and  Airways Development  Act  Amendments  of  1976.
     Public  Law 94-353.

160. Iwata,  Y., et al .   Uptake of PCB (Aroclor 1254)  from soil by
     carrots  under field  conditions.   Bulletin of Environmental
     Contamination and  Toxicity, Volume  2, 1974.  p.  523.

161. Suzuki,   et   al.    Translocation of  polychlorobiphenols  in
     soils into plants:   a  study of a method of culture  of soy-
     bean  sprouts.   Archives  of Environmental Contamination  ad
     Toxicity, Volume  2,  1977.  p.  343.

162. Healy,  W. D.  Ingestion  of soil by dairy cows.   New England
     Journal  of Agricultural Research,  2:  287-499,  1968.

163. Chaney,  R. L.  Unpublished data, 1977.

164. Bicknell, S.  R.    Salmonella  aberdeen  infection in  cattle
     associated with human sewage.   Journal  of Hygiene,  70: 121,
     1972.

165. Love, G. L.    Potential health  impacts of sludge disposal on
     the  land.    Proceedings;  National Conference  on  Municipal
     Sludge  Management  and Disposal, 1975.

166. Jepsen,  A. and H.  Roth.   Epizootiology of Cysticercus boviS:
     resistance of the  eggs of  Tacnia  saginata.   Report  of the
     14th   International   Veterinary  Congress,  Volume 2,   1952,
     p.  43.

167. Kjellstrom,  T.  Calculations on exposure limits  for  the pre-
     vention  of cadmium-induced  health  effects.   Paper presented
     at  the  First  International Cadmium  Conferences,  San  Fran-
     cisco,  February  1977.
                              J-13

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168. DuPont,  H.  L.,  and  Hornick,  R.  B.    Clinical  approach  to
     infectious diarrhea.  Medicine, Volume 52,  1973.

169. Sepp,  E.   The use  of  sewage  for  irrigation:   a literature
     review.   Bureau of  Sanitary  Engineering,  California  State
     Department of Health, 1963.

170. Kreuz, A.   Hygienic evaluation of agricultural utilization
     of sewage.  Gesundheitsing 76:206-211, 1955.

171. Kroger, E.   Detection  of  S.  bareilly in sewages, sludge and
     vegetables  from  an  irrigation   field  after  an  epidemic.
     Z. Hyg. Infektkr,  139:202-207, 1954.

172. Kienholz, E., Ward,  G. M.,  and Johnson, D.  E.,  Health con-
     siderations relating to ingestion  of sludge by farm animals.
     In  Sludge Management  and Utilization,  Proceedings of  the
     Third National Conference on Sludge Management, Disposal and
     Utilization, 1976.

173. Akin,  E.,  W. Jakubowski,  J.  Lucas  and H. Pahren.   Health
     hazards  associated   with  wastewater  effluents  and  sludge:
     microbiological   considerations,   in   Risk  assessment  and
     health effect  of  land  application of  municipal wastewater
     and  sludges.   Center  for Applied Research  and Technology,
     University of Texas, San Antonio,  Texas, 1977.

174. Alexander,  M.    Introduction  to  soil  microbiology,  2nd
     edition.   John Wiley s Sons,  New York, 1977.

175. Moore, B.,  B. Sagik and  C.  Sorber.   Land  application  of
     sludges:      minimizing   the   impact   of  viruses  on  other
     resources,  in Risk  assessment and   health  effect  of  land
     application of municipalkidstewater and  sludges.  Center for
     Applied  Research  and  Technology,  University  of  Texas,  San
     Antonio,  Texas,  1977.

176. Strauch,   D.   Health hazard  of agricultural,  industrial and
     municipal wastes applied to land,  in Land as a waste manage-
     ment  alternative,   by  Raymond C.   Loehr,  Editor,  Ann  Arbor
     Science Publishers,   Inc., 1977.

177. Jackson,   G.,  J.  Bier,  and  R. Rude.    Recycling  of refuse
•''   into  the  food chain:  the parasite problem, in Risk assess-
     ment  and health  effect  of   land  application  of  municipal
     wastewater  and  sludges,   Center  for  Applied  Research  and
     Technology, University of Texas,  San Antonio, Texas, 1977.

178. Transcript;  public   hearing  on the  proposed  classification
     criteria  for solid  waste disposal  facilities,  Cincinnati,
     Ohio,  June  5,  1978.   U.S.  Environmental  Protection Agency
     Publication SW-42p.
                             J-14

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179      Council  for Agricultural  Science  and Technology,  (Report  t64);
         Application of  sewage sludge  to cropland:   Appraisal of  potential
         hazards  of  heavy  metals  to  plants  and  animals,   prepared  at  the
         request of U.S.  EPA,  Office of Water Programs,  November 15,  1976.

180,      U.S.  Environmental Protection Agency, Sludge treatment and disposal—
         Volume 2 (sludge disposal), ERIC Technology Transfer, October 1978.

181      Page,  A.L., Fate and  effects of  trace  elements  in  sewage  sludge when
         applied to agricultureal lands:   A  literature  review study,  prepared
         for U.S. EPA Office of Research and  Development, January 1974.

182-      Baker, D.E,, et. al.,  Monitoring sewage sludges, soils, and  crops for
         zinc  and cadmium.  In:  Land as a waste management alternative.   R.C.
         Lock  (ed.), Ann Arbor  Science, pp. 261-282, 1977.

183.      Pahren,  H.R.,  et. al.,  An appraisal  of  the  relative health  risks
         associated with  land  application of municipal  sludge, presented  at
         the 50th Annual Conference  of  the Water Pollution Control  Federation,
         1977.

184.      Waldbott,  G.K.,  Health  effects  of environmental   pollutants,  C.V.
         Mosby  Company,  St. Louis, 1973.

185.      Engineering News Record,  Sludge-fed  beef  meat  safe; grazing  land
         deposit seen,  p. 16,  March  1,  1979.

186.      Healy, W.D., Ingestion of  soil  by dairy cows,  New Zealand journal  of
         agricultural research, 11:   pp. 287-499.  1968,

187.      Braude, G.L.,  et. al, FDA's overview of the  potential health hazards
         associated  with  land  application of  municipal  sludges,  Proc.  Nat.
         Conf.  on Municipal Sludge Management and Disposal, 1975.

188-      Fitzgerald, P.R.,  Toxicology  of  heavy  metals  in sludges applied  to
         the land.  Proc. Nat.  Conf. on acceptable sludge disposal  techniques:
         Cost,  benefit,  risk,  health, and public acceptance,  1978.

189.      Bates,  T.E., et. al,, Uptake  of metals  from  sludge  amended soils.
         Proceedings Int. Conf. on heavy metals  in the environment, 1977.

190,      Hinesly,   T.D.,  et.   al .  ,  Effects  of   annual  and  accumulative
         applications or  sewage sludge  on assimilation  of zinc and cadmium by
         corn.   Environmental Science and Technology, ll:pp.  182, 1977.

191.      Chaney, R.L. and Hornick,  S.B.,  Accumulation  and  effects of cadmium
         on crops.   Presented  at  the First  International Cadmium  Conference,
         1977.

192.      Chaney,  R.L.,   et.  al. ,   Plant  accumulation  of  heavy  metals  and
         phototoxicity resulting  from  utilization  of  sewage sludge and sludge
         composts on cropland.   Proceedings   Nat. Conf.  on  Municipal   Residues
         and Sludges, 1977.

193      Jelinek, C.F.,  and  G.L.  Braude,  Management of  sludge use  on  land:
                                  J-15

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         FDA considerations,  Proc.  Third  Nat'l.  Conf. on  Sludge Management,
         Disposal, and Utilization,  1976.

194.      U.S. EPA,  Background  document,  land  criteria  (Unpublished Draft),
         June 24, 1977, pp. 44-51, Docket 4004.

195,      Sources of metals  in  municipal  sludge and industrial pretreatment as
         a  control  option.   May,  1977  by  the  U.S.  EPA ORD  task  force on
         Assessment of  Sources  of  Metals  in  Sludges  and  Pretreatment  as  a
         Control Option; p. 9.

196i      This fact  was generally expressed  during  interviews  with  personnel
         within EPA's Effluent Guidelines Division.

197,      D. Ballantine, L. Miller, D. Bishop and F. Rohrman.  The practicality
         of using atomic radiation for wastewater treatment, JWPCF 41(3),  445,
         1969.

198.      C.  Touhi.ll,  E.  Martin, M.  Fugihara, D.  Olesen,  J.  Stein,  and G.
         McDonnell.  The effects of radiation on Chicago metropolitan sanitary
         district  municipal  and industrial  wastewaters,  JVvPCF  41(2),   F44,
         1969.

199.     H.  Lowe,  W.  Lacy, B.  SurKiewicy,  and  R.  Jaeger.    Destruction of
         microorganisms  in  water,   sewage,  and   sewage  sludge  by  ionizing
         radiations, JAWWA, November, 1956.

200,      Anon.   Thermoradiation treats  sewage  sludge,  Public works, January,
         1977.

201.      Jackson, G., J. Bier,  and R. Rude.  Recycling  of refuse  into the  food
         chain:  The parasite  problem, in  risk assessment and health effect of
         land application municipal wastewater and  sludges, center  for  applied
         research  and   technology,  University of  Texas,  San  Antonio, Texas,
         1977.

 202.      Data From Site in Plumstead Township, Bucfcs County,  Pennsylvania,
          EPA Docket 4004.

 203.      The Muncie Star,  Muncie,Indiana,  December 15, 1977.
                                  J-16

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APPENDIX  K






BIBLIOGRAPHY

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                           BIBLIOGRAPHY


RESOURCE CONSERVATION AND RECOVERY ACT OF 1976;     Related   Con-
gressional Reports.

     Environmental Protection Agency.   Identification  of regions
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     Environmental Protection Agency.   Resource Conservation and
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     Resource conservation  and  recovery act of  1976;  Public Law
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     U.S. House  of  Representatives.   Report of  the Committee on
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     U.S.  Senate   Report  No.  94-988,   94th   Congress,   Second
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CRITERIA:  Support Documents and Issue Papers.

     Environmental Protection  Agency.  Solid  waste  planning  and
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     Environmental  Protection  Agency.   Office  of  Solid Waste.
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     1977,  lip.
                              K-l

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     RCRA land  disposal  criteria:   coverage of  surface  impound-
     ments,  July 15,  1977,  7p.

     Sanitary landfill  criteria,  Issue  Paper  No.  3,  15p.  EPA,
     1977.

     U.S. Environmental  Protection  Agency,  Office of Water  and
     Hazardous  Materials,  RCRA  solid waste  disposal  criteria,
     (unpublished memorandum from Thomas C.  Jorling  to Assistant
     Administrators).   December 1977.

CRITERIA:  Public Hearings

     Transcript;  Public  Hearing on  the  Proposed  Classification
     Criteria for Solid Waste Disposal  Facilities,  San  Diego,
     California,  March 1,  1978.  U.S.  Environmental  Protection
     Agency  Publication SW-34p.

     Transcript;  Public  Hearing on  the  Proposed  Classification
     Criteria for Solid  Waste  Disposal  Facilities,   Portland,
     Oregon,   April  26,   1978.     U.S.  Environmental   Protection
     Agency  Publication SW-40p.

     Transcript;  Public  Hearing on  the  Proposed  Classification
     Criteria for  Solid  Waste  Disposal  Facilities, Washington,
     D.C.,  April 21,  1978.   U.S.  Environmental Protection  Agency
     Publication SW-38p.

     Transcript;  Public  Hearing on  the  Proposed  Classification
     Criteria for Solid  Waste  Disposal Facilities, Kansas City,
     Missouri,   April 24,  1978.   U.S.  Environmental  Protection
     Agency  Publication SW-39p.

     Transcript;  Public  Hearing on  the  Proposed  Classification
     Criteria for  Solid  Waste  Disposal  Facilities, Cincinnati,
     Ohio,  June  5,  1978.    U.S. Environmental  Protection  Agency
     Publication SW-42p.

FLOODPLAINS:   Laws,  Executive Order,  Regulations,  Data

     Floodplain   Management,   Executive   Order   11988,  Federal
     Register, Vol.  42,  No.  101.  May  25,  1977, 7p.

     Flood   Insurance   Program   Data   Base,   Washington,  Federal
     Insurance Administration,  may 1978  (unpublished).

     Schaeffer and Roland,  Inc.  Evaluation of the economics  of
     the social   and  environmental  effects of  floodplain regula-
     tion.    Washington,  D.C.,  Federal  Insurance  Administration
     (unpublished study).
                              K- 2

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     U.S.  Water  Resources Council.   A Unified  National Program
     for Floodplain Management.  Washington, D.C., July 1976.

     U.S.  Water  Resources  Council.    A  Uniform Technique  for
     Determining   Flood   Flow   Frequencies,   Bulletin   No. 15.
     Washington,  D.C., December, 1976.

THREATENED AND ENDANGERED SPECIES:  Laws,  Executive Orders, Regu-
lations

     Endangered Species Act.   Public Law 93-205.

     Critical Habitat.  50 CFR Part 17, Subpart F.

SURFACE WATER:  Laws, Executive Orders, Regulations

     Shaw,  S.  P.,  and  C. G.  Fredine.    Wetlands of  the  United
     States.    U.S.   Fish  and  Wildlife  Service  Circular 39.
     Washington,  U.S. Government Printing  Office, 1956.

     The  Water  Pollution  Control  Act  of  1972:    Enforcement
     Vol. 1, October, 1975.  479p.  (Distributed  by NTIS, Spring-
     field, VA as PB-246 321).

     Department  of  Defense,  Department  of  the Army,  Engineer
     Corps.  Regulatory  program   of   the  Corps  of  Engineers.
     (42 Fed. Reg. 37122-37164, July 19, 1977).

     Protection of Wetlands,  Executive Order 11990,  May 24, 1977.

GROUND WATER;  Laws, Executive Orders, Regulations

     Background  document,  Land  criteria  (unpublished  draft).
     June 24, 1977, 121pp. Docket 4004.

     Safe Drinking Water Act.  Public Law  93-523.

     Environmental Protection  Agency.   Water  Programs.  National
     interim  primary   drinking  water   regulations.     Federal
     Register,  Vol. 40,  No. 248, December  24,  1975,  2p.

     Feldsman,  Jim.   Ground  water pollution  standards  chapter.
     March 21,  1977.  30p.

     Landspreading  of  municipal   sludges   (Draft),  USEPA,  1977
     (Unpublished Report).

     Office  of  Water  Supply.    U.S.  Environmental  Protection
     Agency.    Draft  Environmental  Impact  Statement;     State
     underground   injection  control  program.     Proposed   regu-
     lations.   40 CFR,  Part 146.   Washington,  U.S.  Government
     Printing Office, 1976.  207p.
                             K-

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GROUND WATER:  Damage, Environmental Issues

     Coe, Jack J.   Effect of solid waste disposal on ground water
     quality.     Journal,   American   Water  Works   Association
     776-782p. December,  1970.

     Garland, George A.  and Dale  C. Mosher.  Leachate effects of
     improper  land  disposal.    Waste  Age,  March 1975,  pgs 42,
     44-48.

     Geraghty  &  Miller,  Inc.   Development of   a  data  base  for
     determining  the  prevalence  of   migration   of   hazardous
     chemical substances  into  the  ground water at industrial land
     disposal   sites.      Project   Synopsis.     EPA   Contract
     NO.  68-01-3707.   February  1977.

     James,  Stephen C., Metals  in  Municipal Landfill Leachate and
     Their Health Effects.   Am.  J_.  of Public Health  67,  5,  May
     1977, 429-432.

     Jones,   R.L.,   T.D.  Hinesly,  R.J.  Johnson.    Selenium  in
     agricultural  ecosystems,;  a  bibliography of  the literature.
     The  Metorpolitan  Sanitary  District  of  Greater  Chicago,
     August,  1973.   79p.

     Office   of  Solid  Waste Management  Programs.   The  report  to
     Congress;  waste   disposal  practices  and  their effects  on
     ground   water.     U.S.   Environmental   Protection  Agency.
     Washington,  D.C., January  1977.  512p.  (Distributed by NTIS
     as PB-265 081) .

     Shuster,  Kenneth   A.     Leachate   damage:      a   national
     assessment.    U.S.  Environmental   Protection  Agency,  Wash-
     ington,  D.C.  September 1976 (Unpublished Report).

     Shuster, Kenneth A.    Leachate  damage  assessment;  Case study
     of  the  Fox  Valley  solid  waste  disposal   site in  Aurora,
     Illinois.    Environmental   Protection  Agency   publication
     SW-514.   U.S.  Government  Printing  Office, 1976.   34p.

     Shuster,  Kenneth A.    Environmental   impact  of  leachate.
     Outline   of  presentation;   gas and  leachate generation  and
     control   in  landfills.    Presented  at Madison,  Wisconsin,
     March 29-31,  1976.  14p.

     Shuster, Kenneth  A.  Leachate damage assessment:  Case study
     of the  Peoples  Avenue  solid waste  disposal  site in Rockford,
     Illinois, Report  EPA/530/SW-517,  USEPA, 1976.

     Shuster,  Kenneth A.     Leachate   damage  assessment:     an
     approach.  (Unpublished Draft).  December,  1975.
                              K-4

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     Shuster, Kenneth  A.   Leachate damage assessment; case study
     of  the  Islip  (Long  Island)  New  York  solid  waste disposal
     site.   Environmental  Protection  Agency.    U.S.  Government
     Printing Office,  1976.

     World  Health  Organization.    Evaluation   of  certain  food
     additives  and  the contaminants mercury,  lead,  and cadmium.
     Sixteenth  Report  of  the  Joint FAO/WHO  Expert  Committee  on
     Food Additives.   FAO and WHO, Geneva, 1972.  32p.

GROUND WATER:  Data, Technology, and Costs

     Chian, E.S.K., and F.B. Dewalle.  Compilation of methodology
     for  measuring pollution  parameters  of landfill  leachate.
     U.S. Environmental Protection Agency.  October,  1975.   164p.

     Emcon  Associates,   Evaluation  of   clay   liner  materials
     following  in-field exposure to landfill leachate.   Prepared
     for USEPA,  July 1977.

     Erncon Associates  -  City  and  County of Honolulu.   Liners.
     July, 1977.  5p.

     Geswein,   Allen  J,    Liners  for  land disposal  sites;  an
     assessment.    EPA  publication  SW-137.    U.S.   Government
     Printing Office 1975.  66p.

     Geraghty,   J. J.,  et  al.   Water atlas of  the United States.
     Port Washington, New York, Water Information Center, 1973.

     Procedures manual for monitoring solid waste disposal  sites.
     (Office  of  Solid   Waste   Management  Programs).     Wehran
     Engineering  Corporation  and Geraghty & Miller,  Inc.   U.S.
     Environmental Protection Agency, 1976.  287p.

     Proceedings;    Conference    on   Geotechnical  Practice   for
     Disposal of  Solid Waste Materials,  University  of  Michigan,
     Ann Arbor,  Michigan,  June-13-15,  1977,  American Society  of
     Civil Engineers,  1977.  885p.

     U.S.  Environmental  Protection  Agency.   Office  of  Research
     and   Development.      Environmental   Protection   Technology
     Series.   Movement of  selected  metals,  asbestos,  and cyanide
     in  soil:    applications  to waste  disposal  problems.    EPA
     600/2-77-020.  Cincinnati,  Ohio.  April  1977.  242p.

AIR;  Laws, Executive Orders,  Regulations, Environmental Issues

     Clean Air Act.   Public Law 93-319.

     Perkins,  Henry  C.   Air pollution.   New York,  HcGraw  Hill
     Book Company, 1974.   407p.
                              K-5

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LAHDSPREADING:   Damage,  Environmental Issues

     E.  Akin,  W. Jakubowski,  J. Lucas  and H.  Pahren.   Helath
     hazards  associated  with  wastewater  effluents  and  sludge:
     microbiological  considerations,  in   Risk   Assessment  and
     Health Effect  of Land  Application of  Municipal  Wastewater
     and Sludges.   Center  for Applied Research  and  Technology,
     University of Texas,  San Antonio, Texas, 1977.

     Alexander,  M.     Introduction  to  soil  microbiology,  2nd
     edition.   John Wiley  & Sons, New York, 1977.

     Braude,  G.  L.   et  al.,   FDA's   overview  of  the  potential
     hazards associated  with  the  land application of  municipal
     wastewater sludges.   Proceedings of the Second National Con-
     ference of Municipal  Sludge Management Information Transfer,
     Inc.,  Rockville,  Maryland, 1975.  pp.  214-217.

     Bicknell,  S.  R.    Salmonella aberdeen  infection  in  cattle
     associated with  human sewage.    Journal of Hygiene,  70:121,
     1972.

     The carcinogen  assessment  group's  assessment  of  cadmium.
     1977  26p.  (Unpublished Report).

     Chaney, R. L.  Unpublished data, 1977.

     Dotson, G.  Kenneth,   et  al.  An appraisal  of the relative
     health risks  associated  with land  application of  municipal
     sludge.   50th  Annual  Conference  of  the  Water  Pollution
     Control Federation,  Philadelphia, PA.   October 2-6,  1977.
     22p.

     DuPont, H.  L.,  and  Hornick, R.  B.    Clinical  approach  to
     infectious diarrhea,  Medicine, Volume  52,  1973.
                              K-6

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Healy, U. D.   Inqestion  of soil by dairy cows.
Journal of_ Agricultural Research, 2:237-499,

Elinesly, Thomas D.   Agricultural benefits and environmental
changes  resulting  from the use  of  digested  sludge on field
crops.   Metropolitan Sanitary  District  of  Greater Chicago,
prepared for  Environmental Protection Agency,  1974.   375p.
(Distributed by NTIS, Springfield, VA.  as PB-236  402).

Iwata, Y.,  e_t al_.   Uptake of PCS (Aroclor 1254) from soil by
carrots  under  field conditions.   Bulletin  of Environmental
Contamination and Toxicity, Volume 2, 1974.   p. 523.

Jackson, G., J. Bier, and R. Rude.  Recycling of refuse into
the food chain:   the parasite  problem.   In Risk  assessment
and health  effect  of  land application  of  municipal  waste-
water  and  sludges.   Center for Applied  Research  and Tech-
nology, University of Texas, San Antonio, 1977.

Jepsen, A.  and H.  Roth.  Epizootlology of Cysticercus bovis:
 resistance  of  the  eggs  of Tacnia  saglnata.   Report  of the
14th Internation Veterinary Congress, Volume 2, 1952,  p. 43.


K^ellstrom,  T.  Calculations on  exposure limits for the pre-
vention of  cadmium-induced  health  effects.   Paper presented
at  the First  International Cadmium  Conferences,  San Fran-
cisco, February 1977.

Kienholz, E.,  G.  M.  Ward,  and  D.  E.  Johnson.   Health con-
siderations relating to ingestion of  sludge by farm animals.
In  Sludge  Management  and  Utilization,  Proceedings  of  the
Third National Conference on Sludge Management, Disposal and
Utilization, 1976.

Kreuz, A.   Hygienic evaluation  of  agricultural utilization
of sewage.   Gesundheitsing  76:206-211, 1955.

Kroger, E., Detection  of  S. baceilly in sewages,  sludge and
vegetables  from an  irrigation field  after  an  epidemic.   Z_.
Hyg. Infektkr, 139:202-207, 1954.

Love,  G. L.    Potential health  impacts of sludge disposal on
the  land.    Proceedings,   National  Conference  on  Municipal
Sludge Management and Disposal,   1975.

Moore,  B.,  B. Sagik  and  C.  Sorber.   Land  application  of
sludges:    minimizing  the  impact  of   viruses  on  other
resources.    In risk  assessment  and  health effect of land
application of municipal  wastewater and sludges.  Center for
Applied  Research  and Technology,  University of Texas,  San
Antonio, Texas, 1977.
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     Sepp, E.   The use  of  sewage for  irrigation:   a literature
     review.    Bureau  of  Sanitary Engineering,  California State
     Department of Health,  1963.

     Strauch,  D.   Health hazards  of  agricultural,  industrial ana
     municipal  wastes  applied  to  land.    In  Land  as  a  waste
     management  alternative.    Raymond C.  Loehr,   Editor.    Ann
     Arbor Science Publishers,  Inc.,  1977.

     Suzuki,   et  al.    Translocation  of  polychlorobiphenols  in
     soils into plants:  a  study  of  a method  of culture  of  soy-
     bean sprouts.   Archives of  Environmental Contamination and
     Toxicity, Volume  2,  1977,  p.  343.

     Transcript,  Public  Hearing   on  the  Proposed  Classification
     Criteria  for Solid Waste  Disposal  Facilities,  Cincinnati,
     Ohio, June 5,  1978.    U.S.   Environmental  Protection  Agencv
     Publication SW-42p.

     Troast,   Richard,  et  al.  Cadmium.   (Position  Document 1).
     Office  of  Special  Pesticide Reviews.    U.S.  Environmental.
     Protection Agency.

     U.S.  Environmental Protection  Agency.    Office  of  Water
     Program   Operations.     Municipal   Construction  Division.
     Municipal  sludge   management:       environmental   factors.
     EPA 430/9-77-004.  Washington, D.C.  Octooer 1977.   31p.

LAHDSPREADING:  Data,  Technology  Costs

     Anderson, K.  Kent.  Case  studies  of  the  cost  of landspreaa-
     ing  and  hauling  sludge from municipal wastewater  treatment
     plants (Unpublished Document) USEPA.

     Bruade,  G.L.  and Jelinch, C.F.   Management of sludge  use on
     land, FDA  considerations.   Food  and  Drug  Administration,
     Washington, D.C.

     Environmental Protection  Agency.    Winter  sewage  treatment
     plant performance study report.   1977.

     Environmental Protection Agency  Technical Bulletin:   Muni-
     cipal sludge management  technical  factors,  and Notice  of
     availability  of proposed technical bulletin.  1977.

     Gordian  Associates, Inc.   (draft)   An economic analysis of
     municipal  waste   water   sludge   treatment   and  disposal.
     Vlashington:  Gordian Associates,  Inc.,  July ly77.

     Impact  assessment  of   annual  cadmium  limitations  on  the
     agricultural  utilization of  municipal sludge .  (Draft).

     SCS Engineers.    Municipal   sludge  agricultural utilization
     practices—an environmental  assessment.   Volume  I.  Prepared
     for Office of Solid Waste, USEPA,  1977.   151p.

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Jelinch,  C.F.  and G.L.  Brands.  Management of sludge use on
land, FDA Considerationa. 35-37.

Land  Application  of  Residual   Material;   Proceedings
Selected  Papers;  Engineering Foundation Conference, Easton,
Maryland, September  25  -  October 1,  1976.   American Society
of Civil Engineers.  183p.

LA/OMA  Project.    Sludge  management activities  for the Los
Angeles/Orange County metropolitan area,  Whittier,  CA., May
1977.

Manson,  Robert and Merritt,  Clifford.   Land  application of
liquid  municipal  wastewater  sludges.   Journal  of  the Water
Pollution Control  Federation (Vol. 47,  No.  1)  January 1975.
24-24.

Municipal  sludge  management:     EPA  construction  grants
program.   An  overview  of the  sludge  management situation.
U.S.  Environmental  Protection  Agency,   Office  of  Water
Program  Operations.   April  1976.   (Distributed  by National
Technical    Information  Service,   Springfield,   VA    as
PB-266-695).

Municipal Sludge:  what shall we do with it?  Current Focus.
League of Women Voters of the United States. 5p.

Personal  Communication.    Joseph  Hile,  Acting  Associate
Commissioner for Compliance,  Food  and Drug Administration to
DR.  Andrew   W.  Breadenbach,  U.S.  Environmental  Protection
Agency, September 22, 1976.

Recycling  sludge  and  sewage  effluent by  land  disposal;
Environmental  Science  and   Technology  6(10):     871-873,
October 1972.

Singh,  R.N.,  Reefer,  R.F.,   and  Hovath, D.J.,  Can  soils be
used  for sewage  sludge disposal?   Compost Science  22-25,
March-April 1975.

Soil  Conservation Society  of America, Land application of
waste materials.   Ankeny,  Iowa, 1976.  313p.

Sommers,  L.E.   Chemical  composition of sewage  sludges  and
analysis of their potential  use as fertilizers.   J.  Environ.
Qual. 6(2):   225-231.  1977.

U.S.  Environmental Protection Agency.  Office  of  Solid Waste
Management Programs  (Unpublished  Report).    Sewage  sludge
data on U.S.  Cities compiled October 1976.
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     U.S. Environmental Protection Agency,  Office  of Solid Waste?
     Hanagment   Programs   (Unpublished   Document).      Impact
     assessment of annual cadmium limitations on the agricultural
     utilization of municipal sludges, 1977.

     Walker, John,  Sewage  sludges -  management  aspects  for land
     application, Compost Science 12-21, March-April, 1975.

DISEASE:  Environmental Issues, Technology

     Ham, Robert  K.   Vectors.   Conference of  Engineering Foun-
     dation Research.  Deerfield, Massachusetts.   1970  14p.

     Bjornson,   B.F.,  Pratt,  H.D.  and  Littig,  K.S.   Control  of
     domestic rats  and  mice.  Public Health  Service Publication
     No. 563.  Washington,  U.S. Government Printing Office, 1970.
     41p.

SAFETY:  Explosive and Asphyxiating Gases

     Emcon  Associates.   Methane  gas  hazard.    In-house  report.
     1977 6p.

     Hatte,   S.J.  Anaerobic digestion  of  solid waste  and  sewage
     sludge   into  methane.    Compost  Science  ^ Journal  of Waste
     Recycling,  17(1):  January - February 1976.   5p.

SAFETY:  Bird Hazard to Aircraft

     Airport and Airways Development Act of 1970.  Public Law 91-
     258.

     Airport  and  Airways  Development  Act Amendments of  1976.
     Public  Law 94-353.

     Cogswell,   Howard L.   Proceedings  on the Conference  on the
     Biological Aspects  of  the Bird/Aircraft  Collision  Program,
     Clemson University, South Carolina, February 1974.

     Environmental Protection  Agency.   Bird/airport  hazards  at
     airports near solid waste disposal sites, SW-116,  1974.

     FAA Advisory  Circular.   Use  of  chemical controls  to repel
     flocks  of  birds at airports (AC 150/5200-8,  May 2, 1968).

     FAA Advisory  Circular,  Bird  reactions  to  scaring  devices.
     (AC 150/5200-9,  June 26,  1968).

     FAA Advisory  Circular,  Announcing  the  availability  of the
     international  civil  aviation organization  airport  services
     manual, DOC-9137-AM/898,  Part 3,  Bird control  and reduction.
     (AC 150/5200-22).
                              - 10

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     FAA   "Bird   Hazards  to  Aircraft"   Advisory  Circular  AC
     150/5200-3A, 1972.

     FAA Order 5200.5 FAA guidance concerning sanitary landfills.
     October 16, 1974.

GENERAL LANDFILL INFORMATION;    Laws,  Executive  Orders,  Regula-
tions, Issues

     Fred C. Hart Associates, Inc.  Overview of landfilling tech-
     nology  (draft).   Prepared  for  Office of Solid  Waste,  U.S.
     EPA, September 11, 1978.

     Ghasserai, M.,  S.C.  Quinlivon and  H.R.  Day.   Landfills  for
     pesticide   waste   disposal.    Environmental   Science   and
     Technology, 10. 1209-1214.  December 1976.

     Gray, Donald H.,  Environmental  concerns  related to disposal
     fills.   Department of  Civil  Engineering,  the University of
     Michigan.  January 1976.  20p.

     National  Environmental  Research  Center.    Municipal  solid
     waste   generated   gas    and   leachate.      United   States
     Environmental  Protection  Agency,   Cincinnati,  Ohio.    1974.
     119p.

     Pohland,  F.G.   and  R.S.  Engelbrecht,   Impact  of  Sanitary
     Landfills:  An  Overview  of Environmental  Factors and  Control
     Alternatives.     Prepared   for  American  Paper  Institute.
     February 1976.   82p.

     Stewart, W.S.   State-of-the-art study of  landfill impound-
     ment techniques.   Prepared by Exxon Research and Engineering
     Co.,  Linden,  N.J.  for  U.S.  EPA,  Office  of  Research  and
     Development, Cincinnati.  Project  R-803585.

     Waste Age survey of the  nation's disposal sites.  Waste Age.
     21-28.  January 1977.

     Waste Age,  January   1978  (Survey   of  the nation's  disposal
     sites.

GENERAL LANDFILL INFORMATION:  Damage,  Environmental Issues

     American  Society  of Civil  Engineers,   Sanitary  landfill
     manuals  and  reports  of   engineering  practice  -  No.  39.
     Revised 1976.

     Brunner, D.R. and D.J. Keller.  Sanitary  landfill design and
     operation.    Environmental   Protection  Agency  Publication
     SW-65ts.  Washington, U.S. Government Printing Office,  1972.
     59p.
                              K-ii

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     Brunner, D.R.,  S.J.  Hubbard, D.J. Keller,  and  J.L.  Newton.
     Closing  open   dumps.     Environmental   Protection   Agency
     Publication SW-61ts.   Washington, U.S.  Government Printing
     Office, 1971,  19p.

     Comparing  conventionally  landfilled  solid  waste  with  pro-
     cessed  landilled  solid  waste.    Floyd  G.  Brown  and  Asso-
     ciates, Ltd.   Prepared for  Environmental  Protection Agency
     1973,  136p.  (Distributed by National Technical Information
     Service, Springfield, VA as PB-253 304).

     Cost of solid waste  management  facilities.   Board of County
     Commissioners.   Johnson County,  Kansas, March 1975.

     Inglehard,  Cecil.   How  do you measure the costs of landfiJl
     design and  operation?  (Unpublished Report).

     Fourth National Congress  on  Waste Management Technology and
     Resource   and    Energy   Recovery.      Atlanta,   Georgia,
     November 12-14,  1975.  U.S.  Environmental Protection Agency,
     Washington, U.S. Government Printing Office, 1976.   382p.

     Subsurface   application  solves  community  sludge  disposal
     problems.   Public  works 67-68.  December 1976.

     Thermal processing and  land  disposal  of  solid waste; guid€;-
     lines.    40 CFR  Part 241.   39 Federal Register  29327-29338,
     August 14,  1974.

GENERAL SURFACE  IMPOUNDMENT INFORMATION

     Geraghty & Miller,  Inc.     Surface  impoundments  and  their
     effects  on ground-water  quality  in  the  United  States—A
     preliminary survey.   Prepared  for  the  Office   of  Drinking
     Water,  U.S. Environmental Protection  Agency.   EPA 570/9-78-
     004, June 1978.   275p.  267p.

GENERAL INFORMATION:   Environmental Issues, Decision  Models

     Anderson,   K. and  M.  Cowart.   Don't  walk away  from  an  open
     dump.  The  American City and County.   February 1976.   2p.

     Disposal  of  wastewater  residuals,   Environmental  Quality
     Systems, Vol.  1.  March 1976,  1031p.  (Distributed by NTIS,
     Springfield, VA  as PB-251  371-01).

     Council  on Environmental  Quality.    Environmental  Quality
     1976,  Seventh  Annual  Report,  Washington,  D.C.,  September
     1976.

     Disposal  of  wastewater  residuals,   Environmental  Quality
     Systems, Vol.  2.  March 1976.   548p.  (Distributed by NTIS,
     Springfield, VA. as PB-251 371-02).
                             K-12

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     Effluent  limitations  guidelines  for  existing  sources  and
     standards   of  performance  for  new  sources,  national  Field
     Investigation  Center,   Environmental  Protection   AGency.
     August 1974 (Distributed  by  NTIS,  Springfield,  VA as PB-257
     300).Environmental Protection Agency.  Environmental impacts
     of  land disposal  (Unpublished  Draft).  26pp.   Docket 4004.
     1977.

     Riggs,  James L.   Economic decision models for engineers and
     managers.   New York:   McCraw Hill,  Inc. 1968.

     Strategic   environmental   assessment  system:     residuals
     forcasting.    International   Research  and  Technology  Cor-
     poration,   February  1976.    59p.     (Distributed  by  NTIS,
     Springfield,  VA as PB-252041.)

     The National  Energy Act.

     Wolcott,  F.M.  and B.W.  Vincent.  The  relationship  of  solid
     waste  storage  practices  in the inner  city  to  the incidence
     of   rat  infestation  and  fires.   Environmental  Protection
     Agency  Publication SW-150.    Washington,  U.S.  Government
     Printing Office,  Hay  1975.  14p.

GENERAL  INFORMATION:   General  Solid Waste Management

     American Chemical Society.   Solid  wastes.   An Environmental
     Science  and Technology  reprint book.   37p.  CA.,  1971.

     Bergman,   E.B.    KRAP.    A  model  for  regional  solid  waste
     management  planning.      User's   Guide.      Environmental
     Protection Aaency  Publication.    SW-574.   Washington,  D.C.
     U.S. Government printing  Office, 1977.  124p.

     Environmental  Protection  Agency.  Materials  recovery.  Solid
     waste  management guidelines  for source separation.   Federal
     Register,   Vol.  41, flo.   80.    Uashington,   U.S.  Government
     Printing Office,  April  23,  1976.  8p.

     Flnvi ronmental   Protection   Agency.      Resource   recovery
     facilities.    Guidelines.     Federal  Register,   Vol.  41,
     No.  184.   Washington, D.C.   U.S. Government  Printing  Office,
     September  21,  1976.  4p.

     Office  of  Solid  Waste  Management  Programs.    Decision
     Makers   guide   in   solid  waste  management.     Environmental
     Protection Publication  SH-500.  Washington,  U.S.  Government
     Printing Office,  1976   156p.

     Office  of  Solid Haste Management Programs.  Second Report to
     Congress:      resource    recovery   and  source   reduction.
     Environmental  Protection  Publication  SW-122.   Washington,
     U.S. Government Printing  Office, 1974.   112p.
                             K-13

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     Office  of  Solid Waste tfanagment  Programs.   Third Report  to
     Congress;      resource   recovery   and   waste   redaction.
     Environmental    Protection    Agency   Publication   3W-161.
     Washington, U.S. Government Printing Office, 1975.

     The Bureau of National Affairs, Inc. Environmental Reporter:
     State  Solid  Baste  -  Land  Use  (Washington:    The Bureau  of
     National Affairs, Inc. 1976).

     The City of  Scottsdalc,  Arizona.   A handbook  for initiating
     or  improving  commercial  refuse   collection.   Environmental
     Protection  Agency  Publication.    SW-35d,  Washington,  U.S.
     Government Printing Office,  August 1975. 68p.

GENERAL INFORMATION:  Amounts and Character of Solid Waste

     Poyd,   C.B.  and M.8.  Hawkins.   .Methods  of  predicting  solid
     waste characteristics.  environmental Protection Publication
     SW-23C  Washington,  U.S.  Government Printing  Office,  1971,
     28p.

     Smith,  F.A.      Quantity  and  composition  of  post-consumer
     solid   waste;   material flow estimate  for  1973 and baseline
     future projections.  Waste Age, 2-10, April 1976.

     Smith,  F.A.    Comparative  estimates of  post-consumer  solid
     waste.   Environmetnal  Protection  Agency  Publication SW-148.
     Washington, U.S. Government Printing Office, May 1975.   bp.

GENERAL INFORMATION:  Industrial  Wastes, liming Wastes

     Environmental  Protection  Agency.   Polychlorinated biphenyl-
     containing  wastes.    Federal  Register,  Vol. 41,  No. 64.
     Washington, US.  Government  Printing Office,  April  1,  1976.
     3p.

     Environmental  Protection  Agency.    Vinyl  chloride.   Recom-
     mended  procedure  for  disposal of  aerosol  cans.   Federal
     Pegi ster,  Vol.  41.  No. 112.    Washington,  U.S.  Government
     Printing Office, June 9, 1976. 2p.

     Proceedings;  Kentucky  Coal  Refuse  Disposal  and  Utilization
     Seminar  (1st)  held  at  Cumberland,  Kentucky,  flay 22,  1975.
     47p.

     Smith.  F.L.,  Jr.    A solid  waste  estimation  procedure:
     material  flows  approach.    Environmental  Protection  Agency
     Publication  SW-147.    Washington,  O.E.  Government  Printing
     Office, flay 1975.  55p.

     Stanton, W.S. and J.G. Langerton.    Pesticide  container pro-
     cessing  in  commercial  reconditioning  facilities.   Environ-
     mental  Protection Agency Publication  SVi-b8d.   Washington,
     U.S.  Government Printing Office,  November Iy76.  2up.
                             K- 14

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     Terry, Jr., R.C. and J.B. Berkowitz, Arthur D. Little, Inc.
     Waste clearing houses and exchanges.  Chemical  Engineering
     Progress, 58-62.  December 1976.

     USEPA,  Industrial  waste  management:     seven conference
     papers.  EPA/530/SW-156,  January 1975, 111;.


GENERAL INFORMATION:  Census Data

     U.S.  Department of Commerce, Bureau of the Census,  General
     Summary,  1972 Census of Manufacturers, Washington:    U.S.
     Government Printing Office, 1975.

     U.S.  Bureau of the Census.   1970 Census of the Population:
     Number  of  Inhabitants,   Vol. 1.   United  States Summary,
     Table II, Area, 1970, and popultation per square mile, 1920
     to 1970  (Washington:  Government Printing Office, 1972).
                                                  uol881
                                                  SW-821
                               K-15

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                DATE DUE
.3.
....  Environmental Protection Agency.
Region 5,  Literary  (5PL-16)
ZZQ S. Dearborn Street, Room 16/0
Chicago, IL   60604

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                          EPA  REGIONS
U.S. EPA, Region 1
Solid Waste Program
John F. Kennedy Bldg.
Boston, MA 02203
617-223-5775

U.S. EPA, Region 2
Solid Waste Section
26 Federal Plaza
New York, NY 10007
212-264-0503

U.S. EPA, Region 3
Solid Waste Program
6th and Walnut Sts.
Philadelphia. PA 19106
215-597-9377

U.S. EPA, Region 4
Solid Waste Program
345 Courtland St., N.E.
Altama, GA 30308
404-881-3016
U.S. EPA, Region 5
Solid Waste Program
230 South Dearborn St.
Chicago, II 60604
312-353-2197

U.S. EPA, Region 6
Solid Waste Section
1201 Elm St.
Dallas, TX 75270
214-767-2734

U.S. EPA, Region 7
Solid Waste Section
1735 Baltimore Ave.
Kansas City, MO 64108
816-374-3307
U.S. EPA, Region 8
Solid Waste Section
1860 Lincoln St.
Denver, CO 80295
303-837-2221

U.S. EPA, Region 9
Solid Waste Program
215 Fremont St.
San Francisco, CA 94105
415-556-4606

U.S. EPA, Region 10
Solid Waste Program
1200 6th Ave.
Seattle, WA 98101
206-442-1260

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