c/EPA
United States
Enviornmental Protection
Agency
SW-821
December 1979
Solid Waste
Environmental
Impact
Statement
Criteria
for Classification of
Solid Waste Disposal
Facilities
and Practices
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ENVIRONMENTAL IMPACT STATEMENT
CRITERIA FOR CLASSIFICATION
OF SOLID WASTE DISPOSAL FACILITIES AND PRACTICES
THIS EIS (SW-821) FOR THE RESOURCE CONSERVATION AND RECOVERY ACT,
SUBTITLE D, SECTION 4004, Arc THE CLEAN WATER ACT, SECTION
WAS PREPARED BY THE OFFICE OF SOLID WASTE
7/, 'FFENW. PLEHN
DEPUTY DISTANT ADMINISTRATOR
R SOLID WASTE
PROTECTION AGENCY
SEPTEMBER 1979
U.S. Environmental Protection
Region 5, Library (5PL-16)
230 S. Dearborn Street, Room
Cbioego, IL 60604
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SUMMARY
ENVIRONMENTAL IMPACT STATEMENT
CRITERIA FOR
CLASSIFICATION OF SOLID WASTE
DISPOSAL FACILITIES AND PRACTICES
Environmental Protection Agency
Office of Solid Waste
1. Type of Action
Administration Action (Regulatory)
2. Brief Description of Action
On September 13, 1979, EPA published in the Federal Register,
"Criteria for Classification of Solid Waste Disposal Facilities
and Practices" (44 Federal Reg. 53438). That publication included both
final and interim final rules. The action prescribes classifying
solid waste disposal ff ^ilities according to their probability of
causing adverse impacts on health and the environment. The regulations
have been issued under authority of the Solid Waste Disposal Act
as amended by the Resource Conservation and Recovery Act of 1976
(Pub. L. 94-580), and the Federal Water Pollution Control Act as
amended by the Clean Water Act of 1977 (Pub. L. 95-217).
3. Summary o£ Beneficial and Adverse Environmental Impacts
a. In general, implementation of the criteria will result in
significant improvements in environmental quality, with beneficial
impacts on: floodplains, endangered and threatened species, surface
water ( including wetlands ), ground water, air quality, soil
quality ( amount of cadmium and other contaminants entering the
food chain), disease, and public health and safety.
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b. The general effects of the criteria will be threefold:
- Many existing facilities (such as landfills, land-
spreading operations, and surface impoundments) will
close or be forced to close, because of the cost or
physical impossibility of compliance;
Many other existing facilities will upgrade their
operations in conformance with a State compliance
schedule and will reduce to acceptable levels or
eliminate the adverse environmental effects of their
operations;
New and expanded solid waste disposal facilities,
resulting from previous closures/consolidations and new
demands, will be located, designed, and operated in
such a way as to ensure a reasonable probability of
protecting health, safety and environmental quality.
c. In some cases where existing facilities are closed or up-
graded, the environmental adverse effects of past operations (for
example, caused by location in wetlands/floodplains/critical habitats;
leachate and gas generation, and migration; and heavy metal applica-
tion to land) may still continue for some time into the future.
d. Bringing all solid-waste disposal facilities into compliance
with the criteria will increase the cost of landfilling, landspread-
ing, and surface impoundment operations. An annualized cost of ap-
proximately $5.01 billion per year will be needed to bring all sites
into compliance. Of this cost, $3.7 billion per year will be neces-
sary to bring sites into compliance with existing State regulations
(State-standard-induced costs). The remaining $1.3 billion per year
will result directly from the criteria where the criteria are more
stringent than existing State regulations (Federally induced costs).
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4. Alternatives Considered
a. Final Action *
b. Less Restrictive Regulations
c. More Restrictive Regulations
5. Federal, State, and Local Agencies from Which Written
Comments Have Been Received
The proposed regulation was distributed to thousands of indivi-
duals and organizations representing all sectors of our society. The
draft EIS was also distributed to a diverse audience. Comments were
received from organizations including, but not limited to, the
following:
Federal agencies
Department of Energy
Department of HEW
U.S. Department of the Interior
U.S. Department of Commerce
State Government
State of Kentucky, Department for Natural Resources and Environmental
Protection
New York State Department of Environmental Conservation
Commonwealth of Pennsylvania, Department of Environmental Resources
State of Wisconsin, Department of Natural Resources
Missouri Department of Natural Resources
State of New Jersey, Department of the Public Advocate
Oregon Department of Environmental Quality
University of Wisconsin, Cooperative Extension Programs
Minnesota Pollution Control Agency
Washington state. Department of Ecology
* 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 DiseaseSewage Sludge and Septic
Tank Pumpings (under Section 257.3-5 and 257.3-6(b), respectively)
are of an interim final status.
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Alaska Department of Environmental Conservation
Virgin Islands Government, Division of Solid Waste
South Carolina Department of Health and Environmental Control
Indiana State Board of Health
Texas Department of Health
Local Government
Metropolitan Sewerage District of the County of Milwaukee
Weld Co. Colorado, Office of Board of County Commissioners
The Metropolitan Sanitary District of Greater Chicago
Solid Waste Management Professional Groups and Industries
National Solid Wastes Management Association
Browning - Ferris Industries, Inc.
Waste Management, Inc.
John Sexton Contractors
Professional Associations and Companies
Professional Engineers in Private Practice
American Consulting Engineers' Council
Environmental, Health, and Citizens Groups
Environmental Defense Fund
Environmental Action Foundation
League of Women Voters of the U.S.
Trade Associations
American Petroleum Institute
National Food Processors Association
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Utilities
Edison Electric Institute
Pennsylvania Power & Light Company
Public Service Indiana
Consultants
Harding-Lawson Associates
Wals, Harkrader & Ross
Camp Dresser & McKee, Inc.
Pickard and Anderson
Malcolm Pirnie, Inc.
Other Industries
Dow Chemical U.S.A.
General Portland, Inc.
6. Copies of the Final EIS
Copies of the Final EIS can be obtained by contacting:
Mr. David Noble
Office of Solid Waste (WH-564)
U.S. EPA
Washington, D.C. 20460
(202)755-9125
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ACKNOWLEDGEMENTS
This EIS was prepared under EPA contract number 68-01-4677 to
Emcon Associates, Inc. The major contract personnel contributing to
the EIS were:
Emcon Associates, Inc.
Don Andres
David Armstrong
Fred Cope
Ed Griffith
Gail Karpinski
John Pacey
Susan Rex
JRB Associates, Inc.
Robert Colonna
Kathy Durrell
Richard Pannell
Alan Vitberg
Booz, Allen and Hamilton, Inc. (Land Application to Food-chain Crops
Analysis)
Stephen Bailey
Lawrence Cahill
John Durkin
Jeffrey Peirce
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CONTENTS
- PREAMBLE TO EIS
- LIST OF COMMENTORS
I. EXECUTIVE SUMMARY I-l
A. Description of Action 1-2
1. Legal Basis 1-2
2. Purpose of Regulation 1-2
3. Coverage 1-3
4. Adverse Environmental Impacts
(Problem Identification) 1-3
5. Regulatory Approach/Regulatory
Alternatives 1-4
a. Relevant Federal Laws 1-5
b. Technical Feasibility 1-5
c. Environmental Benefits
vs. Economic and Equity
Impacts 1-5
6. Chronology of Alternative Development 1-6
7. The Criteria 1-7
8. Basic Data 1-7
9. Data Base and Gaps 1-8
10. Key Assumptions 1-9
B. Results of Impact Analyses 1-11
1. Environmental Benefits 1-11
2. Economic Impacts
a. State-Standard-Induced Costs vs.
Federally Induced Costs 1-19
b. Impacts of Disposal Types 1-22
c. Final vs. More Restrictive vs.
Less Restrictive Alternatives 1-25
d. Cost-Centers of the Final Criteria 1-26
e. Economic Impacts 1-26
3. Equity Impacts
a. Urban/Rural Community Impacts 1-28
b. Regions Impacted by Specific
Criterion 1-31
c. States 1-31
d. Manufacturing Industries 1-33
4. Other Impacts
II. INTRODUCTION II-l
A. Legal Basis for Action II-l
1. Legislative Intent II-l
a. Adverse Impacts of Past Disposal
Practices II-2
b. Prohibition of Such Practices II-6
2. Statutory Requirements of RCRA and CWA II-7
B. Purpose of Regulation II-9
1. Minimum National Standards II-9
2. Implementation of Criteria II-9
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CONTENTS (cont'd)
C. Relevant Federal Laws 11-12
1. Criteria for Classification of Solid
Waste Disposal Facilities 11-13
a. Basic Provisions of RCRA Pertaining
to Solid Waste Disposal 11-13
b. Basic Provisions of the Clean Water
Act Pertaining to Solid Waste Disposal 11-15
c. Other Federal Regulations 11-15
2. Criteria-Related Federal Laws 11-15
a. Floodplains 11-18
b. Endangered and Threatened Species 11-18
c. Surface Water 11-20
a) General 11-20
b) Wetlands 11-22
d. Ground Water 11-24
e. Application to Land Used for Food-
Chain Crops 11-26
f. Air 11-26
g. Safety 11-27
1) FAA Order 5200.5, "FAA Guidance
Concerning Sanitary Landfills" 11-27
2) Airport and Airways Development
Act of 1970 (P.L. 91-258) and
Amendments of 1976 (P.L. 94-353 11-27
h. General 11-28
D. Coverage 11-29
E. Regulatory Approach 11-31
1. Adverse Impacts 11-31
2. Criteria Alternatives 11-31
a. Operational and Performance Standards 11-34
1) Operational Standards 11-34
2) Environmental Performance
Standards 11-35
3. Decision Making 11-38
F. Purpose of EIS 11-39
G. EIS Approach 11-40
1. Identification of Impacts 11-40
2. Evaluation of Alternatives 11-40
3. Environmental Benefits 11-41
4. Costs/Benefits of Major Criteria 11-43
Alternatives
a. General Approach 11-43
b. Cost Accounting 11-43
c. Method of Analysis 11-44
III. ALTERNATIVE REGULATORY ACTIONS: ENVIRONMENTAL AND
ECONOMIC IMPACTS III-l
A. Floodplains III-3
1. Definition III-3
2. Importance; Adverse Effects from
Improper Disposal III-3
3. Regulatory Alternatives and Environ-
mental Consequences III-4
4. Summary Technology, Economic and
Environmental Impact Analysis III-6
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CONTENTS (oont'd)
Endangered and Threatened Species 111-12
1. Importance; Adverse Effects from Improper
Disposal 111-12
2. Regulatory Alternatives and Environmental
Consequences 111-12
3. Summary Technology, Economic and
Environmental Impact Analysis 111-14
Surface Water 111-16
1. Importance; Adverse Effects from
Improper Disposal 111-16
2. Regulatory Alternatives and Environmental
Consequences 111-23
3. Summary Technology, Economic and
Environmental Impact Analysis 111-24
Ground Water 111-42
1. Importance; Adverse Effects from
Improper Disposal 111-42
2. Major Regulatory Issues 111-50
3. Regulatory Alternatives and Environmental
Consequences 111-51
4. Summary Technology, Economic and
Environmental Impact Analysis 111-55
Application to Land Used for the Production
of Food-Chain Crops 111-68
1. Importance; Adverse Effects from
Improper Disposal 111-68
2. Regulatory Alternatives and Environmental
Consequences 111-83
3. Summary Technology, Economic and
Environmental Impact Analysis III-101
Disease III-128
1. Importance; Adverse Effects from
Improper Disposal III-128
2. Regulatory Approach and Environmental
Consequences III-130
3. Summary Technology, Economic and
Environmental Impact Analysis III-135
Air III-151
1. Importance; Adverse Effects from
Improper Disposal III-151
2. Regulatory Alternatives and Environmental
Consequences III-153
3. Summary Technology, Economic and
Environmental Impact Analysis III-155
Safety III-161
1. Explosive Gases III-161
2. Fires III-162
3. Bird Hazards to Aircraft III-164
4. Access III-167
5. Summary Technology, Economic and
Environmental Impact Analysis III-168
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CONTENTS (cont'd)
IV. ECONOMIC AND ENVIRONMENTAL IMPACT EVALUATION OF
FINAL CRITERIA IV-1
A. Approach and Methodology IV-1
1. Landfills IV-4
2. Surface Impoundments IV-6
3. Landspreading IV-7
B. Environmental Effects and Costs Impacts,
Summary of Criteria IV-8
1. Major Environmental Benefits IV-8
2. State-Standard-Induced and Federally
Induced Costs IV-9
3. Major Cost Factors IV-14
4. Comparison of Alternatives IV-14
C. Environmental Effects and Cost Impacts
Summary of Alternatives (By Disposal
Method) IV-18
1. Landfill Disposal IV-18
a. Landfill Disposal IV-18
b. Major Environmental Benefits IV-22
c. Unit Prices for Each Criterion IV-23
d. State-Standard-Induced vs. Federally
Induced vs. Combined Costs IV-23
e. Major Cost Factors IV-25
2. Surface Impoundments IV-29
a. Data Base IV-29
b. Major Environmental Benefits IV-31
c. Costs for Each Criterion IV-31
d. State-Standard-Induced vs. federally
Induced vs. Combined Costs IV-32
e. Major Cost Factors IV-34
31 Landspreading IV-34
a. Data Base IV-34
b. Major Environmental Benefits IV-39
c. Costs for Each Criterion IV-41
d. State-Standard-Induced vs. Federally
Induced vs. Combined Costs IV-41
e. Major Cost Factors IV-47
D. General Benefits Discussion IV-48
1. Benefits Relating to Ground-Water
Contamination IV-48
2. Benefits Resulting for the Avoidance of
Gas Hazards IV-50
a. Major Gas Hazards IV-51
b. Minor Has Hazards IV-56
c. Summary of Annual Benefits Resulting
from the Avoidance of Has Hazards IV-64
E. Social/Equity Impacts Summary IV-64
1. Rural Aieas IV-65
2. Regions Impacted by Specific Criteria IV-69
(1) Climate IV-69
(2) Hydrogeology IV-70
(3) Usage IV-71
3. States IV-72
t. Manufacturing Industries IV-79
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TABLE OF CONTENTS (cont'd)
a. Data Base IV-79
b. Major Environmental Benefits IV-82
c. Unit Prices for Each Criterion IV-83
d. State-Standard-Induced vs. Federally
Induced vs. Total Costs IV-83
e. Major Cost Factors IV-83
f. Equity Features IV-84
Irreversible and Irretrievable; Short and
Long-Term Impacts IV-84
1. Nature of Impact IV-84
a. Irreversible Changes IV-89
b. Irretrievable Resource Commitments IV-89
2. Duration of Impact IV-89
APPENDICES
A. Text of the Criteria A-l
B. Methodology for Determining Economic Impact B1
a. Analysis of State Standards vs. Federal B-l
Criteria
b. Methodology for Each Disposal Method B-4
C. Selected Industrial Studies C-l
D. Current Types, Quantities and Conditions of
Disposal Facilities D-l
a. Landfills D-l
b. Landspreading D-10
c. Surface Impoundments D-22
E. State Administrative Cost Associated With The
Conduct Of The Inventory E-l
F. Sludge Data for POTWs In Sample Set F-l
G. 1977 Update to the 1976 Waste Age Survey G-l
H. Landfill Gas Incidents: Background Material H-l
I. Acronyms and Glossary of Terms 1-1
J. References J-l
K. Bibliography K-l
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LIST OF TABLES
Table Page
1-1 National Environmental Improvement as a Result of Criteria 1-13
1-2 Control Technologies, by Criteria and Type of Disposal Facility 1-17
1-3 Annualized Combined Full Compliance Cost By Criterion, Disposal 1-18
Method, and Regulatory Consideration
1-4 Annualized Cost Impacts of Criteria Based Upon Full Compliance 1-21
1-5 National Annualized Full Compliance Cost Summary of Criteria 1-22
1-6 National Annualized Cost Summary For Municipal and Industrial 1-23
Landfills
1-7 Annualized Full Compliance Cost Impacts of the Final Criteria, 1-24
More Restrictive and Less Restrictive Alternatives
1-8 Final Criteria: Comparative Percentage Costs for Each Disposal 1-26
Method
1-9 Disposal Method Cost Summation Upgrade & Closure (Final 1-54
Criteria)
1-10 Compliance Costs as a Percent of Annual Sales for the Manu- 1-35
facturing Industries
II-l Relevant Federal Laws and Regulations 11-16
II-2 Typical Sources of Wastes to be Regulated by the Criteria 11-30
11-3 Types of Standard Used to Assess Compliance with Criteria 11-37
ril-l Floodplains: Control Technologies and Unit Costs III-8
LII-2 Floodplains Criterion Comparison of Annualized Incremetal 111-10
Costs Based On Disposal Method and Regulatory Alternative
III-3 Floodplains: Economic and Environmental Comparisons among III11
Alternatives
EII-4 Surface Water: Control Technologies and Unit Costs 111-32
III-5 Surface Water Criterion - Total Comparison of Annualized 111-36
Incremental Costs Based on Disposal Method and
Regulatory Alternative
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LIST OF TABLES (Cont.)
Table Page
III-6 Suface Water Criterion - General Comparison of Annualized 111-37
Incremental Costs Based on Disposal Method and
Regulatory Alternative
III-7 Surface Water Criterion - Wetlands, Comparison of Annualized 111-38
Incremental Costs Based on Disposal Method and Regulatory
Alternative
III-8 Surface Water Criterion - Total: Economic and Environmental 111-39
Comparisons Among Alternatives
III-9 Surface Water Criterion - General: Economic and Environmen- 111-40
tal Comparisons Among Alternatives
111-10 Surface Water Criterion - Wetlands: Economic and Environmen- 111-41
tal Comparisons Among Alternatives
III-ll Summary of Leachate Characteristics Based on 20 Samples From 111-48
Municipal Solid Wastes
111-12 Groundwater: Control Technologies and Unit Costs 111-61
111-13 Groundwater Criterion, Comparison of Annualized Incremental 111-66
Costs Based on Disposal Method and Regulatory Alternative
111-14 Groundwater: Economic and Environmental Comparisons Among 111-67
Alternatives
111-15 Selected Heavy Metal Concentrations in Soils and Municipal 111-72
Sewage Sludges
111-16 Pesticides and PCS Content of Dry Sludges 111-81
111-17 A Summary of the Regulatory Alternatives For Food-Chain 111-84
Landspreading
111-18 Annualized Unit Costs: Food-Chain Landspreading and Alterna- III-105
tive Disposal
111-19 Annualized Incremental Cost of Regulation to POTWs Currently III-119
Food-Chain Landspreading (1978 Dollars)
111-20 Criterion: Land Application to Food-Chain Crops, Comparison III-125
of Annualized Incremental Costs Based on Disposal Method
and Regulatory Alternative
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LIST OF TABLES (Cont.)
Table Page
111-21 Land Application to Food-Chain Crops: Economic and Envir- III-126
onmental Comparison Among Alternatives
111-22 Typical Pathogenic Organisms Found in Municipal Treatment III-131
Plant Sludges
111-23 Time and Temperature Relationships for Pathogen Removal to III-141
Non-Detectable Limits
111-24 Typical Design and Operating Parameters for Biological Sludge III-142
Treatments
111-25 Physical-Chemical Sludge Treatments for Pathogen Removal III-143
111-26 Disease: Control Technologies and Unit Costs III-147
111-27 Disease Criterion, Comparison of Annualized Incremental Costs III-149
Based on Disposal Method and Regulatory Alternative
111-28 Disease: Economic and Environmental Comparisons Among Altern- III-150
atives
111-29 Air: Control Technologies and Unit Costs III-156
111-30 Air Criterion, Comparison of Annualized Incremental Costs III-158
Based on Disposal Method and Regulatory Alternative
111-31 Air: Economic and Environmental Comparison Among Alternatives III-159
111-32 Safety: Control Technologies and Unit Costs III-176
111-33 Safety Criterion, Comparison of Annualized Incremental Costs III-178
Based on Disposal Method and Regulatory Alternative
111-34 Safety: Economic and Environmental Comparison Among Alterna- III-179
tives
IV-1 Summary of Major Environmental Benefits IV-10
IV-2 State-Standard-Induced vs. Federally Induced Annualized Costs IV-13
for Landspreading, Landfills, and Surface Impoundments
IV-3 Disposal Method Cost Summation, Upgrade and Closure (Final IV-15
Criteria)
IV-4 Landfill Data Base IV-19
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LIST OF TABLES (Cont.)
Table Page
IV-5 Landfill Technology Costs Per Facility by Facility Size IV-24
IV-6 State-Standard-Induced vs. Federally Induced Annualized IV-25
Landfill Costs
IV-7 Combined Economic Impact of Proposed Regulations for Each IV-26
State and Criterion: All Landfills
IV-8 Combined Economic Impact of Proposed Regulations for Each IV-27
State and Criterion: Municipal Landfills
IV-9 Combined Economic Impact of Proposed Regulations for Each IV-28
State and Criterion: Industrial Landfills
IV-10 Data Base and Cost Summation: Surface Impoundments IV-30
(Closure and Upgrading)
IV-11 Surface Impoundment Technology Costs Per Impoundment by IV-32
Criterion
IV-12 Annualized Cost for Surface Impoundments by Selected Criteria IV-33
IV-13 Total Annualized Costs for Surface Impoundments: Floodplains IV-35
IV-14 Total Annualized Costs for Surface Impoundments: Groundwater IV-36
IV-15 Total Annualized Costs for Surface Impoundments: Safety IV-37
IV-16 Total Annualized Costs for Surface Impoundments: Wetlands IV-38
IV-17 Number of POTW's in the Sample Set Which Cannot Meet the IV-40
Annual Cadmium Limitation
IV-18 Annualized Unit Costs: Food-Chain Landspreading and Altern- IV-42
ative Disposal
IV-19 State-Standard-Induced vs. Federally Induced Annualized Land- IV-41
spreading Costs
IV-20 Well Contamination Case Studies IV-49
IV-21 Major Landfill Gas Incidents IV-53
IV-22 Vegetation Damage From Landfill Gas IV-59
IV-23 Combined Annualized Criteria-Induced and Per Ton Costs IV-67
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LIST OF TABLES (Cont.)
Table Page
IV-24 Incremental Per Capita Upgrading and Closure Costs for IV-68
all Landfills (Federally Induced Annualized Basis)
IV-25 Combined Economic Impact for Each State: Landfills, Surface IV-73
Impoundments, Landspreading
IV-26 States with Highest Percentage of Floodplains IV-74
IV-27 States with Highest Percentage of Wetlands IV-'75
IV-28 Incremental Federally Induced and Combined Compliance Costs: IV-77
All Landfills
IV-29 Industrial Data Base IV-80
IV-30 Industrial Landfills Compliance Costs IV-85
IV-31 Industrial Surface Impoundments Compliance Costs IV-86
IV-32 Total Costs for Each Manufacturing Industry IV-87
IV-33 Compliance Costs as a Percent of Annual Sales for the Manu- IV-88
facturing Industries
IV-34 Environmental Impact Evaluation IV-90
IV-35 Energy Potentially Recoverable from Residential and Commer- IV-94
cial Solid Waste
IV-36 Post-Consumer Waste and Maximum Material Recycle Potentials IV-99
Relative to U.S. Consumption and Production for Selected
Materials, 1971
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LIST OF FIGURES
Page
Major Wetlands 111-17
Water Withdrawn for Drinking Water by Source and Supply, 1970 111-43
Water Withdrawn by Public Water Systems, Mgd. 111-44
How Waste Disposal Practices Contaminate the Ground-Water 111-45
System
III-5 Possible Scheme for On-Site Treatment of Non-Recycled Leachage 111-58
III-6 Distribution of Sludge Quantities by Method of Disposal 111-69
III-7 The Less Restrictive Regulation: Quantities of Sludge in the III-112
Sample Set which Could/Could Not be Food-Chain Landspread
Under Option 1 (Analysis Excludes Chicago)
III-8 The Final Regulation: Quantities of Sludge in the Sample Set III-113
which Could/Could Not be Food-Chain Landspread Under
Option 1 (Analysis Excludes Chicago)
III-9 The More Restrictive Regulation: Quantities of Sludge in the III-114
Sample Set which Could/Could Not be Food-Chain Landspread
Under Option 1 (Analysis Excludes Chicago)
111-10 The Most Restrictive Alternative: Quantities of Sludge in III-115
the Sample Set which Could/Could Not be Food-Chain Land-
spread Under Option 1 (Analysis Excludes Chicago
III-ll Projected Life of Disposal Sites Used by Large, Medium, and III-117
Small POTW's Under Worst-Case Scenario (Analysis Excludes
Chicago)
111-12 Projected Increases in Sewer Charges Paid by 830,613 House- III-121
holds Served by Large POTW's Identified in the Sample Set,
Excluding Chicago (Average Annual Charge before Regulation
is $49.10 per Household
111-13 Projected Increases in Sewer Charges Paid by 239,655 House- III-122
holds Served by Medium-Sized POTW's Identified in the
Sample Set, Excluding Chicago (Average Annual Charge before
Regulation is $55.05 per Household)
111-14 Projected Increases in Sewer Charges Paid by 37,830 House- III-123
holds Served by Small POTW's Identified in the Sample Set
Excluding Chicago. (Average Annual Charge before Regula-
tion is $65.74 per Household)
111-12 Schematic of Gas Control Systems III-170
IV-1 Four Types of Cost Impacts IV-3
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PREAMBLE
EPA published the proposed "Criteria for the Classification of
Solid Waste Disposal Facilities" in the Federal Register on February
6, 1978. These proposed regulations were issued under the authority
of the Solid Waste Disposal Act as amended by the Resource Conser-
vation and Recovery Act of 1976 (P.L. 94-580), and the Federal Water
Pollution Control Act as amended by the Clean Water Act of 1977 (P.L.
95-217).
On April 21, 1978, EPA released a Draft Environmental Impact
Statement (DEIS) to accompany the criteria. The DEIS was distributed
to concerned citizens, Federal agencies. State and local governments,
solid waste and other professional associations, public and environ-
mental interest groups, and trade associations. Public comment was
solicited for both the criteria and the DEIS, with the comment period
ending on June 30, 1978.
At the time the DEIS was written, the criteria included a classi-
fication for Environmentally Sensitive Areas (ESA's). In subsequent
drafts of the criteria, the components of ESA's have been either re-
designated as floodplains or critical habitats, included as a part of
the surface water or ground-water criteria, or eliminated. However,
the summary response to the comments, shown below, addresses the ESA
criteria as originally written since that was the context in which the
comments were received.
A large number of comments was received concerning the DEIS, all
of which have been considered in the development of the Final EIS
(FEIS). This summary addresses major concerns related to the DEIS
as expressed by commenters, and is organized according to the follow-
ing outline:
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I. By Disposal Facility Type
A. Landfills
1. General
2. Ground Water and Surface Water
3. Environmentally Sensitive Areas (ESA's)
B. Surface Impoundments
1. General
2. ESA's
3. Surface Water
4. Ground Water
5. Air
6. Safety
C. Landspreading
1. General
2. ESA's
3. Surface Water
4. Application to Land Use for Production of Food-
Chain Crops
II. By Criteria
A. ESA's
1. General
2. Wetlands
3. Floodplains
B. Surface Water
C. Ground Water
1. General
2. Recharge Zones of Sole-Source Aquifers
D. Air
E. Application to Land Used for the Production of Food-
Chain Crops
F. Disease
G. Safety
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III. General Comments
A. Usefulness of EIS as a Planning Tool
B. Impact Assessment on Industry
C. Neglected Cost Considerations
D. State Solid Waste Regulations
E. Other Federal Regulations
F. Documentation
G. Range of Alternatives
H. Terminology
ill
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I. By Disposal Facility Type
A. Landfills
1. General: Many commenters were concerned with the
validity and accuracy of the data base used to determine the number,
size, and condition of landfills on a State-by-State basis. Also,
various assumptions used to resolve deficiencies in the Waste Age
survey were questioned. Several steps were taken to improve upon the
landfill data base. The 1977 update of the 1976 Waste Age survey was
used, rather than the 1976 survey. However, the DEIS did not include
an assessment of impacts on industrial "on-site" landfills. In the
final EIS, estimates of impacts on industrial "on-site" landfills have
been added to the public sites in the FEIS. This was accomplished by
use of a study by Fred C. Hart Associates entitled, "The Technology,
Prevalence, and Economics of Landfill Disposal of Solid Waste." This
study served as the basis for determining the number of "on-site"
industrial landfills. Additionally, all fifty States were contacted
twice by EPA Regional Offices. The first time, they were asked to
comment on the data base that had been utilized in the DEIS,with thir-
ty States responding. In the second contact, the States were asked to
comment on the data base used in the FEIS and, where possible, to up-
date their figures. Most States responded, and to indicate their com-
ments,the landfill data base has been footnoted with additional quali-
fications provided by the States with respect to the numbers they pro-
vided to the FEIS.
Additional concerns addressed by commenters were the costs
associated with the landfill disposal of dry sludges, the application
of periodic cover materials, and the closure and replacement of ille-
gal sites. Commenters felt that these costs were generally under-
stated. In the FEIS, EPA has made an effort to update these costs
based on: (1) the results of the Hart Study, and (2) in-house EPA
case studies. These revised costs have been included in the FEIS.
iv
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The feasibility of the use of sanitary landfills (defined by the
Act as those landfills which meet the "Criteria for the Classifi-
cation of Solid Waste Disposal Facilities") in rural areas was ques-
tioned because of the high capital cost per ton for waste disposal and
the inability of low-population density rural areas to meet these
costs. The FEIS has addressed this issue, and has included a dis-
cussion of the feasibility of locating sanitary landfills in rural
areas. However, no adjustment has been made in the final cost sum-
mation because there is no distinction made between urban and rural
landfills in these criteria.
2. Ground Water and Surface Water: Commenters requested just-
ification for EIS cost assumptions concerning leachate collection,
treatment, and disposal. Commenters felt that the costs associated
with the collection and treatment of leachate for compliance with the
criteria were prohibitive, particularly in those States not already
mandating at least some degree of leachate collection and treatment.
Further comment was directed toward the assumption that site size
is directly related to the amount of leachate generated. The FEIS has
made use of engineering and technological assessments for costs of
leachate collection and treatment, and has incorporated these costs in
the cost assessment. The FEIS includes a justification for the as-
sumption relating volume of leachate to site size.
Commenters further requested that the justification and rationale
concerning the assumptions on interest rates and NPDES permit costs be
more fully documented. The FEIS includes an explanation of the
interest rate used. However, NPDES permit costs are not addressed
further because of the variations in cost from site to site.
3- ESA's: Some Commenters, particularly those associated with
the electric utilities industry, expressed concern that the EIS did
not address the transportation costs that would be involved
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with hauling waste out of the 100 year floodplain. However, the
impact evaluation of the criteria assesses only the economic impact
on existing disposal facilities. Costs for increased transportation
and other related factors are not considered. Effectively, the EIS :i_s
a static model, and it is not practical to assess such site-specific
issues such as transportation costs.
B. Surface Impoundments
1. General: Considerable comment was submitted concerning
the legitimacy of the surface impoundment data base. All commenters
felt that the estimated number of sites was significantly lower than
the actual number of sites, and certainly lower than the actual number
of impoundments. In response to this criticism, EPA has determined
that the most authoritative and up-to-date source available concerning
the distribution of surface impoundment sites is the Geraghty ard
Miller report, Surface Impoundments and Their Effect on Groundwater
Quality in the United States. Also, the total number of agricultural,
industrial, and municipal impoundments were included in the FEIS,
whereas only the industrial impoundments were included in the DEIS. In
an effort to maximize State input to the surface impoundment numbers,
the EPA Regional Offices provided States the opportunity to revise the
Geraghty and Miller surface impoundment data and to comment on the
data base prior to inclusion in the Final EIS. The data base as
presented has been footnoted with State qualifications and concerns.
These revisions are included in the FEIS.
An additional concern expressed by commenters was the validity of
the size categories for surface impoundments. Commenters felt that it
would be difficult to accurately express costs given that surface
impoundments range in size from less than one acre to 1,300 acres.
In the FEIS, size categories were determined based on a general
appraisal of commonly occurring site sizes. Two such sizes were used
to represent the existing situation -2.5 acre and 50 acre facilities.
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In the absence of any better data on sizes of impoundments, these
sizes were believed to be reasonably representative.
Some commenters felt that the cost burden to energy and energy-
related industries could significantly alter the supply, mix, and
price of energy. Although this comment may be valid, it is not
possible to designate which effects can be attributed to the criteria
and which effects can be attributed to other factors in the overall
energy picture. Therefore, the Agency simply states that the supply,
mix, and price of energy may be altered, and that this may be due, in
part, to the implementation of the criteria. The criteria have been,
however, assessed with respect to their compatibility with the
National Energy Plan.
An additional assunption which was questioned concerned the
assertion that those surface impoundments not located in ESA's would
be upgraded rather than closed. The Agency has determined that the
purpose of the EIS is to assess compliance costs, and closure is con-
sidered in those cases in which it is mandated by the criteria, or
when the criteria would make site location in a particular highly
unlikely. The rationale for each case is discussed in the text of the
FEIS.
2. ESA's: Commenters questioned the ElS-asserted
impacts of surface impoundments of floodplains and wetlands, and the
necessity of site closure in these areas. Commenters felt that tech-
nologies exist, or could be developed, which would allow site location
in floodplains and wetlands that would control adverse environmental
impacts. EPA maintains that these areas are natural assets which are
especially ecologically productive, and are particularly vulnerable to
the adverse effects of waste disposal. EPA acknowledges that techno-
logies exist which would provide sufficient protection of floodplains
and wetlands from adverse effects and provide compliance with the
final criteria to the disposal facilities. For this reason, one
hundred percent closure of surface impoundments was not considered
necessary. Under the final criteria, site location in wetlands is
governed by the Clean Water Act.
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3. Surface Water: Some commenters felt that the EIS
discussion concerning adverse impacts on surface water from industrial
wastewater impoundments assumed that any leakage into surface waters
would be harmful. EPA has determined that most industrial wastewaters
have an adverse environmental impact, and the FEIS will not address
this issue further. Site-specific determinations may be made, however,
as all industrial discharges to surface waters require an NPDES permit.
4. Ground Water; Commenters requested justification
for the DEIS assumption that 50% of all surface impoundments would
require lining to comply with the ground-water criterion. This per-
centage has been re-evaluated, and an estimate based upon EPA indus-
trial studies has been made. The FEIS provides the rationale for this
estimation.
5. Air: Commenters suggested that the control of
emissions from surface impoundments by evaporation, sublimation, and
oxidation should be addressed more fully. EPA has determined that it
is technologically infeasible, given resource constraints and the
current state-of-the-art, to measure environmental impacts of emis-
sions by evaporation, sublimation, and oxidation from surface impound-
ments. At this time, the impact is assumed by the Agency to be mini-
mal,and therefore it will not be expressed more explicitly in the FEIS.
6. Safety: Commenters requested justification for
the assumption that 50% of all surface impoundments outside ESA's
would incur costs for compliance with the safety criterion. This
assumption has been re-evaluated, and an updated assumption, based
upon EPA industrial studies of surface impoundment conditions, is
provided in the economic impact assessment portion of this FEIS.
C. Landspreading
1. General: Commenters questioned the data base used
for determining landspreading costs. The Agency recognizes the valid-
ity of this criticism, and has made an effort to improve this data
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base through verification and the addition of information on other
landspreading facilities.
Additional comments addressed the concern that restrictions
placed on landspreading operations would result in increased demands
for other types of disposal methods. The FEIS considers the costs of
landfill, thermal processing, composting, and landspreading to non-
agricultural lands when cities are precluded from landspreading to
food-chain croplands.
2. ESA's: Some commenters felt that a total ban
of landspreading operations in ESA's would result in an undue burden
on those making use of such ESA disposal, particularly because some
wastes when landspread have little or no adverse environmental
impact. The electric utility industry was particularly concerned
about this ban.
3. Surface Water: Several commenters requested
documentation of surface water contamination resulting from land-
spreading operations. The FEIS references several documents which
support this assertion (Ref. 202 and 203) .
4. application to Land Used for the Production of
Food-Chain Crops: Some commenters expressed serious reservations
concerning the ability to monitor cadmium retention in soil and uptake
in food-chain crops. Because the final criteria do not require such
monitoring, this is not an issue in the FEIS.
Several comraenters felt that heavy metals other than cadmium
have an adverse impact on human health, and that these other heavy
metals should be addressed. The EIS has been modified to more
thoroughly discuss the effects of these metals. However, the Agency's
position is that cadmium represents the most serious hazard because:
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(1) the concentrations found in some municipal sludges are quite sub-
stantial, (2) cadmium is readily accessible to plants at the pH and
soil conditions commonly utilized for application of sludges to agri-
cultural lands, and (3) cadmium tends to accumulate in soil and
certain animal tissue, and thus, poses long-term health risks. As
more data become available, EPA intends to develop criteria for other
heavy metals.
Some concern was expressed about the economic and technological
ability of municipalities to effectively reduce cadmium levels in
municipal sludge. The FEIS presents an analysis of the effects pre-
treatment programs are expected to have on the amount of cadmium
in sludge.
II. By Criterion
A. ESA's
1. General: Many comments were received concerning the
DEIS discussion of (1) recharge zones of sole-source aquifers; and
(2) permafrost areas. Permafrost areas are no longer addressed by the
Criteria, so no discussion of these areas is included in the FEIS.
The section concerning recharge zones of sole-source aquifers has been
dropped from the ESA criteria, and is now addressed in the ground
water criteria as discussed below.
Some commenters questioned the land-area based approach taken
in the DEIS for apportioning facilities to ESA and non-ESA areas. The
Agency considers this a particularly valid criticism, and the FEIS
reflects a new approach for determining facility location. This
approach, derived in part from the Fred C. Hart landfill study, is
based upon the percentage of population in these areas, rather than
being based on land area alone.
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2. Wetlands: Commenters questioned the validity of
defining wetlands area based on an outdated 1956 study. Although
there is currently underway a National Wetlands Inventory, it is not
yet complete. Therefore, there is at present no U.S. wetland nap that
supercedes the 1956 USFWS circular 39 map.
Additional comment was directed towards the control technology
for wetlands, described in the DEIS as a 10-foot dike or levee.
Commenters expressed concern that this control technology was not
appropriate to wetlands, as the ecological danger in these areas
results from inundation from below facilities, not over the top. The
Agency has responded to this criticism by ensuring that the appropri-
ate control technologies to prevent inundation from below are included
in the cost assessments. However, these costs are more appropriately
attributed to ground water.
The wetlands section of the ESA criteria is addressed in the
final criteria as a subsection of the surface water criteria.
3. Floodplains: Commenters were concerned that the
floodplains discussion would be more appropriate if site-specific
considerations were included. Many noted that some floodplains areas
are already protected by dikes and dams, and that compliance costs for
these facilities should not be included in the economic assessment.
However, the criteria state that all disposal facilities located in
the 100 year floodplain are "designed, operated and constructed" to
protect against over-the-top inundation by floodwaters. For this
reason, all facilities located in floodplains will be required to
utilize appropriate control technologies. The FEIS bases floodplains
costs on this assumption since no data exist on the number of facilit-
ies which currently have floodplains control technology.
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Commenters also took exception to the DEIS contention that
dividing the total floodplains area in half would reduce the likeli-
hood of double counting areas that are both wetlands and floodplains.
This same approach is taken in the FEIS, for lack of more accurate
data. However, the methodology for determining the number of facili-
ties in floodplains and wetlands was refined in the FEIS, and this new
approach is fully explained.
B. Surface Water:
Commenters noted that the surface water criteria were more
appropriately a function of existing Federal legislation, most notably
the Clean Water Act, EPA agrees, and has adjusted the surface water
discussion accordingly.
C. Ground water:
Commenters felt that the more restrictive alternative to the
criteria was impractical. The FEIS offers a
more restrictive alternative that lies between zero discharge and the
final criteria.
Additionally, commenters felt that the seriousness of the
problems related to ground-water contamination warranted an expanded
discussion in the DEIS. Statistics on contamination caused by disposal
facilities have been presented to highlight these problems.
Some commenters questioned measurement techniques used in assess-
ing ground-water quality and requested further explanation. Ground-
water quality often times is not monitored until drinking water con-
tamination has occurred. The EIS describes the techniques used for
effective monitoring.
Some commenters concluded that the more restrictive alternative
did not offer measurable ecological benefits. EPA disagrees with this
comment and feels that by allowing no degradation of usable ground-
xii
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water, whether on-site or off-site, a positive environmental impact
can be realized.
Additional comment was received concerning the lack of substan-
tive discussion on the dangers of polluting recharge zones of sole-
source aquifers. The FEIS has expanded the discussion of this area.
D. Air
Comraenters suggested that the FEIS should further describe
the extent and types of air pollution created through current solid
waste disposal practices. The FEIS specifically discusses the degra-
dation of air quality due to current practices. Data are provided to
document the discussion.
E. Application to Land Used for the Production of Food-Chain
Crops
Commenters asked that EPA justify the assunption that the
criteria for pathogens, pesticides, and persistent organics rfould have
minimal impacts. Both the criteria and the EIS have been significantly
revised in these areas.
F. Disease
Commenters stated that the DEIS did not consider that a
large majority of industrial wastes do not contain putrescible faateri-
als, and therefore, do not support disease vectors. EPA acknowledges
this and has accordingly adjusted the economic impact of the disease
criteria.
G.
Some commenters felt that the technologies for controlling
bird hazards at airports near solid waste disposal facilities were not
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adequately explored. In response to FAA Order 5200.5, "FAA Guidance
Concerning Sanitary Landfills On or Near Airports," which states that
landfills may be incompatible with safe flight operations, EPA has
addressed the various methods of controlling bird populations at land-
fill facilities.
Site-specific studies will be necessary to determine the extent
of the bird hazards problem so that the appropriate control technology
may be used. The control technologies discussed in the FEIS, includ-
ing the application of additional cover material or bird repellants,
present an accurate state-of-the-art view of bird hazards control.
Some commenters questioned the existence of a market for methane
gas. Although the technology for recovering gas from solid wastes is
not yet economically practical, there is no question that the market
for methane gas exists. The FEIS asserts that the criteria would
encourage methane gas recovery. The Agency stands by this assumption.
III. GENERAL COMMENTS
A. Usefulness of the EIS as a Planning Tool
Commenters stated that the DEIS presented a justification
for the proposed criteria rather than a decision-making tool for their
promulgation. During the period June 30, 1978 through January 31,
1979, EPA examined several alternative definitions of the criteria and
determined the environmental impacts of these variations. To this
extent,the EIS was used as a planning tool in finalizing the criteria.
Beyond that, EPA maintains that the purpose of the EIS/EIA is to
objectively assess the environmental effects of the criteria and to
estimate the costs to comply with these criteria. The FEIS fulfills
these objectives.
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Commenters brought forth specific issues concerning land use and
resource planning. Some suggested that, in order to make a more
accurate determination of the Federally-induced impacts, EPA should
project changes in land and resource use that might occur as a result
of the criteria. EPA maintains that it is not within the scope of the
SIS to make projections on any shifts in land, resource and economic
conditions which presently exist. Therefore, the EIS does not address
these issues in detail.
B. Impact Assessment on Industry
Many commenters were concerned with the deficiencies in the
industrial data base, and they felt that the assumptions which were
based on this data base caused a significant understating of industri-
al impacts resulting from compliance with the criteria. Based on a
study by Fred C. Hart Associates of on-site industrial landfills,
costs associated with on-site industrial landfill compliance have been
estimated. These costs add the component of the "impact on industry"
which was missing from the DEIS. Using this approach offers a reason-
able assessment of the impact on industry for upgrading on-property
disposal sites. There remains, however, no assessment of the impacts
on industry due to the landspreading criteria. This is because the
overwhelming majority of problem sludges being applied to food-chain
crops is not from industry but from municipal wastewater treatment
plants. To arrive at more reliable estimates, industry would have to
supply better data on numbers, sizes, and conditions of their disposal
facility sites.
C. Neglected Cost Considerations
Most commenters felt that, in general, cost appraisals were
deficient. This feeling has been attributed to the questionable valid-
ity of the 1976 Waste Age Survey and to the many assumptions which had
to be made where reliable data were lacking. First, the Waste Age
survey has been updated. Next, EPA has undertaken several steps to
improve the data base, as described in Section I.A. of this summary.
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Since the DEIS was released in April 1978, additional studies and
surveys of disposal facilities have been conducted. Based upon these
studies, and studies used in the DEIS, many methodological procedures
and assumptions have been revised in the FEIS.
Commenters felt that several other areas need additional consid-
eration in the EIS cost assessments: (1) monitoring costs; (2) clo-
sure costs for abandoned sites; and (3) transportation costs. EPA has
determined that (1) and (2) are valid cost considerations, and they
have been included in the final cost assessments. Transportation costs
have not, however, (except for the landspreading criteria, in which
costs for alternative disposal are included) because these are im-
pacts resulting from the need for alternative disposal.
D. State Solid Waste Regulations
Commenters were concerned that the comparison of State
regulations to the criteria for determining current State compliance
was incomplete, as only solid waste regulations were examined. Com-
menters pointed out that State regulations other than those dealing
exclusively with solid waste are applicable as well, particularly with
regard to landspreading and surface impoundment operations. The
FEIS includes a more comprehensive assessment of State regulations
concerning surface impoundments, accomplished through additional re-
search of State regulations, and contact with State agencies for
clarification and verification when necessary. The Agency has not
performed an extensive analysis of the degree of compliance with State
landspreading regulations because (1) most State programs are early in
their implementation stages and (2) the total cost impact of the land-
spreading criteria is quite low, therefore, the precise amount as
State-induced versus Federally-induced is not crucial.
Commenters suggested that EPA should not assume that permitted
disposal facilities comply with State regulations where State regu-
lations exist. EPA maintains that where a State regulation exists,
compliance with that regulation should also exist. Any costs to
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comply with a State regulation have not been attributed to the final
criteria, but are instead State-induced costs. All facilities permit-
ted by a State, unless otherwise indicated, are assumed to be in
compliance with that State's regulations.
E. Other Federal Regulations and Actions
Commenters felt that the criteria would impact on a number
of existing Federal laws, regulations, and actions, and that this
issue should be addressed in the DEIS. The Agency has determined that
there is some degree of interface with other Federal laws and actions,
specifically (1) Federal mining laws and regulations; (2) Federal
energy laws; (3) the Clean Air Act; (4) the Clean Water Act; and (5)
the National Energy Plan. The FEIS addresses this interface, in the
areas where it has been determined to exist.
F. Documentation
The use of undocumented statements and unpublished materials
in the DEIS were areas of particular concern to many commenters.
Considerable effort has been made in the preparation of the FEIS to
document all previously undocumented statements. In addition, any
unpublished reports used in the preparation of the FEIS are available
for public inspection upon request to the Agency.
G. Range of Alternatives
Commenters felt that the approach taken in the DEIS for
different alternatives to the criteria was not satisfactory, because
the alternatives represented impractical and unrealistic extremes
allowing unlimited pollution, and forbidding all pollution. The Agency
has determined that the range of alternatives offered in the DEIS was
not realistic. For this reason, the FEIS includes alternatives which
differ incrementally from the final criteria, rather than by such
extremes, where such an incremental distinction was possible.
xvii
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H. Terminology
Confusion concerning much of the terminology used in the
DEIS was expressed by several commenters. For this reason, the FEIS
includes a glossary of terms and acronyms used in an effort to facili-
tate an understanding of the EIS language.
xviii
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COMMENTERS RESPONDING TO DRAFT EIS FOR CLASSIFICATION OF
SOLID WASTE DISPOSAL FACILITIES
Fred C. Hart Associates, Inc.
United States EPA, Region I
United States EPA, Region V
United States EPA, Region VI
United States EPA, Region VIII
United States EPA, Region X
U.S. Department of Energy
U.S. Department of HEW
U.S. Department of the Interior
U.S. Department of Commerce
Environmental Defense Fund
Environmental Action Foundation
League of Women Voters of the U.S.
National Solid Wastes Management Association
Harding-Lawson Associates
National Food Processors Association
Public Service Indiana
American Petroleum Institute
John Sexton Contractors
American Petroleum Institute
Wald, Harkrader & Ross
American Consulting Engineers Council
American Consulting Engineers Council, National Society of
Professional Engineers from a meeting with John Skinner
Dow Chemical U.S.A.
General Portland, Inc.
Edison Electric Institute
Waste Management, Inc.
Pennsylvania Power & Light Company
Browning - Ferris Industries, Inc.
Professional Engineers in Private Practice
Camp Dresser & McKee, Inc.
Pickard and Anderson
Malcolm Pirnie, Inc.
Commonwealth of Kentucky, Department for Natural Resources and
Environmental Protection
New York State Department of Environmental Conservation
Commonwealth of Pennsylvania, Department of Environmental Resources
State of Wisconsin, Department of Natural Resources
xix
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Missouri Department of Natural Resources
Metropolitan Sewerage District of the County of Milwaukee
Weld Co. Colorado, Office of Board of County Commissioners
The Metropolitan Sanitary District of Greater Chicago
Los Angeles/Orange County Metropolitan Area Regional Wastewater
Society Management Program
State of New Jersey, Department of the Public Advocate
Indiana State Board of Health
Oregon Department of Environmental Quality
University of Wisconsin, Cooperative Extension Programs
Minnesota Pollution Control Agency
Washington State, Department of Ecology
Alaska Department of Environmental Conservation
Virgin Islands Government, Division of Solid Waste
South Carolina Department of Health and Environmental Control
Texas Department of Health
Public Hearings on the Proposed "Classification Criteria for Solid
Waste Disposal Facilities"
Portland, Oregon, April 26, 1978
San Diego, California, March 1, 1978
Cincinnati, Ohio, June 5, 1978
Kansas City, Missouri, April 24, 1978
Washington, D.C., April 21, 1978
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I. EXECUTIVE SUMMARY
This Environmental Impact Statement (EIS) identifies the adverse
effects from improper solid waste disposal facilities and practices,
and it summarizes the major regulatory alternatives considered in
the development of minimum national standards to mitigate or prev-
ent these adverse effects. It also summarizes the environmental,
economic, and other impacts of major regulatory alternatives.
It is to be noted that this is a voluntary environmental
and economic impact analysis. This EIS is not required by the
National Environmental Policy Act but provides information pertinent
to the development and use of this regulation. During the develop-
ment of the proposed regulation in late 1977 and early 1978, the draft
EIS was used to assist in the evaluation of alternative approaches.
Subsequently, when all of the public comments were received and
reviewed on the proposed regulation and the Draft EIS, the final EIS
was used as an instrument to assist in evaluating alternatives as
the criteria were changed. Where comments on the proposed criteria
were included with comments on the draft EIS, they are being con-
sidered only in the final rulemaking process. Those comments will be
addressed in the preamble to the final criteria and are therefore not
included in this EIS.
The purpose of this Executive Summary is to familiarize the
reader with (1) the contents of this environmental impact statement,
(2) the purpose, coverage, and content of this regulation and (3)
the regulation's major environmental, economic, equity, and other
impacts. Also discussed are the regulatory development process, regu-
latory alternatives considered, data gaps, and key assumptions.
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A. DESCRIPTION OF ACTION
In the February 6, 1978 Federal Register, EPA published for
public review "Criteria for Classification of Solid Waste Disposal
Facilities" and in April, 1978, the Draft EIS was also published.
Public comments were accepted until June 12, 1978 on the criteria and
until June 30, 1978 on the Draft EIS. Subsequently, the criteria*
were promulgated on September 13, 1979 (44 Federal Reg. 33438).
1. Legal Basis
The criteria are promulgated under the statutory authorities of
Sections 1008(a) (3) and 4004(a) of the Solid Waste Disposal Act as
amended by the Resource Conservation and Recovery Act (RCRA) of 1976
(Public Law 94-580), and Section 405(d) of the Federal Water Pollution
Control Act (FWPCA) as amended by the Clean Water Act (CWA) of 1977
(Public Law 95-217).
2. Purpose of the Regulation
RCRA mandates that the regulations are to contain minimum
criteria for determining which solid waste disposal facilities shall
be classified as posing no reasonable probability of adverse effects
on health or the environment. Facilities not meeting the criteria are
classified as open dumps, and must be closed or upgraded according
to a State-established compliance schedule. Under Section 405 of
the CWA, EPA is to develop guidelines for the disposal or utilization
of sludge. The criteria are proraulagated as partial fulfillment of
this requirement. All public wastewater treatment works owners and
operators who dispose of or utilize sludge on the land must comply
with the criteria.
*These regulations are hereinafter referred to as the "criteria." The
full text of the criteria appear in Appendix A. In addition, pre-
sented in Appendix A is the Preamble to the criteria a background
discussion and explanation, including a review of public comments on
the draft version of the criteria.
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Solid waste management is vital to the protection of public
health and the environment (e.g., Ref. 72) and solid waste disposal
facilities are a necessary component of solid waste management. Even
with increased resource and energy recovery systems there will be a
need for solid waste disposal facilities. Yet, for political and
other reasons, suitable new solid waste disposal facilities are often
very difficult to obtain. For the protection of public health and the
environment, it is important to ensure that disposal facilities are
available, that new sites can be obtained, and that the available
sites are located, designed, constructed, operated, and maintained so
as to protect the environment. To assist in the development of new
disposal facilities, the criteria have been written to provide that
facilities which comply with the criteria do not adversely affect
public health or the environment.
Chapter II reviews (1) the solid waste disposal criteria re-
quirements and implementation provisions, (2) RCRA's legislative
history and intent, and (3) the mandate of the CWA for proper sludge
disposal or utilization.
3. Coverage
The criteria apply to all facilities for the "disposal" of
"solid waste" as these terms are defined in RCRA, including landfills,
dumps, surface impoundments (ponds, pits, and lagoons), and land-
spreading facilities. Certain agricultural, raining, radioactive, and
other wastes and facilities are excluded, however, as discussed in
Chapter II.
4. Adverse Environmental Impacts (Problem Identification)
The first step in developing the criteria was to identify all
the adverse effects of improper solid waste disposal and their rela-
tive impacts on health and the environment. The adverse effects of
improper solid waste disposal are numerous. The criteria specifically
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include the concern for adverse effects on floodplains, endangered
species, ground-water and surface water resources, air, and food-chain
crops. In addition, improperly operated disposal facilities may
harbor disease and pathogens, or they may pose safety hazards in the
forms of explosive gases and fires. These adverse effects and the
importance of the affected resource are summarized in Chapter II,
and discussed in Chapter III together with regulatory alternatives de-
signed to prevent or minimize them.
5. Regulatory Approach/Regulatory Alternatives
In developing the criteria, EPA recognized that there are many
factors which must be considered in determining if there may be am
adverse impact, what the magnitude of the impact may be, and what
regulatory options exist to effectively control the impact. Many of
the factors vary from one facility to another; including climate,
hydrology, geology, the amount and types of wastes, and ground-water
and surface water proximity and usage. Because the criteria are
basically a State-enforced standard, an important goal in developing
the criteria was to be as specific as possible, without reducing
the flexibility of State solid waste management and enforcement
agencies to take into account site-by-site variations and make assess-
ments based on local conditions.
In particular, two types of regulatory options were identified
and evaluated: environmental performance standards and operational
standards. EPA decided to establish environmental performance
standards for each potential adverse environmental effect of improper
disposal, and to use operational standards in addition where they were
necessary to clarify how the performance standard is to be achieved.
In all cases where a specific operational technology or standard was
specified, it was addressed in a manner so as not to inhibit the
advancement of technology development or to preclude the use of other
equally effective site-specific technologies.
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The final criteria,* a more restrictive alternative, and a less
restrictive alternative for each adverse effect are analyzed in depth
in Chapter III.
a. Relevant Federal Laws
In order to avoid duplication, inconsistencies, and
confusion, the criteria utilize other Federal regulations or
approaches where appropriate. For example, the floodplains criteria
utilize the guidance and approaches of the Water Resources Council the
surface water criteria parallel the approach of the permitting and
planning programs of the Clean Water Act, administered by the EPA and
the Corps of Engineers along with State and regional agencies; and
the ground-water criteria utilize provisions of the Safe Drinking
Water Act.
«
A listing of relevant Federal laws and regulations is presented
in Chapter II.
b. Technical Feasibility
Even when operational standards were not specified, the EIS
presents design and operational technology available to be used to
achieve the environmental performance standard or goal specified. The
technology feasibility evaluation included an assessment of current
usage, reliability, unit costs, and effectiveness. The major control
technologies identified for each criterion are summarized in the
section entitled "Summary Technology, Economic, and Environmental Im-
pact Analysis" at the end of the discussion of each criterion in
Chapter III.
c. Environmental Benefits vs. Economic and Equity Impacts
Once the technological feasibility was determined, the
environmental benefits were compared to the economic (both cost and
* 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 DiseaseSewage Sludge and Septic Tank
Pumpings (under Section 257.3-5 and 257.3-6(b), respectively) are of
an interim final status.
1-5
-------
benefit) and equity impacts for each major regulatory alternative.
6. Chronology of Alternative Development
EPA's consideration of alternative approaches to developing the
required criteria was evidenced by the following action:
(1) Solicitation of comments on a May 12, 1977 draft of
the criteria
(2) Publication of "Advance Notice of Proposed Rulemaking,"
July 5, 1977 (Ref. 58)
(3) Solicitation of Comments on "Proposed Classification
CriteriaSolid Waste Disposal Facilities," published
February 6, 1978
(4) Solicitation of comments on "Draft Environmental Impact
Statement, Criteria for Classification of Solid Waste
Disposal Facilities," published April 1978
The comments received were reviewed and debated, and both the
criteria and EIS were modified to reflect concerns posed by the
'commenters. The summary of these responses to comments appears in the
Preamble of this EIS. During the period June, 1978, through August,
1979, thf- economic impacts of various criteria alternatives were cal-
culated to provide an assessment of the estimated cost of criteria
implementation.
1-6
-------
7. The Criteria
The final regulation contains criteria which address the
following:
(1) Floodplains
(2) Endangered Species
(3) Surface Water
(4) Ground Water
(5) Application to Land Used for the Production of Food-
chain Crops
(6) Disease
(7) Air
(8) Safety (explosive gases, fires, bird hazards to
aircraft, and access).
The final criteria are presented in full in Appendix A.
8. Basic Data
In order to make rational decisions concerning regulatory ap-
proaches and to evaluate their impacts, the following data are needed
for each type of disposal facility (landfill, surface impoundment, and
landspreading):
(1) Number and size of existing facilities
1-7
-------
(2) Locations and conditions of facilities from which a de-
termination can be made as to the number of facilities
to be upgraded and the number to be closed
(3) Control technologies and unit costs needed to upgrade
existing facilities or for new facilities to comply
with the criteria.
The data base used in developing this EIS is discussed below
and described further in Chapter IV.
9. Data Base and Gaps
Unfortunately, an inventory of disposal facilities does not
exist, but is required by RCRA to be developed after the regul-
ation is finalized. However, information exists on the number and
sizes of municipal landfills, on the amount and characteristics of
municipal sewage sludge which is landspread, on the potential adverse
environmental effects of landfilling, surface impoundments, and land-
spreading, and on the basic technologies which can be used to achieve
specific levels of environmental protection (with the exception,
perhaps, of groundwater protection). Unfortunately, a number of
assumptions had to be made because the following information is
sketchy or not well known:
(1) Number and size of on-site industrial landfills
(2) Number and size of surface impoundments (an estimate--
considered to be incomplete or conservativeis avail-
able on the number of surface impoundments - Reference
107)
(3) Number and size of landspreading operations on food
chain cropland.
1-8
-------
(4) The specific locations and conditions of all categories
of solid waste disposal facilities.
The available data base includes 18,500 landfills by size, 75,705
industrial landfills by SIC code, 271,566 surface impoundments by
type of impoundment and information on sludges generated by more than
350 publicly owned treatment works.
10. Key Assumptions
To fill the data gaps, the following key assumptions were made:
(1) For surface impoundments, two sizes were assumed: 2.5
acres and 50 acres. Five percent of the surface im-
poundments in the industrial group were assumed to be
fifty acres. The remaining 95 percent were assumed to
be 2.5 acres. All other impoundmentsmunicipal and
agriculturalwere assumed to be 2.5 acres.
(2) For surface impoundments, it was assumed fifty percent
in wetland areas would require upgrading to comply with
the ground-water criteria. Twenty-five percent were
assumed to require upgrading for the access component
of the safety criteria.
(3) All municipal landfills were grouped in one of the fol-
lowing three categories: (a) permitted, (b) authorized,
and (c) illegal. The following assumptions for defini-
tions werere made regarding these categories:
a. Permitted facilities were assumed to comply with
State regulations and their condition was assumed
to be a function of the extent to which the
State's solid waste regulations comply with the
criteria. Thus, the costs for these facilities
1-9
-------
to comply with the criteria is the amount of up-
grading needed on a criterion-by-criterion ba-
sis for the difference between the current State
regulations and the criteria.
b. Authorized facilities are assumed to meet current
State regulations except those for existing
ground-water and surface water standards. The
costs for the authorized facilities to comply with
the criteria are the same as for the permitted
facilities (based on any differences between the
State standard and the criteria), plus any addi-
tional costs necessary to comply with the ground-
water and surface water criteria.
c. Illegal facilities are assumed to be open dumps;
these require closing under RCRA within 5 years.
(4) All on-site industrial landfills are assumed to require
upgrading for each criterion, except for the gas
component of the safety criteria and the disease cri-
teria. Ten percent were assumed to require upgrading
for these criteria.
(5) The number of facilities in a floodplain or wetland is
related to the amount of population and land within a
State that can be classified as floodplain or wetland.
(6) A minimum landspreading application rate of 10 metric
tons of sludge per hectare (10 mt/ha) per year was
utilized as the lowest economically viable rate.
(7) The floodplain criteria do not impact landspreading
operations.
1-10
-------
(8) Upgraded landfill and surface impoundment facilities
have an average site life of 10 years.
The data base, assumptions, and methodology are discussed in more
detail in Chapters III and IV.
B. RESULTS OF IMPACT ANALYSES
The disposal of solid wastes has been grouped into three general
disposal methods for purposes of identifying environmental and econo-
mic impacts. These categories are landfills, landspreading, and sur-
face impoundments (pits, ponds, and lagoons).
1. Environmental Benefits
The benefits to be obtained by the final criteria include the
prevention or minimization of adverse impacts at new facilities and
their gradual elimination or reduction at present disposal facilities.
Some of the specific benefits include:
reduction of the potential for causing an increase in
flooding and pollution problems from landfills in flood-
plains;
protection of threatened and endangered species;
reduction in surface water (including wetlands) pollu-
tion from solid waste disposal;
reduction in ground-water resource damage from leachate
pollution;
improvements in air quality near landfills;
1-11
-------
restrictions on the application of harmful substances
to lands producing food-chain crops;
improvements in both public and occupational health and
safety in and near landfills;
control of explosive gases;
reduction in bird hazards to aircraft;
reduction in fire and smoke hazards; and
controlled access to solid waste disposal facilities.
Table 1-1 summarizes the magnitude of the anticipated national
environmental benefits or improvements as a result of the criteria and
as contrasted to the more and less restrictive alternatives presented
in Chapter III. In general, the more restrictive alternatives ace
bans on disposal in specific areas or zero degradation and the less
restrictive are status quo or do not address the adverse impact. Cn
some areas, no alternative to the final was considerated practical.
Although subjective, these assessments take into consideration (1) the
condition of existing facilities, (2) the anticipated average improve-
ment per facility and (3) the number of facilities.
The major national environmental benefits of the criteria are:
the protection of wetlands and groundwater from unsound landfills, and
surface impoundments, gas control at landfills, and the control of
harmful substances entering the food chain as a result of solid waste
landspreading. The criteria achieve approximately the same magnitude
of national environmental benefit as the more restrictive alternative,
with the exception of the landspreading options, for which more and
most restrictive alternatives are considered.
At this point, it is important to note that new landfills and
surface impoundments being permitted by the States comply with most,if
not all, of the criteria.Therefore, the impact of the criteria on such
new facilities is expected to be minimal. In the case of landfills or
1-12
-------
CO CX
i-3 tn
1-13
-------
surface impoundments, the table of environmental benefits refers only
to existing conditions which States and facility owners and operators
are already gradually upgrading or eliminating. As discussed earlier,
solid waste disposal facilities are a necessity. Unless alternative
facilities can be located and developed, old ones cannot be shut down.
Therefore, achieving some environmental improvements can be a very
slow process. In addition to being a slow process, the reason these
improvements have not already been achieved is that attention to solid
waste disposal and groundwater protection, including land use/ground-
water use planning, are recent developments in the environmental arena.
2. Economic Impacts
It is very important to note that RCRA does not provide EPA with
enforcement authority for the criteria. However State solid waste
management agencies which receive Federal funds under RCRA Section
4008, must include in their plans requirements for solid waste
(excluding hazardous waste) "to be disposed of in sanitary landfills
(within the meaning of 4004(a)...n. Inasmuch as EPA does not have
enforcement authority for 4004, the States are the implementation
mechanism.
The RCRA also requires EPA to publish an inventory of all solid
waste disposal facilities in the United States that do not comply with
the criteria. However, RCRA does not authorize EPA to conduct
evaluations of facilities for the inventory. Therefore, EPA plans to
develop the inventory by funding State agencies to conduct the
facility evaluations.
Inevitably, the States will move to implement the criteria in a
voluntary manner predicated upon both the monetary and manpower
resources available. It is noteworthy that the total amount of
Federal funds which a State receives will be very small as compared to
the financial requirements necessary to fully implement the criteria.
1-14
-------
Therefore/ the potential economic impact of the criteria is de-
pendent on the extent and timing of implementation which each State
pursues and, in turn, will be a function of Federal financial assis-
tance; particularly, funding of the open, dump inventory.
The Agency surveyed the States in an endeavor to assess the
likely extent and timing of implements-ion. The survey was premised
upon the assumption that Federal financial support would continue for
a five-year period at the FY79 funding level. However, the Presi-
dent's FY80 budget calls for a gradual phase-out of Federal financial
support over the next five years. Preliminary data received from
thirty-six States suggests that only forty-seven percent of the States
anticipate evaluation of all municipal solid waste disposal facilities
by the end of FY83. Twenty-seven Stages responded concerning indust-
rial solid waste disposal facility evaluations. Eighteen percent
of the twenty-seven States are planning to evaluate all industrial
facilities by FY83, whereas fifty-two percent of these States do not
expect to begin until after FY83. Current data suggest that approxi-
mately eighty-four percent of the solid waste disposal facilities are
industrial. Therefore, it is apparent that only a small por-
tion of the total number of disposal facilities will be evaluated by
FY83 .
The economic impacts of the criteria have been analyzed, and
costs were determined on both a National, as well as a State, basis
for the purposes of this EIS. These costs were based on the assump-
tion that all disposal facilities will be evaluated against the
criteria, and that all open dumps would be closed or upgraded. There-
fore the costs which have been calculated are representative of a
highest-cost or full compliance situation. However, as stated
earlier, due to limited Federal financial assistance to the States,
much less than full compliance costs e_re anticipated. Furthermore,
much of the cost required for solid waste disposal facilities to meet
the performance goals established by the criteria are actually State-
1-15
-------
induced costs. Many States have existing regulations and programs
with which disposal facilities must first comply. Costs above and
beyond State-induced costs for bringing disposal facilities into com-
pliance with the criteria are Federally induced costs. The economic
impact is based upon bringing only existing facilities into com-
pliance.
The economic impacts have been determined for the final criteria,
a more restrictive regulatory alternative and a less restrictive
alternative. The economic impact of each regulatory alternative was
determined for each disposal method and each criterion.
In order to develop the economic impacts, a "typical" or "average"
condition was assumed for various sizes of each type of disposal
facility/ and then the technologies required as well as the associated
unit costs to comply with the criteria were developed for each site
size category for each disposal type. This was done for the final
criteria, a more restrictive, a less restrictive, and, in the case of
landspreading, a most restrictive regulatory alternative.
Table 1-2 summarizes typical control technologies used to
estimate costs for the final regulatory alternatives for each criterion;
these technologies are discussed briefly in the summary economic and
environmental impact analysis sections in Chapter III.
Some of the results of the economic analyses are shown in Table
1-3 and discussed below. These are annualized costs using first
quarter 1978 unit costs and based on the assumption that upgraded
facilities have a facility life of 10 years, except for landsoreading
facilities for which a ten-year planning period is assumed.
Please note that the economic impact analyses presents the costs
attributable to criteria implementation. However, these costs
were not utilized to determine the regulatory alternatives to be
considered during the criteria development.
1-16
-------
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1-18
-------
It is obvious from this Table that the ground-water criteria re-
sult in the greatest impact, by far, for both landfills and surface
impoundments. This is because high capital costs are being incurred
by a very large number of facilities for upgrading. For landfills,
the next greatest impact is caused by the gas component of the safety
criteria. Again, a large number of facilities are required to incur
a high capital cost for venting and gas removal.
For both landfills and surface impoundments, the next most im-
portant impacts are due to the floodplains criteria. Again, the large
number of facilities in floodplains, for which levees have to be built
is the reason for the high cost impacts.
a. State-Standard-Induced Costs vs Federally Induced Costs
As mentioned previously in the environmental benefits sec-
tion, disposal facility owners and operators are already upgrading
facilities and opening new facilities which comply with State regu-
ations which are often as stringent as the criteria and other Federal
regulations (with the possible exception of landspreading facilities).
It is unknown if or how much the Federal criteria (which are to be
primarily enforced through voluntary, phased State programs) will
speed up or strengthen the State regulation compliance process.
Because of this, the total additional cost to bring facilities into
compliance was divided into two components: State-standard-induced
costs and Federally induced costs.
To do this, existing State regulations for landfills and surface
impoundments were compared to the criteria and the more and less
restrictive regulatory options. Existing State regulations for these
types of facilities were also compared to current facility conditions.
The cost of meeting the criteria was then calculated as follows:
(1) the additional costs necessary for facilities to comply with
existing State regulations (State-standard-induced costs), (2) the
additional cost to meet the criteria in those cases where the
Federal regulations are more stringent than existing state regulations
(Federally induced costs), and (3) the combined costs. In other words,
1-19
-------
the costs assigned to the criteria are those costs beyond the costs
necessary to bring existing facilities into compliance with existing
State regulations, and combined costs are the total incremental costs
to bring existing facilities into compliance with both State regula-
tions and the Federal criteria. In the case of landspreading facili-
ties, 10% of the combined costs were arbitrarily assumed to be State-
induced. This low percentage reflects the early implementation stages
of most state regulatory programs for landspreading facilities.
Table 1-4 shows the annualized cost impacts of the criteria for
each of the three cost categories Federally-induced, State-stan-
dard-induced, and total or combined costs.
In the "Cost Categories" column of Table 4 "Federal" refers to
Federally- induced costs; "State" refers to State-standard-induced
costs.
As indicated earlier, Federally-induced costs are the additional
annualized costs required for disposal facilities to comply with the
criteria above the costs needed to comply with existing State stan-
dards. State-standard-induced costs are the additional annualized
costs required for facilities to comply with existing State standards.
Combined costs represent the sum of the State-standard-induced and
Federally induced costs.
"Closure" costs, as shown in Table 1-4, reflect the cost of ap-
plying certain minimum requirements to close existing illegal land-
fills. In regard to surface impoundments, closure costs were in-
cluded in the costs for each criterion. No closure costs apply to
landspreading operations.
In sum, the annualized economic impact for all three disposal
methods is $5.0 billion, of which $1.3 billion is attributable to
the Federal criteria and $3.7 billion is due to State standards.
1-20
-------
TABLE 1-4
ANNUALIZED ODST IMPACTS OF CRITERIA BASED UEON FULL COMPLIANCE
(Millions of Dollars)
CRITERIA
Flood-
Plains
Ground
Water
Air
Land
Applica-
tion
Disease
Safety
Closure
TOTAL
Other
Regs:
Surface
water
-Wetlands
Total
COST
CATEGORIES
Federal
State
Combined
Federal
State
Combined
Federal
State
Combined
Federal
State
Combined
Federal
State
Combined
Federal
State
Combined
Federal
State
Combined
Federal
State
Combined
Federal
State
Combined
Federal
State
Combined
Federal
State
Combined
DISPOSAL METHOD
SURFACE LAND
LANDFILL IMPOUNDMENTS APPLICATION
81.7
80.3
162.0
302.6
1467.7
1770.3
17.6
109.0
126.6
0
0
19.8
19.8
195.6
87.8
283.4
72.3
0
72.3
669.8
1764.6
2434.4
5.4
145.5
150.9
62.4
19.6
82.0
67.8
165.1
232.9
166.7
88.4
255.1
484.9
1812.5
2297.4
0
0
0
3.5
19.8
23.3
Included in
Costs for
Each
Criterion
655.0
1920.6
2575.6
0
111.6
8.2
119.9
111.6
8.2
119.8
0
0
0
6.2
.7
6.9
0
0
0
6.2
.7
6.9
0
0
0
COST
CATEGORIES TOTAL
TOTAL COST
248.4
168.7
417.1 417.1
787.5
3280'2 4067.6
4067.6
17.6
109.0 126.6
126.6
6.2
.7 6.9
6.9
0
19.8 19.8
19.8
199.0
107.6 306.6
306.6
72.3
0 72.3
72.3
1331.0
3685.9 5016.9
5016.9
5.4
145.5 150.9
150.9
174.0
27.8 201.8
201.8
179.4
173.3 352.7
352.7
1-21
-------
b. Impacts on Disposal Types
Table 1-5 summarizes the economic impact of the criteria by
disposal method.
TABLE 1-5
NATIONAL ANNUALIZED FULL COMPLIANCE COST SUMMARY OF CRITERIA
(Millions of Dollars)
Disposal State-Standard-
Method Induced Costs
Landfill
Surface Impoundments
Landspreading
TOTAL
1764.6
1920.6
.7
$3685.9
Federally Induced Combined
Costs Costs
669.8
655.0
6.2
$1331.0
2434.4
2575.6
6.9
$5016.9
Fifty-one percent ($2575.6 million) of the annualized combined
costs for upgrading or closure is for surface impoundments. Forty-
eight percent is for landfills ($2434.4 million), and less than one
percent is for landspreading ($6.9 million).
In regard to landfills, for the highest cost full-compliance
scenarios, the Federally induced costs for upgrading will increase the
national cost of disposal by an average of $1.65 per ton; the combined
increase (State-standard-induced plus Federally induced) is $5.99 per
ton. On a per capita basis, the national incremental Federally in-
duced cost for landfill closure and upgrading is $3.04 per year.
1-22
-------
It is important to break out the "municipal" portion of the land-
fill data from the on-site industrial. If this is done, the impacts
are $328.5 million of Federally induced costs,$154.3 million of State-
induced costs, and $482.8 million in total impacts for municipal land-
fills. This is shown also in Table 1-6.
TABLE 1-6
NATIONAL ANNUALIZED COST SUMMARY
FOR MUNICIPAL AND INDUSTRIAL LANDFILLS
(Millions of Dollars)
State-Standard-
Induced Costs
Municipal
Landfills
Industrial
Landfills
TOTAL LANDSFILLS
$154.3
$1610.3
$1764.6
Federally Induced Combined
Costs Costs
$328.5
$341.3
$669.8
$482.8
$1951.6
$2434.4
Several conclusions result from Table 1-6. First, most of
the landfill impact (80%) is due to on-site industrial landfills.
There are three major reasons for this:
There are a large number of them (75,705 as opposed to
18,500 municipal);
It is assumed that they all will be upgraded (except
for the gas and disease criteria);
They exist mostly in states with State standards which
equal or exceed the federal criteria.
1-23
-------
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1-24
-------
c. Final criteria vs. More Restrictive vs. Less Restrictive
Alternatives
The definitions of the more and less restrictive alterna-
tives for each criterion are presented in Chapter III; control tech-
niques and unit costs for each regulatory alternative are presented in
Chapters III and IV and discussed in detail in the Appendix.
Table 1-7 shows a summary of the less restrictive, final, and more
restrictive combined annualized costs for each criterion. Note
that the costs of the final criteria are about 60% of the costs for the
more restrictive alternative, whereas the environmental benefits of the
final criteria are similar to the more restrictive benefits (ithe the
possible exception of the food-chain land criterion).
The costs of each regulatory alternative are compared below for
each disposal method.
Landfills. The combined annualized cost of the less
restrictive alternative would be $603.9 million while
the combined annualized cost of the more restrictive
alternative would be $4.6 billion.
- Surface Impoundments. The combined annualized cost of
the more restrictive alternatives would be $3378.0
million while the combined annualized cost of the less
restrictive alternative would be $339.8 million.
Landspreading. The combined annualized cost of the
more restrictive alternative would be $10.7
million while the less restrictive alternative incurs
a cost of $4.0 million.(A most restrictive alternative,
with a cost of $25.3 million, was also examined.)
1-25
-------
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In total, the combined annualized cost of the less restrictive
alternative would be $1 billion; the combined annualized cost of
the more restrictive alternatives would be $ 8 billion. These changes
in cost can be compared with the respective changes in environmental
benefit summarized previously in Section Bl.
d. Cost-Centers of the Criteria
As previously discussed, landfills will incur forty-eight
percent of the combined costs. Also,the State-standard-induced costs
are seventy-four percent of the combined costs, while the Criteria-
induced are only twenty-six percent of the combined costs.
The major cost centers (Table 1-4) are the ground-water criteria
for landfills at thirty-five percent($1770.3 million) of the total com-
bined costs; the ground-water criteria for surface impoundments at
forty-six percent ($2297.4 million); the safety criteria for landfills
(mostly gas controls) at six percent ($283.4 million); and the flood-
plains criteria for surface impoundments at five percent
($255.1 million).
The relative impacts of the criteria on each disposal method are
shown in Table 1-8 by criterion. The major cost centers for landfills
are ground water (72.7%), and safety mostly gas controls (11.6%).
For surface impoundments, the major cost centers are ground water
(89.1%) and floodplains (9.9%). For landspreading, almost all of the
cost impact will be the land application to food chain crop lands
criterion.
e. Economic Benefits
A listing of potential economic benefits is provided in
Chapter IV, Section D. The only economic benefits which were quanti-
fied were protection of ground-water resources used for drinking water
supplies, and benefits resulting from a reduction in methane gas
1-27
-------
explosions. Based on a number of well-contamination case studies, and
a number of very conservative assumptions, the total national benefit
for damage avoidance, and administrative cost for ground water ranges
from $134 million to $668 million and for corrective costs, $3.6
billion. Based on a number of methane gas explosions at landfills
throughout the country, and assumptions concerning the number of
affected facilities, the total national benefit for avoidance of
structural damage, loss of use or occupancy, and injury or death,
ranges between $14 million and $720 million. The definitions of these
terms and the associated assumptions are also given in Chapter IV,
Section D. Note that these are total costs, not annualized costs.
The ground-water benefits are conservatively estimated since, as the
demand for clean water increases and as the supply of clean water
diminishes (by nonpoint source contamination, reduction in recharge
areas, and overpumping, etc.), the value of clean water will increase.
3. Equity Impacts
The equity impacts of the criteria are discussed in Chapter IV E.
The differing impacts of the criteria on rural areas, specific geo-
graphic areas (regions), States, and industry, are summarized below.
a. Urban/Rural Community Impacts
An important equity consideration in developing the criteria
was whether the economic impact of the criteria on rural communities
(users of disposal facilities) would be unreasonable. Of major
concern in assessing this impact were landfills and food chain land-
spreading sites which receive municipal wastes. The criteria as
finalized do not apply to agricultural wastes returned to the soil
as fertilizers or soil conditioners. On-site industrial landfills
and surface impoundments impact consumers of products and services
rather than rural vs. urban communities per se. The major conclusions
were:
1-28
-------
In general, rural landfills are smaller than urban land-
fills in terms of tons per day. However, some land-
fills serving urban communities are rurally located,
and some regional rural landfills are large.
Large facilities are able to obtain economies of scale,
which decrease the cost impacts per capita and per ton
of solid waste disposed.
On the other hand, large urban facilities generally
need more expensive environmental controls than smaller
and more remote facilites. Smaller, remote facilities
generally do not have the leachate and gas production
and control problems that larger facilities have. The
concern at smaller, remote facilites is generally
limited to control of disease and exposure to wastes
both of which can be controlled by periodic application
of cover material. Remote facilities are frequently
cheaper to obtain and engineer than facilities of
equivalent sizes in urban areas. Thus there are some
diseconomies for large and/or urban facilities, but
on a cost per ton basis for compliance with the
criteria, the economies of scale still exist.
In rural areas, economies of scale can be achieved by
(1) development of larger regional landfills, and (2)
rotational use of equipment from one landfill to the
next. Both approaches achieve better use of landfill
equipment, but result in increased transportation
costs. In the first case, longer solid waste haul dis-
tances result. However, many rural areas have effec-
tively demonstrated the use of "green box" systems(bulk
bins or transfer stations along rural roads) to mini-
mize individual haul distances and costs. In many
1-29
-------
cases, urban areas have remote landfills, with 20 to
50-mile haul distances or with congested urban streets
to lengthen haul time, and must likewise resort to
transfer operations to reduce haul costs. In the
second case, a transportation cost is incurred to move
the disposal equipment from one landfill to the next;
but again, several rural communities have effectively
demonstrated the economic viability of such an
approach.
Although on the average urban communities use the land-
spreading option sparingly, where it is used the
cadmium landspreading criterion will have a signi-
ficant impact because cadmium contamination of the
sludges by industry will preclude use of landspreading
as an option.
Historically rural communities have paid more than
urban communities for sludge disposal on a unit cost
basis. Implementation of the landspreading criteria
will probably not affect this experienced distribution
of costs.
The final open burning ban is not expected to cause an
economic hardship in rural areas, since evidence shows
that burning putrescible wastes does not eliminate or
reduce the need to cover the residue where disease
vectors are a problem. The only advantage of open
burning is volume reduction. But with cover material
needed anyway (and therefore the equipment to apply
it), and with space and cover material generally more
available in rural areas, the economic impact of a
burning ban is minimal.
In those States (either rural or urban) which have
adopted stringent regulations, the Federally induced
impact is minimal, and therefore the greatest impact
generally occurs where current regulations are less
stringent than the criteria. This factor probably im-
pacts costs more than does the rural/urban factor.
Also, hydrogeologic setting impacts costs more than the
rural/urban factor.
Given the relatively low income base in many rural
areas, expenditures for acceptable landfills may im-
1-30
-------
pose more of a financial burden in some rural commun-
ities as compared with urban communities.
In conclusion, assuming the highest cost, full compliance
scenario, the impact of the criteria on rural communities is con-
sidered to be quite burdensome. For rural areas to meet their
waste disposal needs and to comply with the criteria, greater
regionalization than already exists will be necessary in order to
realize the economies of scale evident in larger disposal opera-
tions.
b. Regions Impacted by Specific Criteria
The wetlands component of the surface water criteria
effects mainly the low-lying coastal regions, particularly the
Southeast, from Louisiana to Florida to South Carolina.
The criteria for protecting ground water have the greatest econo-
mic impacts on landfills in those regions with poor ground water
quality and with high rates of precipitation, causing large quantities
of leachate which must be controlled. Regions where leachate genera-
tion is a problem are in the Pacific Northwest, and east of the
Mississippi River. Poor ground-water quality is a problem in the
Midwest. Surface impoundments will be impacted in the eastern coal
and steel regions because of high rates of precipitation in these
areas, and in the south-central oil and gas regions, because of their
poor ground water quality.
Throughout much of the Atlantic and Gulf Coast Plain, a high
ground-water table is encountered within permeable sandy deposits.
A difficult and costly technical problem to contend with in these re-
gions is the isolation of refuse from shallow ground water.
The landspreading criteria will have a greater impact on regions
east of the Mississippi because more acid soils are typically found
in these regions; requiring more lime addition for soil conditioning.
c. States
From the above discussion, it can be seen that waste dis-
posal operators in certain States may be impacted more than others
from the criteria;
1-31
-------
States located in the low, coastal areas of the south-
eastern and western parts of the country (Florida,
Louisiana, South Carolina, Georgia, and California),
and along the floodplain areas of the Mississippi River
(Illinois and Arkansas) will be significantly impacted
by the floodplains criteria and the wetlands component
of the surface water criteria.
States located in the eastern and southeastern parts of
the country receive relatively high levels of rainfall,
and experience relatively low rates of evapotranspira-
tion. As a result, the general component of the sur-
face-water criteria will have a substantial impact in
these States.
States that rely heavily on ground water as a source of
drinking water will be impacted significantly by the
ground-water criteria.
Highly industrialized States in the northern Great
Lakes region (Ohio, Illinois, and Michigan) and in the
northeast (Pennsylvania and New York), will be impacted
significantly by the ground-water criteria and the
general component of the surface water criteria.
These States generate substantial quantities of indus-
trial wastes (some hazardous). Industrial impoundments
and landfills in these States are expected to require
upgrading to comply with these criteria.
Those States whose disposal practices and solid-waste
legislation reflect more concern for environmental
protection have already made upgrading expenditures
and therefore are expected to have a smaller
incremental cost to comply with the criteria.
1-32
-------
The total cost impact for each State, due to these overlapping
impacts, is presented in Table 1-9 and discussed further in Chapter
IV.
d. Manufacturing Industries
The main effects on the manufacturing industries derive from
the impact of the criteria on landfills and surface impoundments
for ground water, safety and from the impact of other Federal regu-
lations, specifically those dealing with the discharge of point and
nonpoint source pollutants to surface water. The total cost of upgrad-
ing and closure for surface impoundments in the manufacturing indus-
tries is $81.5 million, of which the Food Processing industry pays
$23.1 million (28%) and the Chemical and Allied Products industries
pay $14.4 million (18%). These same two industrial groups pay 29% and
18%, respectively of the total compliance burden of other Federal reg-
ulations, dealing with surface waters, which cause a cost burden to
the manufacturing industries of $3.0 million. For landfills, the total
cost of upgrading is $1957.7 million, of which the Non-Electrical ma-
chinery group pays $716.8 million (37%) and the Wood Products group
pays $210.9 million (11%). For other Federal regulations (surface
water) these groups pay 37% and 11% of the total compliance cost of
$189.3 million.
The impacts of the criteria on the manufacturing industries are
better illustrated by considering the cost of compliance as a per-
centage of each industrial group's total annual sales. This is illus-
trated by Table 1-10. Overall, the total manufacturing industries
compliance burden (for all of the manufacturing industries) is less
than half of one percent of their total annual sales (.189%).
Direct industrial impacts were not assessed for the landspreading
criteria but it is likely that implementation of the Cadmium
restrictions will stimulate the increased development of local pre-
treatment ordinances, resulting in costs to selected industries 'e.g.,
electroplaters).
1-33
-------
TABLE 1-9
DISPOSAL METHOD COST SUMMATION
UPGRADE & CLOSURE (FINAL CRITERIA)
(THOUSAND DOLLARS)
^I_OAMA
^'_-i\.\
- '-CAA
-A'-:.5AS
CAL: roR-'IIA
COLORADO
co-.'NEcrrcuT
3ELJ.-.HZ
rLORIDA
:IORC:A
--^AII
; SI/ID
:--L::.SI,
-~r"
^:s\s
.r:7T~:
_JCIS;A;U
.- :::i
. '.r_0!D
.,is,c-'.'sirrs
ic-.ic.j-
* : " isoift
"TSSISS:??!
issoc?.:
C-JT.J.A
EBJLo'fCi
I"*DA
r- ^-.^sz^
r .;ssr.
~ "co
.Zl VOKi
csrti C,SOL;:U
'.ORT£ DAKOTA
0-10
X'_^-.C-1A
-r?JIG3.N
'I-.-Nsr.VASIA
;-MO^ ISL^KD
."OIT." CAROLINA
>0..7r< 2Ai:OTA
- ,2!:i:
- -li
r xH
-- ;.-
; ^CIN'IA
-«SnI"CTO'J
-^37 .:RC;TIA
I SCONS IN
-~. ^ ^iNf;
T07ii
LASDFTU.
40,686
11.429
6,081
30,438
59.616
8.6i5
55. '15
5.154
92.198
71.702
7,309
5.858
151 , 200
97.234
13.224
53.630
13,783
25.634
22.782
54.943
169.112
53.901
29.742
15.5SO
3 , 1^1
12.301
1.510
10.650
108 . 134
i 1.033
249.265
69,541
5,682
110.732
10,324
36.508
110.392
19.956
32.828
5,355
51.393
37,263
9.S68
* 751
36.262
51.149
17,440
loi, up
J.327
2.131,398
SDTtFACt
:MpocxsM£:rr
22.31-
;,osi
2.791
2S.673
i7.110
121.233
12,776
UJiS
1.7.707
22.745
2.332
9.350
55 373
16 302
20.320
.-1.233
30.211
318.193
12.317
10.325
2.653
68 . iS7
27.211
30.520
26,733
10.543
66.904
T >-> 1
2.920
5,308
165 ,306
17 .230
33.627
73.979
305.291
-3,121
12. -12
137,221
993
19.077
12.073
14,965
196,383
15.500
11.162
i
17.391
43,530
16,261
12? 323
2,575.665
*
LANGS?RZAD
(Noc
-,denci£i»d
by 3 tact)
i
1
I
6,900
TOTAL
62,820
15,180
8.872
57.111
106,726
129.928
68.191
7,002
139,905
94,447
9.641
15.208
206 .573
115,512
117,554
o>- ,-o*
133,891
361.976
38.151
33.107
87.596
237,299
81.112
60.362
72.313
15, -92
79 ,205
3.731
13.570
113.942
176,511
266,495
1 03 . 1 68
79.661
146.073
59.218
48.920
277.613
20.949
51.905
17,433
66.358
233.546
25.368
20 223
30.656
69.040
60,970
117.131
113.155
5,016,963
07HE3 DERAL RIC'JLATIONS
'LiTdfiLi a surf. Ino.)
4.184
2.858
1.524
6.721
20,651
5,225
4.090
530
19.312
9,071
>95 ,
1.372
11.770
5.606
6,368
6, .46
5.142
13.705
2.209
1.942
6, l->6
16,705
S,3i3
,
5.019
4.198
5.107
416
788
8,035
'"-
17,859
8.684
10.627
15,953
3.250
3.166
12.580
1,520
5,122
2.259
1.118
18.098
3.256
656
3,639
4,532
2.1,5
10.641
3.236
352,632
1-34
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TABLE 1-10
COMPLIANCE COSTS AS A PERCENT OF ANNUAL SALES
FOR THE MANUFACTURING INDUSTRIES
SIC
20
21
22
23
24
25
26
28
29
30
31
32
33
34
35
36
37
38
39
Compliance Cost Annual Sales*
Industry (Millions) (Millions)
Food/Kindred Products
Tobacco
Textile Mill Products
Apparel
Lumber/Wood Products
Furniture
Paper/Allied Products
Chemical/Allied
Products
Petroleum
Rubber/Plastics
Leather Products
Stone/Clay/Glass
Primary Metals
Fabricated Metals
Non-Electrical
Machinery
Electrical Machinery
Transportation
Equipment
Instruments
Mi seel laneous
Manufacturing
TOTAL
*Source: Census of Manufacturing,
199.4
2.1
53.6
155.1
236.4
56.2
43.1
146.2
19.5
0.8
5.2
110.6
44.2
186.2
787.5
1.3
54.6
35.1
94.6
2231.6
"Current
180,929.7
36,389.2
34,758.4
23,129.4
14,232.0
48,218.1
104,138.6
82,347.0
31,765.2
7,176.0
30,635.2
93,001.8
77,507.1
105,525.2
73,867.1
141,025.5
25,030.1
16,285.9
1,177,585.9
Industry Reports",
Percentage
.110%
.023
.147
.446
.792
.395
.089
.140
.024
.003
.072
.361
.048
.240
.746
.002
.039
.140
.581
.189
Table 1, 1976.
1-35
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4 . Other Impacts
In addition to the above impacts, the EIS looked at irreversible
and irretrievable impacts, short and long-term effects (Chapter IV,
Section F), and materials and energy impacts (Chapter IV, Section G).
The major conclusions are:
(1) improper solid waste disposal practices addressed by
the criteria which may result in long-term, often
irreversible, adverse impacts are: destruction of
productive wetlands; reduction in temporary flood
retaining capacities of floodplains, or restricting
the flow of flood waters; destruction of habitats of
endangered species; contamination of food-chain crop
lands; and contamination of ground water, including
sole source aquifers.
(2) by requiring gas controls, the criteria will encourage
methane recovery from the larger landfills.
(3) by increasing the cost of land disposal to achieve a
specific level of environmental quality, the criteria
will encourage energy and material recovery systems
by making them more economically competitive.
(4) The food-chain landspreading criteria may result in an
irretrievable commitment of land if the dedicated
facility approach to cadmium control is opted for by a
particular community. Future uses of this land would
be greatly restricted.
In summary, the criteria will cause wide ranging compliance costs
to be incurred in government and the private sector, with significant
environmental benefits resulting as well.
1-36
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II. INTRODUCTION
A. LEGAL BASIS FOR ACTION
The "Criteria for Classification of Solid Waste Disposal
Facilities" (40 CFR Part 257) are being promulgated under the
authorities of Sections 1008(a)(3) and 4004(a) of the Solid Waste
Disposal Act as amended by the Resource Conservation and Pecovery
Act of 1976 (Public Law 94-580, 90 Stat. 2803 and 2815, 42 U.S.C.
6907(a)(3) and 6944(a)) and Section 405(d) of the Federal Water
Pollution Control Act as amended by the Clean Water Act of 1977
(Public Law 95-217).
1. Legislative Intent
The Resource Conservation and Recovery Act (RCRA) was signed
into law on October 21, 1976, amending the original Solid Waste
Disposal Act of 1965. Of particular concern to Congress were:
(1) Protection of public health and the environment
from solid waste disposal (both hazardous and non-
hazardous wastes)
(2) Plugging the loophole left by other environ-
mentally oriented Federal laws and regulations
(now land and ground-water protection in addition
to surface water and air protection)
(3) Proper disposal of the increasing amounts of
pollution control residuals destined for land
disposal (e.g., as a result of the Clean Air Act
and Clean Water Act)
(4) Resource conservation and recovery.
II-l
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In fact, the House of Representatives' Committee on Inter-
state and Foreign Commerce in Report 94-1491 wrote:
The committee believes that the approach taken by this
legislation eliminates the last remaining loophole in
environmental laws, that of unregulated land disposal
of discarded materials and hazardous wastes. Further,
the Committee believes that this legislation is neces-
sary if other environmental laws are to be both cost
and environmentally effective. At present, the Federal
government is spending billions of dollars to remove
pollutants from the air and water, only to dispose of
such pollutants in an environmentally unsound manner.
The existing methods of land disposal often result in
air pollution, subsurface leachate, and surface runoff,
which affect air and water quality. This legislation
will eliminate this problem and permit the environ-
mental laws to function in a coordinated and effective
way" (Ref. 79, p. 44).
In keeping with the Congressional intent, resource conserva-
tion and recovery are among the highest priorities with EPA;
therefore, practices such as the landspreading of waste materials
in environmentally safe ways are strongly encouraged. The
criteria encourage the implementation of controlled practices
while prohibiting practices that pose a substantial risk to
public health or the environment.
a. Adverse Impacts of Past Disposal Practices
Solid wastes, sometimes referred to as discarded mater-
ials or residual wastes, include residential, commercial, indus-
trial, wastewater treatment sludges, agricultural, and mining
discards and may be solid, semi-liquid, liquid, or contained
qaseous wastes. They are commonly disposed of on the land In
dumps, landfills, ponds, pits or lagoons, or by landspreading.
The ultimate disposal of solid wastes on the land in an
environmentally sound manner is a rapidly increasing problem.
The environmental and economic impacts of improperly located,
designed, operated, monitored, and controlled disposal facilities
II-2
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are sure to increase on a national level, and to be quite severe
on local and regional levels. In developing the RCFA and Clean
Water Act (CWA) legislation, Congress identified a number of
adverse effects from improper solid-waste disposal or utilization
on the land, and a number of factors which are exacerbating the
problems .
This increase in the importance and severity of the solid
waste disposal problem is a result of several factors. First,
more wastes are being disposed of on the land. Population
increases, economic growth, and affluence are accompanied by
increased annual production of residual wastes and pollution
control residues. In addition, legislative mandates are
producing more solid wastes by requiring reductions or elimin-
ations of traditional air and water disposal "sinks" and
requiring higher levels of treatment.
Second, many new, frequently exotic, and often toxic solid
wastes are being produced as a result of chemical research and
new materials productions.
Third, there has been a general lack of control of solid
waste facilities in the United States, including hazardous waste
disoosal, especially for ground-water protection. There has been
very little monitoring of solid waste disposal facilities, indis-
criminant dumping frequently occurs, and until the past few years
there has been no effective Federal legislation for the protec-
tion of around water from solid waste disposal facilities.
Fourth, because of the amount of time before facilities
reach field capacity and produce leachate, the long-term produc-
tion of leachate and the slow movement of ground water, the
impacts of land disposal facilities may not be realized until
years after deposition and are long-term in duration. This means
that closed facilities and new facilities have a cumulative
effect on water resources.
II-3
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The specific adverse effects of environmentally unsound dis-
posal facilities can be grouped into eight categories of impacts:
floodplains, endangered and threatened species, surface water,
ground water, air quality, land used for food-chain crops, dis-
ease, and safety. In essence, the criteria delineate both
performance and operational requirements to eliminate a reason-
able chance of adverse effects on health and environment from
disposal of discarded material at a solid waste disposal
facility.
Floodplains have been prime locations for industrial
disposal facilities historically because many industries have
located along the rivers of the nation. Facilities located in
the 100-year floodplain can be diked for adequate protection.
Endangered and threatened species may be subjected to
the adverse effects of improper disposal of solid waste, experi-
encing habitat destruction, excessive killing, and poisoning from
toxic substances.
Surface water can also be adversely affected by certain
disposal practices. Without proper controls of runoff, surface
leachate, leachate treatment effluent, and non-channeled leachate
seeps, these flows have entered surface waters and caused con-
tamination of water supplies and significant environmental damage
(for example, see Pef. 79, p. 38).
Wetlands have been prime locations for disposal facilities
in the past, generally because of less social resistance, their
lower cost, and the practice of selling the site as "reclaimed"
land after the facility's life was over. However, there is an
increasing public awareness that these areas are vital natural
resources of great hydrological and ecological importance.
II-4
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Ground water is perhaps the resource in greatest need
of protection by the criteria because about one-half of the
population depends upon it as a source of drinking water, and
existing regulations or practices for ground-water protection are
inadequate. A recent report to Congress found that waste dis-
posal practices have affected the safety and availability of
around water on a local basis, but that its overall usefulness
has not yet been diminished on a national basis (Ref. 7).
Landspreading of solid waste on food-chain crop land
can have adverse effects on public health and agricultural pro-
ductivity. Some wastes or sludges have high concentrations of
heavy metals or toxic organic substances.
Natural food chains serve as biological amplifiers for many
trace chemicals distributed in our environment. Landspreading of
solid waste on agricultural land is one of the ways toxic sub-
stances, including some potentially carcinogenic materials, have
been introduced into the food chain.
Emissions of pollutants into the air from open burning
are high, compared to controlled combustion. In addition to the
potential health and property damages from air pollution, signi-
ficant safety and damage threats caused by smoke and fire are
associated with open burning.
Improper solid waste disposal can also create safety
hazards, including hazards from explosive, toxic, or asphyxiating
gases, fires, bird hazards to aircraft, and access. The House
Peport on RCRA (Ref. 79, p. 37) describes a number of examples of
these safety hazards and cites them as a basis for part of the
legislation.
A major gaseous product of solid waste decomposition is
methane. Presence of methane at a disposal facility, in suffi-
cient concentration, can pose a serious threat to the health and
II-5
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welfare of facility employees and users, and occupants of nearby
structures. Explosions and property damages culminating in death
and injury have resulted from methane gas generation.
The threat of property damage and injury or death to facil-
ity employees, users, and nearby residents from fires is all too
evident. Furthermore, funds spent to extinguish such conditions
are often quite high.
Birds may be attracted to disposal facilities which receive
putrescible wastes, thereby creating hazards when such facilities
are located near airports.
Solid waste disposal facilities can also cause injury or
death to persons on the site (whether in a work capacity or by
trespassing) due to accidental or intentional fires, excavations
and earth-moving activities, operation of heavy equipment and
haul vehicles, and hazards associated with the types of waste
deposited there.
Finally, disposal facilities are conducive to the breeding
of rats, fleas, flies, mosquitos, and other vermin. Conse-
quently, there is a need to minimize the propagation of disease.
b. Prohibition of Such Practices
After identifying the adverse effects of improper solid
waste disposal. Congress developed a program to correct these
problems. The RCRA-established program to eliminate unacceptable
disposal activities specifies:
(1) EPA is to develop criteria which define acceptable
solid-waste disposal facilities and practices (Section:?
1008(a) (3) and 4004 (a)} .
II-6
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(2) All facilities which do not meet EPA's criteria are
classified as open dumps (Sections 4004(a) and
4005(a) ) .
(3) EPA is to publish an inventory of all open dumps in the
U.S. (Section 4005(b)).
(4) Open dumping is prohibited (Section 4005(c)) .
(5) States receiving EPA solid-waste grants are to prohibit
the establishment of new open dumps and are to provide
for the closing or upgrading of existing dumps.
(6) Citizen suit and imminent hazard suit provisions enable
other enforcement mechanisms in addition to the State
programs (Sections 7002 and 7003).
The CWA-established program specifies:
(1) EPA is to develop guidelines for the disposal and
utilization of wastewater treatment sludge.
(2) All public treatment works owners and operators must
comply with such guidelines when applicable.
2. Statutory Requirements of PCRA and CWA
Section 1008(a)(3) of RCRA calls for EPA to develop guide-
lines which "provide minimum criteria to be used by the States to
define those solid waste management practices which constitute
the open dumping of solid waste or hazardous waste."
Section 4004(a) calls for EPA to "promulgate regulations
II-7
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containing criteria for determining which facilities shall be
classified as ... posing ... no reasonable probability of adverse
effects on health or the environment from disposal of solid
waste, at such facilities."
Section 405(d) of CWA calls for EPA to develop guidelines
for the disposal and utilization of sludge. Promulgation of the
criteria represents a partial fulfillment of this requirement.
Under Section 405(e), all public treatment works owners and
operators must comply with any applicable guidelines developed by
EPA under Section 405(d). Thus, all public treatment works
owners and operators who dispose of or utilize sludge on the land
must comply with these criteria.
n-e
-------
B. PURPOSE OF REGULATION
1. Minimum National Standards
The purpose of the criteria is to provide minimum national
standards for the protection of health and the environment from
solid waste disposal facilities and practices. The criteria provide
minimum standards for the classification of disposal facilities, to
be used in developing the inventory of open dumps (unacceptable
disposal facilities),
2. Implementation of the Criteria
State solid waste management planning effort, which includes
the inventory of open dumps, is the key to implementation of the
criteria. The inventory process involves evaluating solid waste
disposal facilities against the criteria and determining the
set of facilities which do not comply with the criteria. Since the
inventory process is the precursor to State planning and enforcement
action, it is EPA's intent that the inventory evaluations be con-
ducted by the States, supported by Federal financial assistance.
Since the nature of facilities to be evaluated is large and the
nature of the evaluations complex, EPA proposes to provide guidance
to the States for the progressive, time-phased evaluation of all
disposal facilities for purposes of the inventory. Furthermore, it
is anticipated that a complete inventory will take more than one year
to develop. This proposed guidance is described in "Guidelines for
the Development and Implementation of State Solid Waste Management
Plans" which was proposed in the Federal Register on August 28, 1978
(43 FR 38534).
II-9
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Section 6001 of the Act requires, in part, that Federal agencies
comply with Federal, State, interstate, and local requirements for
control of solid waste disposal in the same manner, and to the same
extent, as any person is subject to such requirements. Thus, the
criteria and the prohibition of open dumping apply also to federal
solid waste disposal facilities.
EPA recognizes the practical difficulties inherent in applying
the criteria to all existing and new disposal facilities. Determina-
tions as to whether facilities pose no reasonable probability of
adverse effects on health or the environment(i.e., whether facilities
comply with the criteria) will require a number of extensive
technical and scientific decisions. This is especially true in deter-
mining the potential for ground-water pollution.
One alternative considered was not to apply certain criteria
(the more difficult criteria to evaluate and correct, such as
gound-water quality goals) to existing facilities. Another alternative
was to phase the application of the criteria to certain disposal types
(essentially exempting classes of disposal facilities initially).
These approaches were rejected by EPA as inconsistent with the stated
goals of RCRA,
Compliance schedules for each disposal facility will consider
severity of environmental consequences, availability and costs of
control equipment, availability of alternative sites, time required to
monitor and determine compliance, and the availability of Federal/
State resources to implement the criteria.
11-10
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Application of the criteria to all types of disposal facil-
ities immediately has several benefits:
(1) In the beginning, it defines the minimum
acceptable levels of disposal for all types of
disposal facilities which will help disposal
facility owners and operators in their planning
and compliance programs.
(2) It aids planning for State and regional solid
waste management agencies.
(3) It minimizes loopholes in EPA's regulatory scheme
to control all land disposal.
(4) It allows the inventory process to be started
immediately for all types of disposal facilities,
which will aid the State and EPA planning programs
as well as improve the inventory efficiency.
11-11
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C. RELEVANT FEDERAL LAWS
The first significant Federal effort in solid waste manage-
ment and resource recovery was initiated with the passage of the
Solid Waste Disposal Act of 1965 (Public Law 89-272). It called
for a research and development program and provided funds to the
States for making surveys of waste disposal practices and for
developing waste disposal plans. The Resource Recovery Act of
1970 (Public Law 91-512) broadened the R&D approach to include
major demonstrations and shifted the emphasis from disposal to
recovery of materials and energy from solid wastes. It also
required several studies and directed the Environmental Protec-
tion Agency to issue guidelines on waste management and recovery
which are mandatory for Federal agencies, but advisory to others.
On October 21, 1976, the Resource Conservation and Recovery
Act of 1976 (Public Law 94-580) became law, amending the original
Solid Waste Disposal Act of 1965. As stated in Section 1003,
"The objectives of this Act are to promote the protection of
health and the environment and conserve valuable material and
energy resources by. . . prohibiting future open dumping on the
land and requiring the conversion of existing open dumps to
facilities which do not pose a danger to the environment or to
health. . ."
Congress was particularly concerned with:
(1) Protecting public health and the environment from
solid waste disposal (both hazardous and non-
hazardous wastes)
(2) Plugging the loopholes left by other environ-
mentally oriented Federal laws and regulations
(now land and ground-water protection in addition
to surface water and air protection)
11-12
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(3) Managing the proper disposal of the increasing
amounts of pollution control residuals destined
for land disposal (e.g., as a result of the Clean
Air Act and clean Water Act)
(4) Implementing resource conservation and recovery.
1. Criteria for Classification of
Solid Waste Disposal Facilities
In the Februrary 6, 1978, Federal Register (43 Fed
4924), EPA published the "Criteria for Classification of
Solid Waste Disposal Facilities" (40 CFR 257)-* The criteria have
been promulgated under the authorities of Sections 1008(a)(3) and
4004(a) of the Solid Waste Disposal Act, as amended by the Resource
Conservation and Recovery Act (RCRA) of 1976 (Public Law 94-480)
and Section 405(d) of the Federal Water Pollution Control Act
(FWPCA), as amended by the Clean Water Act (CWA) of 1977 Public
Law 95-217),
According to RCRA, the regulations are to contain minimum
criteria for determining which solid waste disposal facilities
and practices shall be classified as posing no reasonable probab-
ility of adverse effects on health or the environment. Facilities
not meeting the criteria are classified as open dumps, and the
States are to provide for the closing or upgrading of such
facilities.
a. Basic Provisions of RCRA Pertaining to
Solid Waste Disposal
The basic provisions of RCRA pertaining to solid waste
disposal include the following:
*These regulations are hereinafter referred to as the "criteria. '
The full text of the criteria and the background preamble
appear in Appendix A.
11-13
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(1) EPA is to develop criteria which define unacceptable
solid-waste disposal facilities and practices
(Sections 1008(a)(3) and 4004(a).
(2) All facilities which do not meet EPA's criteria
are classified as open dumps (Sections 400A(a) and
4005(a) ).
(3) EPA is to publish an inventory of all open dumps
in the U.S. (Section 4005(b)).
(4) Open dumping is prohibited (Section 4005(c))-
(5) States receiving EPA solid-waste grants are to
prohibit the establishment of new open dumps and
are to provide for the closing or upgrading of
open dumps.
(6) Citizen suit and imminent hazard suit provisions
enable other enforcement mechanisms in addition
to the State programs (Sections 7002 and 7003).
Section 1008(a)(3) of RCRA calls for EPA to develop guidelines
which "provide minimum criteria to be used by the States to
define those solid waste management practices which constitute
the open dumping of solid waste or hazardous waste." Section
4004(a) calls for EPA to "promulgate regulations containing
criteria for determining which facilities shall be classified
as... posing... no reasonable probability of adverse effects
on health or the enviroment from disposal of solid waste, at
such facilities."
11-14
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b, Basic Provisions of the Clean Water Act
Pertaining to Solid Waste Disposal
The criteria are also promulgated as partial fulfillment
of the requirement contained in Section 405(d) of the Clean Water
Act of 1977 (CWA), which calls for EPA to develop guidelines for
the disposal or utilization of sludge. Under Section 405(e),
all public treatment works owners and operators must comply with
any applicable guidelines developed by EPA under Section 405(d).
Thus all public works owners and operators who dispose or utilize
sludge on the land must comply with these criteria.
c. Other Federal Regulations
Where appropriate EPA sought to coordinate the criteria
with other Federal laws and programs. For example, the surface
water criteria, including wetlands, rely on the NPDES permit
system established for point-source discharge of pollutants under
Section 402 of the Clean Water Act (P. L. 95-217). Also, the
ground-water criteria utilize parameters established by the
Primary Drinking Water Standards.
2. Criteria-Related Federal Laws
There are a number of Federal laws, regulations, and
Executive Orders related to the criteria.
To avoid duplication, inconsistencies or conflicts, the
criteria use existing laws and regulations or approaches wherever
feasible. Table II-I lists the major relevant Federal laws, reg-
ulations, and Executive Orders. Brief summaries of each of these
are presented below.
11-15
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TABLE II-l
RELEVANT FEDERAL LAWS AND REGULATIONS
Criterion
Law/Regulation/Executive Order
Floodplains
Endangered and
Executive Order 11988, Floodplain Management
Public Law 93-205, Endangered Species Act of
Threatened Species 1973 (16 U.S.C. 1530), Sections 4, 7
50 CFR, Part 17, Subpart F, Critical Habitat
Surface Water
General
Wetlands
Ground Water
Public Law 95-217, Clean Water Act (Section
402)
Public Law 95-217, Clean Water Act (Sections
402, 404)
33 CFR Part 323, Permits for Discharges of
Dredged or Fill Material Into Waters of the
U.S.
Executive Order 11900, Protection of Wetlands
Public Law 93-523, Safe Drinking Water Act
Primary Drinking Water Standards
(EPA-570/9-76/003)
Air
Public Law 93-319, Clean Air Act, as amended
11-16
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TABLE II-l (continued)
RELEVANT FEDERAL LAWS AND REGULATIONS
Criterion Law/Regulation/Executive Order
Bird Hazards FAA Order No. 5200.5, FAA Guidance Concerning
Sanitary Landfills On or Near Airports
General 40 CFR Part 241, Guidelines for the Land
Disposal of Solid Wastes
11-17
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a. Floodplains
The floodplains criteria comply with Executive
Order 11988, "Floodplain Management." The Order's approach is to
bring Federal regulations and procedures into conformity with the
provisions of the "United National Program for Floodplain Manage-
ment" of the Water Resource Council (ref. 87).
The Executive Order seeks "to avoid, to the extent possible,
the long- and short-term adverse impacts associated with the
occupancy and modification of floodplains, and to avoid direct or
indirect support of floodplain development wherever there is a
practicable alternative," by providing leadership and taking
action "to reduce the risk of flood loss, to minimize the impact
of floods on human safety, and to restore and preserve the
natural and beneficial values served by floodplains (Ref. 87)."
b. Endangered and Threatened Species
Under the Endangered Species fret of 1973 (Public Law
93-205), all Federal agencies are required to cooperate in the
conservation of endangered and threatened species. Section 7 of
the Act states that:
The Secretary [of Interior] shall review other
programs administered by him and utilize such pro-
grams in furtherance of the purposes of this Act.
All other Federal departments and agencies shall,
in consultation with and with the assistance of
the Secretary, utilize their authorities in
furtherance of the purposes of this Act by
carrying out programs for the conservation of
endangered species and threatened species listed
pursuant to Section 4 of this Act, and by taking
such action necessary to insure that actions
authorized, funded, or carried out by them do not
jeopardize the continued existence of such
endangered species and threatened species or
result in the destruction or modification of the
habitat of such species which is determined by the
SecretaryT after consultation as appropriate with
the affected States, to be critical" (Emphasis
added) .
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The Secretaries of Interior and Commerce requested the coop-
eration of other Federal agencies in implementing this act
(December 3, 1974); a mechanism has been established for deter-
mining the "critical habitat" for endangered and threatened
species pursuant to Section 7 of the Endangered Species Act of
1973 (see Federal Register, April 22, 1975, 40 CFR 17764-17765).
Proposed regulations have been issued which define "critical
habitat" as:
Any air, land or water area (exclusive of those
existing man-made structures or settlements which
are not necessary to the survival and recovery of
a listed species) or any constituent thereof, the
loss of which would appreciably decrease the like-
lihood of the survival and recovery of a listed
species or a distinct segment of its population.
The constituent elements of critical habitat
include, but are not limited to, physical struc-
ture and topography, biota, climate, human acti-
vity, and the quality and chemical content of
land, water and air. Critical habitat may repre-
sent any portion of the present habitat of a
listed species and may include additional areas
for reasonable population expansion.
In addition, the term "modification" cited above was changed
to mean "adverse modification," which has been defined as:
A direct or indirect alteration of critical
habitat which appreciably diminishes the value of
that habitat for survival and recovery of a listed
species. Such alterations include, but are not
limited to, those diminishing the requirements for
survival and recovery listed in Section 17.94(b).
There are many types of activities which could be
carried out in a critical habitat without causing
such diminution.
11-19
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The Department of Interior has currently designated critical
habitats of the following Species:
Fish - Alabama Cavefish, Slender Chub, Spotfin
Chub, Leopard Darter, Slackwater Darter, Snail
Darter, Yellowfin Madtom, Little Kern Golden Trout
Amphibians and Reptiles - St. Croix Ground Lizard,
Giant Anole, American Crocodile, Pine Barrens
Treefrog, Golden Coqui, Houston Toad, Mona Boa,
Nona Ground Iguana, New Mexican Ridge-nosed
Rattlesnake
Birds - Palila, Yellow-Shouldered Blackbird, Dusky
Seaside Sparrow, Cape Sable Sparrow, Whooping
Crane, California Condor, Florida Everglade Kite,
American Peregrine Falcon, Mississippi Sandhill
Crane
Mammals - Indiana Bat, Morro Bay Kangaroo Rat,
Gray Wolf, Manatee
Plants - Contra Costa Wallflower, Antioch Dunes
Evening Primrose
These habitats may not be used for the disposal of solid
waste unless it is demonstrated that the facility design, con-
struction, operation, and maintenance will not result in the
taking of endangered or threatened species, or result in destruc-
tion or adverse modification of critical habitats.
Surface Water
(1) General
The Clean Water Act requires the development of a
comprehensive coordinated national program to control all sources
of water pollution to meet the goals of swimmable, fishable, and
navigable water. The objective of the Act is to restore and
maintain the natural chemical, physical, and biological integrity
11-20
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of the nation's waters with the intent that the discharge of
pollutants into navigable waters be eliminated by 1985. This
policy, supplemented by other provisions of the Act relative to
the control of toxic pollutants, construction of waste treatment
facilities, research and demonstration, and regional waste
management, provides an overall identification of program goals
and methods of program implementation.
CWA is related to the criteria in four major aspects.
First, in a physical mode, certain sections of CWA and its corre-
sponding regulations result in the increased generation of waste
which will have to be disposed of through one of the following
methods: (1) impounding, (2) subsurface methods, (3) land-
spreading, or (4) resource recovery. Specific portions of CWA
related to the criteria include Sections 208, 301, 303, 304, 402,
and 404.
Of special importance to the generation of wastes are
regulations issued under Section 402 of the CWA, the National
Pollutant Discharge Elimination System (NPDES), which is a permit
system "for the discharge of any pollutant, or combination of
pollutants."
Each point source under CWA must comply with specific
effluent limitations attainable by "Best Practicable Tech-
nology" and "Best Available Technology." Furthermore, these
regulations also detail performance and pretreatment standards
for new sources (40 CFR, Parts 405-460).
Municipal sludges will increase as a result of mandates
under 40 CFR Part 133, "Secondary Treatment," issued under Sec-
tions 304(a)(l) and 301(b) and (c) of the CWA. Specifically,
these regulations require that by July 1977, municipal wastewater
treatment plants three years or older must show secondary treat-
ment capacity. New plants must have secondary treatment capacity
as of July 1983.
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Second, in an institutional/planning mode, Sec-
tion 208(b)(2)(J) and (K) (Area-wide Waste Treatment Management
Plans) places the disposal of residual wastes in a management
planning context. Specifically, this section calls for a "pro-
cess to control the disposition of all residual waste generated
in such areas which could affect water quality," and "a process
to control the disposal of pollutants on land or in subsurface
excavations within such area to protect ground and surface water
Quality."
With the promulgation of the RCRA criteria and subsequent
guidelines for delineating acceptable practices, the efforts of
CWA to promote higher water quality will be considerably
strengthened. To avoid duplication, the criteria rely on NPDES
permits for point-source discharge of pollutants in waters of the
United States (including wetlands).
(2) Wetlands
Executive Order 11990, Protection of Wetlands, was
developed "to avoid, to the extent possible, the long- and short-
term adverse impacts associated with the destruction or modifica-
tion of wetlands and to avoid direct or indirect support of new
construction in wetlands wherever there is a practicable alterna-
tive. To further this end, the Order directs that each agency
shall provide leadership and shall take action to minimize the
destruction, loss or degradation of wetlands, and to preserve and
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enhance the natural and beneficial values of wetlands in carrying
out the agency's responsibilities" (Ref. 40).
The adverse effects of solid waste disposal on wetlands have
been widely studied and noted. The wetlands portion of the cri-
teria for surface water reflects the emerging EPA policy toward
wetlands which complements and enhances this Executive Order.
In the July 19, 1977, Federal Register, the Army Corps of
Engineers published the final regulations for "Permits for Dis-
charae of Dredged or Fill Material Into Waters of the United
States" (33 CFP Part 323).
The authorities for these regulatory programs are based
primarily on Section 404 of the Clean Water act. With regard to
the discharge of solid wastes into wetlands, the definition of
fill material is clarified as follows:
The term fill material means any material used for
the primary purpose of replacing an aquatic area
with dry land or of changing the bottom elevation
of a water-body. The term does not include any
pollutant discharge 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.
In this definition, the Corps has classified discharges
according to their primary purpose. Thus, if solid wastes are
being discharged into a landfill located in a wetland for the
primary purpose of waste disposal, an NPDES permit will be
reauired under Section 402 of the CWA. Solid waste discharge for
the primary purpose of altering the elevation of land beneath
water or of impounding water is considered a fill activity,
subject to Section 404, CWA.
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A person wishing to open a landfill in a wetland will apply to
the agency to the appropriate EPA Regional Office for an NPDES
permit (or to a State, if the State has been designated by
EPA to administer its own NPDES program). If the facility requires
preparation and/or construction of dikes for containing the garbage,
then a Section 404 permit will be processed for the facility at the
same time by the District Engineers Office. The Corps will withhold
final action on the 404 permit until final action on the MPDES
permit is taken.
d. Ground Water
The Safe Drinking Water Act (SWDA) of 1974 (Public Law
93-523) authorizes EPA to establish Federal standards for protec-
tion of all harmful contaminants (applicable to all public water
systems), and to establish an on-going Federal-State system for
assuring compliance with these standards for protecting under-
ground sources of drinking water. The drinking water standards
promulgated and proposed under the SDWA establish ground-water
duality goals pertinent to the ground-water portion of the cri-
teria.
EPA recognizes the importance of avoiding overlaps and
inconsistencies between the SDWA and the criteria. In general,
the SDWA protects ground water through guidelines established by
the Primary Drinking Water Standards. These standards establish
heaJth and other water quality guidelines which provide the basis
for the determination of desirable drinking water. These regula-
tions were not initially intended to apply to facilities other
than public water systems. However, to maintain consistency in
promulgated standards, EPA has used them to define
the adverse effects n ground-water caused by solid waste
activities. Under these standards, and the final ground-
water criteria, ground-water protection is
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not a function of the type of waste being disposed, but instead
of the Quality of the underlying ground water.
The Resource Conservation and Recovery Act requires the
Administrator of EPA to integrate the provisions and enforcement
of RCFA with other Acts under the Administrator's authority,
including the Safe Drinking Water Act, to the maximum extent
practicable. There is a potential overlap between the Solid
Waste Disposal Act and the SDWA with regard to surface impound-
ments such as pits, ponds, and lagoons.
The criteria proposed by EPA apply to all solid waste dis-
posal facilities, including surface impoundments. Thus, the
inventory of open dumps would include those surface impoundments
which, through application of the criteria, are determined to
pose a reasonable probability of adverse effects on health or the
environment. EPA intends to develop the inventory through grants
to State agencies.
To this end, the studies and assessments planned under the
SDWA will be used as the basis for identifying those surface
impoundments that have the greatest potential for adverse effects
and thereby will help the States in developing the inventory
required under the Resource Conservation and Recovery Act. Those
impoundments which are identified as having the greatest poten-
tial for serious impact on ground-water quality would be con-
sidered high priority for development of the RCRA open dump
inventory. Such impoundments which are found to violate the cri-
teria proposed by this action would be placed on the inventory
and be subject to closure or upgrading in accordance with the
State planning and plan implementation provisions of RCRA,
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Air
The intent of the Clean Air Act (as amended June 1974
[Public Law 93-391]) is to "protect and enhance the quality of
the nation's air resources so as to promote the public health and
welfare and the productive capacity of its population." An
important consideration in the standard is reflected by this
Act's mandate on particulate emissions. In particular,
Section 111 (Standards of Performance for New Stationary Sources)
and Section 112 (National Emission Standards for Hazardous Air
Pollutants) and their corresponding regulations have a great
impact upon open burning of wastes.
f .
(1) FAA Order 5200.5, "FAA Guidance Concerning
Sanitary Landfills"
This Federal Aviation Administration order
addresses the problems of bird hazards to aircraft. The order
states that disposal facilities have been found by study and
observation to be artificial attractants to birds and are, there-
fore, "incompatible with safe flight operations" when located in
the vicinity of an airport. The bird hazard criteria use the
separation distance restrictions contained in the FAA order, with
the exception of that provision dealing with conical airspace,
which is not included in the criteria.
(2) Airport and Airways Development Act of 1970
(Public Law 91-258) and Amendments of 1976
(Public Law 94-353)
The Airport and Airways Development Act of 1970
establishes "an expanded program of Federal matching grants to
sponsors of airports serving commercial and general aviation. . .
[and] ... a system of user taxes paid into a trust fund to
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provide an assured, long-term source of funding." The Airport
and Airways Development Act Amendments of 1976 (Public Law 94-
353) set forth the requirement for studies to be conducted of
facilities which may be closed because of "land requirements"
(e.g., the safety criteria). The objective of these studies is
to "make recommendations concerning methods for preserving those
airports which should be preserved in the public interest." In
addition, studies for the identification and evaluation of poten-
tial locations for new airports are also required.
General
The "Guidelines for the Landfill Disposal of Solid
Waste" (40 CFP Part 471) recommend considerations and preferred
methods for the location, design, construction, operation, and
maintenance of solid waste landfill disposal facilities.
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D. COVERAGE
The criteria apply to all "solid waste" and "disposal"
facilities as these terms are defined in Section 1004 of RCRA.
The definition of "solid waste" includes liquid, contained
gaseous and semi-solid wastes, and sludges.
Based on the statutory definition of solid waste, the land
application of domestic sewage and liquid effluent from the
treatment of domestic sewage is excluded from the criteria
coverage. However, the criteria do apply to the land disposal of
sludge resulting from the treatment of domestic sewage.
In addition, the criteria do not apply to irrigation return
flows or discharges which are point sources subject to Section
402 permits under CWA. The criteria also do not apply to the
location and operation of septic tanks. However, the disposal of
septic tank pumpings is subject to these criteria.
Based on Congressional intent as described in the House
Report on RCRA (Ref. 79), the following wastes are excluded from
the criteria: "agricultural wastes (e.g., manures and crop
residues) which are returned to the soil as fertilizers or soil
conditioners" and "overburden (mining and milling wastes)
resulting from mining operations and intended for return to the
mine site" (Ref. 146).
The criteria also do not apply to source, special nuclear,
or byproduct material as defined by the Atomic Energy Act of
1954, as amended.
When regulations for hazardous waste disposal facilities are
promulgated under RCRA, facilities for the disposal of hazardous
waste must comply with those regulations. Similarly, when
regulations for the State Underground Injection Control Program
(UICP) are promulgated under authority
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of the Safe Drinking Water Act of 1974 (Public Law 93-523), they
apply to underground well injection.
Table II-2 lists typical sources of wastes to be regulated
by the criteria. The types of disposal methods covered by these
regulations include: landfills, dumps, surface impoundments
(ponds, pits, and lagoons), landspreading of wastes, and resource
recovery practices involving land application of solid waste as
soil conditioners or fertilizers.
TABLE II-2
TYPICAL SOURCES OF WASTES TO BE REGULATED BY THE CRITERIA
1 - Municipal: residential, commercial, institutional (e.g.,
schools, litter containers, street sweepings)
2 - Sewage sludge/septic pumpings
3 - Industrial wastes: manufacturing residues, air and water
pollution sludges
4 - Construction/demolition wastes
5 - Agricultural wastes not returned to the soil as fertilizer or
soil conditioner. Also, feedlot manures, process wastes, etc.
6 - Mining and milling wastes not intended to be returned to the
mine
NOTE: Hazardous wastes in the above categories are subject to
regulation under Subtitle C of RCRA once the hazardous waste
regulations become effective.
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E. REGULATORY APPROACH
The need and mandate for EPA to develop a regulation for
solid waste disposal was established by Congress and contained in
RCRA and CWA. EPA must, therefore, develop such a regulation.
The following discussion summarizes the approach and considera-
tions used by EPA to develop the criteria in response to this
mandate.
1. Adverse Impacts
The regulatory approach begins with a statement of the need
for regulation. This need stems from the adverse impacts of
current disposal practices and the lack of adequate State
requlation. A number of studies, both published and unpublished,
have identified a number of adverse effects from improper solid
waste disposal (Refs. 7, 8, 10, 12, 16, 43, 79). RCRA and the
accompanying committee reports summarized the major areas of
impact as: ground-water quality, surface water quality; air
quality; and human health and safety (from disease transfer,
pollution of food sources, fires and explosions, personal injury,
bird hazards to aircraft, poisoning, etc.) (Refs. 43, 79, 101).
These environmental impact concerns provide the basic goals
and objectives for the regulatory approach.
2. Criteria Alternatives
Several basic issues and alternatives were considered in the
development and adoption of the criteria. In determining the
coverage of the regulations, the scope of RCRA was considered to
include almost all wastes being disposed of to land (regardless
of physical state). Addressing this broad spectrum and large
quantity of wastes, each with its resulting or potential
environmental effects in the varied physical and climatic
conditions throughout the United States, presented a mammoth
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challenge. Environmental effects of national environmental
concern and the methods of handling these concerns were key
issues addressed in EPA's approach to implementing the charge of
RCRA,
EPA's consideration of alternative approaches to developing
the required criteria was evidenced by the following actions:
1. Solicitation of comments on a May 12, 1977 draft
of the criteria
2. Publication of "Advanced Notice of Proposed Rule-
making," July 5, 1977 (Ref. 58)
3. Solicitation of comments on "Proposed Classifica-
tion CriteriaSolid Waste Disposal Facilities,"
published February 6, 1978
4. Solicitation of comments on "Draft Environmental
Impact Statement, Criteria for Classification of
Solid Waste Disposal Facilities," published April
1978.
In the latter two cases, public comments were accepted
through June 12 and June 30, 1978, respectively. These criteria
comments were reviewed and debated, and the criteria were modi-
fied to reflect the substantive concerns. The summary of these
responses to comments on the criteria appears in the Preamble to
the criteria in Appendix A. During the period July 1978 through
May 1979, the economic and environmental impacts of various cri-
teria alternatives were examined. This EIS also reflects consi-
deration of comments received on the Draft EIS. The response to
these EIS comments is provided in the EIS Preamble.
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The steps in the regulatory approach included: identifica-
tion and evaluation of the major alternatives based on available
technology and management practices; assessment of uncertainties
and risks associated with physical processes (hydrogeology) which
disperse pollutants; analysis of available implementation methods
and their feasibility, as well as performance expected from each
level of reaulation; and preliminary evaluation of costs to indi-
viduals, firms, industrial groups, geographic regions, social
groups and Governmental agencies for each level and type of regu-
lation.
The factors considered in selecting the various criteria
alternatives and their subsequent evaluation were:
(1) Effectiveness and degree of certainty of each
criterion for achieving goal
(2) Technological feasibility, availability, and reli-
abili ty
(3) Economic impact and feasibility
(4) Feasibility of compliance monitoring, inventory-
ing, and correcting disposal facilities
(5) Utilization of existing Federal and State regula-
tions or approaches in order to avoid conflicts or
unnecessary duplication.
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a. Operational And Performance Standards
One of the basic questions addressed by EPA was the
relative merits of operational standards versus performance
standards.
(1) Operational Standards
With operational standards, particular practices
(technology, designs or operating methods) are specified to
provide for reasonable protection of health and environment.
Considerable detail is required to identify the best operational
techniques for the great variety of solid wastes which exist and
for the varied physical and climatological conditions which exist
throughout the nation. The advantage in using this approach is
that the best practical technology available could be implemented
and utilized for the disposal of wastes, leading to a reasonable
uniformity of results. Also, it is relatively easy to determine
compliance with a specific operational criterion. Currently, EPA
is developing site operating guidelines for landfills which, when
completed, will provide an up-to-date version of operating
standards.
One of the major disadvantages to this approach is that
compliance is measured by assessing conformance to operational
criteria rather than by assessing or monitoring the actual
effects on the environment. Also, it is likely that most people
would follow an established operational practice rather than
applying creative thinking, i.e., finding the best method for a
given situation. Additionally, operational standards often have
the disadvantage of requiring revisions in State laws and regula-
tions as changes occur in waste types and disposal methods, dis-
posal technology, and in the understanding of environmental
effects.
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In summary, the primary reason for not basing the require-
ments of the criteria exclusively on operational standards is to
avoid the need to specify the explicit operational parameters of
such factors as type of waste, methods of waste pretreatment,
facility location (including hydrogeology, precipitation, climate
and ground-water regime), facility design, pollution abatement
strategies, construction methods, operation and maintenance pro-
cedures, and monitoring and testing procedures.
(2) Environmental Performance Standards
Under environmental performance criteria, reducing the
actual impacts on the environment would be the controlling factor
in technology selection. Performance levels are developed around
the goal of providing given levels of protection to all environ-
mental media at a given site in order to meet RCRA's goal of pre-
venting a "reasonable probability of adverse effects on health
and the environment." This approach allows broader State and
local interpretation and technical creativity in providing
adequate disposal. It also provides for emerging technology to
be implemented rapidly without creating the necessity for
changing regulations specifying current techniques which may be
more costly and/or less effective in the future. Determining
compliance with the performance criteria is generally not as easy
as with operational criteria, and monitoring the effectiveness of
the environmental control measures is generally more complex and
costly. Inspectors need a far greater grasp of the potential
effects of waste disposal on the environment and a broader grasp
of technical skills to identify and evaluate conditions of com-
pliance and noncompliance.
Given the complexity and variability of solid wastes as well
as site-specific situations, EPA considered it preferable to
allow for some State and local discretion in meeting the criteria
and making site-specific evaluations based on local conditions.
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Therefore, performance criteria were considered generally
preferable for addressing the variety of conditions which will be
governed by these regulations. There was, however, a need for
the performance criteria to be as specific as possible in order
to provide unequivocal and uniform criteria, while maintaining
the State prerogative of setting specific limits where known
environmental problems dictate this approach. The type of
standard embodied in each criterion is shown in Table II-3. In
most cases, there are environmental performance standards, and in
some, operational requirements are also specified.
EPA recognizes there are many site-specific factors which
must be considered in determining if there will be an adverse
impact and, if so, what the magnitude of the impact will be.
These factors include climate, hydrology, geology, and waste com-
position. In addition, in the case of landspreading to food-
chain cropland, other factors include application rate, type of
crop arown, and potential future uses of the site.
One aim in developing these criteria was to be as specific
as possible. This approach facilitated the distinction or class-
ification of disposal facilities without reducing the flexibility
of State solid waste management and enforcement agencies to take
into account site-by-site variations and local conditions. These
criteria are not intended to prevent or restrict the authority or
discretion of States to develop more stringent State or site-
specific (situational) criteria. States may choose to require
more stringent location, design, construction, operation, main-
tenance, and performance standards where local conditions
indicate.
Due to the difficulties of determining compliance with
certain criteria (particularly the ground-water criterion), EPA
plans to allow States to phase the conduct of the inventory.
Priorities for the inventory will be based on degree of potential
environmental harm and the ease of determining compliance. The
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TABLE II-3
TYPES OF STANDARD USED TO ASSESS
COMPLIANCE WITH CRITERIA
Criteria
Performance Operational
1.
2.
3.
Floodplains
Endangered and Threatened Species
Surface Water
a. Point Sources (includes
wetlands)
b. Discharge of Dredged Material
to U.S. "waters
c. Non-Point Sources
d. Discharge of Leachate to
Wastewater Treatment Works
X
X
X
X
X
X
X
X
4. Ground Water
a. Principal Ground-Water Sources X
4. Air X
5. Application to Food-Chain Crop Land
a. Cadmium X
b. Polychlorinated Biphenyls (PCB's) X
6. Disease
a. Disease Vectors X
b. Sewage Sludge and Septic Tank X
Pumpings
7. Safety
a. Explosive Gases
b. Fires
c. Bird Hazards
d. Access
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five-year maximum compliance schedule will start when a facility
is listed as an open dump.
3. Decision Making
The criteria alternatives were examined for various aspects
of feasibility based upon the degree of environmental protection
provided and the technological capabilities required to achieve
these degrees of protection. The basic process was iterative, in
which a balance was struck between the environmental protection
mandates of PCRA, environmental risk, and the technological
feasibility of achieving the level of protection offered by the
alternatives. In addition to these factors, economic impact of
the alternatives was evaluated.
Due to the current national economic situation, it is
Administration policy to require economic impact analyses of
major federal regulations. By assessing the economic impact of
the various regulatory alternatives, and comparing these assess-
ments to the degree of environmental protection afforded by the
alternatives, decision-making was facilitated. Less restrictive
alternatives, not as costly as the final criteria, did not ful-
fill the interpreted level of environmental protection mandated
by RCRA. More restrictive alternatives, more costly than the
final criteria, met and often exceeded the mandates of RCRA, but
were either technologically or economically not feasible. The
final criteria, however, are intended to fulfill the requirements
of RCRA, be technologically feasible, and endeavor not to impose
an overwhelming financial burden on the nation for compliance.
Therefore, decision-making on the best alternative for each cri-
terion was a function, in order of significance, of:
1. Degree of environmental protection provided;
2. Technological feasibility of compliance; and
3. Economic impact of each alternative.
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F. PURPOSE OF THE EIS
This EIS was prepared in response to EPA's procedures
governing voluntary Environmental Impact Statements (39 Fed.
Reg. 37419). The EIS process and preparation of this EIS report
assisted EPA (as documented in the previous discussion) in five
important areas:
(1) Summarizing the major alternatives considered and
their environmental, economic, social and equity
impacts
(2) Comparing trade-offs among alternative courses of
action
(3) Promoting public understanding of the EPA decision
(4) Facilitating public participation in the decision-
making process
(5) Identifying areas where additional information and
data are needed.
This EIS is, therefore, a policy-making tool whereby
(1) comprehensive alternative courses of action were first
developed and examined, and (2) the rationale for the action
taken by EPA was then analyzed and evaluated.
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G. EIS APPROACH
1. Identification of Impacts
The first task in the criteria development and preparation
of the EIS was to identify all the potential adverse effects of
improper solid waste disposal, and to identify the importance of
the resource being affected. Only then could relative evalua-
tions be made as to the importance of each criterion and the
degree of control desired. Next, technologies and methods are
identified which may be utilized, and their effectiveness in
reducing the adverse effects is assessed (Chapter III).
2. Evaluation of Alternatives
The next step in the development of the criteria and pre-
paration of the EIS was to identify and evaluate criteria alter-
natives based on technology and methods, performance (including
risk and certainty), and economics (including equity considera-
tions) .
The social and environmental impacts of solid waste disposal
practices include a wide range of concerns such as public health,
occupational health and safety, environmental damage, and
maintenance of ecological systems. These concerns have led to a
variety of methods for measuring impacts and costs. Three broad
categories of criteria can be used to characterize the impacts of
solid waste disposal technology: criteria that are quantifiable
and amenable to comparison among different technologies; criteria
that are quantifiable, but difficult or impossible to compare
among alternative technologies; and criteria that are difficult
or impossible to quantify even for a single technology (Ref. 92).
The severity of future environmental impacts depends on the
effectiveness of government regulations and the technological
developments necessary to implement regulations. Our under-
standing of the health and ecological effects of present solid
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waste disposal systems is only sufficient for setting standards
for a few of the pollutants associated with such disposal, e.g.,
cadmium, PCB's pathogens, and some compounds such as nitrates.
Reasonably detailed ambient and emissions data exist for only a
few pollutants; even for these pollutants, actual health and
ecological effects are still being determined.
As pore is learned about the impacts of solid waste disposal
?ystems on the quality of our air, land, and water, new standards.
in the protection of public health and welfare can be expected.
Nevertheless, if aross waste generation continues to increase,
maintaining a qiven level of environmental quality may become
increasinaly difficult, from both a technological and economic
standpoint (Pef. 92, op. 196-197).
The criteria and alternatives were derived in an attempt to
reduce the environmental impacts of solid waste disposal to
"reasonable" levels, while at the same time remaining consistent
with Conoressional mandates for economic and technical feasi-
bility. The FIS thereby serves to present the evaluation of
their relative merits.
3. Environmental Benefits of Criteria Alternatives
The degree to which the criteria reduce to acceptable levels
or eliminate the significant cumulative adverse environmental
impacts of the solid waste disposal practices of landfilling,
landspreadino, and impoundments depends on several factors:
Which potential or actual impacts are addressed by the
criteria and which are not;
Nature and importance of the impacts not addressed;
For the impacts addressed:
How well do the criteria address the problem?
How many sites will continue to operate because
there are no feasible alternatives, and what
impacts will they cause?
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How well will the available technology for
environmental control work?
How well will the regulations be enforced?
To what extent will the criteria finally be
implemented by the States?
How well will the system of environmental
monitoring work?
How well will the sites be operated?
Although considered in the development of the criteria, it
is not the purpose of this report to present the evaluation of
the efficiency and practicality of the systems for enforcing the
regulations (including monitoring to determine compliance) and
the probability of efficient (predictable) site operation.
Bather, the report evaluates the beneficial environmental effects
which reasonably can be expected to occur when the criteria are
fully implemented and contrasts them with the probable economic
and social costs of the regulations.
The costs of achieving these effects will be borne directly
by the general public, disposal site operators, public agencies
at local, State and Federal levels, industries, and other waste
generators. Some of these economic and social costs will fall
eaually on all people, while others may be distributed
inequitably to segments of the population.
Finally, it should be mentioned that there will continue to
be potential impacts from solid waste disposal which are
primarily local in nature, are generally best regulated at the
local or State level, and which are not covered by the criteria.
These potential impacts include effects on archaeological and
historical sites; local traffic and related noise problems;
conflicts with established uses of on-site or nearby affected
lands for recreational, scientific and educational purposes; and
the problems of locating solid waste disposal sites on or near
karst terrain, fault zones, and areas of high water table.
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4. Costs/Benefits of Major Criteria Alternatives
a. General Approach
One aspect of the EIS is to identify costs and benefits
of the criteria. Since the environmental benefits generally are
not quantifiable in a coherent overall economic framework,
economic benefits were generally not determined. The major
exception is in the analysis of the ground-water and gas cri-
teria; the economic value of implementing these two criteria has
been assessed in Chapter IV, using case study examples.
Thus, the analysis of alternatives generally compares cost
of criteria to environmental benefit.
b. Cost Accounting
The basic analytical framework of the EIS divides the
costs of meeting the criteria into two parts: (1) the costs of
meetinq existing State solid waste disposal regulations (State-
standard-induced costs) and (2) additional costs of meeting the
criteria beyond the level specified by State regulations
(Federally induced costs). The true cost impact of the criteria
is found in (2), but the total (combined) cost to industry and
consumer is the sum of the costs in (1) and (2).
In order to compare the impacts of each regulatory alterna-
tive, specific costs were attributed to meeting each criteria.
To avoid double-counting, specific technologies which would
achieve compliance with a combination of criteria were assigned
for cost accounting to the criteria of greatest importance or
where the technology had the greatest impact.
In calculating the additional cost of compliance with the
criteria, the cost impact assessment takes as-given Federal
regulatory control of certain aspects of solid waste disposal
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(e.a., NPDES permits, Army Corps of Engineers' permits), and
local/State regulations governing water pollution, air pollution,
noise, nuisance, litter, and similar effects. It is assumed that
there is considerable variation throughout the country in imple-
mentation of State regulatory controls on solid waste disposal
practices. The net effect of these regulations is related to the
existing standards: the new criteria lead to effects only if
they uparade an existing situation (as determined by standing
Federal and State laws and regulations) or introduce a new
standard. This assessment of the net effect of the criteria thus
limits the economic costs as well as the environmental and social
benefits. Environmental benefits will also be limited by (1) how
each criteria is implemented since some criteria give a degree of
State discretion, and (2) the technological effectiveness of the
acceptable environmental measures.
c. Method of Analysis
The methodology for economic and environmental 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 disposal facilities. In lieu
of complete information on the number and condition of land-
spreading sites, substantial data has been collected on the
amount and characteristics of municipal sewage sludge which is
landspread. 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
sites may be so affected; therefore, criteria costs may include
estimates for some facilities that will be regulated by the
hazardous waste regulations of RCRA. The availability of data is
discussed in Appendices B and D.
11-43
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The basic method used on a state-by-state basis (land-
snreading impacts were only assessed nationally) was four-fold:
(1) Estimate the number of disposal sites (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
existing sites (by size and location).
(3) Identify control technologies (by adverse effect
and regulatory alternative) and estimate unit
costs (based on site size) to meet each criterion.
(4) Derive total control cost 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 sites.
11-44
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III. ALTERNATIVE REGULATORY ACTIONS: ENVIRONMENTAL
AND ECONOMIC IMPACTS
As summarized in the last chapter and discussed further in
this chapter, research efforts have identified a number of
potential adverse effects on health and the environment from
improper solid waste disposal practices. These are: surface and
ground-water contamination; air pollution; taking of endangered
or threatened species, or adverse modification of critical
habitats; contamination of food-chain crops; explosive gases;
fires; bird hazards to aircraft; disease; and exposure to wastes,
heavy equipment, and other safety hazards.
This chapter summarizes information on each of these adverse
effects in terms of: (1) the magnitude of each adverse effect and
the importance of control, (2) the major regulatory approaches,
including discussions of control technologies, and (3) the
environmental consequences and economic impact for each regula-
tory approach. For simplification, only three regulatory
approaches for each adverse effect are discussed in this chapter
(except in the food-chain land application section): (1) the
final criterion, (2) one more restrictive alternative, and
(3) one less restrictive alternative.
The economic impact analysis shows costs for each of the
several regulatory approaches, identifying these as Federally
induced costs and combined (State-standard-induced plus Federally
induced) costs for each type of disposal facility: (1) land-
fills, (2) surface impoundments (ponds, pits, and lagoons), and
(3) landspreading.
To determine the economic impact of the criteria,
assumptions on the following information were developed for each
type of disposal facility (landfill, surface impoundment, and
landspreading) for each site size category considered:
III-l
-------
(1) Technologies needed for compliance
(2) Unit costs for each technology and total costs for each
facility size
(3) Number of facilities in each facility size category
needing modification.
The number of facilities needing modification was divided
into two categories: facilities needing upgrading and facilities
needing closure. The unit and total costs for each facility size
were determined for both of these categories.
The cost figures developed represent the increments or addi-
tional cost above current disposal costs to bring existing
facilities into compliance with the criteria. By comparing the
criteria to existing State standards, it was possible to divide
these incremental costs into two categories: State-standard-
induced cost (cost to come into compliance with existing State
standards) and Federally induced cost (cost beyond those needed
to achieve compliance with State standards). This breakdown was
necessary 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 expenditures necessary to bring
existing facilities into compliance with State standards and the
criteria.
Chapter IV and Appendix B contain additional information on
the economic impact analysis: data base, methodology, assump-
tions, technologies, unit costs, costs by facility size, numbers
of facilities needing modification, and impacts on various
sectors of the country.
III-2
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A. FLOODPLAINS
1. Definition
Floodplains are defined as "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"
(Ref. 41).* The final criterion uses the 100-year floodplain
rather than the 50-year or other level (1) to be consistent with
the approaches of the Water Resources Council and the Federal
Insurance Administration, and (2) to give the added safety factor
necessary because of changes in the 100-year levels caused by
human activities. The U.S. Water Resources Council has developed
procedures for determining the extent of floodplains, "A Uniform
Technique for Determining Flood Flow Frequencies" (Ref. 128), as
well as a "Uniform National Program for Floodplain Management"
(Ref. 87). The 100-year floodplains for many areas of the
country have been mapped by the U.S. Geological Survey, U.S. Army
Corps of Engineers, and the U.S. Department of Housing and Urban
Development. For unmapped areas, the Water Resources Council is
to develop procedures for determining flood levels, according to
Executive Order 11988 (Ref. 41).
2. Importance; Adverse Effects from Improper Disposal
There is currently underway a Federal program of floodplain
management designed to avoid, as much as possible, the long-term
and short-terra adverse impacts associated with the occupancy and
modification of flood plains. One element of this plan involves
discouraging direct or indirect Federal support of floodplain
development wherever there is a practicable alternative. The
*The flood with a 1% frequency of annual occurrence is called the
100-year flood, because it will occur, on the average, once every
hundred years. The 100-year floodplain is not fixed; it is subject
to changes caused by future urban development and flood control
improvements, including physical structures and land conservation
practices, i.e., it may expand or contract in the future.
III-3
-------
adverse impacts of floodplain occupancy and continued development
in floodplains include: the risk of flood loss; effects detri-
mental to human health, safety, and welfare (e.g., loss of life
and property); and erosion of valuable land (soil and vegetation)
by flooding.
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 inundated by water and flow from the facility, impacting
water duality and aquatic life in downstream waters, and also
causing erosion, siltation, and increased flooding; (2) filling
in the floodplain may restrict the flow of flood waters and/or
reduce the size and effectiveness of the floodplain in assimi-
lating flood waters which may result in higher flood levels and
greater flood damages downstream or upstream; and (3) since
floodplains generally have a hydraulic connection to wetlands,
surface water, and ground water, locating disposal facilities in
floodplains may result in leachate contamination.
3. Pegulatory Alternatives and Environmental Consequences
a. Final Criterion
The floodplains criterion requires that a solid waste
disposal facility not be located in a floodplain unless it is
orotected against being washed out (carried away by flood waters)
by the base flood, so as to pose a hazard to human life, wild-
life, or land or water resources; does not reduce the temporary
storage capacity of the floodplain; and does not restrict the
flow of the base flood.
A base flood is defined as one that has a 1 percent or
qreater chance of recurring in any year, or a flood of a magni-
tude eaualled or exceeded once in 100 years on the average over a
III-4
-------
significantly long period. In any given 100-year interval, such
a flood may not occur, or more than one such flood may occur.
The provision relating to inundation by the base flood pro-
tects against washout of waste materials, thereby precluding
adverse impacts on human health and wildlife, surface water
quality and damage to downstream structures. Facilities where
solid waste is incorporated into the soil as agricultural soil
conditioners or fertilizers would not be expected to be washed
out by flooding; therefore, such practices are not explicitly
addressed in the floodplain criterion.
b. More Restrictive Alternative
The more restrictive alternativea total ban on
disposal of wastes in floodplain areaswould ensure the protec-
tion of such environmentally sensitive regions. However, such a
proposal would impact severely on current disposal practices, and
the amount of potential disposal facility lands. When properly
designed, facility floodplains can protect against inundation,
and impact on flooding or water quality may be negligible. In
fact, selection of alternative sites in more sensitive areas
(e.g., areas of principal drinking water sources) may result in
potentially more serious environmental impacts.
c. Less Pestrictive Alternative
No less restrictive alternative was considered because
of the importance of protecting floodplains from adverse environ-
mental impacts and because of the direction provided by Executive
Order 11988.
III-5
-------
4. Summary Technology, Economic and Environmental
Impact Analysis
a. Control Technologies and Unit Costs
Floodplains require certain special considerations.
The primary contamination potential from landfills sited in
floodplain areas is the degradation of the ground and surface
waters caused by the adverse impact of flooding, which removes
the waste from the facility by erosion or adds significant
leachate to the ecosystem. In addition to the standard counter-
measures of preventing seepage and controlling leachate required
for all landfills, perimeter protection is most frequently
utilized to preclude the effects of flooding on water quality.
Perimeter berms or dikes are usually constructed around the
waste disposal area. Such berms rise above the 100-year flood
level and are protected from flood erosion by adequate erosion
mechanisms including rip-rap, vegetation, and erosion-resistant
materials. The perimeter system, while it isolates facilities
from the impact of flood waters, itself creates some impacts on
the flood regime. By the mere process of isolating the facility
from flooding, perimeter protection reduces the storage capacity
of the flood basin. This results in back-water impacts, affect-
ing the direction and magnitude of the flow of water through the
floodplain, and occasionally causing flooding of new lands. This
impact of perimeter protection can be precluded or minimized by
siting the solid waste facility at a location which will not
impact on the water flow basin storage capacity or the "back-
water curve." For example, the disposal facility might be shaped
in a more streamlined configuration to minimize its impact on the
water velocity or flow directions. Creating an equal storage
volume for flood waters is often a suitable alternative for
retaining the storage capacity of the floodplain. By appropriate
siting of the replacement volume, the back-water effects might be
totally eliminated. Drainage ways, channel improvements,
III-6
-------
deflector systems, and berras are all techniques available to
assist in the control of the flood-water flow velocity and back-
water consequences.
Table III-l shows control technologies and unit costs as a
function of site size for the final criterion; costs are identi-
fied for each disposal method impacted by this criterion.
b. Assumptions
The major economic impacts of this criterion result
from the need to provide levees for landfills and surface
impoundments located in floodplains, to protect from over-the-top
inundation during periods of flooding. For surface impoundments,
it was assumed that 2/3 of those facilities located in flood-
plains would require upgrading or closure. Of the total surface
impoundments located in floodplains, 5% would be assumed to
require closure.
Landspreading of waste as soil conditioners or fertilizers
is exempt from the floodplains criterion, and would therefore
incur no costs.
Costs
Cost estimates for the effect of this criterion were
developed based upon the above technologies and on unit costs for
each technology, as a function of facility size. Unit costs and
the data base are presented in greater detail in Chapter IV and
in Appendix B.
Twenty-three States have regulations which provide protec-
tion to floodplains, and for these States, induced costs were
ascribed to on-site industrial landfills and to surface impound-
ments. In those States which provide no floodplain protection,
III-7
-------
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costs were ascribed to all landfills, and to surface impound-
ments. Since all on-site industrial landfills have been assumed
in need of upgrading for this criterion, every State has incurred
either State-induced costs, Federally-induced costs, or both.
The impact of the criterion on individual States ranged from a
high of $54.4 million to a low of $297,300. For the more
restrictive alternative, costs ranged from a low of $634,000 to a
high of 177.2 million.
Table III-2 compares annualized costs based upon disposal
method and regulatory alternative.
d. Economic and Environmental Comparisons Among
Alternatives
Table III-3 shows the economic and environmental com-
parisons among alternatives for this criterion. Comparing the
more restrictive alternative with the final criterion shows that
an additional combined cost of $638.5 million per year for the
more restrictive does provide a return in terms of environmental
benefits. However, in addition to being unnecessarily strict,
the more restrictive alternative would force the displacement of
large Quantities of wastes.
III-9
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III-ll
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B. ENDANGERED AND THREATENED SPECIES
1. Importance; Adverse Effects from Improper Disposal
Many species of animals and plants have become rare or
endangered in the past through the cumulative effects of human
activity, including habitat destruction, excessive killing, and,
recently, release of toxic substances into the environment. Con-
struction and operation of waste disposal facilities may restrict
wildlife mobility, temporarily or permanently disturb natural
habitats, or otherwise threaten the continued existence of wild-
life in certain areas of the county. Endangered species should
be protected from any disturbance caused be waste disposal prac-
tices. These practices should not jeopardize the continued exis-
tence of endangered and threatened species as listed pursuant to
the Endangered Species Act of 1973.
2. Regulatory Alternatives and Environmental Consequences
a. Final Criterion
In accordance with Section 7 of the Endangered Species
Act of 1973 (ESA) (16 U.S.C. 1536), all Federal departments and
agencies, in consultation with the Department of Interior, are to
use their authority to further the purpose of this act, including
the protection of endangered and threatened species (Ref. 129).
Facilities for the disposal of solid waste must be so constructed
or operated that they will not "cause or contribute to the taking
of endangered or threatened species, as listed pursuant to the
Endangered Species Act of 1973 (16 U.S.C 1530, et seq.) in 50 CFR
Part 17 or result in the destruction or adverse modification of
their critical habitat as contained in 50 CFR Part 17" (Ref. 129
and 130).
As defined in regulations promulgated by the Departments of
the Interior and Commerce (pursuant to Section 7 of the ESA (43
111-12
-------
FR 875), "destruction or adverse modifications" means a direct or
indirect alteration of critical habitat which appreciably dimin-
ishes the likelihood of the survival and recovery of endangered
and threatened species; "taking" means harassing, harming, pur-
suing, hunting, wounding, killing, trapping, capturing or
collecting, or attempting to engage in such conduct. This
criterion would be applicable to a facility which was operating
prior to a critical habitat designation. Such a facility may
have to modify its operation in order to comply with the
criterion where nearby areas are designated as critical habitats.
This could occur where the facility's location, construction, or
operation would be shown to be likely to contribute to the taking
of listed species or result in the destruction or adverse modi-
fication of their critical habitat.
b. More Restrictive Alternative
A more restrictive alternative would be a total ban on
locating disposal facilities in areas where the continued
existence of endangered and threatened species would be jeo-
pardized by such facilities. Such a ban would guarantee that
disposal facilities would not further threaten such species.
However, since some of the threatened habitats and endangered
species encompass very large areas, a ban could be very costly.
Moreover, most of the endangered and threatened species identi-
fied to date are such that a disposal facility could be located
at certain places within the area without further endangering the
species.
c. Less Restrictive Alternative
A less restrictive alternative is to omit from the
criteria consideration of endangered and threatened species.
However, to fail to address the problem of locating, con-
structing, or operating disposal facilities in a manner that jeo-
pardizes endangered and threatened species could add to the
111-13
-------
process of extinction. In addition, overlooking this concern
would disregard the Congressional objectives of the Endangered
Species Act of 1973 and would directly violate this law.
3. Summary Technology, Economic, and Environmental
Impact Analysis
a. Control Technologies and Unit Costs
If other feasible and environmentally sound alterna-
tives exist, disposal facilities should not be located in areas
which diminish the likelihood of the survival and/or recovery of
endangered and threatened species. Disposal facilities that are
located in such areas must be so designed, constructed, operated,
and maintained that they do not cause or contribute to the taking
of endangered or threatened species. For example, the facility
could be designed to create new sources of food or cover to off-
set habitat lost during the construction and operation processes.
The appropriate technology and cost involved in complying
with this criterion will necessarily have to be determined on a
case-by-case basis. Although the number of existing facilities
impacted by the final regulation is not known at this time, it is
expected that few facilities will be so identified. For these
reasons, no specific technologies and costs are enumerated.
b. Assumptions
It was assumed that the effect of this criterion would
be minimal, because of (1) the relatively small land area desig-
nated as critical habitat, and (2) the general lack of large
population centers in these areas.
111-14
-------
Costs
Because the impact of this criterion was considered
minimal, no costs were attributed for purposes of this economic
impact assessment. Furthermore, any costs determined would be
induced by the Endangered Species Act, not by the criteria.
111-15
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C. SUPFACE WATER
1. Importance; Adverse Effects from Improper Disposal
The quality of this country's rivers, lakes, and streams is
of vital concern from both an aesthetic and ecological point of
view. These resources serve as recreational places for people
and living environments for a wide variety of fish and aquatic
organisms that depend on an oxygen-sufficient, uncontarainated
living environment. Contamination of these valuable resources,
including the widespread pollution of several of the Great Lakes
and large stretches of lakes and rivers, dramatizes the need for
regulatory measures to control these environmental impacts; the
surface-water criterion has been developed to control adverse
impacts caused by improper disposal of solid wastes.
The nation's coastal and inland wetlands are vital natural
resources of great hydrological, ecological, and social impor-
tance. Wetlands provide natural flood and storm control, sedi-
ment and erosion control, recharge of aquifers, natural purifica-
tion of waters, and flow stabilization of streams and rivers.
Wetlands also produce large quantities of nutrients which support
complex ecosystems extending into estuaries and streams, well
beyond the marshes and wetland areas. Wetland habitats support
fish, shellfish, mammals, waterfowl, and other wildlife fauna and
flora. Moreover, wetlands are used in the production of many
agricultural products (food and fiber) and timber, as well as for
recreational, scientific, and cultural pursuits.
The major wetlands of the nation are shown in Figure III-l.
Wetlands occur locally in other parts of the country, parti-
cularly along the ocean coastlines, bayfronts, and riparian
corridors.
Wetlands have been used extensively for solid waste disposal
because the land was cheap, the resistance to disposal facility
II1-16
-------
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111-17
-------
location was small, the location was close to major coastal and
riverine cities, and filled-in wetlands could be used for other
more economically beneficial activities. The effect of this
practice has been to eliminate wetlands and reduce the value or
productivity of adjacent wetlands. Disposal facilities in wet-
lands often degrade adjacent surface water quality. The altera-
tion and destruction of wetlands through draining, dredging,
landfilling, and other means has had an adverse cumulative impact
on hydrologic stability and the ecosystems involved. Recent
estimates indicate that about 40 percent of the 120 million acres
of this country's wetlands that existed 200 years ago have been
destroyed (Ref. 109).
Solid waste disposal has often led to surface water con-
tamination from runoff of leachate, accidental spills, and drift
of spray occurring at dumps, landfills, surface impoundments,
farmlands, and landspreading operations.
One study cited 162 cases of surface water contamination
from industrial waste disposal alone, of which 42 (26%) occurred
at surface impoundments, 49 (30%) at landfills or dumps, and 7]
(44%) at landspreading operations or from haphazard disposal on
farmland (Pef. 79) .
In most areas of the country, except in arid zones, any con-
tamination of ground water usually threatens the quality of
surface water. The actual extent of degradation depends on
numerous factors, including:
Travel distance (and time of travel) between the
source of ground-water contamination and the
surface water body
Degree of hydraulic connection between the aquifer
and the surface water body
Nature and quantity of contaminants that actually
enter the aquifer
111-18
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Physical nature of the aquifer, i.e., granular or
fractured, and the nature of the aquifer
materials, which together determine the treatment
that will occur in the aquifer and the ultimate
quality of the ground water discharge
Ratio of baseflow discharge from upstream sources
to the contaminated discharge (i.e., how much
dilution occurs)
Quality of baseflow from upstream sources
- Pumping wells between the area of contamination
and the line of discharge.
The principal source of surface water contamination is
leachate, caused by water percolating through the refuse.
Leachate, a highly mineralized fluid, typically contains such
constituents as chloride, iron, lead, copper, sodium, nitrate,
and a variety of organic chemicals. Where manufacturing wastes
are included, hazardous constituents can be present in the
leachate (e.g., cyanide, cadmium, chromium, chlorinated hydro-
carbons, and PCBs) . The particular makeup of the leachate is
dependent upon the city and/or industries using the landfill or
dump. The types and concentrations of contaminants in leachate
are of great importance in determining its potential effects on
the quality of surface water.
The amount of infiltration from precipitation that falls on
a disposal facility is the major factor affecting the quantity of
leachate that can be generated. Therefore, the extent of the
potential problem of surface water contamination resulting from
leachate is greatest in areas where average annual precipitation
exceeds the potential water losses by evaporation and transpira-
tion. Such areas are generally found east of the Mississippi
River and in the coastal region of the Pacific Northwest. About
60 percent of the municipal refuse disposal facilities found in
the United States are located in these water surplus areas.
While the most common economic damage resulting from
leachate is the contamination of domestic, industrial, and public
111-19
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supply wells, there are numerous cases where leachate has
directly contaminated surface waters. In confined, slow-moving,
or relatively low-volume surface waters, leachate has killed
vegetation and fish, wiped out spawning areas, and ruled out the
use of existing and planned recreational areas (Ref. 7, p. 152).
Fish kills by leachate have been reported at 47 disposal
facilities in 20 States, involving over 65 miles of steams, 42
acres of lakes, and at least 215,000 dead fish. Up to 8 miles of
a stream and 12 acres of a lake were contaminated in one
individual instance (Ref. 10).
Industrial wastewater impoundments also pose a serious
threat to surface water because of their large number and their
potential for leaking hazardous substances which are relatively
mobile in the surface water environment. Faulty design, acci-
dent, or failure of surface impoundments containing industrial
effluent can cause surface water contamination because of leakage
of wastewaters into streams, lakes, or rivers. Potential
contaminants cover the full range of inorganic chemicals and
organic chemicals normally contained in industrial wastewaters.
Those documented as having degraded surface water quality include
phenols, acids, heavy metals, and cyanide.
In Maryland, discharge of phenolic wastewater to several
clay-lined lagoons had been occurring for 10 years before it was
discovered that the lagoons were leaking. Contaminated ground
water had migrated downslope to a fresh-water pond and a small
stream. Geophysical surveys and monitoring wells installed under
the direction of the State's Water Resources Administration indi-
cated that an extensive zone of ground-water contamination
existed in the water-table aquifer. Phenolic concentrations were
at a highly toxic level of 14.4 ppm. Discharge of this contami-
nated ground water had adversely affected the entire stream, from
the industrial plant site to a marshy area two miles away.
Because of the slow rate of movement of the contaminated ground-
water body, it has been estimated that a century or more will be
II1-20
-------
required before the stream can fully recover, even though the
leaky lagoons are presently being removed (Ref. 7, p. 108).
In another investigation conducted in the Northeast, a
stream adjacent to a chemical company was found to have arsenic
concentrations of 40 ppm (highly toxic). That source of
contamination was an unlined surface impoundment containing
arsenate compounds. Although the lagoon was subsequently
abondoned, the stream still shows evidence of arsenic concentra-
tion (Ref. 7).
Because heavy metals can be transported in surface runoff
waters, good engineering and soil management practices to limit
runoff and sediment transport during landspreading are appropriate.
Factors affecting runoff include land slope, distance from
receiving waters, rate of sludge application, water content of the
sludge, existing vegetation, soil permeability, and weather
conditions. The steeper the slope of land receiving the sludge
and the shorter the distance to receiving waters, the greater the
potential for surface water contamination. Use of conservation
tillage practices and engineering designs available from the
Soil Conservation Service for sloping land will help reduce
transport of metals by erosion and runoff.
Fluid sludges are more prone to loss in runoff shortly after
application than are dried sludges. If surface-applied to culti-
vated land, fluid sludges should be worked into the soil as soon
as practicable after application. Transport in runoff is a dis-
tinct possibility where sludges are applied to frozen and snow-
covered soils.
With fluid sludges low in available nitrogen, which would
otherwise be applied in relatively large quantities on the basis
of their nitrogen content, the amount of any single surface
application should preferably be limited to surface layers no
111-21
-------
more than 0.8 to 1.2 cm (1/3 to 1/2 inch) in thickness to avoid
undue runoff.
Although the effect on surface water of diffuse land dis-
posal of industrial sludge is not documented, some contamination
caused by runoff in the heavily industrialized regions of the
country can be expected. Indeed, surface water contamination
from landspreading of industrial residuals is considered a
regional problem (Ref. 7).
Industrial residuals create the greatest potential for
surface water contamination in areas where net recharge to ground
water from precipitation is greatest. The soluble substances in
the waste solids are transported to ground water percolating
through soil, and, depending on the geological conditions, may
ultimately be carried to streams, lakes, or rivers. The Great
Lakes and mid-Atlantic industrial regions receive enough pre-
cipitation to virtually assure that soluble waste components will
be carried to ground water, barring geochemical attenuation or
geological barriers. Along the Gulf Coast, evapotranspiration
rates are higher and reduce the net recharge rate. However, the
shallow ground-water table in the region increases the vulner-
ability of the ground-water system to contamination, and poses a
threat to surface water as well. In southern California and
other southwestern States, recharge from precipitation is only
associated with unusally intense storms, or storms of long dura-
tion (Ref. 7).
111-22
-------
2. Regulatory Alternatives and Environmental Consequences
a. Point-Source Discharges
(1) Final Criterion
This criterion seeks to achieve the objective of
the CWA: restoring and maintaining the integrity of the surface
waters of the United States. Accordingly, all point-source
discharges of pollutants to waters of the U.S.*, must comply with
NPDES permit requirements, according to Section 402 of the Clean
Water Act.
The environmental benefit of the final criterion is minimal;
the major benefit is the implementation of an existing control
mechanism, section 402 of the Clean Water Act, to ensure that
surface waters will be protected from contamination due to point-
source discharges.
The final criterion will apply to wetland areas and, as
such, is expected to safeguard all productive and ecologically
important wetland areas. (As used by the EPA, the term "wet-
lands" includes only areas which occur naturally, thus excluding
manmade ponds or lagoons.) Since the productivity and ecological
value of wetlands vary, not all wetlands require the same degree
of protection against discharges of pollutants. As provided by
* (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 drainage and irriga-
tion ditches excavated on dry land are not considered waters of the
United States under this definition); (4) interstate waters and
their tributaries, including adjacent wetlands; and (5) all other
waters of the United States not identified 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
of which could affect interstate commerce (33 CFR Part 323)(Ref. 146),
II1-23
-------
the CWA, it is the intent of this criterion that each NPDES
permit application be evaluated on a case-by-case basis and that
the importance of each wetland area, in terms of productivity and
value, be considered in the permitting process.
Upon issuance of the NPDES permit, the discharger must main-
tain compliance with it; upon denial or revocation of a permit,
the discharge must be discontinued.
The U.S. Environmental Protection Agency is currently
developing guidelines for the procedures to be used in applying
for and being issued an NPDES permit for a solid waste disposal
facility in a wetland. When issued in final form, this policy
guidance will provide direction to permit applicants and will
serve as the basis for evaluation of permit applications for
solid waste disposal facilities in wetlands.
(2) More Restrictive Alternative
A more restrictive alternative to the final cri-
terion would be a total ban of all point-source discharges. With
respect to wetlands, the siting of all landfills and surface
impoundments in such environmentally sensitive areas would be
prohibited. Banning all point-source discharges would severely
affect states with a high percentage of wetlands, such as Florida
and Louisiana. Since not all wetland areas are ecologically pro-
ductive, this restrictive alternative was rejected in favor of a
case-by-case study of each wetland area during the permitting
process.
(3) Less Restrictive Alternative
A less restrictive alternative to the final
criterion was not considered, since it would conflict with the
requirements of the Clean Water Act.
111-24
-------
b. Discharge of Dredged Material to the Waters
of the United States
(1) Final Criterion
Dredged material or fill material may be dis-
charged to "waters of the United States" provided that such dis-
charge complies with the requirements of Section 404 of the Clean
Water Act (Public Law 92-500, as amended by Public Law 95-217).
As used here, dredged material refers to that excavated or
dredged from waters of the United States, while fill material
refers to that used for the primary purpose of replacing an
aquatic areas with dry land or of changing the bottom elevation
of a water body. The term does not include any pollutant dis-
charged into the water primarily to dispose of waste, as that
activity is regulated under Section 402 of the Clean Water Act.
(2) More Restrictive Alternatives
A more restrictive alternativebanning discharge
of dredged material to the waters of the United Stateswould be
unnecessarily restrictive, with minimal environmental gain. The
existing regulatory provisions of the Clean Water Act are thought
to be sufficient to ensure the protection of surface waters from
the discharge of dredged or fill material.
(3 ) Less Restrictive Alternative
In order to avoid conflict with the requirements
of the Clean Water Act (Public Law 95-217), no less restrictive
alternative was considered.
111-25
-------
c. Nonpoint Sources
(1) Final Criterion
The final criterion calls for controlling nonpoint
sources of pollutants into any waters of the U.S. Nonpoint
sources must comply with the stipulations of applicable legal
requirements implementing an areawide or Statewide water quality
management plan approved by the EPA Administrator established
pursuant to Section 208 of the CWA. According to this criterion,
nonpoint sources would be prevented through facility design,
operation, and maintenance (e.g., by artificial or natural
barriers (e.g., liners, levees, and dikes), and collection of
such waters if produced (e.g., by ditch or trench). If such
wastewaters are collected, they then would become a point source,
thereby requiring an NPDES permit if discharged to waters of the
U.S.
(2) More Restrictive Alternative
A more restrictive approach to the problem of
protecting surface water from nonpoint sources would be the pro-
hibition of all nonpoint sources--!.e., zero discharge. An
outright prohibition would mean that disposal facilities would
have to install dikes, culverts, and storage basins, etc. of such
capacity to handle all likely precipitation incidents and of such
design to prevent any discharge (regardless of volume,
concentration reduction or quality). Since ground water is
generally connected to surface water, this could mean zero
discharge to ground water would be necessary regardless of site-
specific situations. Such a prohibition would also create some
inconsistencies in logic, since point-source discharges are
permitted under regulated conditions; nonpoint sources would have
similar environmental consequences and should not be more
severely regulated.
111-26
-------
(3) Less Restrictive Alternative
To avoid conflict with the requirements of the
Clean Water Act, no less restrictive alternative was considered.
3. Summary Technology, Economic, and Environmental
Impact Analysis
a. Control Technologies and Unit Costs
(1) Control Technologies
Proper site selection, as well as the proper
design and maintenance of a facility, are the principal tech-
niques available for minimizing surface water contamination
problems. Such technology as advanced waste treatment, physical
containment, drainage control, and effective facility management,
play major preventive roles where economic considerations dictate
that the sites be located in areas of critical surface water use
or high-contamination potential. In areas where land disposal is
neither economically nor environmentally feasible, such alter-
natives as waste transport, resource recovery, ground-water
injection, and air discharge should be investigated and may be
environmentally more acceptable.
This section presents a general discussion of control tech-
nologies for surface water protection; a more detailed evaluation
of technology for surface water and ground-water protection,
including recommended leachate control methods, is presented in
the discussion of ground-water technology (Section III-D).
(a) Landfills
The primary contamination potential from
disposal facilities is the discharge of leachate effluent either
as a point source or nonpoint source. The way to prevent such
111-27
-------
effects is through proper design, operation, and management of
the landfill with particular attention to the control of leachate
generation and discharge. Methods available to limit leachate
generation include surface capping with relatively impervious
soil, thickened soil cover, compacted soil, capping with
synthetic materials, adequate surface gradients, vegetation to
facilitate transpiration and minimize erosion, and subsurface
interceptor drains to control ground-water infiltration. Methods
available to dispose of leachate include discharge to a sewer and
on~site treatment.
The same technology for control or mitigation of the seepage
to the ground water is equally applicable to the protection of
surface waters. A detailed discussion of technology to control
percolation from impoundments, landspreading facilities, and sub-
surface disposal facilities is presented in Section III-D.
A wide range of design tools is available for the control
and management of surface waters which flow toward, or come from,
a disposal facility. Ditches, berms, dikes, levees, pipes,
retention and storage ponds, surface grade controls, surface
vegetation, flow deflectors, and energy dissipators are among the
techniques useful in the control and management of surface water
flows to, through, and from disposal facilities. A wide range of
products is utilized in constructing and maintaining these
systems, including asphalt, natural soils, concrete, synthetic
membranes, pipe material of all types, wood, and metal products.
The selection of such materials is subject to local availability,
economics, judgment, and experience. Selection and use of these
systems is not a guarantee against eventual infiltration of
surface waters to produce percolate, nor protection from erosion
which might expose the refuse to off-site movement of contamin-
ants through surface water contact with the refuse. Proper
selection of such systems and their maintenance are important in
the successful performance of the system in the protection of the
environment.
111-28
-------
The primary preventive method for adverse impacts on surface
water from adjacent areas is to direct all surface waters around
the disposal facility. If they must go through the disposal
facility, then a conveyance system should be used which is sound
and protects the water from adverse impacts. Another approach is
to encapsulate the disposal areas so that any surface water will
not have the opportunity of entering the waste materials.
Surface caps, barriers, linings, steep slopes, and thick cover
materials are all design mechanisms which have been successfully
used to accomplish this objective.
Erosion of cover soil and wastes can be minimized by
reducing water velocity, revegetating bare soils, and lining
water conveyance facilities. Where erosion is a problem, impacts
may be reduced by constructing settling ponds, check dams, brush
and straw dikes and filter cloth fences.
In addition to the application of standard technology, the
preservation of an ecosystem which provides habitat for flora and
fauna must be considered with respect to landfills located in
wetlands. Also, wetlands are frequently associated with a flood-
plain area and should receive, therefore, all considerations
necessary for sites located in floodplains. Although there
appears to be no satisfactory way to site a facility in wetlands
without adverse impact, there are methods for mitigating the
impact on the environment. The primary adverse impact on the
disposal site in the wetlands is the destruction of a portion of
an ecosystem which provides habitat, food material, breeding,
and/or activity areas for plant and animal life. When consider-
ing a facility in a wetlands area, the local areal and regional
system should be studied to determine locations for candidate
sites out of the wetlands as well as inside them. Candidate
sites could then be ranked and a chosen site selected to have the
least significant impact on the ecosystem. Further, local sites
similar in size and nature could be restored or returned to the
ecosystem to keep the same total area in wetlands.
111-29
-------
Every effort should be made to contain the wastes within the
facility and prevent seepage of contaminants. As a minimum, the
entire facility should be confined within a dike or 10-foot high
levee. In addition, restoration or preservation activities else-
where in the wetlands may provide tradeoffs to mitigate the
adverse impacts of disposal activities within such an eco-
logically fragile environment.
Where feasible, the final end use of the facility could be
blended with the ecosystem so as to provide additional habitat,
nutrients, or food supply for the plant and animal system in the
vicinity of the disposal facility.
Facilities located in wetlands could be developed in a more
efficient manner by using higher density disposal methods and
higher final contours, to minimize the amount of land used while
obtaining the maximum capacity from the landfill itself. High
density can be achieved by preprocessing the waste through baling
or shredding, and/or by using compaction equipment on-site to
increase refuse density. The benefit achieved is increased
facility life, resulting in the need for fewer landfills and a
smaller proportion of total wetlands acreage.
(b) Impoundments
The primary contamination potential from
impoundments is the degradation of surface waters from seepage or
spillage of liquids. One countermeasure is to prevent such
seepage or spillage by installing an impermeable barrier to fully
contain the liquid. Another approach is to provide adequate
freeboard so as to minimize spray or wave overtopping. A third
approach is to chose an alternative treatment method which can
perform the function of the impoundment to be replaced, i.e.,
additional treatment, storage, or disposal.
111-30
-------
(c) Landspreading
Proper site selection, design, operation, and
maintenance of controlled rates of waste application are the
principal techniques available for minimizing the surface water
contamination problems of landspreading.
The primary surface water contamination potential from land-
spreading is degradation caused by runoff of contaminated liquids
emanating from the landspreading area. The main countermeasure
is to use sound agricultural management practices that control
surface water runoff and incorporate the solid waste into the
soil.
Table III-4 shows control technologies and unit costs as a
function of site size for the final criterion; costs are iden-
tified for each disposal method impacted by this criterion.
Landspreading operations were considered to be minimally affected
by this criterion because of current control techniques such as
contour plowing. Controlling erosion minimizes surface runoff
from landspreading operations.
b. Assumptions
The major economic impact of this criterion results
from the mandates of the CWA to control nonpoint sources from
disposal facilities to surface waters, and from the need to
control waste disposal in wetlands, included in the criteria
definition of surface waters.
The control of nonpoint sources from landfills is currently
governed by existing legislationthe Clean Water Act. For this
reason, the costs displayed in Table III-4 are those induced by
this previously existing legislation, and are not attributed to
the criteria. Because of the CWA, a less restrictive alternative
was not considered applicable. However, a more restrictive
111-31
-------
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ni-32
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alternative requiring a higher degree of surface water protection
was considered, and the costs of this alternative above those
induced by existing legislation were attributed to the criteria
in the more restrictive cost assessment. For both the final and
the more restrictive alternatives, all on-site industrial land-
fills were assumed to be upgraded. Municipal landfills were up-
graded based upon existing State regulations.
It is also assumed that surface impoundments will be mini-
mally affected by the nonpoint provisions of this criterion,
inasmuch as nonpoint-source pollution of surface waters from
surface impoundments would probably result from dike leakage,
which is generally unlikely or insignificant. Landspreading
operations were considered to be minimally affected by this
criterion because of current erosion control techniques such as
contour plowing, which have the effect of reducing surface
runoff.
Included in the surface water criterion is the provision for
controlling waste disposal in wetlands. This portion of the
surface water criteria impacts both landfills and surface
impoundments. For this component of the surface water criterion,
a more restrictive alternative was considered. The more restric-
tive alternative would require that all disposal in wetlands be
banned. No less restrictive alternative was considered applic-
able, because of existing Federal legislation. Under the wet-
lands component of the surface water criterion, all on-site
industrial landfills were assumed to be upgraded. Municipal
landfills were upgraded, depending on State regulations. For
surface impoundments, it was assumed that two-thirds would
require upgrading or closure. It was also assumed that five
percent of the surface impoundments located in wetlands would be
forced to close and would be replaced by alternative disposal
methods or locations.
111-33
-------
In isolated cases there may be some adverse surface water
impacts on landspreading operations. The criteria require that,
in these cases, best agricultural management practices are to be
used for these operations to prevent contamination of surface
waters. Nationwide costs of the surface water criteria with
regard to landspreading will be negligible; however, some
operators may incur some moderate additional costs. Therefore,
economic impacts for surface water criteria for landspreading are
not included in the analysis.
c. Costs
Cost estimates for the effect of this criterion were
developed based upon the above technologies and upon unit costs
for each technology, as a function of facility size. These costs
were not attributed to the criteria but rather to the CWA. Unit
costs and the data base are presented in greater detail in
Chapter IV and in Appendix B.
In summary, the final regulation would result in costs in
every State. These costs, attributable to the CWA, would range
from a total high of $43.7 million to a low of $416,000. Of this
total cost, the general provisions of the surface water criterion
were most often State-induced, whereas the wetlands provisions
were most often Federally-induced. The general costs ranged
between $200,000 and $15.7 million, while the wetlands provision
incurred costs between $217,000 and $41.8 million per State. For
the more restrictive alternative, costs fell between a low of
$797,000 and a high of $132.4 million per State. More restric-
tive general costs of this criterion ranged between $256,000 and
$20.3 million, while for the wetlands the costs ranged between
$434,000 and $132.6 million.
The cost for monitoring surface water for nitrogen from
landspreading operations was found to be minimal.
111-34
-------
Tables III-5, III-6 and III-7 compare annualized costs based
on disposal method and regulatory alternative.
d. Economic and Environmental Comparisons Among
Alternatives
Tables III-8, III-9 and 111-10 show the economic and
environmental comparisons among alternatives for the surface
water component.
Comparing the more restrictive alternative with the final
surface water criterion shows that an additional combined cost of
$330.2 million would be incurred. Of this, the wetlands compo-
nent accounts for $284.9 million. Although significant environ-
mental benefits might occur through absolute protection of wet-
lands, such a measure would appear to result in prohibitive
costs.
111-35
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111-41
-------
D. GPOUND WATER
1. Importance; Adverse Effects from Improper Disposal
a. General
The importance of protecting ground water from con-
tamination is evidenced by the following facts (Pef. 43):
Ground water accounts for about half of all domestic
water use. (Ground-water withdrawals for public
supplies and rural domestic water in 1970 are shown in
Figure III-2)
The U.S. population is heavily dependent on ground
water as a source of drinking water in 32 States, as
shown in Figure III-3.
Once an aquifer is contaminated, it may remain so for
many decades.
- Contamination in ground water tends not to he dispersed
or diluted but rather moves slowly in "plumes" or
"sluas."
The dynamics of ground-water flow make it difficult to
predict movement of contaminants as they depend on
unknown future pumping patterns.
Severe impacts have been identified at 50,000 industrial
impoundments yielding over 380 million cubic meters (100 billion
qallons) of contaminants per year to around water; moderate to
severe impacts are occurring at 16,000 municipal solid waste land
disposal sites yieldinn about 340 million cubic meters (90
billion qallons) of contaminants per year to ground water; and
23,000 municipal waste water treatment plants are causing low to
moderate impacts of an unknown amounts through a variety of dis-
posal practices (Pef. 7).
Fiaure III-4 shows schematically and graphically the various
routes by which contaminants reach ground water from a variety of
waste Generators and disposal methods.
111-42
-------
SURFACE WATER-
PUBLIC SUPPLIES
64 %
GROUND WATER-
SUPPLIES
33%
GROUND WATER
RURAL DOMESTIC
SUPPLIES 12 %
SURFACE WATER
RURAL DOMESTIC
SUPPLIES 0.6%
Fig. III-2Water withdrawn for drinking water by source and supply, 1970.
ASource: Ref. 7, P. 2'
111-43
-------
E
III44
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111-45
-------
b. Leachate Contamination
Leachate is contaminated water which is produced when
water (precipitation, ground water, or surface water) passes
through wastes in a land disposal facility. Contamination can
occur through direct contact with ground water, disposal of wet
residues such as sludges, and through rainfall. The latter
effect gives rise to contamination most frequently in humid
regions, where the available moisture gain from precipitation
exceeds the potential moisture loss through evaporation, trans-
piration, and surface runoff. Leachate production is common in
the United States because most facilities are subjected to sub-
stantial precipitation and very few have liners to prevent infil-
tration. Furthermore, wastes at many facilities are placed
directly in surface or ground water (e.g., in streams, marshes,
and sand and gravel pits). Once produced, uncontrolled leachate
migrates from the facility and frequently enters surface or
ground water.
Ground water contaminated by leachate has been measured up
to 2 miles from two disposal facilities in the United States, and
up to five miles from a facility in Germany. Frequently, the
extent of migration in ground water is cut off by ground-water
discharge into surface waters.
The characteristics of leachate are primarily a function of
the types of wastes, amount of infiltrating water, and pH. High
concentrations of heavy metals,other inorganics, organics, and
biological contaminants, generally higher than wastewater, are
common in raw leachate.
At least 25 percent of the disposal facilities in the U.S.
are thought to be contaminating ground-water resources, with
estimates ranoing up to 90 percent. In the U.S., there are about
18,000 recognized municipal waste disposal facilities currently
in operation, at least 13,000 additional facilities have been
II1-46
-------
closed in the past 10 years, and as many as 100,000 unauthorized
roadside or promiscuous dumps currently exist (Ref. 7). The
number of industrial waste facilities is unknown. The impacts of
both existing and closed facilities are cumulative and long-term,
since it generally takes several years for disposal facilities to
reach field capacity and produce leachate. Leachate is produced
for many years, and leachate migration in ground water is very
slow since ground water frequently moves only a few feet each
year and only a few hundred feet each year even through very per-
meable substrata.
Due to increased utilization of water resources and
increased land disposal activities, the long-term duration of
leachate production and persistence in ground water, and the
generally high cost of corrective actions, the economic impacts
of improperly located, designated, operated, controlled, and
monitored disposal sites is sure to be severe on local and
regional levels, if not nationally. Such is already the case in
several areas of the country such as New Castle County, Delaware,
where the demand for water is approaching the existing uncon-
taminated surface and ground water supplies (Ref. 7).
The potential effects of leachate on ground and surface
waters depend on its characteristics and volume. Latest esti-
mates indicate that 122 million tonnes (135 million tons) of
residential and postconsumer commercial wastes are disposed of
annually in the U.S. (not including sludges, industrial wastes,
demolition/construction residue, discarded automobiles and parts,
street sweepings, and trees), with an additional 218 million
tonnes (240 million tons) of industrial wastes disposed of
annually to the land (Ref. 7, pp. 149,151). Characteristics of
leachate from municipal waste are shown in Table III-ll.
Because of the lack of ground-water monitoring around dis-
posal facilities, water supply wells located near such facilities
have often become de facto indicator wells. Fortunately,
111-47
-------
TABLE 111-11
SUMMARY OF LEACHATE CHARACTERISTICS BASED ON 20 SAMPLES
FROM MUNICIPAL SOLID WASTES
(Ref. 7, P.148)
Components
Alkalinity (CaC03)
Biochemical Oxygen Demand (5 days)
Calcium (Ca)
Chemical Oxygen Demand (COD)
Copper (Cu)
Chloride (Cl)
Hardness (CaCO,)
Iron, Total (Fe)
Lead (Pb)
Magnesium (llg)
Manganese (Mn)
Nitrogen (NH^)
Potassium (K)
Sodium (Na)
Sulfate (S04)
Total Dissolved Solid (TDS)
Total Suspended Solids (TSS)
Total Phosphate (PO.)
Zinc (Zn)
pH
Median Value
(ppm)a)
3,050
5,700
438
8,100
0.5
700
2,750
94
0.75
230
0.22
218
371
767
47
8,955
220
10.1
3.5
5.8
Ranges
0
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60
40
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4.7
0
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0.06
0
28
0
1
584
10
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3.7
of all Values
(ppm)a)
-20,850
-33,360
- 7,200
-89,520
- 9.9
- 2,500
-22,800
- 2,820
- 2.0
-15,600
- 125
- 1,106
- 3,770
- 7,700
- 1,558
-44,900
-26,500
- 130
- 370
- 8.5
a) Where applicable
Iir-48
-------
however, most disposal facilities have been located far from
water supply wells in remote areas, in ground-water discharge
zones (e.g., in lowlands and marshes, or near streams), in indus-
trially zoned areas or next to sewage treatment facilities where
contamination already exists or there are no wells. Neverthe-
less, at least 36 disposal facilities in 21 States have contamin-
ated drinking water supply wells (Ref. 7).
The social, psychological, and economic impacts of well con-
tamination are quite severe. Typically, the well owner goes for
a year or more without a permanent water supply, using bottled
water and any other sources available. In one case involving
domestic wells, the cost for permanent supply (excluding the cost
of inconvenience) was over $20,000 per affected home. With
public supply well fields, the costs are even higher. In another
case, over $2 million has already been spent and another $8
million in costs is anticipated. In a similar case, $4 to $18
million is anticipated to correct the problem (Pef. 7).
c. Landspreading Impacts
Although long-term studies have not been completed,
those working on the subject agree that soils readily remove
heavy metals from the soil solution and prevent them from
reaching the ground water. Contamination of the ground water
with metals, therefore, is not likely to result from application
of sewage sludge to soils.
On very permeable soils or on soils with water tables or
bedrock within a few feet of the soil surface, sludge application
at rates supplying more nitrogen than the crop requires can
result in ground-water contamination with nitrate. When
selecting sites for sludge application, the permeability and
drainage of the soil and the depth of the water table and bedrock
should be considered.
111-49
-------
d. Impoundment Impacts
The basic effects of leachate damage have been des-
cribed above. 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 coeffi-
cients and the estimated 6.4 billion cubic meters (1700 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
(Ref. 7).
2. Major Regulatory Issues
The major regulatory issues for ground water are:
Definition of ground water to be protected
- Place of compliance
Criteria alternatives
Ground water can literally include all the water under the
earth's surface. Classification or definition of this water is
necessary to identify under what conditions this water is a
valuable resource reauiring protection. Generally, the
occurrence of this water may be divided into zone of saturation
and zone of aeration. The water below the land surface within
the zone of saturation is commonly referred fo as ground water,
and it is this water that is considered for coverage by the
criteria (Pef. 146). Identifying ground water for protection
should also consider the following factors:
Quantity (yield-transmissivity)
Usage (existing or planned)
Quality
111-50
-------
Providing protection for ground water must also address the
olace of compliance, such as:
Solid waste boundary
?11 usable ground water
Specific distance from waste disposal
Disposal facility property boundary
Nearest usable well
The last major issue is what impact, if any, is allowable.
The criterion may specify allowable impact, or it may specify
technology level which is based on probable impact. Examples of
such criteria alternatives are:
Zero discharge
Zero degradation beyond background quality
Zero degradation beyond a specific limit
Zero impact on treatment required
Specific technology - best management practice
3. Pegulatory Alternatives and Environmental Consequences
Proper site location and ground-water/land use planning, as
well as design, construction, operation and maintenance of
facilities, are the principal techniques available for minimizing
ground-water contamination problems. Where economics or other
factors dictate that sites be located in areas of usable ground
water (such as existing and potential drinking water sources),
such technologies as physical containment (liners), collection,
and treatment of leachate may be necessary.
FPA feels that the ground-water criterion should establish a
coiporehensive ground-water protection standard for all solid
waste disposal practices. The goal is to protect all current
users of the ground water and to protect other designated ground
water for future usage. Of primary concern is protection of
current and future ground water used for drinking water supply.
111-51
-------
AS a national policy, EPA feels that those ground waters
currently used or potentially usable as a drinking water supply
should be protected for that use. States should be given the
option to classify ground water for other uses.
a. Final Criterion
The final criterion prohibits contamination of an
underground drinking water source beyond the solid waste boundary
or beyond an alternative boundary specified in accordance with an
EPA-approved State solid waste management plan.
Other key definitions in the final ground-water criterion
are "ground water", "contaminate", and "underground drinking
water source". "Ground water" refers to usable quantities of
water in the zone of saturation. As used here, contamination
refers to introducing a substance that would cause the concentra-
tion of that material in ground water to (1) exceed the maximum
contaminant level (MCL) specified in any National Primary
Drinkinci Water Regulation (NPDWR) promulgated under the Safe
Drinkinq Water Act of of 1974 (SDV'A), as amended (Public Law 95-
190) and other HCL's as specified in Appendix I of the criteria,
or (2) increase in cases where the existing concentration of that
substance exceeds the maximum contaminant level specified in
Aopendix I of the criteria. Note that as used here, regulation
is in effect a standard. An underground drinking water source is
defined as an aquifer (1) supplying drinking water for human con-
sumption, or (2) containing around water designated as a drinking
water source, provided that the total dissolved solids concentra-
tion in this water is less than 10,000 mg/1.
To prevent contamination of underground drinking water
sources beyond the solid waste boundary, or drinking water
sunolies beyond the facility property boundary, the disposal
facility must (1) utilize natural hydrogeologic conditions or
soil attenuation mechanisms, and/or (2) collect any leachate pro-
111-52
-------
duced by using natural synthetic liners and dispose of this
leachate (when necessary to meet this criterion), and/or
(3) reduce the infiltration of water into solid waste, and/or
(4) divert the ground water or leachate.
For as long as leachate may contaminate an underground
drinking water source, ground-water monitoring will be conducted
in order to detect and predict contamination.
The first part of the definition of "contaminate" for ground
water is intended to protect water that can be used as drinking
water without treatment. The second part of this definition is
intended to protect ground water already requiring treatment for
use as drinking water by preventing introduction of substances
necessitating additional or more extensive treatment.
The ground-water criterion also provides some protection of
property overlying ground water for present or future owners.
Thus, owners will be notified in the event that this ground water
is contaminated by a facility and is unusable for drinking water.
A stipulation to this effect would be incorporated in the pro-
perty deed or land record.
b. More Pestrictive
A more restrictive ground-water alternative would be to
prohibit contamination of all usable (10,000 mg/1 TDS or less)
ground water (in the saturated zone), on or off the site (zero
discharge).
The environmental benefit of this more restrictive approach
would be the protection of ground water under the disposal
facility as well as beyond the solid waste or other specified
boundary; such an approach would minimize the possibility of off-
site pollution migration caused by designer error or unforeseen
subsurface hydrogeologic conditions. Implementation of the more
111-53
-------
restrictive alternative would necessitate relatively expensive
containment, collection, and treatment system for leachate at
most landfills and impoundments.
By implementing the best available technology, collecting
and treating leachate, and monitoring disposal facilities in
these regions, important drinking water sources should be ade-
quately protected.
During the public comment period, opposition to more
stringent limits was expressed on the basis that scientific evi-
dence does not exist to support the need for more stringent stan-
dards to protect health.
c. Less Restrictive
A less restrictive alternative would be to limit the appli-
cation of the ground-water criterion to water at the nearest
usable well and allow the unrestricted designation of ground-
water "sinks". Such an approach would fail to ensure protection
of underground drinking water sources beyond the solid waste or
other designated boundary of the disposal facility.
The environmental consequence of the less restrictive alter-
native is that off-site degradation of ground water could con-
tinue undetected and uncontrolled; since ground water is often
consumed without treatment, such a lax approach is considered un-
acceptable.
The less restrictive approach is considered by EPA to be
environmentally unacceptable since: (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) ground water is often consumed without treatment, and
(3) disposal facilities are often not monitored.
111-5 4
-------
4. Summary Technology, Economic, and Environmental
Impact Analysis
a. Control Techniques and Unit Costs
(1) Overview
Ground water is protected by controlling
(1) leachate generation and (2) the flow of leachate and wastes
from the facility; these are achieved through proper site selec-
tion, design, and maintenance. Such technology as advanced waste
treatment and physical containment play a major preventive role
where economic considerations dictate that facilities be located
in areas of critical ground-water use. If land disposal of
wastes is not environmentally feasible in some areas, such alter-
natives as waste transport, resource recovery, and surface-water
or air discharge should be investigated as they may be more
environmentally acceptable.
(2) Control Technology for Landfills;
Leachate Control
The primary contamination potential from subsur-
face disposal is from seepage of leachate. Methods for pre-
venting, reducing, or managing leachate are (1) natural atten-
uation, (2) prevention of formation, (3) collection and treat-
ment, (4) pretreatment capable of reducing the volume or solu-
bility of the waste, and (5) detoxification of hazardous wastes
prior to disposal.
Descriptions of the first three of these processes are given
below, including the effectiveness of protecting ground-water
resources. Pretreatment options are generally not available to
the disposal facility operator, while detoxification of hazardous
wastes will be an option covered by forthcoming EPA regulations
for hazardous wastes.
111-55
-------
(a) Natural Attenuation
As leachate migrates through soil, it under-
goes natural attenuation by various chemical, physical, and bio-
logical processes. The ability of a proposed sanitary landfill
site to attenuate the leachate generated should be estimated on a
site-by-site basis; if natural attenuation appears inadequate, it
may be desirable to line the site and collect and treat the
leachate.
(b) Prevention
The second control method involves preventing
leachate generation. If water is restricted from entering the
site, then the amount of leachate generated will be greatly
reduced. Water cannot be completely prevented from entering in
some locations, but through proper design and operation, the
Quantity can be minimized.
Control measures available to the design engineer and oper-
ator include diversion of upland drainage; use of relatively
impermeable soils for cover material; compacting,- grading, and
sloping of the daily and final cover to allow runoff; planting of
high-transpiring vegetation; use of impermeable membranes over-
lying the final layer of solid waste; maintenance of final
grades; and use of subsurface drains and ditches to control
ground water. The use of impermeable membranes and soil cover
reouires vents to control landfill gases and drains to manage the
intercepted leachate.
(c) Collection and Treatment
The third control method is to collect and
treat the leachate. A relatively new technique involves use of
an impermeable liner to prevent the movement of leachate into the
ground. The long-term durability of impermeable liners has not
111-56
-------
been proven; nevertheless, their potential is very promising.
Figure III-5 shows a schematic for a leachate treatment system.
Impermeable liners can be made from different types of
materials, including: natural clay, soil additives, conventional
paving asphalt, hot sprayed asphalt, polyethylene (PE), polyvinyl
chloride (PVC), butyl rubber, Hypalon, polyolefin, chlorinated
polyethylene (CPE), and ethylene propylene rubber (EPDM).
Where landfills use collection for control of leachate,
provisions must be made for treatment prior to discharge to the
surrounding environment. Biological treatment methods are effec-
tive when treating fresh, high-strength leachate generated in a
new facility. Physical-chemical treatment methods show better
results than biological methods when treating leachate of inter-
mediate to low strength. Industrial leachate may require more
specific treatment techniques, depending upon the wastes
involved.
(3) Control Technology for Landspreading
Ground water may be protected from contamination
due to landspreading of solid waste by proper site selection,
design, and operational management controls. Site selection
parameters must consider the hydrologic regime and geologic
setting. The selection parameters for soils and land surface
features focus on protection of surface water and ground water by
promoting maximum on-site retention of wastes.
Climate and geology are two important components of the
hydrologic cycle that strongly influence the distribution,
circulation, and chemical properties of water. The site
selection process should document watershed or drainage basin
characteristics, water resources and management, and water
quality. Key factors in evaluating the hydrologic regime are
quantity and timing of water fluxes, and resulting water quality.
111-57
-------
Row Leochate
«-Woste Solids
Recovery or
Disposal
Recovery or
XFinol Disposal
Regenerant
10% NaOH
III-5 Possible Scheme for On-Site Treatment of
Non-Recycled Leachate
Source: Ref. 46
111-58
-------
Sludge applications do not usually involve high-liquid loading
rates; thus, the water regime can be viewed as a natural flow
system. The water budget for a potential facility is important
for maximum crop production and adequate retention time to
prevent contaminant movement to ground water. In certain
critical qround-water regions, hydrologic limitations will
influence the design and operation management of sludge appli-
cation facilities, and ground-water controls may be required.
(4) Control Technology for Impoundments
The primary contamination potential from impound-
ments is degradation of ground waters from seepage of liquids.
One countermeasure is to prevent seepage by installing an imper-
meable barrier. Another approach is to choose an alternative
treatment method which can perform the function of the impound-
ment to be replaced (i.e., additional treatment, storage, or dis-
posal). Seepage can also be stopped by chemical or physical soil
sealant applications.
A wide range of materials are useful as barrier membranes
for impounding liquids and sludges. Many are being used in the
lining of ponds, reservoirs, lagoons, and canals for reducing or
eliminating the seepage of liquids into ground water. Today an
increasing number of industries are installing synthetic liner
materials, especially Hypalon and polyvinyl chloride, to meet
environmental quality standards.
Soil sealants take the form of chemical additives which
either form a seal coating at the soil-liquid interface or
restrict the flow space of the soil-void system. Lagoons used
primarily for storage can be replaced by leakproof facilities,
such as above-ground tanks or concrete basins. The ma^or para-
meters for storage tank selection involve quantity of waste and
expected length of storage, and the physical and chemical proper-
ties of the waste; thus, a waste containing volatile contaminants
111-59
-------
should be stored in properly vented closed tanks. In those cases
in which volatility or odors pose no problem, wastes can be
stored in open facilities.
A waste which is not corrosive can be stored in a concrete
or steel tank; storage of wastes which are corrosive would
reauire tanks made of other materials. Reinforced-wall design is
required for concrete basins, and the concrete must be water-
proofed with a suitable paint or plastic coating. Short-term or
temporary storage basins would have less stringent construction
reauirements than long-term or permanent storage.
N'ore effective and environmentally sound techniques are
available to replace wastewater treatment operations now in use
at nonds and lagoons or to reduce the volume of wastewater dis-
charged to impoundments. Solids separation can be more effec-
tively performed in clarifiers, by infiltration or centrifuga-
tion. Another example is biological stabilization through use of
activated1 sludge or trickling filtration rather than lagoons.
Diaestion (anaerobic, aerobic) can be used as an alternative
treatment for sludges or wastes with high-organic content.
Chemical treatment is occasionally carried out in lagoons. The
same reactions can be carried out in other facilities less prone
to causing contamination.
In general, an alternative to on-site treatment is connec-
tion to a municipal treatment plant, assuming that it has the
capacity and capability of treating the particular waste.
Table 111-12 shows control technologies and unit costs as a
function of site size for the final criterion; costs are identi-
fied for each disposal method impacted by this criterion.
111-60
-------
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b. Assumptions
The major economic impacts of this criterion result
from the need to control leachate generation and migration from
landfills and surface impoundments. Since, as a practical
matter, landspreading on food-chain crop lands is limited to
amounts and concentrations which will not retard plant
productivity, it is assumed that landspreading operations will
have a minimal impact on ground water and, therefore, will be
only minimally affected by the ground-water criterion. It is
further assumed that, although some landspreading on non-food
chain crop lands may impact ground water, the national impact
will be minimal because, as a practical matter, landspread wastes
are generally applied in relatively thin layers to meet the
nitrogen needs of the crops, which allows for natural phenomena
to attenuate or otherwise minimize the impact on ground water.
Thus, the economic impacts of the ground-water criterion were
assumed to be negligible for landspreading operations.
The level of control technology for each of the alternatives
was considered to be a function of hydrogeologic, attenuation,
and other factors impacting infiltration rates. For the final
criterion, the level of ground-water protection was a function of
disposal facility location in net infiltration or negative infil-
tration areas. For the more restrictive alternative, the maximum
level of technology was applied, while the minimum level of tech-
nology was applied for the less restrictive alternative. For
landfills, an appropriate combination of lining, leachate collec-
tion and treatment, and ground-water monitoring was used to
measure cost. For surface impoundments, lining and ground-water
monitoring were used.
To assess costs for this criterion, the following
assumptions were made:
111-63
-------
All disposal facilities (municipal and industrial)
located in wetlands would require upgrading for the
ground-water criterion.
In States with standards equivalent to this criterion,
50 percent of the authorized municipal landfills in net
infiltration areas would require upgrading, none in
negative infiltration areas.
In States with standards less stringent than the
ground-water criterion, 50 percent of the permitted and
authorized municipal landfills in net infiltration
areas would require upgrading, none in negative infil-
tration areas.
All illegal municipal landfills would require closure.
Fifty percent of the industrial landfills in net infil-
tration areas would require upgrading, none in negative
infiltration areas.
For surface impoundments, 50 percent of all impound-
ments located in non-wetland areas would require
upgrading.
Costs
Cost estimates for the effect of the ground-water
criterion were developed based upon the above technologies and on
the unit costs for each technology as a function of facility size
and degree of ground-water protection required. Unit costs and
data base are presented in greater detail in Chapter IV, and in
Appendix B.
The combined costs of the technology to control ground-water
contamination for all disposal facilities are the following:
111-64
-------
The final regulation would result in costs in all
States, ranging from a high of $396.5 million to a low
of $3.9 million, totalling $4067.7 million nationwide.
The more restrictive alternative would impact all
States, ranging between $7.5 million and $546.1
million, totalling $6676.5 million nationwide.
The less restrictive alternative would impact all
States, causing costs between $139.8 million and
$875,000, totalling $931.4 million nationwide.
The cost for monitoring ground water for nitrogen from land-
spreading operations was found to be minimal.
Table 111-13 compares annualized cost on a nationwide basis
by disposal method and regulatory alternative.
d. Economic and Environmental Comparisons Among
Alternatives
Table 111-14 shows the economic and environmental com-
parisons among alternatives for the ground-water criterion.
Comparing the more restrictive alternative with the final
shows that an additional combined cost of $2608.8 million per
year for the more restrictive alternative does provide a return
in terms of environmental benefits; however, this increased
benefit would result in prohibitive compliance costs. On the
other hand, in comparing the less restrictive alternative to the
final regulation, EPA has concluded that the environmental
benefits of the final criterion justifies the cost, in spite of
the sianificant cost difference between the two alternatives.
II1-65
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E. APPLICATION TO LAND USED FOR THE PRODUCTION OF
FOOD-CHAIN CROPS*
1. Importance; Adverse Effects from Improper Disposal
a. Importance of Landspreading
Seven major municipal and industrial groups, including
municipal wastewater treatment, food processing, pulp and paper,
leather, textiles, Pharmaceuticals, and petroleum refining, now
produce the majority of wastes suitable for landspreading. When
one considers the relative impacts of each of these groups in
terms of both the quantities of sludge landspread and the poten-
tial toxicity of the sludge, the municipal wastewater treatment
sludges become a prime concern.**
Five million dry metric tons of municipal sludge are
generated each year in the United States, with sludge volumes
expected to increase dramatically in the next few years. As
shown in Figure III-6, approximately 30% of municipal sludge is
now landspread in some fashion. Other major practices currently
used to dispose of municipal sludge are incineration, land-
filling, and ocean disposal. Current trends suggest that the
practice of landspreading of municipal sludges can only increase
beyond the levels indicated, since practices such as ocean dis-
posal and incineration are being eliminated or severely curtailed
as a result of implementation of the Marine Protection Research
and Sanctuaries Act, and the Clean Air and Clean Water Acts.
* Food-chain crops are tobacco; crops grown for direct human con-
sumption; and pasture, forage, and feed grain for animals whose
products are consumed by humans.
** Further discussion of this point can be found in Appendix D.
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 DiseaseSewage Sludge and Septic
Tank Pumpings (under Section 257.3-5 and 257.3-6(b), respectively)
are of an interim final status.
111-68
-------
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111-69
-------
The application of municipal wastewater treatment sludges to
agricultural land (i.e., landspreading to food-chain cropland)
can provide significant benefits in addition to fulfilling a
primary function as a waste disposal method. Since municipal
sludge is relatively high in organic content, it may function as
a soil conditioner, especially in damaged or marginally produc-
tive soils. Although low in nutrient content relative to commer-
cial fertilizers, sludge can be applied at rates which will
supply all the nitrogen and phosphorus requirements of most
crops. In addition, municipal sludge can be used as a source of
crop micronutrients to soils which are low or deficient in
certain other essential trace elements such as zinc, copper, man-
ganese, and iron.
b. Adverse Effects from Improper Disposal
The application of municipal sewage sludges to agricul-
tural land is not without potential hazards and problems. These
include odor, pathogens, contamination of surface or ground
waters, toxicity to plants, and endangerment to human health due
to increased concentration of potentially toxic elements in the
food supply. Discussions of the adverse effects of odor,
pathoqens, and surface and ground-water contamination are pre-
sented in other sections of the EIS document.
In this section, the discussion of adverse effects of
trunieipal sludge application to food-chain land will be
restricted to the phytotoxic effects of excessive amounts of
heavy metals, and the human health impacts of the accumulation of
these toxic elements, as well as hazardous industrial organic
chemicals, in the human food chain as a result of sorption and
adherence of these substances on crops and soil. As will be
shown, the toxic impacts to man of the heavy metals, cadmium and
lead, and the organics, chlorinated hydrocarbon pesticides and
polychlorinated biphenyls represent the major sources of concern
surrounding the application of municipal sludge to food-chain
land.
111-70
-------
(1) Heavy Metals
The application of sludge-borne metals to land can
pose potentially serious hazards to plants, animals, or humans as
a result of two distinct transfer mechanisms. These are the
mechanisms of plant absorption of raetals from the soil through
the roots and into the food chain and direct ingestion of the
metal by animals or humans from sludge present on plant foliage
or on the soil surface.
Table 111-15 presents data on concentrations of selected
heavy metals in soils and municical sewage sludges.
Plant Absorption
With respect to plant absorption or uptake,
certain heavy metals in sludge may present a hazard. Metals
which pose relatively little hazard to crop production and plant
accumulation when sludge is applied to soil are manganese, iron,
aluminum, chromium, arsenic, selenium, lead, and mercury. These
elements all either have low solubility in slightly acid or
neutral, well aerated soils, or are present in such small amounts
in the sludge that the concentration is low in soils (Ref. 179).
As a result, the availability of the elements to the plants is
relatively low, and little uptake by plants occurs.
Manganese, iron, and aluminum, for example, are not
hazardous at normal soil pH, and have no known problems in soils
when found at high concentrations (Ref. 183). In addition to
having low solubility in soil, chromium and lead are not readily
taken up by plants, and this limits their entry into the food
supply (Pef. 179). Mercury, when added to soil in large quan-
tities may be taken up by plants, but generally is bound by clay
and organic matter in unavailable forms (Pef. 183). Fortunately,
municipal sludges tend to have low mercury concentrations. Con-
siderable quantities of arsenic may be added to soil with the
111-71
-------
TABLE IH-I5
Selected Heavy Metal Concentrations
In Soils and Municipal Sewage Sludges
Element
Arsenic (As)
Cadmium (Cd)
Chromium (Cr)
Copper (Cu)
Mercury (Hg)
Molybdenum (Mo)
Nickel (Ni)
Lead (Pb)
Selenium (Se)
Zinc (Zn)
Concentration (mg/kg)
Sludge Range ^
6-230
3-3,410
10-99,000
84-10,400
0.2-10,600
5-39
2-3,520
13-19,700
10-180
101-27,800
Sludge Median-"-
10
16
890
850
5
30
82
500
20
1,740
Soil Range2
1-50
0.01-1
1-100
2-100
0.01-1
0.2-10
1-100
0.1-10
0.1-10
10-300
Footnotes :
1. Sommers, L.E., "Chemical Composition of Sewage
Sludges and Analysis of Their Potential Use as
Fertilizers." Journal of Environmental Quality,
6:225-239, 1977.
2. Strauch, D., "Health Hazards of Agricultural,
Industrial, and Municipal Wastes Applied to Land."
In: Land as a Waste Management Alternative. R.C.
Loehr~(ed), Ann Arbor Science, pp. 317-342, 1977.
111-72
-------
sludge. Little hazard is posed by this element, however, because
arsenic is strongly held by the clay fraction, and plants tend to
exclude arsenic from their aerial tissues (Ref. 179, 183).
Selenium concentrations in sludge are so low that they do not
present a hazard. However, as selenium can be toxic to animals,
if sludge with a high concentration of selenium were applied to
soil for a number of years, the concentration could build up to
the extent that forage might absorb sufficient amounts to be
toxic (Pef. 181).
The remaining heavy metals found in sludge--copper, molyb-
denum, nickel, zinc, and cadmiumtend to accumulate in plants,
and under certain circumstances may be considered to pose a
hazard to plants, animals, or humans. These metals are discussed
in detail below because of the potential problems concerning
toxicity and health.
The uptake and translocation of copper through the roots of
plants is slow (Ref. 180). Hence, application of sludge to soil
results only in slight to moderate increases in the copper con-
tent of plants, even though appreciable amounts of the element
may be added to the soil. Copper has the added characteristic of
phytotoxicity at low plant concentrations (30 mg/kg)(Ref. 180).
As a result, plants act as a biological barrier to copper, since
the plant dies or fails to grow long before it can accumulate a
metal content toxic to a mammalian consumer.
Molybdenum is apparently taken up by plants, but is not
particularly toxic to them (Ref. 179) . However, it is possible
that plants could absorb molybdenum from sludge-amended soils in
such quantities sufficient to be toxic to animals (Ref. 181).
Animal toxicity is manifested in a disorder in ruminant animals
called molybdenosis (a molybdenum-induced copper deficiency). In
most cases, molybdenum in sludge should not pose a serious hazard
to the health of grazing animals, due to the typically low con-
centrations that are usually found in sludges.
111-73
-------
Nickel is toxic to plants at concentrations of 30 to
50 rag/kg, but only on acid soils (Ref. 179,180). As with copper,
plants serve as a biological barrier to nickel by dying or
failing to grow before quantities toxic to animals can be accumu-
lated. Nickel should, therefore not pose a threat to the food
supply.
Zinc toxicity in plants has been reported at relatively high
concentrations (400 mg/kg)(Pef. 180). Toxicity in animals starts
when the zinc content of the diet exceeds 1000 rag/kg (Ref. 180).
Most plants are severely injured at such high zinc levels
(Ref. 182). Therefore, lower toxicity levels of plants, when
compared to animals, serve as protection against zinc accumula-
tion in the food chain (Ref. 180). Zinc also appears to be in
need of supplementation in the human diet, and slightly elevated
levels in plants may, therefore, be regarded as beneficial
(Pef. 183).
Cadmium (Cd) is currently the element of greatest concern as
a food-chain hazard to humans, since it is readily absorbed by
most crops and can be found in plant tissues at extremely high
levels long before any indications of phytotoxicity. Therefore,
cadmium can accumulate in plants and enter the food chain.
The chemistry of cadmium in soil is not well understood, but
cadmium appears to be influenced by soil organic matter, clay
content and type, hydrous oxide content, soil pH, and redox
potential. Currently, there is considerable disagreement among
researchers as to whether the total amount of cadmium added to
the soil or annual applications of sludge-borne cadmium ulti-
mately control the uptake of cadmium by plants. Some data exist
to show that the amount applied in a given year influence the
cadmium content in the crop to a greater extent than the total
cumulative amounts of cadmium applied (Ref. 190, 191). This
implies that the annual loading rate is more important than the
total amount of cadmium applied and that the cadmium applied by
111-74
-------
previous applications is unavailable to plants (Ref. 183). How-
ever, when cadmium application stops, the applied cadmium remains
available for extended periods of time, which indicates that the
total soil cadmium is also extremely important (Ref. 191).
Studies conducted by the USDA Agricultural Research Service found
the effect of soil pH to be the most important observation con-
cerning cadmium accumulation by plants (Ref. 192). Lowering of
the soil pH due to natural processes in sludge-amended soils
caused increased crop uptake of cadmium after sludge application
had ceased; soil pH increases due to limestone addition can sub-
stantially decrease crop accumulation of sludge-applied cadmium
(Pef. 192).
Crops differ widely in cadmium uptake characteristics. Con-
siderably higher levels of cadmium accumulate in the foliar
(leafy) portions of many crops than in the grain, fruit, or
edible roots. Moreover, the older leaves of most plants will
contain higher amounts of heavy metals than the younger tissues.
Consequently, the uptake of cadmium by tobacco and leafy vege-
tables such as lettuce, chard, spinach, and turnip greens is
significantly higher than grain crops such as corn, wheat, and
soybeans.
Although cadmium has no known function in animal systems, it
tends to undergo bioaccumulation in certain animal tissues
(Ref. 184). Domestic animals (beef, chicken, lamb) ingesting
cadmium in their feed retain most of it in the liver and kidney,
with very little being found in either the meat or milk. Steers
directly fed varying amounts of Denver sewage sludge since 1975
showed either very low or no detectable levels of metals
(including cadmium) in muscle tissue; metals accumulated almost
exclusively in the liver and kidney (Ref. 185).
The human health hazard associated with cadmium ingestion is
one of chronic toxicity, expressed only after long exposure. The
kidney is considered the main target organ in humans for chronic
111-75
-------
exposure to cadmium, the major routes of exposure being dietary
intake and cigarette smoking. Upon ingestion 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 ug/g (wet weight) in the average human. At
that level renal tubular proteinuria is expected to occur. This
condition is manifested by the excretion of B2-microglobulin,
which is the earliest discernible laboratory evidence of organ
damage. Although mild or moderate increases in excretion of B2-
microglobulin, 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 glycos-
uria, amino-acid uria, and phosphaturia).
Various metabolic models have been established to calculate
the daily level of exposure which will result in a_ cadmium con-
centration of 200 ug/g in the kidney cortex (i.e., the concentra-
tion .at which tubular proteinuria can be expected to occur) . EPA
scientists reviewed these metabolic models and have reached the
following consensus. Ingestion of 440 micrograms of cadmium per
day over a 50-year period is a reasonable estimate of the amount
of cadmium necessary for 50 percent of the individuals within the
population to develop proteinuria. It is significant to point
out, however, that there are many individuals who may develop
proteinuria at lower exposure levels. The metabolic model,
developed by Friberg, shows that ingestion of about 200 micro-
grams per day over a 50-year period is the level at which most
sensitive individuals accumulate 200 ug/g cadmium in the kidney
cortex. The dose-response model, developed by Kjellstrom and
Nordberg, reflects a non-threshold dose-response. Using this
model, daily cadmium exposures in the range of 100 to 125 micro-
grams would produce renal dysfunction in about 5 to 8 percent of
the population after some 50 years of exposure.
111-76
-------
These model calculations are based 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 equivalent
to cadmium retention in 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 non-dietary intake sources and for
sensitive individuals, the WHO recommended that human exposure to
cadmium should not exceed 57 to 71 inicrograms 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 habits. Based on annual market basket surveys conducted
by the Food and Drug Administration (FDA), the median ingestion
level is about 39 micrograms per day and the mean ingestion level
is about 71 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 as 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.
Two other methods for estimating cadmium levels in the human
body include chemical analysis of fecal excretions and of_ autop-
sied body organs. The fecal excretion studies are based on the
experimental finding that only about six percent of ingested
111-77
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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 ingestion levels. Thus,
five percent of the population appeared to exceed 30 to 40 micro-
grams per day intake, and one percent appeared to exceed 50
micrograms per day intake.
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
the concentration of the metal increases with age. Further,
the autopsy data indicate that for the general U.S. 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.
There are population groups for whom an increase 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. Vege-
tarians also may be experiencing higher cadmium intake than the
average population, since certain vegetables contain signifi-
cantly more cadmium than other food items. Also, the scientific
literature indicates that certain nutritional deficiencies, such
as low calcium, zinc, or protein, result in a marked increase in
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cadmium absorption through the gastrointestinal tract, while
individuals with Vitamin D deficiency are more susceptible
to injury by a given level of cadmium in the body.
In addition to concerns over renal toxicity, potential onco-
genic, carcinogenic, mutagenic, and teratogenic effects of
cadmium are currently being investigated. However, based on an
evaluation of the available scientific data, these effects cannot
be sustantiated for low-level human dietary exposure at this
time. Although certain epidemiologic evidence suggest that
cadmium may be carcinogenic, the evidence is not conclusive
enough to implicate long-term ingestion of low-level cadmium as
a human carcinogen. Similarly, there is no substantial evidence
that human exposure to cadmium results in inheritable genetic
damage.
Direct Ingestion
In addition to the potential hazard associated with the
uptake of heavy metals directly into food-chain crops, there
is also a possibility of hazards related to direct ingestion of
metals by grazing animals and humans. Metals in sludge/soil
mixtures, or sludge-borne metals which may adhere to plant
surfaces, may be ingested by animals grazing on such crops, and by
humans exposed to sludge-amended soils.
Heavy metals which can be toxic to animals or humans if
directly ingested include arsenic, cadmium, copper, lead, mercury,
molybdenum, nickel, selenium, and zinc. If sludge is incorporated
into the soil, many of these potentially hazardous metals pose
little risk to the animals which may consume such crops. However,
if sludge is ingested directly, the metals which are considered
relatively innocuous may represent a significant hazard. Moreover,
the concentrations of these ingested contaminants are likely to be
higher than those associated with uptake, and the bioaccumulation
of these substances in animal tissues and milk may also be substan-
tially greater.
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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. 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 situation.
(2) Organics
The concentration of toxic organics, such as chlorinated
hydrocarbon pesticides and polychlorinated biphenyls (PCB's), can
be elevated in sewage sludges from cities receiving wastes from
industrial dischargers of these organic compounds (Ref. 180). At
present, there is limited information regarding the amounts of
toxic organics in municipal sludges, as well as the fate and
potential health risks of these substances.
PCB's, however, are a class of toxic industrial chemicals
which have been demonstrated to cause a variety of adverse
effects on the health of humans and experimental animals. Human
health effects have included skin eruptions, headaches, swelling
of eyelids, temporary loss of vision, and many others (Yusho
incident, Japan, 1968). Low-level PCB exposure to monkeys has
induced similar symptoms. Other animal experimentation has
demonstrated the effects of PCB's on reproduction and liver func-
tion. Although there still exist some questions, PCB's have also
been indicated, in several mice and rat studies, to be carcino-
genic and have given rise to liver tumors following oral exposure.
Table 111-16 presents data on the pesticide and PCB content
of municipal sewage sludges.
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TABLE 111-16
Pesticides and PCB Content of Dry Sludges
Compound
Aldrin2
Dieldrin-'
Chlordane
DDT + ODD2
PCB'S4
Ranqe (raq/kg)
Min.
ND
<0.03
3.0
0.1
ND
Max.
16.2
2.2
32.2
1.1
352.0
Number of Sludges
Examined
5
21
7
7
83
1 From Pahren, et. al. (See References)
2 Examined in 1971.
3 Examined in 1971, 1972, 1973.
4 Examined 1971, 1972, 1973, 1975.
5 Not detectable.
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The following is a discussion of the hazards associated with
plant absorption and translocation of toxic organics into the
food chain and direct ingestion of these substances by animals
grazing on forages treated with sludge.
Plant Absorption
In general, a minimal amount of pesticides is
absorbed by plants and translocated to aerial parts (Ref. 180).
Organochlorine pesticides are absorbed by plants and translocated
to aerial portions, but at a very low rate compared to the con-
centration in the soil (Ref. 183).
The absorption of PCB's by plant roots and translocation
within plants is considered minimal, but some studies have
reported low levels of what appeared to be plant uptake as a
result of heavy application rates (Ref. 160). These studies
further suggest, however, that PCB's are not actually taken up by
the plant, but rather physically adsorbed on the surface of the
roots (Ref. 180) . It should be emphasized that the PCB applica-
tion rates used to effect plant uptake in these studies far
exceeds the quantities expected from sludge application.
Generally, organics with large molecules, such as pesticides
and PCB's, do not tend to pass the semipermeable membrane of
plant roots. Consequently, plants possess the ability to exclude
the majority of organics added to soils, resulting in minimal
impact on the quality of forage and grains. Furthermore, even
though PCB's and related compounds resist icrobial degradation,
they are slowly decomposed after incorporation in soils
(Pef. 180).
111-82
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Direct Inqestion
The potential problem arising from toxic organics
in sludge is that they adhere to plants and soil and are subse-
quently ingested by grazing animals. The organics could then
concentrate in certain animal tissues (fats) as well as in the
milk of dairy animals. The recent discovery of elevated levels
of PCB's in milk obtained from a family cow which had been
grazing on sludge-amended pasture land indicates that the hazard
from direct ingestion may be potentially serious (Ref. 193). The
PCB level in the cow's milk was found to be 5 mg/kg, as compared
to the tolerable level of 1.5 mg/kg established by FDA for
unavoidable PCB contamination of milk when shipped interstate.
There is insufficient information to make definitive judgments,
but caution should be exercised in applying sludge high in PCB's,
or other hazardous organics, to land where the material may be
ingested by animals.
2. Regulatory alternatives and Environmental
Consequences
The regulations governing the application of solid waste to
land used for the production of food-chain crops focus on con-
trolling cadmium and polychlorinated biphenyls. It should be
noted that solid waste application to agricultural lands must
also meet the other criteria in the final regulations, including:
floodplains, endangered or threatened species, surface water,
ground water, disease, air, and safety. This section describes
the regulations and the environmental consequences associated
with their implementation. In addition, three regulatory alter-
natives are presented with concomitant discussion of the asso-
ciated environmental impacts. The alternatives' discussion will
focus on the incremental impacts between each alternative and the
final criterion. Table 111-17 summarizes the mandate of the
regulations and the three regulatory alternatives which were con-
sidered.
111-83
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111-85
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a. Final Criterion
(1) Heavy Metals (Cadmium)
Description of the Final Criterion
With the goal of minimizing the movement of solid
waste into the human food chain, two regulatory options are
available to landspreaders. The first option, referred to as the
controlled application approach, requires adherence to three site
management techniaues:
The maximum allowable annual application of
cadmium from solid waste is controlled as a func-
tion of time and the type of crop to be grown. A
phased reduction of the application rate with a
cadmium addition of 2.0 kg/ha until June 1984,
1.25 kg/ha from then until December 1986, and
0.5 kg/ha thereafter, is allowed for all food-
chain crops other than tobacco, leafy vegetables,
and root crops grown for human consumption. A
rate of 0.5 kg/ha is in force immediately for
these accumulator crops.
The cumulative amount of cadmium applied to a
hectare of land is restricted by the cation
exchange capacity of the soil (CEC) and the back-
ground soil pH. At low pH's and CEC's, a maximum
cumulative application of 5.0 kg/ha is allowed;
whereas at high CEC's and soils with high or near
neutral pH levels, a 20 kg/ha amount is allowed (a
mid-range value is also established). Also, for
soils with relatively low background pH, cadmium
application rates may be increased if the
soil/solid waste mixture is maintained at or above
6.5 for as long as food-chain crops are grown,
depending on the soil CEC.
The pF of the solid waste and soil mixture is 6.5
or greater at the time of application, except for
solid waste containing cadmium at concentrations
of 2 mg/kg (dry weight) or less.
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The second option, referred to as the dedicated facility
approach, is distinguished from the first option by its reliance
on output control, or crop management, as opposed to input
control, or limiting the amounts of cadmium that can be applied
to the soil. The second cadmium control option is designed
specifically for facilities with the resources and capabilities
to closely manage and monitor the performance of their respective
operations. It allows for operational flexibility while mini-
mizing the entry of cadmium into food chain. The requirements
under this option include:
Only the growing of animal feed crops is allowed.
The pH of the solid waste and soil mixture is 6.5
or greater at the time of solid waste application
or at the time the crop is planted, whichever
occurs later, and this pH level is maintained
whenever food-chain crops are grown.
There is a facility operating plan which demon-
strates how the animal feed will be distributed
to preclude ingestion by humans. The facility
operating plan describes the measures taken to
safeguard against possible health hazards from
cadmium entering the food chain, which may result
from alternative land uses.
Deed restrictions which notify future property
owners that the 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.
Environmental Consequences
The controlled application approach recognizes
that the greatest detrimental impact of applying sludge to agri-
cultural lands is likely to be associated with the cadmium con-
tent of the sludge. Annual application rates, crop species,
cumulative rates, and soil pH, all of which have been shown by
research to influence the concentration of cadmium in plant
tissures, are controlled.
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The final regulation calls for phased reduction of the
allowable annual cadmium application rate from 2.0 kg/ha to
0.5 kg/ha by January 1987. By allowing phased reduction of
application rates, communities and industry will be given 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. it should be noted that a dis-
cussion of the numbers of communities impacted by this regula-
tion, as well as those communities precluded from utilizing land-
spreading as a long-term disposal method, will be summarized
under the economic impact discussion in the following section of
this chapter.
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. Other data indi-
cate that uptake can be even greater where cadmium from land-
spreading in previous years is already in the soil.
The final regulation also includes limitations on cumulative
application of cadmium and on soil pH. As discussed in the
section on adverse impacts of improper disposal, results from
actual USDA field data indicate plant uptake of cadmium continued
after sludge application ceased, depending on plant species, soil
pH, and the total cadmium concentration in the soil. Garden
vegetable uptake of cadmium was excessive on soils where the
cumulative cadmium application approximated 6 kg/ha and where the
pH was less than 6.2 and the CEC was less than 15 (the normal
range of cadmium present in the soil is 0.2 to 1.4 kg/ha, at a
soil depth of 15 cm) . The uptake of cadmium by crops grown on
soils with near-neutral pH was less than the uptake on acid soils
with similar total cadmium concentrations. However, even on
soils of relatively high pH, plants can absorb significant
111-88
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quantities of cadmium if the background concentration of cadmium
in the soil is high. For example, USDA data show almost 20-fold
increases in leafy vegetable cadmium content on soils which had
cumulative cadmium amounts of 15 kg/ha. Consequently, a person
who is receiving a portion of his vegetable diet from soils where
sludge was applied within the limits established by the criteria
will most likely be increasing his dietary intake of cadmium.
However, the magnitude of this increase is dependent on the
Quantity of vegetables ingested and the cadmium concentration of
the vegetables, which is largely dependent on the three para-
meters mentioned above.
Controlling the pH of the sludge/soil mixture at 6.5 or
above at the time of application serves to initially reduce the
availability of cadmium, as well as phytotoxic metals such as
zinc, copper, and nickel to plants, especially in naturally low-
pH soils. However, natural mineralization and oxidation of
sludge nitrogen and sulfur can result in the increased crop
uptake of cadmium, with the attendant threat of increased dietary
intake of cadmium for persons eating those crops. Also, an
increase in the potential for crop phytotoxicity from zinc,
copper, and nickel can occur.
It is worth noting that the effectiveness of such control
measures is strongly dependent on good operation and maintenance
practices, as well as sufficient enforcement. Without proper
controls to assure that the operational limitations are being
met, there is a possibility that the degree of protection
afforded by controlling cadmium applications could be signifi-
cantly reduced.
The dedicated facility approach option for cadmium control
(Option 2) relies primarily on crop management and legal/institu-
tional mechanisms to prevent the entrance of significant amounts
of cadmium into the food chain. Bv restricting the type of crops
which may be grown on sludge-amended soils to animal feed crops
111-89
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only, the likelihood of significantly increasing general dietary
cadmium is negligible for two reasons. First, dietary intake of
cadmium through ingestion of crops grown for direct human con-
sumption on sludge-amended soils is eliminated. Second, rela-
tively small amounts of cadmium accumulate as a result of uptake
in typical animal feeds (pasture crops and grains). Moreover,
research data show that most of the cadmium that is consumed by
animals is excreted, and that the remaining amount is accumulated
in viscera such as the kidney and the liver. Since the primary
source of animal meat that enters the human food chain is muscle
tissue, the marketing of kidneys and livers from such animals is
not likely to result in a significant increase of cadmium in an
individual's diet.
The institutional measures required by the dedicated
facility approach, such as the establishment of a facility
operating plan and property deed restrictions, ensure that crops
for human consumption will not be grown on sludge-amended soils.
Consequently, the entry of significant increases of cadmium into
the diet will be prevented. While these measures should provide
significant protection to human health by preventing farms where
sludge had previously been applied from being housing develop-
ments (where home gardeners could raise vegetables), they could
also lead to a devaluation of the farmland for the same reason.
The dedicated facility approach also includes provisions
requiring pH control at the time of solid waste application or
crop planting, whichever occurs later, and the maintenance of a
near-neutral pH whenever food-chain crops are grown. This should
suppress the availability and toxicity of heavy metals to plants
and reduce the cadmium content in the harvested animal feed crops
during the initial operation of the facility. However, after
long periods of sludge application, cadmium and other heavy metal
concentrations in the soil will increase, and a concomitant
increase in the crop availability and uptake of these elements
will occur even at near-neutral pH's. The result could be
111-90
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increased potential for crop phytotoxicity due to zinc, copper, and
nickel as well as increasing levels of cadmium in the derived animal
feed.
There is one important distinction between the controlled
application and dedicated facility approaches to controlling cadimum.
The dedicated facility approach does not serve to pre-clude land-
spreading as a solid waste disposal option for those sludge generators
who have above-average concentrations of cadmium in their sludge
and who also possess the necessary resources and expertise to
manage their operation. The large sludge disposal operators will
typically benefit from being able to opt for the dedicated facility
approach.
On the other hand, some communities may be precluded from
using landspreading as a disposal technique because of the inability
to comply with either cadmium control option 1 or 2. In such
cases, communities will be forced to go to alternative sludge
disposal methods such as landfilling, surface impoundments,
thermal processing, and non-food-chain landspreading. The public
health, land commitment, and, in some cases, the increased energy
use aspects associated with the increase in utilization of alternative
disposal methods must, therefore, be attributed, in part, to
environmental consequences of the food-chain land-spreading regulation.
Provisions for direct control of heavy metals other than
cadmium are not included as part of the final regulation. Im-
pacts that result from the exclusion of these elements may be
categorized as crop-related, animal-related, and human health-
related. Continued applications of many sewage sludges for long
periods of time (which could occur under cadmium control option 2)
will probably adversely affect plant growth due to tract element
soil enrichment and subsequent plant toxicity. The trace
element composition of the sludge will determine the total
amounts which can be applied to soils over a period of years
111-91
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before adverse effects on crop yields ar.d possibly quality, will
occur. For example, depending upon the concentration of molyb-
denum in sludge and the amount applied, it is possible that soils
could become enriched to the extent that plants could absorb
quantities of molybdenum sufficient to be toxic to ruminant
animals.
(2) Organics (PCB's)
Description of the Final Criterion
The final regulations control the amounts of sludge-
borne polychlorinated biphenyls (PCB's) t.-.at may enter the food
chain in the following manner:
Sludge with PCB concentrations greater than or
equal to 10 mg/kg (dry weight) is to be incorpo-
rated into the soil when applied to land used for
producing animal feed, unless the PCB concentra-
tion is less than 0.2 mg/v.g (actual weight) in
animal feed, or less than 1.5 Tic/kg (fat basis) in
milk.
Environmental Consequences
Requiring soil incorporation of sludge with PCB
content greater than or equal to 10 mg/kg provides the insurance
that the FDA tolerance levels for PCB's in milk and animal feed
will not be exceeded. Based on assumptions for total daily dry
matter intake for cattle, percent of dry weight of forage that is
actually adhering sludge, and percent of the animal's life-time
spent grazing on pasture land which has received sludge, concen-
trations of PCB's in sludges less than 10 rag/kg should not vio-
late the FDA levels if sludge is surface-applied. Monitoring of
PCB's will be necessary in either crops, milk, or applied sludge
to ensure compliance with the regulation or to determine whether
the sludge is to be incorporated into the soil rather than just
surface-applied.
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The implementation of the regulations may preclude land-
spreading as a disposal method for some communities. However,
this condition is expected to be temporary, since under the Toxic
Suhtances Control Act, all manufacture, processing, or use of
PCP's in the United States has been, or will be, banned by EPA.
Consequently, PCB concentrations in municipal sludge are expected
to decrease over the long term.
Toxic orqanochlorine pesticides and herbicides that may be
applied to food-chain land via sludge are not controlled by the
regulations. Tolerances for residues of these substances on
crops that are shipped interstate have been established by the
FDA pursuant to the Federal Food, Drug and Cosmetic Act, and no
additional adverse health impacts are expected.
b. N'ore Pestrictive Alternative
(1 ) Heavy Metals (Cadmium)
Description of the Alternative
A more restrictive alternative for both cadmium
control options was developed. The alternative to the controlled
application option differs from the final regulation in the
following respects:
The maximum allowable annual cadmium limitation is
0.5 kg/ha and is to be imposed immediately.
The application of solid waste to land used for
the production of tobacco, leafy vegetables, and
root crops grown for human consumption is pro-
hibited.
The cumulative amount of cadmium applied to a
hectare of land is restricted to 5 kg/ha for back-
ground soil pH less than 6.5 and to 10 kg/ha for
pH greater than or equal to 6.5. Soil CEC does
not influence cumulative application loadings.
111-93
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The pH of the solid waste and soil mixture is 6.8
or greater at the time of application, with the
exception of solid waste containing cadmium at
2 mg/kg (dry weight) or less.
The more restrictive alternative to the second option, the
dedicated facility approach, adds further restrictions to four
crop management techniques proposed under the final regulation.
Specifically, only the growing of animal feed grains, as opposed
to the broader category of animal food crops, is allowed. Also,
the kidneys and livers of grain-fed animals are prohibited from
being marketed. All other controls for the dedicated facility
approach under the final regulation remain in effect for the more
restrictive alternative.
Environmental Consequences
Immediate imposition of the 0.5 kg/ha annual application
limit will restrict or preclude landspreading as a viable dis-
posal method for some additional communities, whereas the final
criterion would not. Landspreading would be precluded primarily
in industrial cities. A discussion of the added numbers of
communities precluded from agricultural landspreading is pre-
sented in the economic impacts section. The additional adverse
environmental impacts of the alternative sludge disposal method
that the precluded communities will have to adopt must also be
considered as an impact of imposing the 0.5 kg/ha limit imme-
diately. Relative to the final criterion, annual cadmium appli-
cation rates will result in a decrease in cadmium entering the
food chain, with consequent reduction in the risk of significant
increases in dietary intake.
By precluding application of solid waste to accumulator
crops, the more restrictive alternative should afford significant
protection to human health by preventing the entry of cadmium
into the human diet via certain vegetables. These added benefits
could be important, since ingestion of cadmium-contaminated vege-
111-94
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tables typically represents the most significant source of
dietary intake, as compared to intake of cadmium via animal
tissues. However, it is important to note that very little
sludge is currently used in the agricultural production of vege-
tables.
The more restrictive alternative also involves more
stringent cumulative application limitations under certain soil
conditions for crops other than those grown for human consump-
tion. This should further reduce the amount of cadmium entering
the human food chain (as compared to the final criterion) from
those areas where pH is greater than 6.5 and soil CEC is greater
than 15. The magnitude of the reduction is uncertain, however,
due to other factors besides cumulative loadings which control
cadmium uptake. On the other hand, disposal facility life in
these areas will be cut in half; stated alternatively, twice as
much land will be necessary to dispose of the sludge. This adds
concomitant institutional and economic burdens on the disposal
facility operator.
Requiring a pH of 6.8 at the time of solid waste application
may reduce crop uptake of cadmium over the long term, even though
research shows that a pH at or greater than 6.5 is adequate. The
higher initial pH will serve to offset the effects of the natural
sludge acidification process, which lowers pH of the sludge/soil
mixture over time. Conseqently, there will be less potential for
increased uptake of cadmium and other heavy metals as acidifica-
tion occurs.
The environmental impacts of implementing the more
restrictive alternative for the dedicated facility approach to
cadmium control involve affording increased protection to human
health via restrictions on marketing of animal organs known to be
the primary sites of cadmium accumulation in grazing animals. In
addition, increased control over the entrance of cadmium into the
food chain is provided by restricting the animal feed grown on
II1-95
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sludge-amended soils to grains only. This attempts to minimize
the daily intake of cadmium by the grazing animals, thereby mini-
mizing accumulation in the marketable animal tissues. It is
difficult, however, to ascertain the magnitude of the reduction
in cadmium entering the food chain by implementation of the more
restrictive dedicated facility approach alternative. Moreover,
the institutional impacts of implementing this more restrictive
alternative are of concern. The logistics and practicality of
monitoring the marketing of kidneys and livers, together with the
potential unwillingness of municipal sludge disposal managers to
adhere to either the marketing or crop-growing restrictions, may
prove burdensome. Municipalities may opt for alternative sludge
disposal methods in lieu of employing the personnel with the
technical and managerial skills to carry out such a monitoring
and enforcement program.
(2) Organics (PCB's)
Description of the Alternative
The more restrictive alternative for the control
of PCE's employs an "input" control approach as opposed to the
"output" control approach of the final regulation. The applica-
tion of solid waste containing PCE concentrations greater than
1 mg/kg to land used for the production of food-chain crops is
prohibited. In addition, incorporation of solid waste into the
soil is required where it is being applied to land used for the
grazing of animals raised for food production.
Environmental Consequences
By addressing lower allowable PCS concentrations
in the sludge to be applied, the more restrictive alternative
further ensures that the tolerance levels established by FDA for
PCB's in milk and animal feed will not be exceeded as a result of
sludge application to agricultural land. An analysis of poten-
111-96
-------
tial PCB ingestion by cattle (with assumption for total daily dry
matter intake, percent of dry matter forage that is actually
adhering sludge, and percent of the animals' lifetime spent
arazing on sludged pasture land) indicates that PCB sludge levels
greater than a few mg/kg may cause the ingested forage levels to
exceed the FDA tolerance level (0.2 mg/kg) for animals grazing
shortly after sludge application. Consequently, maintaining PCB
levels below 1 mg/kg should all but eliminate any risk of PCB's
entering the food chain at hazardous levels.
On the other hand, the more restrictive alternative does not
allow for any flexibility in the management of a land disposal
operation: either the waste can be landspread, or it can't be.
As a result, the implementation of this alternative could signi-
ficantly affect current landspreading practices and current
utilization of this as a disposal method. Specifically, Publicly
Owned Treatment Works (POTW's) serving industrial cities could be
effectively precluded from landspreading, thereby imposing the
requirement for alternative disposal.
By requiring that all solid waste be incorporated into the
soil when applied to land used for grazing of animals, the hazard
associated with animals ingesting PCB's adhering to plants and
the soil surface is effectively reduced. Considerably fewer
PCB's would find their way into the food chain, since the primary
means of transportdirect ingestion of residues adhering to
plants and the soil surfacewould be eliminated. The adverse
impacts associated with this regulatory alternative are that it
has the potential to effectively eliminate the practice of land-
spreading to pasture land, as such land is not generally tilled.
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c. Host Restrictive Alternative
(1) Heavy Metals (Cadmium)
Description of the Alternative
The most restrictive alternative bans the applica-
tion of solid waste to land used for the growing of food-chain
croos.
Environmental Consequences
The implementation of this alternative results in
no increase in toxicity of heavy metals to plants, livestock, or
huirans due to landspreading of solid wastes. Heavy metal
loadings in soils currently receiving landspread wastes would be
reduced.
while this alternative affords maximum protection to human
health and the environment from landspread-induced effects, it
does not orotect man from the environmental effects he may suffer
as 3 result of the alternative sludge disposal methods that are
ueed in place of landspreading. Moreover, there is no realiza-
tion of the benefits afforded by application of sludge to agri-
cultural land, including its resource value as a fertilizer and
soil conditioner.
The adoption of the most restrictive alternative parti-
cularly hurts the smaller, rural community. In most cases, the
application of sludge to agricultural lands represents the most
effective means of disposing of municipal sewage sludge for these
communities. Ml totaled, some 200 communities with sewage
treatment facilities greater than 1 mgd in capacity, and count-
less smaller facilities, would have to seek some alternative
method of sludge disposal.
111-98
-------
(2) Organics (PCB's)
Description of the Alternative
Same as for Heavy Metals (Cadmium).
Environmental Consequences
The environmental impacts associated with PCB's
not being applied to farm land via sludge disposal are similar to
those discussed above under heavy metals.
d. Less Restrictive Alternative
(1) Heavy Metals (Cadmium)
Description of the Alternative
A less restrictive alternative was developed for
both cadmium control options. The alternative to the controlled
application approach differs from the final regulation in the
following respects:
The maximum allowable annual cadmium limitation of
2.0 kg/ha throughout the planning period is
allowed for all food-chain crops with the excep-
tion of naturally acid soils used for the produc-
tion of tobacco, leafy vegetables, and root crops
grown for human consumption, A rate of 0.5 kg/ha
is in force for these accumulator crops grown in
these soil conditions.
The cumulative amount of cadmium applied to a
hectare of land is restricted by the soil cation
exchange capacity only. For low CEC's (<5)
5 kg/ha cadmium is allowed, and for CEC's >15,
20 kg/ha is allowed. Soil pH does not influence
allowable loadings.
The pH of the solid waste and soil mixture is 6.2
or greater at the time of application, with the
exception of solid waste containing cadmium at
2 mg/kg (dry weight) or less.
111-99
-------
The less restrictive alternative to the second option, the
dedicated facility approach, differs from the final criterion
only by the fact that no pH controls are mandated for the
sludge/soil mixture.
Environmental Consequences
Implementation of a 2.0 kg/ha annual cadmium
application rate allows more of the current landspreading
operations to continue, as compared to the final criterion. How-
ever, the added number of communities that are not precluded from
applying sludge to farmland must be considered within the context
of allowing an application rate four times greater than the rate
of 0.5 kg/ha specified in the final criterion. Annual cadmium
rates of 2.0 kg/ha to accumulator crops, even in near-neutral
soils, may produce hazardous cadmium concentrations in vegetables
marketed for human consumption.
The less restrictive alternative for the dedicated facility
approach to cadmium control allows for increased uptake of
cadmium in animal feed crops, since there are no pH controls.
This, in turn, increases the potential for entrance of cadmium
into the food chain via animal tissue. Also, other heavy metals
toxic to animals will be more available for plant uptake at lower
pH.
(2) Organics (PCB's)
Description of the Alternative
The less restrictive alternative imposes no
controls on PCB's or any other toxic organic that may be applied
to food-chain land via sludge disposal.
III-100
-------
Environmental Consequences
As a result, these substances may enter the food
chain, primarily by direct ingestion by grazing animals. The FDA
controls PCB and other hazardous organic residues on animal
feeds, milk, and foods for human consumption for interstate com-
merce only; assuming these controls are enforced, the less
restrictive alternative allows the maximum amount permissible by
FDA to become associated with foodstuffs marketed interstate.
Food, milk, and annual feed grown and marketed in the same state
may, therefore, be contaminated by sludge-applied PCB's,
resulting in potential health hazards.
Benefits that are realized by the implementation of the less
restrictive alternative include an elimination of the need for
monitoring of sludge PCB content and reduced operation require-
ments by the disposal operator.
3. Summary Technology, Economic, and Environmental
Impact Analysis
a. Control Technologies and Unit Costs
Land used for production of food-chain crops can be
protected from the adverse effects of toxic metals and organics
by a variety of methods. Control can begin prior to discharge to
the municipal treatment plant (i.e., pretreatraent), at the treat-
ment plant, and at the disposal site, and through proper disposi-
tion of the food products. This section discusses the methods
available to control cadmium and PCB's.
(1) Cadmium
Control technologies for cadmium include (1) pro-
cessing the sludge in the plant, (2) imposing application or crop
type limits, or (3) limiting the future use of existing or
III-101
-------
proposed sites. In-plant control systems for cadmium are gener-
ally practical. Cadmium is conserved in municipal wastewater
treatment; therefore, its total mass loading is distributed pri-
marily between the treated effluent and sludge discharge streams.
Oxidative and low-pH treatment conditions favor cadmium leaving
in the treated effluent; conversely, reducing conditions and high
pH favor discharge in the sludge. Selection of sludge processing
methodology is the most likely point for control. For example,
anaerobic digestion is performed in a highly reduced environment,
thus favoring higher cadmium yields in sludge, whereas aerobic
digestion and other oxidative treatments would favor cadmium dis-
charge in the treated effluent. Thus, control of cadmium in
sludges can be accomplished by in-plant processing, but will
result in higher concentrations in the effluent.
Costs for pretreatment of cadmium are difficult to ascer-
tain, since the pretreatment cost will be absorbed by the indus-
trial discharger. There should be no cost to the treatment plant
operating agency.
Application limits can be used effectively to reduce cadmium
additions to cropland. The result is an increase in application
costs due to spreading the same quantity of sludge over a larger
area. The increase in costs will depend on local conditions, but
a decrease in application rate will result in a proportionate
increase in application costs.
Cadmium can also be controlled by limiting crop type or
ultimate use of the crop grown. The cost of utilizing this
method of controlling cadmium depends on local market conditions
and prevailing cropping patterns. Limiting the farm market by
placing controls on the ultimate use of the crop may or may not
impact the returns to the farmer.
In addition, cadmium may be prevented from entering the food
chain by limiting the future use of existing or proposed sites.
III-102
-------
The cost of this option depends entirely on site-specific condi-
tions. If the area of concern is located in a major food-growing
region, the land value in the area might be substantially
reduced.
(2) PCB's
Little is known concerning crop uptake of PCB's;
limits on safe levels in soils have not been determined. Conse-
quently, those facilities receiving wastewater from industries
that are likely to discharge PCE's should make every effort to
limit quantities being discharged into the sewer system. The
most effective method of controlling PCB's is through pretreat-
ment by industry.
In-plant treatment is possible if the sludge is processed by
heat treatment. Normal heat treatment processing will generally
break down the complex organic compounds to forms which are
readily degradable after being applied to the land. Wet air
oxidation or incineration will completely break down these com-
pounds .
Direct ingestion of PCB's can be prevented by incorporating
the sludge into the soil. There are two methods of incorporating
sludge into the soil. The first is to surface-apply and then
disc or plow the sludge into the soil. This method should be
observed carefully after several years of application, since the
plowing operation may be turning up old sludge. If this occurs,
deeper plowing will be necessary. The second method is subsur-
face injection. Unless sludge is applied to permanent pasture
land or to forage crops, the sludge will be incorporated by
standard tillage practices.
Another means of preventing PCB's from entering the food
chain is by eliminating grazing animals from lands receiving
III-103
-------
sludge; this practice would require that the farmer change the
crop grown.
An additional means of control of PCB's is to provide
some time lapse between application and forage harvest. This
would be suitable if the plants were effectively washed by
rainfall or spray irrigation. This would not be suitable for
grazing animals since these compounds would be on the soil
surface which could then be ingested when the animal grazes.
Table 111-18 shows control technologies and unit costs for
food-chain landspreading and alternate disposal methods. All
values are in terms of 1978 dollars, assuming a 10 year planning
period and an interest rate of 10 percent.
b. Assumptions
The methodology used to calculate the cost of the final
regulation and the three alternatives is organized into five
activities:
Defining Cost Considerations
Developing Regulatory Alternatives
Estimating Sludge Quantities and Qualities
Estimating Unit Costs
Estimating National Costs
Within each activity, simplifying assumptions were made. An
effort was made to avoid assumptions which would understate
nationwide costs. Included in Appendix B of this document is a
detailed discussion of each assumption within the overall context
of methodology.
Costs
The results of the cost analysis are discussed below.
For the final regulation and three alternative regulations, esti-
mates are presented for:
III-104
-------
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c
-------
TABLE 111-18 (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, $9/hr.
2. Cadmium, lead, nitrogen, pesticides and persistant organics are
to be monitored at each facility. Monitoring requirements and
associated unit costs for large and small and medium facilities
are summarized in the following table. These requirements are
overstated if this analysis for POTW's where the levels of Cd,
Pb, N and PCB1s are low. Especially in cases of small POTW's,
monitoring may be required on a much less frequent basis. The
frequency of monitoring for organics (PCB's) by large cities is
assumed to be 1 sample every 5 years. (Monitoring for organics
(PCB's) is only required under Option 2 of the regulations and
only large cities select Option 2.}
SLUDGE MONITORING COST
Unit Cost Frequency of Sampling
Analysis ($/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 $49/mt, thus a cost of
$87.70/ha. At a sludge application rate of 10 mt/ha, this is
$8.77/mt of sludge. This value was increased to $10/mt to cover
miscellaneous related 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 $5000 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
III-106
-------
7.
TABLE 111-18 (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
;ctare, the annualized cost of land is $24/mt. Only cities
tlecting 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.
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.
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.
For composting, no hauling costs are included. This data was
taken from "Sewage Sludge Composting," Sludge Treatment and
Disposal. 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, injection
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.
III-107
-------
TABLE 111-18 (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 rngd
facilities to represent the three sizes of POTW's, under consi-
deration :
rejection
- Small Facility: $38/mt injection plus $24/mt
hauling = $62/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 $29/mt
pipeline = 545/mt (6% solids,
tractor-towed injection system)
III-108
-------
TABLE 111-18 (Continued)
. Surface Landspreading with Plowing or Disking After
Spread
- Small Facility: $50/mt haul and spread with same
truck
- Medium Facility: $5/mt spread/disk-in plus $39/mt
pipeline
- Large Facility: 55/mt spread/disk-in plus S29/mt
pipeline
Surface Landspreading Without Plowing or Disking After
Spread
- Small Facility: $47/mt haul and spread with same
truck
- Medium Facility: 53/mt spread plus $39/mt
pipeline
- Large Facility: $3/mt spread plus $29/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.
Dewatering Costs assume vacuum filtration. Estimates are based
on data presented in Municipal Wastewater Sludge Alternatives,
Prepared by G. L. Culp 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).
III-109
-------
Quantities of municipal sludge which could
and could not continue to be landspread
Annualized incremental nationwide costs
Impacts on residential sewer charges
The analysis indicates that the final regulation will impose a
$10.5 million annual cost to POTW's nationwide. The annual cost
of the alternatives ranges from $5.8 million to $25.3 million.
This estimate can be translated into a relatively insignificant
impact on household sewer charges.
(1) Quantities of Sludge Which Could/Could Not
Continue to be Landspread
The final regulation and the three alternatives
were designed to limit the application of cadmium to land used
for the production of food-chain crops. Within the regulations,
the cadmium limitations have two distinct forms:
Annual restrictions (maximum allowable kilograms
of cadmium per hectare per year)
Cumulative restrictions (maximum allowable kilo-
grams of cadmium per hectare)
Each form of restriction has a different impact on current land-
spreading practices. Assuming an application rate of 10 metric
tons of sludge/ha/yr, an annual restriction of 2 kg Cd/ha/yr
would immediately preclude the application of sludge which had a
cadmium content greater than 200 mg/kg. The POTW generating the
sludge would immediately be forced to find an alternate disposal
method. Sludge application not precluded by an annual restric-
tion could continue to be landspread on food-chain crop land
until a cumulative restriction is reached. The POTW generating
the sludge would then be forced to find an alternate disposal
facility if the sludge were to continue to be landspread on food-
chain crop land. The projected impacts of annual and cumulative
restrictions are discussed further below.
III-110
-------
Annual Limitations
For the final regulation and for each regulatory
alternative, the impact of the annual cadmium limitation was pro-
jected for sludge currently being landspread by small, medium,
and large POTW's. Based on its cadmium concentration level, the
sludge may continue to be landspread according to Option 1 of the
regulation, or must be disposed of by an alternate method. These
alternate methods include:
Option 2 landspreading
Landfilling
Thermal processing
Composting
Non-food-chain landspreading
The projected impacts on sludge quantities in the sample set are
presented graphically in Figures III-7 through 111-10. Because
of the relative magnitude of Chicago's landspreading operation,
data for that city is excluded to avoid skewing the analysis.
Chicago is, however, included in the projections for nationwide
costs of regulation.
Two major conclusions can be drawn from this analysis of the
annual cadmium limitations:
The final regulation does not greatly impact the
quantity of sludge which can continue to be land-
spread on food-chain crop lands. If implemented,
only 15 percent of the sludge would be precluded
from continued Option 1 landspreading.
The quantity of sludge which is precluded from
continued landspreading on food-chain crop lands
increases only slightly with the severity of regu-
lation. The projected impacts are:
Ill-Ill
-------
FIG. III-7
The Less Restrictive Regulation:
Quantities of Sludge in the Sample Set Which
Could/Could Not be Food-Chain Landspread
Under Option 1 (Analysis Excludes Chicago)
224.055
200,000
150,000
17,228
206,571
12,118
211,900
JUUY1
1979
JULY1
1984
JULY1
1989
2.00 Kg/ha ANNUAL
Cd LIMITATION
PRETREATMENT
50% EFFECTIVE
KEY WHITE SECTION MT/VR WHICH CAN CONTINUE TO BE LANDSPREAD UNDER OPTION 1
SHADED SECTION MT/YR. CURRENTLY LANDSPREAD BY MEDIUM POTWs l>1 mgd, <25 mgdl
BUT WHICH ARE PRECLUDED FROM SPREADING UNDER OPTION 1
LINED SECTION
MT/YR. CURRENTLY LANDSPREAD BY SMALL POTWs K1 mgd) BUT WHICH
ARE PRECLUDED FROM SPREADING UNDER OPTION 1
(NO LARGE POTWs (>25 mgd) ARE PRECLUDED FROM SPREADING UNDER 1)
III-112
-------
FIG. III-8
The Final Regulation:
Quantities of Sludge in the Sample Set Which
Could/Could Not be Food-Chain Landspread
Under Option 1 (Analysis Excludes Chicago)
256
256
438
224,055
200,000
- 150,000
GC
§ 100,000
a
50,000
JUL
19
17.228
206.571
17.228
206.571
32,741
190,876
Y1 JULY1 JANUARY 1 JULY 1
9 1984 1987 1989
2 00 Kg/ha ANNUAL
Cd LIMITATION
1.25 Kg/ha ANNUAL
Cd LIMITATION,
AND
PRETREATMENT
50% EFFECTIVE
0.50 Kg/ha ANNUAL
Cd LIMITATION
TIME -
WHITE SECTION MT/YR WHICH CAN CONTINUE TO BE LANDSPREAD UNDER OPTION 1
SHADED SECTION MT/YR CURRENTLY LANDSPREAD BY MEDIUM POTWs I 1 mad. 25 mail)
BUT WHICH ARE PRECLUDED FROM SPREADING UNDER OPTION 1
LINED SECTION
MT/YR CURRENTLY LANDSPREAD BY SMALL POTWs l<1 mgd) BUT WHICH
ARE PRECLUDED FROM SPREADING UNDER OPTION 1
(NO LARGE POTWs I 25 mjill ARE PRECLUDED FROM SPREADING UNDER 1)
111-113
-------
FIG. III-9
The More Restrictive Regulation:
Quantities of Sludge in the Sample Set Which
Could/Could Not be Food-Chain Landspread
Under Option 1 (Analysis Excludes Chicago)
438
200.000
150,000
100,000
50,000
37,376
173,956
32,741
190.876
JULY 1
1979
JULY 1
1984
050 Kg/ha ANNUAL
Cd LIMITATION
PRETREATMENT
50% EFFECTIVE
-TIME-
KEY- WHITE SECTION MT/YR WHICH CAN CONTINUE TO BE LANDSPREAD UNDER OPTION 1
CROSSSECTION MT/YR CURRENTLY LANDSPREAD BY LARGE POTWs O25 mgd) BUT WHICH
ARE PRECLUDED FROM SPREADING UNDER OPTION 1
SHADED SECTION MT/YR. CURRENTLY LANDSPREAD BY MEDIUM POTWs (>1 mgd, «25 mgd)
BUT WHICH ARE PRECLUDED FROM SPREADING UNDER OPTION 1
LINED SECTION-
MT/YR CURRENTLY LANDSPREAD BY SMALL POTWs l<1 m9dl BUT WHICH
ARE PRECLUDED FROM SPREADING UNDER OPTION 1
III-114
-------
FIG. 111-10
The Most Restrictive Alternative:
Quantities of Sludge in the Sample Set Which
Could/Could Not be Food-Chain Landspread
Under Option 1 (Analysis Excludes Chicago)
,4,215
224,055
200,000 U
= 150,000 h
5 100,000
LANDSPREADING
BANNED
PRETREATMENT
50% EFFECTIVE
KEY CROSSSECTION MT/YR CURRENTLY LANDSPREAD BY LARGE POTWs (>25 mgil) BUT WHICH
ARE PRECLUDED FROM SPREADING UNDER OPTION 1
SHADED SECTION MT/YR CURRENTLY LANDSPREAD BY MEDIUM POTWs (>1 mjd. <25mgd)
BUT WHICH ARE PRECLUDED FROM SPREADING UNDER OPTION 1
LINED SECTION MT/YR CURRENTLY LANDSPREAD BY SMALL POTWs K 1 mgd) BUT
WHICH ARE PRECLUDED FROM SPREADING UNDER OPTION 1
III-115
-------
Less restrictive: 8% precluded
Final regulation: 15% precluded
More restrictive: 22% precluded
The exception is the most restrictive alternative, where
landspreading on food-chain crop land is totally banned,
indicating 100% preclusion.
Cumulative Limitations
Sludge application not precluded by an annual
restriction could continue to be landspread on food-chain crop
lands under Option 1 until a cumulative restriction is reached.
When the cumulative restriction is reached, and if a new site is
available, the sludge could continue to be spread under Option 1.
To predict the minimum site life for individual POTW's, this
anlysis adopted a worst-case scenario:
No industrial pretreatment during the planning period
Acid soil throughout the nation, mandating a cumula-
tive limit of 5 kg Cd/ha.
Application rate is 20 metric tons of sludge per
hectare per year.
This worst-case scenario is thus based on conditions which are
more severe than those assumed to exist under the more restric-
tive alternative. Figure III-ll graphically displays the pro-
jected site life for all small, medium and large POTW's in the
sample set.
The major conclusion to be drawn from this analysis is
that the impact of even the most severe cumulative limitation is
minimal. Nearly 60 percent of the sludge being landspread by
large POTW's is applied to sites with a projected life of 10
years or more; the estimate for sites used by small and medium
facilities is even longer.
This finding supports a key assumption made in the cost
methodology. The methodology assumes that a zero cost is
III-116
-------
FIG. III-ll
Projected Life of Disposal Sites Used by Large,
Medium, and Small POTW's Under Worst-Case Scenario
(Analysis Excludes Chicago)
70-
60-
50-
40-
30-
20-
10-
100 -.
90-
80-
70-
60-
50-
40-
30-
20-
LARGE POTWs
r"l
r i
i i r~
25 50 7.51
(100% = 110.997 MT/YR)
A
0 20 30 40 50 50 100
MEDIUM POTWs
(100%= 76,088 MT/YR)
r T_
1 I A, , 1 1
255.07510
100
70-
60
50-
40-
30-
20-
10-
SMALL POTWs
(100%= 3774 MT/YR)
r
r-r -i
1 A,. 1
2.5 5.0 75 10
30 40 50
SITE LIFE (YEARS)
100
NOTE. SLUDGE PRECLUDED BY THE 2.0 KgCd/Ha/Yr ANNUAL LIMITATION IS NOT
INCL UDED IN THIS ANALYSIS THIS ANNUAL LIMITATION CORRESPONDS
TO THE LESS RESTRICTIVE ALTERNATIVE AND TO THE INITIAL PHASE OF
THE FINAL REGULATION.
III-117
-------
associated with a POTW reaching the cumulative cadmium limit and
being forced to move to a new food-chain landspreading disposal
site. The projections made in Figure III-ll indicate that, even
under the worst-case scenario, POTW1s would not be impacted until
several years after the implementation of the regulations. The
results indicate that, in fact, the site life of most POTW's
would be longer than 10 years. Thus, even if a cost were
incurred by affected POTW's, their numbers would be small and
thus the nationwide cost would be minimal.
( 2) Cost of Regulation
The costs of the final regulation and the three
alternatives are shown in Table 111-19, where unit costs are
cited, sludge quantities are noted, and total costs are esti-
mated. If the analysis includes costs only up to site closure,
the total annualized national costs, in millions of dollars, are:
flNNUALIZFD NATIONWIDE COSTS (WITHOUT ALTERNATE DISPOSAL)
33 Restrictive
lal Regulation
re Restrictive
st Restrictive
(MILLIONS OF
Federally
Induced
$ 3.6
6.2
9.6
0.0
DOLLARS)
State- Standard-
Induced
$ .4
.7
1.1
0.0
Combined
? 4.0
6.9
10.7
0.0
If the analysis includes the costs for alternate disposal once a
landspreading site is closed, the total annualized national costs
in millions of dollars are:
III-118
-------
o
O Q
C r-
0 en
03
rH CP
3 C
0^ H
(U T3
K 10
11
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ftNNUALIZED NATIONWIDE COSTS (WITH ALTERNATE DISPOSAL)
Less Restrictive
Final Regulation
More Restrictive
Most Restrictive
(MILLIONS OF
Federally
Induced
S 5.2
9.4
13.3
22.8
DOLLARS )
State-Standard-
Induced
$ .6
1.1
1.5
2.5
Combined
$ 5.8
10.5
14.8
25.3
These cost estimates are based on the assumption that all
sludge is applied to the land at a rate of 10 mt/ha. In many
cases, however, POTW's with low sludge cadmium concentrations
could and would spread at greater rates. If all POTW's which
are permitted to spread at higher rates do, in fact, spread at
higher rates, lower nationwide costs can be anticipated.
Seven criteria were reviewed at the beginning of this
analysis. With the exception of the relatively minimal cost
associated with monitoring the sludge for nitrogen, these
projected costs are due entirely to the criterion which
controls the application of sludge to land used for the
production of food-chain crops. These criterion costs are due
almost entirely to regulations which control cadmium: adminis-
tration, soil pH control, and land requirements.
(3) Impacts of Regulation on Residential Sewer Charges
The projected costs of the regulations due to the
annual limitation were further analyzed for the impacts on sewer
charges paid by households served by large, medium, and small
POTW's in the sample set. The average annual increase per house-
hold and the distribution of increased costs is presented
according to POTW size for each regulatory alternative in
Figures 111-12 through 111-14. In general, more households will
experience a greater percent increase in sewer charges as the
severity of regulation increases. For example, under the less
restrictive alternative, all households served by large POTW's
would incur an increase of less than 4 percent in their sewer
bills. Under the most restrictive alternative, more than half of
III-120
-------
FIG. 111-12
Projected Increases in Sewer Charges Paid By
830,613 Households Served by Large POTW's Identified
in the Sample Set, Excluding Chicago
(Average Annual Charge Before Regulation is 549.10 per Household)
LESS RESTRICTIVE
ALTERNATIVE
AVERAGE ANNUAL INCREASE
SO AS/HOUSEHOLD
FINAL
REGULATION
AVERAGE ANNUAL INCREASE
SO 92/HOUSEHOLO
1
MORE RESTRICTIVE
ALTERNATIVE
AVERAGE ANNUAL INCREASE
51 44/HOUSEHOLD
50%-
MOST RESTRICTIVE
ALTERNATIVE
AVERAGE ANNUAL INCREASE
S2.15/HOUSEHOLD
-L
IDS 20S IK
PERCENT INCREASE IN RESIDENTIAL SEWED CHARGES
III-121
-------
FIG. 111-13
Projected increases in Sewer Charges Paid 3y
239,655 Households Served by Medium-Sized POTrf's Identified
in the Sample Set, Excluding Chicago (Average Annual
Charge Before Regulation is $55.05 per Household)
LESS RESTRICTIVE
ALTERNATIVE
AVERAGE ANNUAL INCREASE
SO SO/HOUSEHOLD
FINAL
REGULATION
AVERAGE ANNUAL INCREASE
St ID/HOUSEHOLD
MORE RESTRICTIVE
ALTERNATIVE
AVERAGE ANNUAL INCREASE
SI 39/HOUSEHOlD
MOST RESTRICTIVE
ALTERNATIVE
AVERAGE ANNUAL INCREASE
SI 76/HOUSEHOLD
ior. 20%
PERCENT INCREASE IN RESIDENTIAL SEWER CHARGES
I 11-122
-------
FIG. 111-14
Projected Increases in Sewer Charges Paid 3y
37,830 Households Served by Small POTW1s Identified
in the Sample set, Excluding Chicago (Average Annual
Charge Before Regulation is 565.74 per Household)
LESS RESTRICTIVE
ALTERNATIVE
AVERAGE ANNUAL INCREASE
SI DO/HOUSEHOLD
FINAL
REGULATION
AVERAGE ANNUAL INCREASE
SI IS/HOUSEHOLD
MORE RESTRICTIVE
ALTERNATIVE
AVERAGE ANNUAL INCREASE:
SI 69/HOUSEHOLD
MOST RESTRICTIVE
ALTERNATIVE
AVERAGE ANNUAL INCREASE
S1C5,HOUSEHOLD
10% 20% 10%
PERCENT INCREASE IN RESIDENTIAL SEWER CHARGES
III-123
-------
these same households would experience an increase of greater
than 4 percent, and more than one-third clearly would incur an
increase of more than 8 percent.
The average annual increase in residential sewer charges,
weighed according to the number of households affected, rises
monotonically for each plant <=ize category as the severity of the
regulation is increased:
ANNUAL INCREASES IN RESIDENTIAL SEWER CHARGES
($/HOUSEHOLD)
Small
POTW's
strictive $ 1.00
egulation 1.18
strictive 1.69
strictive 2.05
Medium
POTW's
$ 0.80
1.10
1.39
1.76
Large
POTW's
? 0.46
0.92
1.44
2.15
All
POTW's
S 0.55
0.97
1.44
2.06
In general, these increases are small, and show little corre-
lation with the size of the POTW's serving the households.
Assuming that the sample set is representative of all POTW's in
the country, these estimates can be extrapolated directly to
represent a relatively insignificant impact on household sewage
charges nationwide.
d. Economic and Environmental Comparison
Among Alternatives
Tables 111-20 and 111-21 summarize the cost and
environmental impacts of the regulatory alternatives for the
food-chain landspreading criteria.
As shown in Table 111-21 the less restrictive alternative is
$4.7 million less costly than the final regulation. However,
this alternative poses an undesirable risk of increased cadmium
III-124
-------
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III-125
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intake, as well as allowing increased levels of PCB's to be pre-
sent in milk and animal feed. Thus, the $4.7 million cost
increase incurred by selection of the final regulation over the
less restrictive alternative, which translated to an increase of
42* per year per household, would seem to be a small price to pay
for the expected added health protection.
On the other extreme, the most restrictive alternative,
which bans food-chain landspreading altogether, would provide
maximum health protection, since no cadmium, other heavy metals,
or toxic organics would be applied to the land via sludge
application. Yet, the cost increase over the final regulation,
$14.8 million (translating to $1.09 per household per year), and
the fact that all current landspreaders would immediately have to
seek other disposal methods and the resource value of even very
clean sludge would not be utilized, eliminates this option from
consideration.
The comparison between the final regulation and more
restrictive alternative is not so clear-cut. For an added cost
of $4.3 million, translating to 47* per household per year, less
cadmium will enter the food chain. A similar reduction is found
for PCB's. Thus, the more restrictive alternative offers some
measureable increase in environmental benefits for what appears
to be a reasonable cost on both national and household scales.
Moreover, although the implementation of the more restrictive
alternative in lieu of the final would increase from 15 to 22
percent the amount of currently landspread sludge that needs to
be disposed of in an alternative manner, this increase cannot
be characterized as a severe disruption of current practices.
Consequently, it appears that the implementation of the more
restrictive alternative could be justified on economic grounds.
However, the Agency believes that the more restrictive alternative
may be unnecessarily restrictive and that the interim final regu-
lation offers sufficient protection of public health and the
environment, in accordance with the mandate of Section 4004 of
RCRA.
III-127
-------
F. DISEASE
1. Importance; fidverse Effects from Improper Disposal
a. Open Dumps and Surface Impoundments
One of the major health problems of open dumps has been
that they provide food and harborage (shelter and breeding) for
common disease vectors such as rats, other rodents, flies, and
birds. In addition, surface impoundments can often breed
mosquitoes, with attendant disease problems.
Rats are responsible for the spread of a number of diseases,
either by contaminating food directly, rat bites, or through
flies and mites. The more common diseases include rat-bite
fever, leptospirosis (a mild to severe infection); trichinosis
(an infection of the intestine and muscles), and murine typhus
fever.
Flies and birds pose less of a threat to human health than
do rats; nevertheless, they do act as mechanical carriers of such
diseases as salmonellosis or food poisoning. Mosguitos may
transmit such diseases as encephalitis, malaria, and yellow
fever.
b. Land application of Sewage Sludge and
Septic Tank Pumpings
The improper disposal of sewage sludge and -septic tank
pumpings on land is of concern, particularly with regard to
public health, due to their pathogen content. Such wastes con-
tain various types of pathogenic bacteria, viruses, and para-
sites. Possible routes of infection to humans and animals
include direct contact with sludge during landspreading
III-128
-------
operations, contact with soil or plants which have been contami-
nated by sludge-related pathogens, or through ingestion of con-
taminated food or water.
Only a few of the hundreds of disease organisms that may be
found in sewage sludges have high enough survival rates in soil
and water to warrant concern, although there is very little
epidemiological data linking disease transmission to humans and
animals from landspreading of sludge. The organisms of most con-
cern are: Ascaris lumbricoides, Entamoeba histolytica, other
parasites, Salmonella typhi, other Salmonella species, Shigella
species, Vibrio cholera, certain other bacteria, and some viruses
(Ref. 180).
Bacteria are apparently the most fragile of the three groups
of pathogens. The survival of bacteria in soil is reduced by
sunlight, drying, and other factors when sludge is applied to
land. Contamination of plants can occur by direct contact and
rain splashes, but survival for an infective dose is usually
short (a few weeks) (Pef. 180). Bacteria can survive longer when
protected from sunlight or desiccation {Ref. 183).
Viruses may persist in soils and on vegetation for several
weeks or months. If exposed to sunlight and desiccation, viruses
will eventually be inactivated. For man, the virus of greatest
potential concern appears to be Hepatitus A (Ref. 183). This is
a serious disease which has an appreciable potential for long-
term liver damage.
Relatively little is known about the possibility of para-
sitic disease transmission via sludge-amended soils. Parasitic
ova and cysts are generally quite resistant to sludge digestion,
disinfectants, and adverse environmental conditions. The round-
worm Ascaris is most frequently mentioned as a potential problem
in human health. The infectious eggs are quite resistant to
destruction and may persist in soil for several years (Ref. 183).
III-129
-------
In summary, although questions arise concerning the impact
of nathoaens in landspreading of sludge and septic tank pumpings,
the lack of problems encountered by the numerous ongoing projects
using landspreading suggest that pathogens are a potential
oroblem only. However, it cannot be disputed that some viable
pathogens do occur in municipal sewage sludge and, consequently,
that the hazard of infection does exist. The difficulty lies in
the inability to Quantify the potential risk to human health.
Table 111-22 summarizes the major types of pathogenic
organisms that are considered to pose a threat to human health as
a result of landspreading municipal treatment plant sludges.
?. Regulatory Approach and Environmental Consequences
a. Final Criterion
This criterion requires that the disposal facility
protect the public health from disease vectors (any organism
capable of transmitting disease to humans, such as birds,
rodents, flies, and mosquitos). This may be achieved by
minimizing the availability of food and harborage for disease
vectors. At landfills, an effective means to control vectors,
especially the rodents which are of particular concern, is the
acplication of cover material at the end of each day of opera-
tion. Other techniques include poisons, repellants, and natural
controls (e.g., predators). Treating sewage sludge and septic
tanV pumpings by pathogen reduction processes serves to control
t^e spread of disease as a result of landspreading these wastes.
"Periodic application of cover material" is defined as the
application of soil or other suitable material over disposed
= olici waste at such freauencies and in such a manner as to
(]) impede vectors; (2) reduce infiltration of rainwater (by
III-130
-------
TABLE 111-22
Typical Pathogenic Organisms Found
in Municipal Treatment Plant Sludges
TYPE OF PATHOGEN
KNOWN PATHOGEN
SPECIES
DISEASE PATHOLOGY
BACTERIAL AGENTS
Pseudomonas
Salmonella
Shigella
VIRAL AGENTS
Poliviruses
Echoviruses
Coxsackie viruses
Hepititis viruses
PARASITIC ORGANISM
Helminths
Pseudomonas^ aeruginosa
Alcaligenes faecalis
Salmonella typhosa
Salmonella septicemia
Salmonella sp
typhinunum
Shigella dysenteriae
Shigella f lexner_i
Shigella sonnei
Entamoeba histolvtica
Balantidium coll
Ascaris lumbricoides
DiabothriQcephalus
latus
Taenia solium
I. saginatta
Hymenoplepis nana
Urinary tract infec-
tion
Urinary tract infec-
tion
Typhoid/enteric fever
High fever, septecemia
without gastrointesti-
nal involvement
Gastroenteritis
Bacillary dysentary
Bacillary dysentary
Bacillary dysentary
Poliomyelitis
Aseptic meningitis
Febrile illnesses
Diarrhea
Enteric infections
Infectious Hepatitis
Chronic diarrhea
Anebic hepatis
Abscesses of liver,
brain or lunn
Intestinal pathology
similar to E. histolytica
Adult inhabis lumac
intestinal tract, larvae
may migrate to lunas
causing hemorrhages,
possible pneumonia
With exception of
Hymenolpepis sp. in-
tection occurs through
eating raw or imper-
tectly cooked meats.
When eggs are ingested
by humans larvae migrate
to lumen of intestine.
Souice: U.S. EPA, "Background Document, Land Criteria" Unp'_±>lished Draft) ,
June 24, 1977, pp. 44-51, Docket 4004.
III-T31
-------
increasinq runoff, thereby decreasing leachate generation and
surface and ground-water contamination); (3) reduce and contain
odors, fires, and litter; and (4) enhance the facility's appear-
ance and future utilization (Ref. 30). In general, the results
can be achieved by covering at the end of each day the site is
open to receive wastes. In remote areas, on days when sites are
not open, storage bins may be provided for temporary enclosed
storage of wastes.
Landspreading of stabilized and composted wastes, surface
impoundments, and certain relatively inert wastes such as con-
struction, demolition, and land-clearing debris generally do not
require cover material because the wastes are nonputrescible, are
relatively stable and inert, or are impractical to cover. Some
disposal facilities, because of their location or because they
use other means of control, will not need periodic cover.
Because of these exceptions, the final criterion calls for
periodic application of cover material "where appropriate."
With respect to landspreading of solid wastes, the final
criterion stipulates that sewage sludge and septic tank pumpings
that are applied to the land surface or incorporated into the
soil are treated by a "Process to Significantly Reduce Pathogens"
prior to application. However, the final criterion provides an
alternative to this processing if the waste is septic tank
pumpings; these may be applied or incorporated "raw" if public
access to the facility is controlled for at least 12 months and
grazing by food-producing animals is prevented for at least
1 month. In the case of sewage sludge land application or incor-
poration, it is required, in addition to the significant pathogen
reduction process, that public access and grazing be prevented
for the same time periods. Acceptable pathogen reduction pro-
cesses are described in Appendix A of this EIS.
In addition, the final criterion states that facilities at
which sewage sludge and septic tank pumpings are applied to the
III-132
-------
land surface or incorporated into the soil and where crops are
grown for direct human consumption (except where there is no con-
tact between the solid waste and the edible portion of the crop)
shall either treat the sewage sludge or septic tank pumpings by
"a Process to Further Reduce Pathogens" prior to land applica-
tion, or not grow crops for human consumption for at least 18
months subsequent to land application. "Processes to Further
Peduce Pathogens" are also found in Appendix A.
Implementation of these criteria should effectively minimize
potential hazards to human health. Increased protection is asso-
ciated with the requirement for additional pathogen reduction for
application to those crops for which pathogens represent the
greatest health risk. The final regulation will result in some
cases where upgrading of POTW sludge treatment facilities, with
attendant increases in use of energy and chemicals, or a change
in crop management practices at the disposal site will be neces-
sary to meet the requirements. In most cases, however, no addi-
tional treatment or management costs will be incurred. The final
regulations will most likely simply serve to ensure the proper
operation and management of in-place sludge treatment facilities.
This final regulation is expected to control disease at
improperly regulated landfills and impoundments. The choice of a
general criterion for disease rather than specific operational
standards permits local choice of cost-effective measures for
landfills and enables impoundments operators to make the neces-
sary site-specific determinations.
Current practices in landfill disposal will not be measur-
ably affected by this criterion, since all States require disease
control. Increased supervision of application would probably be
required at many landspreading facilities to comply with the
regulation. In summary, this criterion protects public health
from disease by use of best control technologies.
III-133
-------
b. More Restrictive Alternative
? more restrictive alternative could require further
pathogen reduction for all sewage sludges and septic tank
pumpings that are to be landspread. While implementation of this
alternative should provide the maximum protection to human health
and assures significant reduction in potential health service
demands, it is unclear whether the potential increase in health
benefits is consistent with the costs associated with further
oathoqen reduction. This is particularly true since the combina-
tion of pathogen reduction and optimal land application facility
controls appear to provide an adequate margin of safety. The
economic impacts associated with implementation of this regula-
tory alternative may act as significant disincentives for con-
tinuation of existing landspreading, and may significantly affect
the future utilization of landspreading as a viable sludge dis-
posal alternative.
c. Less Pestrictive Alternative
The less restrictive approach to controlling pathogens
in sewage sludge and septic tank pumpings would be to require
treatment by "A Process to Significantly Reduce Pathogens" prior
to application on land only if the sludge is applied to crops
grown for human consumption or if it is applied directly to the
soil surface. While implementation of this alternative should
provide a margin of protection to human health, it may not ade-
auately protect human health from adverse impacts associated with
sludge-related pathogens. Treatment by the significant pathogen
processes listed in the regulation may be ineffective with
respect to potential risks associated with certain parasitic
organisms (when human foods are grown), as these parasites are
generally resistant to these processes.
Therefore, implementation of the less restrictive alterna-
tive may not provide adequate health benefits. It does not
III-134
-------
provide the additional margin of protection afforded by further
pathogen reduction for sludges applied to crops grown for human
comsuraption. While significant pathogen reduction is required
for sludges which are applied directly to the soil surface, the
less restrictive alternative allows subsurface incorporation of
sludges which have not undergone significant pathogen reduction.
Although incorporation alone may afford some measure of health
protection, it is not as effective in reducing pathogens. Also,
there is additional risk of infection from contact with the
sludge during application.
3. Summary Technology, Economic, and Environmental
Impact Analysis
a. Control Technologies and Unit Costs
(1) Disease
The most effective method of controlling disease
vectors is to minimize harborage and readily available foodstock,
thereby creating an inhospitable habitat.
Proper and adequate control of rodents and insects requires
a well operated and maintained landfill. Rodents can be con-
trolled by rodenticides and repellants, while rat and fly control
can be achieved by maximum compaction of the refuse and daily
placement of an adequately compacted soil cover.
Studies have shown that a daily cover consisting of 152 mm
(6 inches) of compacted low-clay-content soil will discourage rat
propagation as well as fly emergence. However, even under the
best of conditions, a landfill should have a regular inspection
III-135
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and a rat and fly control program. Local officials can best
dictate the specific controls used in any such program. Shredded
or milled waste and baled waste may also discourage rat attrac-
tion depending in part on how well these operations are performed
and how available other food sources are.
Mosquito control at landfills is best obtained by preventing
development of stagnant water bodies anywhere on the facility.
Certain fish thrive on mosquito larvae and are effective in
aerobic impoundments.
(2) Pathogens in Sewage Sludge and
Septic Tank Pumpings
(a) General Inactivation Mechanisms
Pathogen numbers can be reduced significantly
throucth the various processes employed for sludge treatment; how-
ever, it is unlikely that a completely sterile product can be
oroduced at reasonable cost. This is due, in part, to the diver-
sity of pathogenic organisms present in municipal wastes and to
their variable resistance to the different treatment processes
available.
Currently, there are linited data concerning the effective-
ness of various waste treatment methods and, in general, the
available information is not Quantitative. This lack of defini-
tive information makes it difficult to establish "relative risks"
for the various treatment alternatives available. As such,
sludge management decisions are necessarily guided by the general
effects or trends of solid waste treatment with respect to the
major groups of pathogens. For this di scu<;'- ion, the major cate-
gories considered are: bacteria, viruso0, and natssitic worms
and protozoa.
III-136
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Pacteria
Fnteric bacterial pathogens are the least likely
of the above groups to survive the extreme environmental condi-
tions to which they are exposed during wastewater and sludge
treatment (Pef. 196). Bacterial inactivation can be effected by:
(1) elevated temperatures, (2) pH extremes, (3) decreased mois-
ture, (4) chemical disinfectants, and (5) irradiation. Also,
enteric bacteria tend to be poor competitors outside the host
even under near optimal environmental conditions.
Temperatures which are conducive to growth of enteric
bacteria range from 30° to 40°C. Decay occurs at temperatures
below 30°C, although at very slow rates; and freezing can
actually preserve the existing population for extended periods.
Temperatures above 40°C are detrimental to most bacterial
pathogens and, in general, higher treatment temperatures result
in more raoid rates of decay. Bacterial pathogens are reportedly
reduced to "safe" levels by 30-minute contact at temperatures in
excess of 60°C.
Bacterial numbers can also be reduced by raising pH above 9,
or lowering it below 4. Most bacteria are destroyed by alkaline
treatment above pF 11.
Bacterial pathogens can be destroyed by heat drying. In
this case, the primary inactivation mechanism is the increased
temperatures, in excess of 100°C, encountered in such treatment.
Thus, bacterial destruction would be enhanced by using higher
drying temperatures for extended contact time.
Chlorine compounds are the most common chemical disinfec-
tants considered for sludge treatment. Bacteria are quite sus-
ceptible to low levels of free-residual and combined forms of
chlorine; however, chemical consumption by other organic consti-
tuents is considerable, and many chlorinated organics are pro-
duced.
III-137
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Irradiation, either by natural sunlight or ionizing radia-
tion, is effective for disinfecting municipal sludges. Quantita-
tive information is lacking for assessing exposure to solar
radiation, although it is generally believed that prolonged expo-
sure sianificantly reduces bacterial numbers. It is also
feasible to disinfect sludge using ionizing irradiation
(Pef. 173,197,198). In general, for this method, higher radia-
tion dosages result in greater bacterial kills--a 99 percent
reduction of bacteria has been reported using a dose of 105 rad
for both settled sewage sludge and an air-dried sludge (87% mois-
ture) (Pef. 198). In addition, the bactericidal effect is
enhanced at elevated temperatures (50-55°C) during irradiation.
Viruses
Information available on the virucidal effect of
sludge processing is less definitive than for inactivation of
Bacteria, due primarily to increased difficulty of virus
sampling. ?lso, the resistance among different species is vari-
able, thus making generalization difficult. Basically, however,
the same mechanisms delineated for inactivating bacterial
cathoaens are also effective for viral destruction: (1) elevated
temperature, (2) pH extremes, (3) decreased moisture, (4) chem-
ica] disinfectants, and (5) irradiation. In addition, viruses
are obligate parasites and most species are host-specific, i.e.,
reauire either human, animal, plant, or bacteria for replication
(Pef. 199). therefore, viruses can be inactivated by prolonged
periods of isolation from the host organism, thus resulting in
natural decay without replication. The decay rate seems to be
increased with hioher temperatures (Pef. 174). As is the case
with bacterial pathogens, low temperatures reduce the rate of
decay, thus actino to preserve the existing populationextended
survival has been documented at temperatures of 4°C (Ref. 174).
All-aline treatment is quite effective for reducing viral
infectivitv (Pef. 196). Inactivation is substantial when the pH
III-138
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is raised above 11, although viral activity has been detected in
sewage after 3.5 hours contact at pH 11.5.
The tendency of viruses to adsorb particulates complicates
the process of viral disinfection. By this means, sludge solids
act as a buffering agent protecting viruses against inactivation
processes.
The effect of irradiation treatment on virus destruction is
not well documented. It appears that the virucidal effect of
irradiation may be comparable to its bactericidal effect, and
inactivation rates are comparable between pathogens (Pef. 173,
175, 197, 198).
Parasitic Worms and Protozoa
The most resistant of the sewage pathogens are
eggs, or ova, of the parasitic worms (helminths). In particular,
flscaris eggs are extremely resistant (Fef. 196). For this para-
sitic roundworm to be infective, it must pass through a complete
life cycle, which includes embryonation and subsequent staged
larval development (Fef. 200). The optimum temperature range for
embryonation and development is relatively broad, 17° to 3C°C;
however, the eggs of flscar is can persist in an inactive, but
viable, state through much greater extremes. Pefrigerated eggs
can remain viable up to 20 years, and are known to withstand
repeated freezing and thawing (Pef. 200). Temperatures in excess
of 60°C are generally recommended for complete inactivation. The
protective shell of the ova is layered and very resistant to
chemical agents and disinfectants.
The extent to which pathogens are reduced by sludge pro-
cessing depends on the treatment process and the type of pathogen
considered. The primary inactivation mechanisms are: (1) ele-
vated temperatures, (2) pH extremes, (3) chemical disinfection,
and (4) irradiation. In general, pathogen inactivation rates are
III-139
-------
logarithmic for each treatment condition and are increased by
rising temperatures, greater pH extremes, and greater chemical or
irradiation dosages. Viruses and parasite eggs are the pathogens
most resistant to sludge treatment.
(b) Pathogen Removal by Sludge Processing
Pathogens are reduced in numbers by the various biological
and/or physical-chemical treatments employed for municipal sludge
processing. Biological inactivation occurs primarily through
natural decay and is accelerated at elevated temperatures.
Table 111-23 shows the time-and-temperature relationships for
reducing selected pathogens to non-detectable limits.
The most common biological treatment processes considered
for pathogen removal are anaerobic digestion, aerobic digestion,
composting, and long-term storage. Typical design and operating
criteria pertinent to pathogen destruction are summarized for
each method in Table 111-24.
Physical-chemical pathogen removal methods of sludge pro-
cessing include heat treatment, lime addition, chlorination, and
irradiation. Respective design and operating criteria for
physical-chemical treatments are listed in Table 111-25.
A brief description of each sludge treatment method is given
in the ensuing discussion, with specific reference to pathogen
removal efficiency.
Biological Processes
ftnaerobic Digestion. Biochemical stabilization of
sludge in an oxygen-free environment is termed
anaerobic digestion. For this process, the prin-
cipal design criteria that influence pathogen
removal are: sludge retention time, operating
temoerature, and degree of mixing. Pathogen
removal is enhanced by higher temperatures and
longer retention times, which unfortunately are
III-140
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TABLE HI-23
TIME AND TEMPERATURE RELATIONSHIPS
FOR PATHOGEN REMOVAL TO NON-DETECTABLE
Low Range High Range
Organism
Salmonella typhosa
Salmonella sp.
Shigella sp.
Ent. Histolytica cysts
Taenia saginata
Mycobactenum tubercu-
losis var. honunis
Necator americanus
Temp(°C)
55-60
55
55
45
55
66
45
Time (Min)
30
60
60
Few
Few
15-20
50
Temp(°C) Time (Min)
60 20
60 15-20
-
55 Seconds
-
67 Momentary
_
Ascaris lumbricoides
eggs 50 60
1 Gotass, H. "CompostingSanitary Disposal and Reclamation of
Organic Wastes", WHO Mono. Ser. No. 31 (1956).
IIM41
-------
TABLE 111-24
Typical Design and Operating Parameters
For Biological Sludge Treatments
Process
Design and ' Anaerobic Aerobic Long-Term
Operating Criteria Digestion Digestion Composting Storage
Temperature, °C a) Mesophllic
30-40° Ambient 55-65° Ambient
b) Thermophi-
lic, 50-60° 5-20° 0-20°
Detention Time 15-30 Days 10-20 Days a) Aerated, Greater
10-40 Days Than One
Year
b) Intermit-
tant Mix-
ing, 8-12
Weeks
Pathogen Removal a) Good Good Excellent Variable,
Efficiency1 Poor to
Good
b) Good to
excellent
Qualitative description of pathogen removal where: poor=less than
90% destruction, good=greater than 90% destruction, and excellent=
greater than 99% destruction and effective removal of parasite eggs.
III-142
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TABLE 111-25
Physical-Chemical Sludge Treatments for
Pathogen Removal
Process
Design and ' Heat Alkaline
Operating Criteria Treatment Treatment Chlorination Irradiation
Temperature, °C a) Pasteuri^a- a) Ambient
tion, 70°
b) 50-55°
b) Thermal
Condition- Ambient Ambient
ing, 170-220°
c) Heat drying,
>100°C
Detention Time a) 30 Minutes Variable,
Depending
b) 30 Minutes 1-4 Hours 3-5 Minutes on Dosage
Rate
c) Variable
Chemical or Lime to 0.05-1.2 Ib a) 10 - 10
Radiation* Dose Raise pH Cl /Ib Dry Rads
11.5-12 Solids
b) 2 x 10
Rads
Pathogen a) Excellent a) Good, Good to Ex- a) Excellent
Removal Effi- Parasite cellent
ciency b) Excellent Eggs Effect on b) Excellent
Survive Parasite
c) Excellent Eggs Unknown
Radiation absorbed dose expressed as 100 ergs per gram material.
Qualitative description of pathogen removal where: poor=less than 90%
destruction, good=greater than 90% destruction, and excellent=greater than
99% destruction and effective removal of parasite eggs.
III-143
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associated with higher treatment costs. Most
anaerobic digesters are designed for operation at
mesophilic temperatures (30-40°C). For this
range, reduction of viral and bacterial pathogens
is typically greater than 90 percent, depending on
species and operating conditions; however, para-
site eggs are not effectively destroyed. Short
circuiting can occur in digesters that are not
properly mixed, thus causing inefficient sludge
stabilization and pathogen removal. Anaerobic
digestion is not conducted for the intermediate
temperature range from 40° to 50°C due to unstable
performance; however, thermophilic fermentation at
50 to 60°C is an effective method of sludge
stabilization. Improved pathogen removal occurs
at the higher operating temperatures employed for
thermophilic digestion and significant inactiva-
tion of parasite eggs can be expected. Thermo-
philic digestion has been employed extensively in
the USSR but has seen little application in the
U.S. to date.
Aerobic Digestion. Small plants typically use
aerobic digestion for sludge stabilization.
Pathogen removal is reportedly good for this pro-
cess, but parasite eggs are not effectively
destroyed by the near-ambient operating tempera-
tures.
Composting. Composting can be a very effective
method for pathogen removal and stabilization of
sludge. In this process, a bulking agent (refuse
or agricultural residues) is combined with sludge
to provide an adequate carbon/nitrogen ratio
(greater than 20) and proper moisture content
(about 40 percent). The composite mixture is
placed in piles or windrows which are kept aerobic
by intermittent turning and blending or mechanical
aeration. The ensuing stabilization process is
exothermic and results in temperatures as high as
55-65°C in the internal regions of the windrows or
piles, depending on ambient conditions. These
temperature extremes are effective in removing
most pathogens (including parasite eggs) to very
low and relatively safe levels.
Long-Term Storage. Another biological, or
natural, alternative for pathogen removal is long-
III-144
-------
term storage. For this case, the rates of
pathogen removal and sludge stabilization are
highly dependent on the climate or ambient condi-
tions. Very little stabilization will occur and
pathogens will essentially be preserved during
cold seasons. Thus, virtually all pathogen
inactivation will be restricted to the warmer
months for seasonal geographic regions, and
inactivation will occur in varying degrees,
depending on species. It is unlikely that long-
term storage will completely inactivate parasite
eggs; however, in most cases, bacterial and viral
pathogens will be reduced to very low levels after
one year of storage.
Physical-Chemical Processes
Heat Treatment is an effective and well-
established means of destroying all types of
pathogens. The degree of pathogen removal in
sludge treatment is dependent on contact time and
temperature. The pasteurization process is
employed specifically for pathogen removal in
sludge processing, and essentially provides a
pathogen-free product. In this process, contact
temperatures of 70°C are typically held for 30
minutes. Although thermal sludge conditioning
(such as wet oxidation and the Porteous process)
and heat drying processes are designed for
improving sludge handling characteristics, they
reach temperatures far greater than 70°C during
treatment, and thus destroy virtually all living
organisms.
Alkaline Treatment. Lime sludge stabilization
removes most all viral and bacterial pathogens,
but does not destroy resistant parasites. Lime
treatment is designed to improve sludge filter-
ability and produce a more stable product. This
is typically accomplished by initially raising the
pH above 11.5 and holding it above 11.0 for two
hours. Lime dosages greater than 1 lb/100 Ib dry
solids are typically required.
Chlorination. The Pur ifax process employs large
dosages of chlorine for stabilizing municipal
sludges. In this treatment, oxidation of organics
JII-145
-------
occurs rapidly (in about 3 minutes) and frequently
causes the pH to drop below 4, which enhances
pathogen removal. Although there is insufficient
data relative to pathogen removal by sludge
chlorination, it is unlikely that such treatment
will result in significant inactivation of the
resistant parasites unless extended contact is
practiced.
Irradiation. Sludge irradiation has been proved
effective for removing bacterial and viral
pathogens at both ambient and elevated (50°-55°C)
temperatures. Higher treatment temperatures
increase pathogen removal rates. An irradiation
dose of 10 rads reduces pathogen numbers to non-
detectable limits.
In summary, it is clear that most sludge stabilization and
conditioning processes are very effective in removing bacterial
and viral pathogens; however, only treatments that employ extreme
temperatures can assuredly reduce the more resistant parasites to
relatively safe levels.
Table 111-26 shows control technologies and unit costs as a
function of disposal site size for the final criterion; costs are
identified for each disposal method impacted by this criterion.
b. assumptions
The major economic impact of this criterion results
from the need to prevent or minimize food and harborage for
vectors such as rodents or insects. Only one regulatory alterna-
tive was considered practicalthe final criterion.
III-146
-------
KH O
"S o
III-147
-------
An analysis of State solid waste rules and regulations
reveals that all States require periodic application of cover
material at landfill sites, as well as the control of pathogens
in landspreading operations. Since permitted and authorized
landfills already apply cover material, these costs are assigned
only to those sites requiring closure and are, therefore, counted
in closure costs to avoid double counting of costs. It is
assumed that landspreading operations already control pathogens,
as mandated by State law. However, 10% of the on-site industrial
landfills are assumed to require upgrading to comply with this
criterion.
Since the economic impacts of the disease criterion on
surface impoundments and landspreading operations are considered
negligible, only landfills were assessed.
c. Costs
The application of a daily cover soil is the best
available technology for minimizing disease. Table 111-27 pro-
vides costs for each disposal method for compliance with this
criterion.
Costs, all State-standard-induced, for cover can be expected
to be incurred at on-site industrial landfills in each State.
These costs range between $19,000 and $2.3 million.
d. Economic and Environmental Comparison Among
Alternatives
Table 111-28 shows the economic and environmental com-
parisons among alternatives for the disease criterion.
Costs for the more and less restrictive alternatives were
not developed because the only difference between the alter-
natives relates to the degree of pathogen reduction required for
land application. For all alternatives, this cost is negligible.
III-148
-------
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G. AIR
1. Importance; Adverse Effects from Improper Disposal
Clean air is recognized as an essential component of a
healthy environment for all living things. Indeed, the primary
air quality standards of the Clean Air Act of 1970 were estab-
lished to protect human health, while the secondary standards
were designed to protect crops, plants, and property from the
adverse effects of air pollution.
The amended Clean Air Act of 1970 provides for the first
national ambient air quality standards, the first national
emission standards for stationary sources, as well as the first
standards of performance. However, the States retain the right
to determine how the ambient standards are to be achieved.
Section 107 of the 1970 act provides that:
"(a) each State shall have the primary responsibility
for assuring air quality within the entire geographic
area comprising such State by submitting an implementa-
tion plan for such State which will specify the manner
in which national primary and secondary ambient air
quality standards will be achieved and maintained
within each Sir Quality Control Region (AQCR) in such
State." Note that each AQCR may use its own methods
but all must eventually meet these standards
(Ref. 133).
According to Section 110 of the 1970 law, Federal air
standards will be enforced at the State level in the following
manner (Ref. 133):
Each State shall, after reasonable notice and public
hearings, adopt and submit to the Administrator, within
nine months after the promulgation of a national pri-
mary ambient air quality standard, a plan which pro-
vides for implementation, maintenance, and enforcement
of such primary standard in each air quality control
region (or portion thereof) within such State
(Pef. 133).
III-151
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One of the major air quality effects of solid waste disposal
has been participate pollution (smoke and ash) from open burning,
which is uncontrolled or unconfined combustion. Uncontrolled
means (1) the air or oxygen-to-fuel ratio (which determines the
temperature and efficiency of combustion) is not governed,
(2) the combustion residence time and mixing is not governed, or
(3) the emissions of pollutants into the air are unchecked.
Fmissions of pollutants into the air from open burning are high
compared to controlled burning such as municipal incinerators
with air pollution control equipment (Ref. 30). Tests indicate
that smoke from most open burning can cause definite eye irrita-
tion up to 400 feet from the fire (Ref. 79, p. 37).
The impact of open burning is particularly acute in the
major metropolitan areas and air basins. Currently, States
generally prohibit open burning of wastes is generally prohibited
in critical air quality basins unless a variance* is obtained
from the State and local air pollution control agency. However,
establishing variances based on potential impacts is very complex
because of the dynamic nature of the many variables involved,
such as existing air quality, wind speed, humidity, mixing lid
and vertical dispersion, efficiency of the burn, terrain, amount
and type of wastes, etc. Because of this complexity, adequate
variance procedures are often difficult to administer and
enforce.
In addition to the potential health and property damages
from air pollution, significant safety and damage threats caused
by smoke and fire are associated with open burning. Smoke from
open burning of wastes can reduce air and auto traffic visi-
bility, and has resulted in incidents of multiple car accidents
and deaths on expressways. Unconfined fires at dumps may spread
and result in damage to property (Pef. 30).
*A license to pollute for a limited time, typically a year, usually
with the agreement that the polluter will institute procedures to
clean up (Pef. 140).
III-152
-------
2. Pegulatory Alternatives and Environmental Consequences
a. Final Criterion
The final criterion for air seeks to achieve the objec-
tive of the Clean Air Act (CAA) (Public Law 93-319) under which
State Implementation Plans are developed for State and local con-
trol of air emissions. The facility is to control air emissions
so as to comply with State Implementation Plans (SIP's) developed
in accordance with Section 110 of the CAA (which was referenced
above). The open burning of residential, commercial, institu-
tional, and industrial solid waste is prohibited; however, the
following special wastes are excluded from this prohibition:
land clearing debris; diseased trees; debris from emergency
clean-up operations; and silvaculture, agricultural and ordnance
wastes.
As used in this criterion, "open burning" means the combus-
tion of solid waste wi thout (1) control of combustion in air to
maintain adequate temperature for efficient combustion, (2) con-
tainment of the combustion reaction in an enclosed device to pro-
vide sufficient residence time and mixing for complete combus-
tion, or (3) control of the emission of the combustion products.
In most cases, States already prohibit open burning of solid
wastes, and have restrictions on burning in urban areas.
Therefore, the environmental benefits that would result from the
proposed ban on open burning and variance for certain wastes
would occur outside of urban areas.
b. More Restrictive Alternative
A more restrictive alternative would be a ban of all
open burning. Such a ban would obviously protect air quality
from the adverse effects of this practice. However, it would
have a significant impact on disposal practices in agricultural
III-153
-------
areas of the country where field and brush burning would be
permitted under specific atmospheric conditions (provided that
the State has issued a variance for such burning) . To ban all
open burning is to force all agricultural wastes (especially
slash piles and brush/debris from landclearing) to be composted,
plowed under, used as a mulch, or deposited in landfills.
c. Less Restrictive Alternative
A less restrictive approach to the problem would be to
allow open burning of all solid wastes, provided that such
burning is in compliance with State and local air regulations.
This would allow open burning at a larger number of small facili-
ties and thus would be expected to have some adverse effects on
air Quality in rural areas of the country; these effects include
ootential health hazards (contributing to such respiratory ill-
nesses as chronic bronchitis), plant damage, and threats to
public safety (caused by reduced visibility of operators of auto-
mobiles, trucks, and other modes of transportation (Ref. 140).
The advantages of open burning as a waste management
practice are limited; such a practice does not eliminate the need
for cover material, disease vector control, or leachate control
for maintaining surface and ground-water quality. Moreover,
variance procedures provided for in the State Implementation
Plans are difficult to administer and enforce because of the
dynamic nature of the many variables involved (including existing
air Quality, wind speed, humidity, mixing and vertical disper-
sion, efficiency of the burn, terrain, and amount and type of
wastes).
III-154
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3. Summary Technology, Economic, and Environmental Impact
Analysis
a. Control Techniques and Unit Costs
The primary air contamination potential from solid
waste is particulate matter created by open burning. The
principal means of controlling this problem is the elimination of
all open burning. Deliberate open burning can be controlled by
regulations and enforcement; however, naturally occurring
spontaneous combustion can develop if organic matter is left
exposed to free oxygen. Soil cover on a daily, or more frequent
basis, is a very effective method of limiting free oxygen,
thereby precluding spontaneous combustion.
Other sources of potential air contamination from solid
waste occur as liquid evaporates or sublimates from surface
impoundments. Technical solutions to air pollution problems
caused by impounded wastes include covering the impoundment
surface with membrane, covers and evaporation suppressants or
storing liquid materials in closed containers. The gases from
the impoundments can be collected with the aid of induced exhaust
and taken to an area where they are either incinerated or
properly cleaned before they are released to the environment. If
these alternative technologies are neither practical nor
economical, another solution is to completely shut down the
impoundment and substitute the other waste-disposal methods.
Table 111-29 shows control technologies and unit costs as a
function of facility size for the air criterion; costs are
identified for each disposal method impacted by this criterion.
III-155
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111-156
-------
b. Assumptions
Since it is assumed that the impact of the air
criterion on almost all surface impoundments and landspreading
sites is either negligible or non-existent, the economic impact
on these disposal methods was assumed to be zero. Unlike land-
filling, neither of these disposal methods utilizes open burning.
as a method of volume reduction of waste. Costs will be
incurred, however, under the final and more restrictive
regulatory considerations, at landfills that currently burn
wastes. For the less restrictive regulatory alternative, costs
have not been assigned to the criteria because they are the
purview of the particulate emission standards and other provi-
sions of the Clean Air Act.
Costs
Cost estimates for the effect of this criterion were
developed based upon the above technology and on unit costs as a
function of site size. Unit costs and the data base are
presented in greater detail in Appendix B.
In summary, the final regulation would impact costs in all
States ranging from $119,000 to $13.9 million per State.
Similarly, for the more restrictive alternative, costs could
range from $134,000 to $15.7 million per State.
Table 111-30 compares annualized costs based upon disposal
method and regulatory alternative.
d. Economic and Environmental Comparisons Among
Alternatives
Table 111-31 shows the economic and environmental com-
parisons among alternatives for the air quality criterion.
III-157
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Comparing the more restrictive alternative with the final
criterion shows that an additional combined cost of $15.6 million
for the more restrictive alternative provides only a minimal
increase in environmental benefit. Further, a complete prohibi-
tion of open burning would have a significant effect in some
areas of the country where open burning practices are prevalent.
In comparing the less restrictive alternative to the final cri-
terion, FPA has concluded that the $152.4 million per year
increase for the final regulation is justified in terms of
environmental benefits.
III-160
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H. SAFETY
1. Explosive Gases
a. Importance; Adverse Effects From Improper Disposal
Solid waste disposal sites may contain or produce
explosive oases which may accumulate on-site or migrate off-site.
Products of solid waste decomposition, oxidation, volatilization,
sublimation, or evaporation may include gases such as methane and
hvdroaen. The presence of any of these or similar gases at a
disposal site, in sufficient concentration, can pose a serious
threat to the health and welfare of site employees and users, and
occupants of nearby structures. Explosions resulting in injury
and death have resulted from disposal site gases. In addition,
nroperty damage, around-water contamination, and vegetation kills
(on-site and on adjacent lands) have been attributed to gases
Generated by solid waste disposal.
In 1969, seepage of gas from a landfill caused an explosion
in a National Guard Armory in Winston-Salem, North Carolina that
took the lives of three men and seriously injured two others. In
1975, buildings at two separate fills in Michigan suffered frame
damage due to methane explosions, and in Vancouver, Canada, a
newly-poured foundation slab was structurally destroyed by an
explosion initiated by a ciaarette in the air space underslab.
Gas miaration from dumps in Richmond, Virginia, in 1975 required
the closina of two public schools and resulted in an explosion in
a multi-family apartment unit. No one was seriously injured.
The City anticipated the expenditure of over $1 million to
control the gas. The list of similar incidents continues to
lengthen annually, dramatically illustrating the hazards posed by
gas miaration (Ref. 117).
Althouah methane gas generated in landfills can be explosive
in fairly low concentrations when mixed with oxygen, potential
III-161
-------
problems can be readily averted by venting the gas. In addition,
there is a beneficial side to methane control that should be
noted: the gas has commercial value as an energy source if it is
cleaned. Currently, there are several new production-scale
projects underway to recover and sell the gas.
b. Pequlatory Approach and Environmental
Consequences
(1) Final Criterion
This criterion requires that the concentrations of
explosive qases in facility structures (excluding gas control or
recovery system components) not exceed 25 percent of the lower
pxrlosive limits for the gases, whereas at the facility property
boundary concentrations must not exceed the lower explosive
Units. Implementation of the criterion will protect the public
and the environment from the potentially hazardous effects of
explosive aases. The development of gas recovery facilities
should not be impeded by the gas criterion.
No less or more restrictive alternatives for the gas
criterion were considered practical by EPA.
2. Fires
a. Importance; Adverse Effects From Improper Disposal
Fires at solid waste disposal facilities pose a
significant hazard to public safety and environmental quality.
Death, injury and property damage have resulted from fires
breaking out in open dumps.
Circumstances other than intentional burning which may lead
to such fires include: vandalism, carelessness, spontaneous
combustion, and disposal of solid waste still undergoing
III-162
-------
combustion (ashes). Any fire at a solid waste disposal facility
poses a threat of property damage and injury or death to facility
employees, users, and nearby residents. Underground fires may
become very difficult to extinguish if not attended immediately.
A fire which began at a 40-acre facility in Wisconsin late in
1968 took almost 6 months to extinguish. Expenditures of
hundreds of thousands of dollars were needed for manpower and
eauipment used to fight the blaze (Kef. 79, p.37).
Other evidence of the harmful impacts of open burning are
illustrated by the following:
In 1968, a seven-year-old boy died in a fire at
the (now closed) Kenilworth Dump in Washington,
D.C.
An older man died while fighting his own trash
fire, and one child was severely burned in a trash
fire in St. Joseph, Missouri in 1972.
In the summer of 1972, a major fire at a dump in
Easton, Pennsylvania required the expenditure of
large sums of public funds to extinguish.
Smoke from open dump fires has reduced visibility
on nearby traffic arteries and caused multiple-
vehicle accidents, e.g., on the Oakland (Cali-
fornia) Nimitz Freeway; also, on the New Jersey
Turnpike on the night of October 23-24, 1973,
there were nine separate multiple-vehicle acci-
dents, involving 66 vehicles and resulting in 9
fatalities and 34 injuries.
Tests indicate that the smoke from most open dump
burning contains sufficient aldehydes to cause
painful eye irritation up to 400 feet away from
the fire.
III-163
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b. Pequlatory Approach and Environmental Consequences
The final criterion stipulates that the disposal site
facility must not pose a hazard to public safety or environmental
quality. This goal will be achieved through compliance with the
air criterion (see Section IIIG), and through periodic applica-
tion of cover material or other techniques, where appropriate.
Such techniques include monitoring waste received, limiting the
exposure of flammable material, and providing fire-fighting
eauipment to promptly extinguish such fires.
The fire-safety criterion supplements the air quality
criterion banning open burning by minimizing the chances for
accidential fires, thereby protecting public safety and property.
No less or more restrictive alternatives for the fire
criterion were considered practical.
3. Bird Hazards To Aircraft
a. Importance; Adverse Effects From Improper Disposal
Solid waste disposal facilities may attract large
numbers of birds that feed on the fresh refuse and rest, preen
and strut on areas of open, relatively flat land frequently found
near the sites. The gathering of flocks not only creates a
potential nuisance and health hazard, but may pose a safety
hazard (collision threat) to low-flying aircraft if the disposal
facility is located in the proximity of an airport (See Refs. 80-
84). Since the juxtaposition of airports and disposal facilities
is relatively common, particularly in coastal states, such a
safety hazard must be taken seriously. In the San Francisco Bay
area, for example, over thirty solid waste disposal sites are
located in the vicinity of seven major and thirteen smaller
airports. Two large landfills are adjacent to the J. F. Kennedy
Airport in New York.
III-164
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According to Federal Aviation Administration (FAA) personnel
and other experts knowledgeable about bird/aircraft problems,
hazards exist when disposal facilities are located between air-
ports and bird feeding, roosting, or watering sites. The hazard
arises as birds traverse the airport while flying between the
disposal facility and watering, feeding, or roosting areas. A
crash of a private jet airliner near Atlanta, Georgia, on
February 27, 1973, resulted in seven fatalities. The crash has
been attributed to jet ingestion of starlings which, allegedly,
had conareqated near an uncovered, shredded refuse disposal site
near the end of one runway of the DeKalb County (Georgia) Air-
port.
In an effort to alleviate this problem, the FAA issued an
order in 1974 giving guidance for evaluating the feasibility of
locating disposal facilities within the proximity of airports.
The FAA guidance suggested that facilities falling into any of
these various proximity categories should be closed "within a
reasonable time" (Pef. 84).
It is important to note that while the FAA is authorized to
control airport operations to reduce bird hazards to aircraft,
their authority does not extend to disposal facilities outside of
airport boundaries.
b. Regulatory Approach and Environmental Consequences
(1) Final Criterion
The final criterion stipulates that several categories
of solid waste disposal facilities receiving putrescible wastes
that may attract birds must be so designed, operated, and
ma intained that they do not pose a bird hazard to aircraft. The
specific categories of disposal facilities are those (1) within
3,008 meters (10,000 feet) of any airport runway used by turbojet
aircraft; or (2) within 1,500 meters (500 feet) of any airport
III-165
-------
runway used only by piston-type aircraft; or (3) that are likely
to so alter bird feeding, watering, and roosting patterns as to
pose a bird hazard to aircraft approaching or departing an air-
port.
The reponsible agencies and/or parties that will determine
the existence of such a bird hazard are (1) the FAA, (2) the Fish
and Wildlife Service (U.S. Department of the Interior), and the
owners and operators of the airport and the disposal facility.
Definitions essential to the interpretation of this cri-
terion are those for "airport" and "a facility poses a bird
hazard." "Airport" refers to active military airports as well as
airports within the National Airport System Plan published in
accordance with Section 12 of the Airport and Airways Development
Act of 1970, as amended (Public Law 91-258). "A facility poses a
bird hazard" means the facility (1) attracts birds that feed on
putrescible waste, or (2) disrupts normal bird flight patterns,
or (3) alters bird roosting and watering sites to the extent that
approaching or departing aircraft are subjected to the public
safety and property hazards posed by bird/aircraft collisions.
(2) More Restrictive Alternative
A more restrictive alternative would be the banning of
all disposal facilities that are included within the categories
specified in the final criterion. Although such an approach
might reduce the risk of potential bird hazard to aircraft, it
may eliminate the use of a facility with minimal or no bird
problems and result in the selection of less desirable
alternative sites.
III-166
-------
(3) Less Restrictive Alternative
A less restrictive approach would be to have no
criterion governing bird hazard to aircraft, relying instead on
the authority of the Federal Aviation Administration. Such an
approach might contribute to increased numbers of incidents
involving collision of birds with aircraft, with attendant
threats to public safety and property (Refs. 80-84). To exclude
the bird hazard criterion would be to abrogate the expressed
intent of the criteriato prevent adverse effects on health and
the environment.
4. Access
a. Importance; Adverse Effects From Improper Disposal.
Solid waste disposal facilities and operations can
cause injury or death to persons at the facility; the sources of
hazards are often easy to control and include:
(1) operation of heavy equipment and haul vehicles;
(2) exposure to waste including sharp objects,
pathogens, and toxic, explosive, or flammable
materials;
(3) accidental or intentional fires;
(4) excavations and earth-moving activities.
Control of access to disposal facilities or unsafe portions
of facilities is considered vitally important to ensuring the
public safety. A 1970 study of solid waste management practices
at Indian reservations found open dumping common. U.S. Public
Health Service physicians reported treating large numbers of cuts
and punctures received by Indian children playing in the dumps.
III-167
-------
(1) Final Criterion
The final criterion calls for controlling entry to
disposal facilities, thereby minimizing exposure of the public to
hazards of heavy equipment operation, construction, and exposed
waste. Professionals in waste management agree that the most
effective means of minimizing the risk of injury to the public is
by prohibiting access to the facility by non-users and by
strictly controlling the activities of users on-site. For
persons wishing to dispose of small amounts of wastes, storage or
special disposal facilities are recommended.
No less or more restrictive alternatives for the access
criterion were considered practical.
5. Summary Technology, Economic, and Environmental Analysis
a. Control Technologies and Unit Costs
Control technologies are available for the safety
criteria: explosive and toxic gases, fires, bird hazards to
aircraft, and injuries due to improper access. These tech-
nologies are discussed below.
(1) Explosive and Toxic Gases
Gases generated within landfills will migrate
through the cover soil, base, and side walls. Many above-ground
landfills and those below-ground landfills in an impermeable soil
or rock environment will reouire no special lateral gas control
features. On the other hand, a gas control system such as vents
or barriers must be provided where refuse extends below ground in
landfills with permeable side walls or base. Lateral control
features must also be provided where utility or other man-made
features of a permeable nature penetrate the refuse perineter.
Such facilities could otherwise serve as gas conveyors and thus
III-168
-------
foster a hazard condition.
Certain climatic effects may reduce the permeability of the
soil, thus restricting the passage of gas through the cover
resultina in lateral gas migration and potential gas hazard. For
example, sufficient rain or frost will render any type of soil
less permeable, encouraging the lateral migration of the gas. In
addition to decreasing the permeability of surface soils, rain
water or snow melt may infiltrate the refuse; the resulting
increase in moisture may stimulate the rate of waste decomposi-
tion and gas production. This combination of decreased
permeability of the cover and increased gas production may cause
a significant increase in lateral migration of the gas during the
rainy season. On the other hand, the low temperature snow-melt
water may reduce gas generation by slowing microbial metabolism.
Since aas migration may ultimately result in such hazards as
fire or explosion, special control systems have been developed to
alleviate this problem.
Methods of controlling landfill gas migration include one or
more of the following:
1. Placement of impervious liner materials to block
the subsurface flow of gas to adjacent lands or
into bu ildings.
2. Selective placement of granular materials for gas
venting and/or collection.
3. Atmospheric or pumped wells for evacuation and
venting of gas from the landfill itself.
Fiqure 111-12 shows schematics of several gas control
systems.
III-169
-------
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Impervious liner materials used to control gas flow include
plastic, rubber, similar synthetic films, natural clay and
asphalt. Plastic film is the most widely used synthetic material
since it not only has the ability to contain gases, but also has
a high resistance to deterioration. On the other hand, a
disadvantage of plastic liners is their susceptibility to
puncture during placement and their somewhat limited life-span.
Polyolefin or rubber products have potentially longer life than
other synthetics.
Natural soil barriers such as saturated clay may furnish a
highly efficient barrier to gas migration, provided the soil is
kept nearly saturated; dry soils, however, are ineffective, since
cracks may develop across the surface or perimeter boundary of
the fill. Barriers typically are best installed during landfill
construction, as subsequent installations are often costly, less
extensive than required, and occasionally impossible to
accomplish. During construction, barriers can be placed to cover
the base and lateral surfaces of the fill space. Installation
after fill completion might be limited to trenching in the area
requiring protection and inserting a membrane into the trench,
followed by backfilling.
Gravel trenches, perimeter rubble vent stacks, gravel-filled
vent wells and combinations thereof are examples of perimeter
vent systems (see Figure 111-12). Venting systems may be either
passive (relying on naturally occurring pressure or diffusion
gradients) or active (inducing exhaust by using pumps to create a
pressure gradient), with selection being dependent on site
conditions. Passive systems can be effective in controlling
convective gas flow, but not diffusive flow. Since there are
numerous instances where passive flow controls have been
ineffective, the user should question the value of a passive
perimeter control system; nevertheless, many have been
constructed (Ref. 117).
III-171
-------
Induced flow systems, particularly those employing suitably
designed vertical wells, have proven very effective in migration
control. From a practical standpoint, systems combining both
migration control and gas recovery are finding increased favor.
These systems usually incorporate perforated pipe in grouped
vertical gravel-filled wells similar to those used in gas
recovery for fuel systems. The wells are spaced at intervals
along the margin of the landfill, located either inside the limit
of fill or outside it in the surrounding natural soils, depending
on system requirements, The wells are connected by manifolds to
a central exhaust pump which draws gas from the well field. The
gas flow influenced by each well, therefore, is directed toward
the well, effectively controlling migration. Alternatively, the
collection pipe can also be placed in a gravel-filled trench and
then connected to a vacuum exhaust system to enhance the control
ability of the trench system.
Gases collected by exhaust systems are generally disposed of
by direct stacking, incineration, or by passage through various
absorption media. Gases from passive vent systems usually are
combusted in torches. In all instances, uncombusted gas must be
exhausted at a location where it is not subject to careless
iqnition, i.e., generally in a protected enclosure or above
normal reach. Malodors associated with uncombusted gas may
dictate some form of odor control; ignition is the simplest and
most effective malodor control.
A combination of gravel-filled trench and barrier membrane
can be a very effective passive system if the control trench
depth is within the backhoe depth limit and an impermeable
barrier exists within this depth limit. In this instance, the
trench is dug and a membrane is placed across the bottom and up
the wall away from the landfill. Gravel is then used to backfill
the trench; a vent pipe may or may not be included. This fairly
common passive vent system is well suited to a landfill of
shallow depth located in an area with a high water table.
III-172
-------
(2) Fires
Fires in landfills can result from the dumping of
a hot load, sparks from vehicles, or deliberate ignition; the
latter is unlikely at a well-run landfill. Hot loads can be
minimized by proper policing of incoming trucks; these loads
should be deposited away from the working face and immediately
extinguished by water or covering with soil. Adequate daily soil
cover is essential to smother any potential fire and to provide a
natural barrier to a fire and prevent it from spreading.
Fires at landfills are infrecment; those that break out in
the fill close to the surface should be dug out and smothered.
Deep fires should be smothered by placing moist soil on the
surface and by constructing soil barriers around the fire. Where
this smothering technique fails, the material must be excavated
and smothered or quenched with water once it is brought to the
surface. Water is usually not effective unless it can be applied
directly to the burning material. As a precaution, the fire
department should always be called to the facility when a fire is
being extinguished.
(3) Bird Hazards to Aircraft
The principal method for controlling bird hazards
to aircraft is to minimize harborage and readily available food
at sanitary landfills and to locate facilities so as to reduce
the potential for collisions of aircraft and birds. Periodic
application of cover is the principal method of discouraging the
attraction of birds to disposal facilities. To determine whether
birds constitute a hazard to low-flying aircraft, a site-specific
study is needed for each disposal facility.
III-173
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(4) Access
Fencing is used to control or limit access to the
disposal facility. Permanent or portable, or both, woven and
chain link fencing is commonly used for these purposes. A gate
should be provided at the facility entrance and should be closed
and locked when the facility is unattended or otherwise closed to
users.
A prominently located sign should identify the disposal
facility, the hours of operation, fees, and any restrictions on
users or materials acceptable for delivery. It may be beneficial
to provide drop-box containers at the landfill entrance gate.
This will allow for wastes delivered by individual citizens to be
deposited properly and for keeping traffic away from the working
face of the landfill.
Uncontrolled scavenging by the public should not be allowed;
where regulations do allow controlled salvage, strict safety
practices must be followed. All salvagable materials must be
placed in containers and not allowed to accumulate at the
facility. The persons doing the salvaging should be under the
control of or employed by the landfill operator to ensure strict
compliance with rules governing the practice.
(5) Other Safety Concerns
Safety management and control techniques include
worker safety training programs, equipment selection and mainten-
ance programs, good maintenance programs, environmentally safe
disposal practices, adequate posting, and well organized public
relations programs.
Fach disposal facility should be properly investigated, and
adequate design safeguards should be incorporated to provide for
future public and environmental safety or protection.
III-174
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All employees at a disposal facility must be provided with
and instructed in the use of safety equipment as required by the
Occupational Safety and Health Act and by other regulations. All
landfill equipment should be fitted with roll-over protective
cabs that are completely enclosed to protect the employee from
accidents, inclement weather, and flying debris. The windows of
the equipment should be of safety glass or nonbreakable scratch-
resistant plastic. Normal safety precautions should be observed
while around and operating the heavy equipment. The Construction
Industry Manufacturers' Association has safety manuals available
for instructing workers in proper procedures.
Table 111-32 shows control technologies and unit costs as a
function of facility size for the safety criterion; costs are
identified for each disposal method impacted by this criterion.
b. Assumptions
The major economic impact of this criterion results
from the need to control explosive gases at landfills and to
control access at surface impoundments. The economic impact of
this criterion upon landspreading operations was considered to be
minimal.
For both landfills and surface impoundments, the economic
impact of the proposed safety criterion was determined. More and
less restrictive alternatives were considered practical only for
bird hazard controls for landfills. For surface impoundments,
fencing was considered to be the best available technology for
access control. It was assumed that to comply with the final
access criterion, fencing would be needed at 25% of all
impoundments. The more restrictive alternative for the bird
hazard alternative calls for banning waste disposal at facilities
located within a specified distance from the airports. However,
since it was assumed that the cost impacts of the bird hazard
criterion would be minimal, these costs were not calculated.
III-175
-------
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III-176
-------
Costs
Cost estimates for the effect of this criterion were
developed based on the above technologies and on unit costs for
each technology, as a function of site size. Unit costs and the
data base are presented in greater detail in Section IV and in
Appendix B.
In summary, the final regulation would result in costs for
landfills and surface impoundments ranging from $261,000 to $26.9
million per State in all States.
Table 111-33 compares annualized costs based on disposal
method and regulatory alternative.
d. Economic and Environmental Comparisons Among
Alternatives
Table 111-34 shows the economic and environmental com-
parisons among alternatives for the safety criterion (encom-
passing explosive gases, fires, bird hazards to aircraft, and
access). As noted above, the only element of the safety cri-
terion having more and less restrictive alternatives is the bird
hazard component. However, additional costs for the more
restrictive alternative were considered negligible; therefore,
the costs and environmental benefits of the three alternatives
are described as being comparable.
III-177
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IV. ECONOMIC AND ENVIRONMENTAL IMPACT
EVALUATION OF FINAL CRITERIA
Chapter III addressed each adverse effect associated with improper
solid waste disposal, discussing the merits of various regulatory
alternatives to control each adverse effect. Discussed in detail for
each adverse effect were the environmental and economic consequences of
the criteria and of selected more and less restrictive regulatory
alternatives.
This chapter evaluates the impact of the criteria as a whole,
identifying the major environmental benefits and costs on a national
basis and on various cross-sections or segments of our society.
Section A presents the Approach and Methodology of the Analysis.
Section B aggregates the national environmental benefits and costs of
the criteria, and of the major regulatory alternatives. Section C
examines each of the three disposal methods in terms of the environ-
mental and economic effects of the final regulations. Section D pre-
sents specific cases of the economic benefits of the criteria from
damages that will be avoided. Section E examines the social and
equity impacts of the criteria, i.e., how different groups in the
population are affected by the final regulation. These impact
groups include rural areas, States, regions, and specific industrial
groups. Section F presents the environmental and economic effects,
in terms of short-term and long-term considerations, as well as
irreversible and irretrievable effects. Finally, Section G discusses
the impact of the final criteria on energy use and resource recovery.
A. APPROACH AND METHODOLOGY
The first task in the preparation of the EIS was to identify all
the potential adverse effects of improper solid waste disposal and to
assess the importance of the resources being affected. Only then could
relative evaluations be made as to the environmental benefits and
IV-1
-------
importance of each criterion. Next, technologies and methods were
identified which may be utilized to comply with the criteria, and their
costs and effectiveness in reducing the adverse effects were assessed
(Chapter III).
The social and environmental impacts of solid waste disposal
practices include a wide range of concerns such as public health,
occupational health and safety, environmental damage, and maintenance
of ecological systems.
The degree to which the criteria reduce to acceptable levels or
eliminate the significant cumulative adverse environmental impacts of
the solid waste disposal practices of landfills, land spreading, and
impoundments depends on the effectiveness of criteria implementation by
the States.
Although considered in the development of the criteria, it is not
the purpose of this report to evaluate the efficiency and practicality
of the systems for enforcing the regulations (including monitoring to
determine compliance) and the probability of efficient (predictable)
facility operation. Rather, the EIS evaluates the beneficial environ-
mental effects which reasonably can be expected to occur when the
criteria are fully implemented and contrasts them with the probable
economic and social costs of the regulations.
The costs of achieving these effects will be borne directly by the
general public, disposal facility operators, public agencies at local,
State and Federal levels, industries, and other waste generators. Some
of these economic and social costs fall equally on people, while others
may be distributed inequitably to various segments of the population.
The basic analytical framework of the EIS divides the costs of
meeting the criteria into two groups, each of which is in turn divided
into two parts. The first group, shown in the upper two cells in
IV-2
-------
Figure IV-1 as (1) and (2) are cost impacts attributable to this regu-
lation. According to the final criteria, this includes impacts on or
pertaining to: Floodplains, Ground Water, Application to Land for the
Production of Food-Chain Crops, Air, Disease, Safety, and Facility
Closure. The second group, shown in the lower two cells in the figure
as (3) and (4), are cost impacts attributable to other regulations
(e.g.. Section 402 or 404 Of CWA) but referenced in this regulation.
According to the final criteria, this includes surface water (general)
and surface water (wetlands). The format is used throughout the
analysis.
FIGURE IV-1. FOUR TYPES OF COST IMPACTS
Federally
Induced Costs
Cost Impact of this
Regulation
State-Standard-
Induced Costs
Cost Impacts of Other
Regulations (NPDES-Section 402 3
of CWA, Corps of Engineer Permits,
Section 404 of CWA)
In order to identify the impacts, specific costs were attributed
to meeting all of the criteria. To avoid double-counting, specific
technologies which would achieve compliance with a combination of
criteria were assigned for cost accounting to the criteria of greatest
importance or where the technology had the greatest impact.
The methodology for economic and environmental analysis was devel-
oped with the aid of fairly complete data on the number of landfills
and State solid waste disposal regulations. There is limited data
on the number of landspreading operations and surface impoundments as
well as conditions or current impacts of all three types of land
IV-3
-------
disposal facilities. Although some industrial waste disposal facilities
may be regulated by the hazardous waste regulations of RCRA and not
by this criteria, no attempt was made to estimate how many facilities
may be so affected; therefore. Federal costs may include estimate for
some facilities that are regulated by the hazardous waste regulations of
RCRA. The availability of data is discussed in Appendices B and D.
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 and estimate unit costs
(based on site size) to meet each citerion; and
(4) Derive total control cost of closure or upgrading 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 first quarter
1978 dollars. The methodology for the cost calculations is discussed
in detail in Appendix B.
1. Landfills
The 1977 update to the 1976 Waste Age survey and subsequent State
revisions provided most of the data base necessary for the economic
impact assessment of municipal landfills. The Fred C. Hart Associates,
Inc. study entitled, "The Technology, Prevalence, and Economics of
Landfill Disposal of Solid Wastes," provided an assessment of the
numbers of on-site industrial landfills for each manufacturing industry
group.
IV-4
-------
The Waste Age survey identifies the total number of municipal
landfill disposal facilities within each State and presents two cate-
gories permitted and authorized. Since these two categories do not
sum to the total, a third category illegal facilities is deter-
mined .
This latter category is assumed to be open dumps; these require
closing under RCRA within 5 years. In other words, illegal facilities
meet none of the criteria, and consequently, costs for these facilities
reflect costs for closure.
Permitted facilities were assumed to comply with State regulations
and the facility condition was assumed to be a function of the extent
to which the State's solid waste regulations comply with the criteria.
Thus, the costs for these facilities to comply with the criteria is the
amount of upgrading needed on a criterion-by-criterion basis for the
difference between the current State regulations and the criteria.
Authorized facilities, according to the Waste Age survey, are
facilities which have applied for a permit, or are somewhere in the
permitting process. In order to maintain consistency, it was assumed
that both authorized and permitted facilities would need to upgrade to
meet the criteria. The authorized facilities are assumed to meet the
current State regulations except those for existing ground and surface
water criteria. The costs for the authorized facilities to comply is
the same as for the permitted facilities, plus any additional costs
necessary to comply with ground and surface water criteria.
All on-site industrial landfills were assumed to require upgrading
except for the disease criterion and the gas component of the safety
criteria. Only 10% of the facilities were assumed to required upgrading
for these two criteria.
IV-5
-------
2. Surface Impoundments
The surface impoundment methodology is predicated on data from
USEPA Contract No. 68-10-4342; Surface Impoundments and Their Effect
on Groundwater in the United States (Ref. 107). In addition to the
above, The Ground Water Report to Congress (Ref. 7) provided necessary
information.
Due to the limited data on the location, size, and condition of
impoundments, facilities were grouped into three categories based upon
the type of impoundment municipal, industrial, and agricultural.
The impoundments in each of these groups were placed in either 2.5 acre
or 50 acre size categories. Five percent of the industrial impound-
ments were considered to be fifty acres; all other impoundments were
considered to be 2.5 acres. Therefore, cost impacts for each impound-
ment group are a function of the number of impoundments within each
odtegory, and the size mix of the impoundments within each group.
Although there can be a continuum of facility sizes, they tend to
fall into either a "large" or "small" category. For the cost assess-
ment of the manufacturing industries, two questions remained before
upgrading or closure costs could be estimated.
o The distribution of impoundments into the two size
categories; and
o The distribution of the two size categories by SIC code.
The first question was answered with an assumption, based on best
engineering judgment, that 95% of the facilities were of the smaller
size and 5% were of the larger size. The second question was answered
with an assumption that this 95/5 split was the same in all SIC codes.
IV-6
-------
All criteria were analyzed to determine their economic impact upon
this disposal practice. However, only the land application criteria
were considered to have the potential to significantly impact land-
spreading practices. See Appendix B for a more detailed explanation.
B. ENVIRONMENTAL EFFECTS AND COST IMPACTS: SUMMARY OF ALTERNATIVES
1. Major Environmental Benefits
The general effects of the criteria will be threefold:
(a) Many existing facilities (such as landfills, land-
spreading operations, and surface impoundments) will
close or be forced to close;
(b) Many other existing facilities will upgrade their
operations in conformance with a State compliance
schedule and will reduce to acceptable levels or
eliminate the adverse environmental effects of their
operations; and
(c) New and expanded solid waste disposal facilities, re-
sulting from previous closures/consolidations and new
demands, will be designed and operated in such a way
as to ensure a reasonable probability of health, safety,
and environmental quality.
In some cases where existing facilities are closed or upgraded,
the adverse environmental effects of past operations may continue for
some time into the future. These adverse environmental conditions
include those caused by (1) location in floodplains, (2) leachate and
IV-8
-------
The ground water criteria were identified as having the greatest
potential impact on surface impoundments based on observation that
most impoundments are unlined and leak part of their contents downward
into the soil.(Ref. 107). A total of 50% of the impoundment facilities
were assumed to require maximum upgrading. Fifty percent also required
ground-water monitoring. Five percent were assumed to require closure.
These assumptions were based on an analysis of the industry assessments
presented in Appendix C. A more detailed discussion of the cost
methodology and assumptions is presented in Appendix B.
3. Landspreading
The landspreading methodology was derived from the following
sources:
(1) An EPA survey of sludge disposal practices of over
350 POTW's, as presented in an appendix to this report.
(2) Ground Water Report to Congress (Ref. 7).
(3) Consultation with major cities and EPA regional offices.
(4) Construction grant design and planning report.
(5) Other research reports and published articles.
Initially, information regarding industrial groups and municipal
wastes were examined to determine the effects of the criteria on land-
spreading; however, available data would allow a detailed cost asssess-
ment of the impact of the criteria on landspreading of municipal waste-
water treatment sludges only.
IV-7
-------
gas generation and migration, or (3) heavy metal application to land.
The adverse effects of improper disposal may take some time to elimi-
nate because of the prohibitively high corrective and retrofit costs
and technological infeasibility or uncertainty associated with closing
or upgrading an existing facility. Herein lies the major economic
benefit of the criteria avoidance of damages (including corrective
and retrofit costs). Unfortunately, this economic benefit is not
readily quantifiable; this is discussed further in Section D.
Specific environmental benefits resulting from the proposed cri-
teria were discussed in detail in Chapter III of this report; these are
summarized by criterion for landfills, landspreading, and surface
impoundments in Table IV-1,
2. State-Standard-Induced and Federally Induced Costs
To arrive at costs induced by State Standards, a methodology was
developed for each type of disposal method. For landfills. State-
standard-induced costs were based on three considerations: the number
of "permitted" and "authorized" facilities within each State (Ref. 76),
the number
-------
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-------
regulations. Conversely, if the State regulation did not meet the
Federal criteria, then upgrading and closure costs were considered
Federally induced.
For landspreading. State-standard-induced costs were assumed to be
10% of the total projected cost of the regulation, since landspreading
costs could not be calculated on a State-by-State basis.
In summary, the combined annualized cost for all three disposal
methods is $5017.0 million of which $1331.0 million (27%) are Federally
induced costs and $3686.0 million)73%)are State-standard-induced costs.
Other Federal regulations, specifically those promulgated under the
Clean Water Act, cause an additional combined cost of $352.7 million.
Of this, $179.4 million are Federally induced, and $173.3 million are
State-standard-induced. Table IV-2 shows Federally and State-standard-
induced costs for landspreading, landfills, and surface impoundments.
TABLE IV-2
STATE-STANDARD-INDUCED VS. FEDERALLY INDUCED ANNUALIZED COSTS
FOR LANDSPREADING, LANDFILLS, AND SURFACE IMPOUNDMENTS
(criteria)
(millions of dollars)
Surface Other Fed.
Annualized Costs Landspreading* Landfills Impoundments Total**Regulations
Federally Induced
State-Standard-
Induced
Combined
6.2/ 9.4
.7/ 1.1
6.9/10.5
669.8
1764.6
2434.4
655.0
1920.7
2575. 7
1331.0
3686.0
5017.0
179.4
173.3
352.7
* Cost without alternate disposal/cost with alternate disposal
** Total does not include alternate disposal for landspreading
IV-13
-------
3. Major Cost Factors
The major combined costs of the criteria derive from three in-
dividual cirteria (floodplains, ground water, and safety). To meet the
floodplains criteria, a total annualized cost of $417.0 million will be
incurred; these costs include closure costs for surface impoundments
and landfills which would not be able to provide adequate floodplains
control. In order to meet the ground water criteria, a total annuali-
zed cost of $4067.7 million will be incurred. Safety considerations
involve an annualized cost of $306.7 million, a significant portion of
which can be attributed to the lack of State legislation for control of
toxic and asphyxiating gases at landfill facilities. Table 1-3 in
Chapter I summarizes the annualized combined costs for each criterion.
For surface impoundments, the cost of closure involved pumping out
the impoundment and covering it with soil. Closure costs for surface
impoundments are attributable to individual criteria, unlike landfills,
for which all illegal sites were closed. For this reason, the concept
of surface impoundment closure is not a separate cost element as it is
for landfills. Therefore, closure costs do not appear as a separate
cost element in tables presenting data for surface impoundments.
Table IV-3 shows combined upgrading and closure costs by State for
landfills, surface impoundments, and landspreading.
4. Comparison of Alternatives
In Chapter III the environmental benefits and economic costs of
the final, more restrictive and less restrictive alternatives were
discussed for each criteria.
The major environmental benefits of the criteria were summarized
in Table IV-1. Foremost among these benefits are protection of:
- floodplains from major water quality impacts during
floodings;
IV-14
-------
TABLE IV-3
DISPOSAL METHOD COST SUMMATION
UPGRADE & CLOSURE (FINAL CRITERIA)
(THOUSAND DOLLARS)
IV-15
-------
ground water and surface water by minimizing or preventing
leachate damage;
food-chain crops by minimizing the plant uptake of cadmium;
reduced exposure to pathogens and PCB's;
- the public and environment from hazardous effects of explo-
sive gas.
These significant environmental benefits would be sacrificed if
less restrictive alternatives were selected. As a result, existing
adverse effects enumerated in Chapter III would not be adequately
addressed. Thus, the less restrictive alternatives would not provide
comprehensive protection of floodplains; in addition, a less restric-
tive approach does not offer regulatory controls to minimize or prevent
off-site degradation of ground water and contamination of food-chain
crops. Consequently, even though the implementation of less restric-
tive alternatives for all the criteria would result in an annual sav-
ings of $4007.4 million over the final criteria, the resulting adverse
environmental impact would be so substantial as to offset any savings.
As discussed in Chapter II, the House of Representatives' Committee on
Interstate and Foreign Commerce in Report 94-1491 determined that
legislation regulating land disposal of wastes is necessary if other
environmental laws (such as those governing air and water) are to be
both cost and environmentally effective.
As indicated in the summary economic and environmental impact
analyses in Chapter III, the environmental benefits of the more re-
strictive alternatives are quite similar to the benefits offered by the
final criteria, with the possible exception of the criteria for the
application to land used for the production of food-chain crops. For
example, the banning of solid waste disposal in floodplains and wet-
lands (the most restrictive alternative) would result in less risk of
IV-16
-------
damage potential than that offered by the final criteria. On the other
hand, the final criteria provide essentially the same environmental
benefit as the more restrictive alternatives, by protecting almost all
productive wetlands, protecting ground and surface water from con-
tamination due to flooding; and reducing the potential for flood haz-
ard. In effect, the final regulations governing disposal of solid
wastes in floodplains and wetland areas provide significant environ-
mental protection without resorting to an outright ban.
In terms of aggregate costs, more restrictive alternatives would
cost $2937.7 million more than the final, in spite of the minimal
additional environmental benefit offered by the more restrictive
approach. The major cost differential results from the groundwater
criteria; the more restrictive alternative for ground water would add
$2608.8 million (a 64% increase) annually to the cost of the final
ground-water criteria. The additional environmental benefit of the
more restrictive over the final is the protection of ground water re-
gardless of current ground-water quality or rates of infiltration, re-
sulting in the protection of all ground water regardless of present or
future use.
With respect to the criteria for land application to food-chain
crops, implementing the most restrictive regulatory alternative, and
including the cost of alternate disposal, would add $18.4 million
annually. Since the most restrictive alternative would result in
effectively banning land application of solid wastes to food-chain
crops, the environmental benefit of the most restrictive alternative
would offer maximum protection for humans and animals. However, cur-
rent EPA data indicate that a ban on land application of solid waste is
unnecessarily restrictive, whereas controlled application is benefi-
cial. In addition, as discussed in Chapter III, such a stringent
regulatory approach would impact severely on many small communities.
IV-17
-------
In summary, the final criteria developed by EPA address the key
environmental issues of concern in the disposal of solid wastes to
land, providing substantial protection of the environment.
C. ENVIRONMENTAL EFFECTS AND COST IMPACTS SUMMARY OF THE CRITERIA
1. Landfill Disposal
a. Data Base
The land fill data base was developed using the Waste Age
Survey and State revisions. (Ref. 76). The survey provides, on a
State-by-State basis, the numbers of permitted and authorized facili-
ties within each State and a breakdown of these facilities by tonnage
received per day (TPD). Additionally, the number of on-site industrial
landfills, by size, was obtained from the Fred C. Hart Associates, Inc.
study, "The Technology, Prevalence, and Economics of Landfill Disposal
of Solid Wastes" (Ref. 41).
Table IV-4 presents assumptions on landfill status and size de-
reived from the survey.
Since no detailed data exist to establish the location and con-
dition of these facilities, several assumptions were made:
Location* - Information is available (Ref. 7) to estab-
lish the percentage of land within each State classi-
fied as floodplain or wetland. An assumption was made
that the number of landfills by size and type within
floodplains or wetlands is a function of the percentage
of the population within each State classified as
floodplain or wetland. Thus, if 10% of the population
within a State was classified as residing in a flood-
plain or wetland then 10% of the 0-50 TPD, 50-200 TPD.
* To avoid double-counting wetlands and floodplains, a figure for the
total number of square miles or wetlands and half of the total number
of square miles of floodplains was used. See Appendix B.
IV-18
-------
TABLE IV-4
LANDFILL DATA BASE*
'1A
..-
<-',:,. ?A!
F~ iI'-iD i^T'i-jRI^EL . i^uA^,
,: o 3
25 L25 "3
1.4 r i
, ..^, D 2vi
:
f 1..50 i
-
-1C1)
os: ;
:o ~PD 100 r1"! 300 TPD
1,232 55 10
-.2L 2 !
591 i: 6
923 52 11
:%-
: -h.lnaj^^c.'l
-0.-J20 5.41J
-.710 1,225
3,910 2,317
17.730 -,610
39 ! -2,690
L2 1 29.+50
I .427
3,591
335
2,168
15,361
2,223
3,358
IV-19
-------
Table IV-4 (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.
Maryland
Waste Age data not updated since State requires written requests
for information on waste disposal facilities and time constraints
precluded this.
IV-20
-------
Table IV-4 (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.
IV-21
-------
and greater than 200 TPD (permitted, authorized, and il-
legal) facilities were considered to be located in a
floodplain or wetland.
Condition - An assessment of the condition of the
facilities was based upon the type of facility and
State regulations. Permitted facility conditions were
assumed to be in compliance with the State regulations.
All authorized facilities were assumed to need controls
for ground and surface water. Illegal facilities were
assumed to be so environmentally unsound that the most
practicable solution was closure.
Appendix B presents a detailed explaination of the methodology
and assumptions concerning location and condition of landfills.
b. Major Environmental Benefits
For landfills, the significant environmental benefits of the
criteria include:
- Protection of floodplains from major water quality im-
pacts during flooding.
- Protection of endangered and threatened species from
harmful impacts.
Protection of principal or sole source drinking water
aquifers.
Protection of the nation's wetlands, rivers, streams,
and lakes from bacterial and chemical contamination.
Reduction in air pollution caused by open burning.
- Reduction in safety hazards (explosive gases, fires,
bird hazards to aircraft, and injuries due to improper
access.
Protection of public health.
IV-2 2
-------
c. Unit Prices for Each Criterion
Costs for each criterion were based upon a hypothetical
scenario of an "average existing condition" and an "average compliance
technology." In other words, for each facility size, asssumptions were
made regarding; (1) average current operation and maintenance;
(2) the physical dimensions, properties, and other characteristics of
the facility; and (3) the technology required to upgrade, and to de-
velop unit costs. Appendix B presents a more detailed description of
these assumptions of average conditions and average technologies.
Unit costs also assumed that the life of an average landfill was
10 years. The detailed economic methodology can also be found in
Appendix B.
Table IV-5 summarizes the landfill cost for all of the criteria
and facility sizes.
d. State-Standard-Induced vs. Federally Induced vs.
Combined Costs
State costs were developed according to the methodology
briefly described earlier for upgrading and closure. Table IV-6 sum-
marizes State-standard induced costs for landfills.
IV-2 3
-------
TABLE IV-5
LANDFILL TECHNOLOGY COSTS PER FACILITY BY FACILITY SIZE
(IN FIRST QUARTER 1978 DOLLARS)
Criteria
Floodplains
Surface Water
-NFS Controls
-Wetlands
Ground Water
Min. Technology
-Max. Technology
Disease
Air
Safety
-Gas Controls
-Fire
-Access
Facility Capital Costs 0 & M
Size (Materials, Machines, Labor) Costs
10
100
300
10
100
300
10
100
300
10
100
300
10
100
300
10
100
300
10
100
300
10
100
300
10
100
300
10
100
300
63,000
138,600
227,000
10,500
37,900
91,200
63,000
138,600
227,000
3,000
4,000
7,000
110,900
493,300
1,301,500
0
0
0
9,900
46,200
123,900
41,800
90,600
111,400
1,000
2,000
10,000
3,000
6,600
10,800
0
0
0
0
0
0
0
0
0
2,100
2,800
4,900
26,700
48,800
66,500
2,600
13,000
26,000
0
0
0
4,400
9,600
12,000
100
500
1,000
0
0
0
Annualized
Costs
10,300
22,600
37,000
1,700
6,200
14,800
10,300
22,600
37,000
4,700
6,300
10,900
42,200
125,700
272,600
2,600
13,000
26,000
1,600
7,500
20,200
11,600
25,100
31,400
300
800
2,600
500
1,100
1,700
IV-24
-------
TABLE IV-6
STATE-STANDARD-INDUCED VS. FEDERALLY INDUCED
ANNUALIZED LANDFILL COSTS
(millions of dollars)
Annualized Costs
Upgrade
Close
Total
Other Federal
Regulations
State-Standard-
Induced
1764.6 N.A.
1764.6
165.0
Federally Induced
Combined
597.5 72.3
2362.1 72.3
669.8
2434.4
67.8
232.8
Tables IV-7, IV-8, and IV-9 present a detailed examination of the
combined economic impact on landfills of the final regulations by cri-
terion and by State for all landfills, for municipal landfills only,
and for on-site industrial landfills only.
e. Major Cost Factors
The greatest cost factors for landfills are the ground water
criteria, followed by the safety criteria, which are large due to the
lack of regulation of toxic and explosive gases at the State level.
Other Federal regulations, specifically those governing the discharge
of point and non-point source pollutants to surface waters, account
for the third highest cost impact (these costs are not attributed to
the criteria, but to other Federal Regulations.) For the ground water
criteria, 83% of the costs are State-standard-induced. This is due to
several factors: (1) the fact that most States have a ground water
regulation; (2) the assumption that authorized sites do not comply
IV-25
-------
TABLE IV-7
COMBINED ECONOMIC IMPACT OF PROPOSED REGULATIONS FOR EACH STATE AND
CRITERION: ALL LANDFILLS
(THOUSAND DOLLARS)
STATt
ALASKA
ARIZONA
AKXANSAS
CM I FORD I A
COLORADO
DELAWARE
FLORIDA
GEORGIA
HAWAII
IDAHO
KANSAS
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MISSISSIPPI
MISSOURI
MONTANA
NLBRASKA
NEVADA
[JEW HAMPSHIRE
NEW MEXICO
NORTH CAROLINA
OHIO
OKLAHOMA
OPECON
KHOW, ISLAND
SOUTH CAKOIItM
SOUTH DAKOTA
TENNESSEE
TtXAS
UTAH
VI RMUN1
W^IIGIHTON
WI ST VIRrlNIA
UfOMIHC
li'UI,
rLoonri ,\i M )
950
941
6,575
8. 79-1
983
189
7,377
5,230
231
1,012
8,069
4, 308
2,659
6,804
2 , 7 >t 4
985
6,153
4,158
1,578
972
1,639
381
772
2,275
...»
5,42?
1,748
1,716
5,062
752
3,819
489
2,986
9,037
1, 768
657
1,950
1,905
1,303
967
162,029
sum
GEKCKAl
348
1, 168
1, 111
15,681
1,291
314
4, 376
3,377
322
639
7,812
4*970
2,206
1,879
1,072
1,290
9,028
1, 312
2.5B9
535
1,547
200
535
924
3,385
7,721
1,291
1,865
7,962
1,126
1,486
234
2,994
7,507
698
339
1,828
3,204
718
254
1 50, S52
\ct WAU'R
WLUANDb
1,872
290
3,156
3.S26
516
132
8,407
3,687
178
374
573
5,206
639
388
'
1,495
850
311
773
113
190
420
3,148
2,060
596
857
1,939
370
2,372
899
959
3,676
1, 368
108
720
853
401
119
81 ,965
101AL
2,220
1,458
4 ,267
19,507
1,807
456
12,783
7,064
500
1,013
2, 779
7 ,085
1,711
1,678
2,808
846
2,321
312
725
1,345
6,534
9, 782
1.887
2,723
9,901
1,496
3, 858
1, 133
3,953
11,183
2,006
447
1 , 5 4 9
4.05T
373
332,817
WAPHK
6,743
1,364
19,027
17,649
2 ,402
4,334
76,308
53,798
5 ,630
1,099
2,762
29,399
17,047
18,610
20,959
977
3,418
518
7,684
1,151
52,374
110,356
2,887
27,233
112,807
16,279
24,045
1,046
40.690
14,865
3, 122
6, 264
26, 321
43,311
10,303
324
1 , 770, ?90
AIR
119
756
1,047
13,925
1,026
355
3,575
2,723
436
1,114
1,863
1,088
1,217
4.C15
978
324
615
148
504
692
3,390
9,175
1.218
1 ,758
7.029
1 ,061
1,400
] 88
1,991
5,610
305
1,657
1 ,966
661
1 35
J 26, '.SO
RISFASE
19
123
170
2,264
167
33
581
443
39
71
210
181
222
113
198
653
159
52
99
24
81
55
518
1 ,175
198
286
1,143
173
228
31
3M
912
78
50
269
320
107
22
19, H05
SAFFTY
3,179
2,898
2,624
16,984
4,066
243
4,356
8,656
921
2,153
6,507
3, 793
3,629
1,483
7,158
3,033
2,850
6,529
439
616
7,353
4,036
8,615
14,036
4 , 773
5,462
13,420
1,296
6,240
825
5,710
6,838
1,615
1,159
5 ,729
2 ,398
2 ,017
1.7*6
2")3,3S3
nosunr
418
0
995
0
0
0
0
853
1,086
5,127
0 "
1.702
1,013
290
J ,005
455
876
268
0
0
992
0
2,624
0
618
0
52
931
397
95
2, 778
192
0
2 ,803
326
337
1 ,248
2 ,970
! 74
72,340
IV-26
-------
COMBINED ECONOMIC IMPACT OF PROPOSED REGULATIONS FOR EACH STATE AND CRITERION:
MUNICIPAL LANDFILLS
(THOUSAND DOLLARS)
STATE
ALABAMA
ALASKA
ARIZONA
ARKANSAS
C «,IK>RN I A
COLORADO
CONNECTICUT
DELAWARE
I LORI DA
GEORGIA
HAWAII
IDUiO
ILLINOIS
INDIANA
IOWA
KANSAS
UN TUCK Y
OUISIANA
MAINE
MARYLAND
"JESACHUStTTS
MICHIGAN
MINNESOTA
MISSISSIPPI
HISSOJRI
-iONTANA
NLBRASKA
NLVADA
NEW HAMPSHIRE
NLW JERSEY
HtW Mi. XI CO
NEW YORK
NORTH CAROIINA
NORTH DAKOTA
OHIO
01 I.A1IOHA
mi CON
W1NSYIVMIIA
RHODE 1 51 AMU
SOUTH CAROIINA
SOinil IW01A
UNNLSSLL
TJ-XAS
UlAh
"HWH
VIIMN1A
U^HIHt I»H
M 1 VIHI ISIA
Ivl'id I',T 1
wxi-i-t
1 ,' 1 Al
FLOODl'LAINS
724
790
248
2,819
302
134
123
50
657
1,378
39
516
1,885
550
3, 103
1,052
5,846
3.241
1 , 324
42
560
1,771
900
1,027
97
404
382
75
217
475
1,731
1.001
0
257
6118
49.
10
346
69
I ,2V,
374
I ,524
1 ,122
23H
504
MS
6()S
2.414
,,n
4ri.7>1l
(1NERAL
0
222
366
0
913
202
324
101
587
488
65
176
0
181
3.600
1,025
0
434
335
0
459
1,498
372
275
0
19,,
895
43
0
85
564
1,061
0
32
59
0
0
50<>
0
0
34
882
i. *'>')
I8f>
15
72
1.119
17
2.'>3n
111
!\ d42
Wl HANDS
212
1,556
76
1.523
132
144
117
29
1,524
663
52
191
626
177
1,007
22?
1,597
2.480
289
16
245
1,422
763
481
120
171
442
22
53
14
320
3B8
636
507
?31
168
185
212
34
80'.
7(1?
199
1,025
edfl
39
!H6
277
212
1 ,4 (8
/!<
'""
TOTAL
212
1.778
443
1,523
1,045
346
441
131
2,111
1,151
117
367
626
358
4,606
1,252
1,597
2,913
625
16
705
2,9?0
1.134
756
120
363
1 .338
65
53
99
883
1.404
636
519
290
168
185
71H
34
flO'i
/J6
1 ,()81
3,585
\ , 05 r>
5'i
2i«
1 ,1 16
,,
'..Obi
GROUND WATER
0
4.285
393
0
807
707
8,226
1,180
8,436
7,111
1,796
263
0
11,280
47,202
1,183
0
3,288
6,107
0
5,712
16,986
5,195
4,362
0
J41
1,907
106
0
973
694
11,858
0
1,585
f,3ft
938
0
G.152
0
0
145
9,H74
2,780
842
1,642
90'.
13,27)
211
'5.707
I3fl
AIR
0
0
0
G
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o
0
0
0
0
0
0
0
u
0
0
fUSMSh
0
0
0
0
0
o
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
SAIITY
2,657
3.035
1 ,976
1,345
0
2,813
0
0
0
5,333
625
1,620
6,933
0
17,815
5,149
1 ,875
2,132
2,782
0
2,257
11,141
0
1,840
0
Z.4S5
5,799
259
0
238
3,621
11,2^1
4,7.,,
1,225
5,223
3,2,18
3,316
4,842
0
4.294
i>«.
3 , 'HI
0
981
7 -if,
j.y.a
0
1 290
0
,.V,I
63
418
0
995
0
0
0
0
0
853
60
1,086
6,360
563
5,127
0
23,940
1,702
1,013
290
3,005
6,159
1,630
454
876
268
0
0
992
0
2,624
0
0
318
u 18
0
52
931
397
95
;.77R
1 j,9fi6
0
2,803
1,",
317
I ,2-8
2.-X.9
(04
II.
7..,,,.
IV-2 7
-------
TABLE IV-9
COMBINED ECONOMIC IMPACT OF PROPOSED REGULATIONS FOR EACH STATE AIID CRITERIA',
INDUSTRIAL LANDFILLS
(THOUSAND DOLLARS)
IV-28
-------
with State ground water regulations; (3) the large number of authori-
zed municipal sites; (4) the assumption that 50% of all on-sit3 indus-
trial landfills would be upgraded in net infiltration areas (100% in
wetlands); and (5) the large number of on-site industrial landfills.
Considering only municipal lanlfills however, the ground-water criter-
ia still cause the highest cost burden to be incurred and State-
standard-induced costs remain the highest at 59 percent of the total
ground-water compliance cost.
2. Surface Impoundments
a. Data Base
The surface impoundment data base was derived from an EPA
report (Ref. 107) which provided an estimate of the number of impound-
ment sites in each State. These numbers were made available to solid
waste agencies in each State by their respective EPA regional offices
for verification or revision. Due to the limited data on the location,
size, and condition of surface impoundments, assumptions had to be
made concerning these factors. Impoundment sites, as reported by the
EPA report (Ref. 107) and State revisions, were considered to consist
of between two and three actual impoundments. Impoundments rfere
grouped according to type municipal, industrial, or agricultural
and each group was analyzed for appropriate site size categories. All
impoundments were considered to be 2.5 acres, with the exception of
five percent of the industrial impoundments, which were considered to
be 50 acres. For a detailed discussion of these assumptions, see
(Appendix B).
Table IV-10 presents the data base and cost summary for surface
impoundments.
IV-2 9
-------
TABLE IV-10
DATA BASE & COST SUMMATION: SURFACE IMPOUNDMENTS
(CLOSURE AND UPGRADING)
STATE
ALABAMA
ALASKA
ARIZONA
CALIFORNIA
COI ORADO
CONNECTICUT
DELAWARE
FLORIDA
CbOR&IA
HAWAII
IDAHO
ILI INOIS
INDIANA
IOWA
KANSAS
KFNTUCKY
LOUISIANA
MAINE
MAi'.YLAN D
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
OHIO
OK1.AHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
'iOIJTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
Ui-.KHONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
TOTAL
DATA BASF.
875 638 1,250
15 273 37
94 91 202
450 1,515 268
1,935 2,013 2,618
343 11.800 613
500 1.000 37
43 133 33
3,550 800 1,000
488 513 1,835
19 111 170
190 60 1,135
1,800 4,400 230
458 2,773 2,668
643 525 1,750
640 11,722 2,658
1,698 6,922 0
203 23,482 808
333 667 437
133 802 278
100 200 25
355 5,622 1,730
588 122 2,963
1,500 750 1.050
830 547 2,660
400 162 790
558 4,982 1,758
26 144 61
250 125 18
23 575 33
40 16,100 50
83 1,433 510
875 875 2,515
220 31,151 1,245
1,100 3,750 650
260 220 1,318
51 14 , 180 354
12 67 50
593 882 593
720 113 880
145 838 848
948 17,605 1,288
95 9C2 585
200 9 38 113
225 3,773 373
228 638 1,680
1 018 3,750 87
553 258 1,495
160 12,682 55
27,188 198.624 45,755
2,763
325
387
6,566
12,756
1,537
209
5,350
2,836
300
1,385
6,430
5.S99
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
398
631
16,190
2,026
4,265
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.B97
271,567
rn<;T iTTMMATTnM /THnncmm nni t
6,269 6,902 8,954
126 3,604 320
595 ,908 1,284
11,900 19,105 16.100
2,179 115,207 3,902
3,075 9,474 228
274 1,368 215
29,402 10,025 8,285
3,576 5,715 13,454
1,253 603 7,492
11,345 42,579 1,4*9
2,908 26,971 16,93'
4,092 5,096 11,136
4,288 119,129 17,81
11,118 69,088
17,837 309,314 7, JO
2,405 7,253 3,15
834 7,744 1.74
616 1,876 156
2,248 54,964 10,974
4,286 1,336 21,619
12,558 9,268 8,793
2,794 1,724 5,520
3,769 51,272 11,874
186 1,585 449
1,617 1,197 117
141 5,472 20
272 165,200 336
509 13,596 3,132
6,238 9,451 17,937
1,361 296,244 7,686
7,126 37,092 4,211
1,683 2,205 8,524
314 134,717 2,187
76 600 308
4,488 10,102 4,488
4,885 1,220 5,973
960 8,412 5,594
6,416 181,153 8,716
685 10,587 4,228
1,318 9,406 744
1,430 36,784 6,185
1,410 6,067 10,420
6,478 36,495 556
3,709 2,618 9,935
1,172 138,257 404
190,321 2,074,101 311,306
'
22,134
4,051
2,791
47.110
121,283
12,776
1,848
47,707
22.745
2,332
9,350
55,373
46,802
20,320
141,233
80,211
318,193
12,817
10,325
2,653
68,187
17,241
30.620
10.048
66,904
2,221
2,920
5,808
165,808
17,230
33.627
305,291
48,424
12,412
137,221
993
19,077
12,078
14,965
196,283
15.500
11,462
44,394
17,891
43,530
12,261
139, 8?8
2,575,665
OTHLH
991
638
67
1.143
3,419
284
85
6,558
2_,007
95
359
1,280
1,151
526
3,366
1,947
36,621
493
26i
55
2,737
2,57iJ
2.2U
75J
380
2,78i>
10-t
6)
12<.
3,58 '
35'!
2.15
6,17,
1.36J
44'.
2 , 67*1
24
1.56'
1,126
465
6,91*
1,190
20
-------
TABLE iv-10 (cont.)
*SURFACE IMPOUNDMENTS - STATE QUALIFICATIONS TO DATA BASE
Georgia
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
IV-30a
-------
-------
b. Ma-jor Environmental Benefits
For surface impoundments, the significant environmental ben-
efits of the criteria include:
Reduction of impacts in low-lying industrial areas, en-
suring that new facilities will be permitted in flood-
plains only if they do not endanger the environment.
Elimination of adverse water quality effects of flood-
ing, especially in areas of high net precipitation.
Reduction of potential harmful impacts on endangered
and threatened species.
- Protection of principal drinking water supplies.
- Reduction in air pollution caused by gaseous emissions.
Control of toxic gases.
- Reduction in injuries due to improper access.
c. Costs For Each Criterion
Costs for surface impoundments were based upon the average
facility sizes described in the previous section. Only three criteria
were judged to have the potential for the greatest economic impact
ground water, floodplains, the wetlands component of the surface water
criteria, and the access requirement of the safety criteria. Appendix
B presents a more detailed description of the cost methodology.
Costs are based on the assumption that an average surface impound-
ment would last 10 years. Table IV-11 presents costs by each criteria
area and type of impoundment.
IV-31
-------
TABLE IV-11
SURFACE IMPOUNDMENT TECHNOLOGY COSTS PER IMPOUNDMENT
BY CRITERION
(Annualized;Millions of First Quarter 1978 Dollars)
Criterion
2.5 Acre Impoundment 50 Acre Impoundment
Upgrade/Close Upgrade/Close
Floodplains* $6,000/9,000
Ground Water*
- Minimum technology 4,700/N.A.
- Maximum technology 5,700/9,000
Safety* 300/0
Other Federal Regulations** 6,000/9,000
*Includes closure costs.
Cost for access control
+Cost for wetlands component of the surface water criterion.
$25,917/180,000
10,900/N.A.
113,300/180,000
1,467/0
25,917/180,000
(d) State-Standard-Induced vs. Federally Induced vs.
Combined Costs
Cost categories were developed based on the status of cur-
rent disposal practices and on whether the final criteria are more
stringent than current State standards. If the State standards were
at least as stringent as the Federal criteria, the costs to upgrade
current practices were attributed to the State standards. Table IV-12
shows that out of a combined cost of $2575.6 million, $1920.7 million,
or 75%, are State-standard-induced costs, and $654.9 million, or 25%,
are Federally induced. Other Federal regulations, specifically the
wetlands component of the surface water criteria, add an additional
$199.9 million 93% of which if Federally induced.
IV-3 2
-------
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-------
Tables IV-13, IV-14, IV-15, and IV-16 show total annualized costs
for surface impoundments resulting from the final criteria for flood-
plains,ground water, safety and other Federal regulations,respectively.
e. Major Cost Factors
The major cost factors for surface impoundments are as fol-
lows :
- Industrial surface impoundments incur the greatest cost
impact, because of their prevalence and their number of
larger impoundments.
The ground water criteria will cause the greatest im-
pact for each surface impoundment group.
- Closure costs are mainly attributable to the criteria.
3. Landspreading
a. Data Base
The data sources used for calculating the impact of the cri-
teria on landspreading practices included:
EPA survey of sludge disposal practices of over 350 POTWs,
as presented in an Appendix to this report.
EPA technical publications
Interviews with major cities and EPA regional offices
Research publications.
Initially, information regarding municipal waste treatment plants
and industrial groups was examined. Of all industrial groups sur-
veyed, seven were thought to have wastes which could feasibly be land-
spread: pulp and paper, Pharmaceuticals, tanneries, feedlots, food
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 DiseaseSewage Sludge and Septic
Tank Pumpings (under Section 257.3-5 and 257.3-6(b), respectively)
are of an interim final status.
-------
TABLE IV-13
TOTAL ANNUALIZED COSTS FOR SURFACE IMPOUNDMENTS:
KLOODPLAIMS
(THOUSAND DOLLARS)
TV-35
-------
TABLE IV-U
TOTAL ANNUALIZED COSTS FOR SURFACE IMPOUNDMENTS (THOUSAND DOLLARS):
GROUNDWATER
XLA3A.MA
\LASKA
SOUTH DAKOTA
TENNESSEE
TEXAS
'.TAH
IV-36
-------
TABLE IV-15
TOTAL ANNUALIZED COSTS FOR SURFACE IMPOUNDMENTS (THOUSAND DOLLARS):
SAFF.TY
STATE
\LABAMA
ALASiCA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
FLORIDA
GEORGIA
HAWAII
IDAriO
ILLINOIS
INDIANA
IOWA
22
19
31
56
i ,456
173
333
593
2,913
49 1 i69
99
27
14
66
64
97
44
3
73
126
7
112
;,432
138
1,307
11
168
130
150
1,752
138
108
429
200
420
177
1 ,157
23,347
FEDERAL STATE
21"
-
31
29
-
190
-
-
-
V-\
1,134
130
13
413
-
220
:4
-
-
-
-
105
5u8
-84
227
1,302
1 750
2,189
-
-
118
103
-
-
-
-
-
27 '
662
277
259
311
- i
i 622
| 19
-
56
_
-
-
-
-
3i
-
1 ,-.56
173
333
593
2,913
j 4b9
138
! 1.307
-
-
-
-
_
138
_
429
-
-.:o
-
-
3,504
11
168
130
150
1,752
108
200
-
r?
1,157
19,343
TV-17
-------
TABLE IV-16
TOTAL ANNUALIZED COSTS FOR SURFACE IMPOUNDMENTS (THOUSAND DOLLARS):
WETLANDS
STATE
ALABAMA
UASKA
ARIZONA
ARKANS AS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
T-ORIDA
GEORGIA
rfAWAI :
IDAHO
ILLINOIS
INDICIA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
'<:rN£SOTrt
y:53ISSI?°I
MI 5 SO', R I
10 VTA:, A
NEBRASKA
NEVADA
MEW HAMPSHIRE
NEW JERSEY
\-EW MEXICO
NEW YC=L<
',ORTH CAROLINA
'IORr-i DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA.
TENNESSEE
TEXAS
ITAH
VERMONT
VIRGINIA
JASHI\GTON
JEST VIRGINIA
WISCONSIN
'JTOMI *.'G
TOTAL
^f.'IcrPAL
396
24
L6
"30
lift
75
33
i:
4,213
331
3
308
INDUSTRIAL
270
551
16
1,767
398
3,205
197
61
1.U1
-.17
36
16
933
33 ; 598
L10
132
323
2ig
103
24
16
107
406
959
15-*
107
i35
3
-.3
^
3
12
422
746
36
237
63
3
4
406
-,66
36
276
59
23
43
39
178
233
32
:2,-t90
108
2,735
1,619
35,378
262
iGaiCULTYTAL
+ 22
63
36
256
-,2ft
138
3
12
1,187
1,255
55
292
39
-73
>o«
309
0
994
134
135 i 51
32
2,101
100
332
116
61
2,021
73
20
529
2,059
671
->89
209
534
116 4
3,571 3
266
510
7,210
5,942
984
69
2,615
12
1,219
1,521
i93
142
312
55
3
748 406
92
223
5*i3
197
6,263 375
776
165
903
132
799
124
2,d73
39,402
375
16
193
30"
16
623
12
[7,950
TOTAL
991
b38
67
2,453
1.141
3,419
234
35
6,553
2,007
95
359
1,280
1,151
526
3,366
1,947
36,621
498
264
55
2,737
2,570
2,212
759
380
2,786
104
63
124
3,587
352
:,i5i
9,583
6,171
1,363
444
2,678
24
1,564
1,126
465
6,914
1,190
209
1 ,140
475
996
980
2,912
119,866
^DERAL
991
638
57
2,453
3,419
234
~
6,558
95
359
1,280
I, LSI
526
3,366
STATE
_
-
-
-
1 '-3
-
85
-
2,007
-
-
-
1,947
36,621
-
-
-
2,737
-
2,212
759
380
2,786
104
498
26^
53 1
-
2 ,570
j
1
-
63
124
3,587
352
2,151
9,333
6, 1"!
1,363
4-4-.
2,678
24
1,564
1,126
-.65
6,914
1 , 1 90
209
1 140
-
9Q6
-
2,012
111,601
-
-
_
"
-
-
-
~
-
~
-
-
_
475
-
930
-
8.255
IV-38
-------
processing, textiles, and the petroleum industry. Due to a lack of
data regarding their landspreading practices, industries were not
considered in the analysis. Thus, municipal wastewater sludge was
the only category selected for impact analysis because it is the only
one for which there are national estimates of the amounts landspread.
Furthermore, it is the only category where there is available infor-
mation on waste composition and quantities. Information on sludge
disposal practices at more than 350 POTW's is contained in Appendix F
to this EIS. Further, Appendix F provides data on the amount of sludge
currently spread on agricultural land and the amount that will not be
permitted on agricultural land under the regulations and under three
regulatory alternatives.
Table IV-17 shows the number of facilities in the sample set
which would be affected by the regulations and the alternatives.
b. Major Environmental Benefits
For landspreading on food-chain crops, the significant environ-
mental benefits associated with implementation of the criteria include:
Allows for continued utilization of nutrient and soil
conditioning benefits of sludge
Controls amount of cadmium that enters the food chain
Controls PCB's so that application will not exceed FDA
tolerance levels for milk and animal feed.
IV-39
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c. Costs for Each Criterion
In the analysis, unit costs are divided into two areas: the
costs to comply with the regulations in order that landspreading
activities may continue, and the costs to select an alternate dis-
posal technique in the event that landspreading may not continue. All
unit costs are based on costs per ton or per facility, the time phased
nature of the criteria and the present worth of money. Table IV-18
summarizes the unit costs which are used in the analysis. All values
are in terms of 1978 dollars assuming a planning period of 10 years and
an interest rate of 10 percent. The footnotes in Table IV-18 discuss
how each of these unit costs was developed and list all key assump-
tions made in the analysis about the unit costs.
d. State-Standard-Induced vs. Federally Induced vs.
Combined Costs
Few States have developed regulations concerning landspreading oper-
ations. For the purpose of this analysis. State-standard-induced costs
were assumed to account for 10 percent of the total regulatory costs. The
remaining 90 percent was assumed to be induced by the federal regulations,
i.e., federally induced. These costs are displayed in Table IV-19.
TABLE IV-19
STATE-STANDARD-INDUCED VS. FEDERALLY INDUCED
ANNUALIZED LANDSPREADING COSTS
(Millions of First Quarter 1978 Dollars)
Without With
Annualized Costs Alternative Disposal Alternative Disposal
State-Standard-Induced .7 1.1
Federally Induced 6.2 9.4
Total 6.9 10.5
A more detailed discussion of the underlying assumptions can be
found in Appendix B.
IV-41
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IV-42
-------
TABLE IV-18 (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, $9/hr.
2. Cadmium, lead, nitrogen, pesticides and persistant organics are
to be monitored at each facility. Monitoring requirements and
associated unit costs for large and small and medium facilities
are summarized in the following table. The frequency of monitor-
ing for organics (PCB's) by large cities is assumed to be 1 sam-
ple every 5 years. (Monitoring for organics (PCB's) if only re-
quired under Option 2 of the regulations and only large cities
select Option 2.)
Analysis
Cadmium
SLUDGE MONITORING COST
Unit Cost
($/Sample)
Frequency of Sampling
#1 Year
Small and
Large
Cities
Medium Cities
10
Lead
Nitrogen
Organics (PCB's)
10
40
250
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 $49/mt, thus a cost of
$87.70/Ha. At a sludge application rate of 10 mt/ha, this is
$8.77/mt of sludge. This value was increased to $10/mt to cover
miscellaneous related 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 $5000 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
hectare requires 33.6 mt of sludge to fulfill its nitrogen
IV-43
-------
TABLE IV-18 (Continued)
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 represented 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 method-
ology.
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, re-
cycle treatment and odor control are included. The estimates are
based on the best available data presented in Effects
-------
TABLE IV-18 (Continued)
Most equipment or processes used in wastewater and sludge treat-
ment are mechanical and are not as susceptible to local condi-
tions 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
consideration:
Injection
Small Facility:
$38/mt injection plus $24/mt
hauling = $62/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 $29 /rat
pipeline = $45/mt (6% solids,
tractor-towed injection system)
IV-45
-------
TABLE IV-18 (Continued)
Surface Landspreading with Plowing or Disking after Spread
- Small Facility: $50/mt haul and spread with same
truck
Medium Facility: $5/mt spread/disk-in plus $39/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 $29/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).
IV-46
-------
e. Major Cost Factors
Table IV-19 summarized the increased landspreacjing costs for the
final regulations. Appendix B details how these costs were developed.
Table 111-19 includes the components of the total annualized costs of the
final regulations:
' Soil pH control: 71.0 percent
° Costs for large cities landspreading
under Option 2: 22.0 percent
0 Sludge monitoring 0.5 percent
° Administration: 6.5 percent
These percentages do not include disposal costs incurred by cities
precluded from continued food-chain landspreading.
In addition to the costs presented in Table IV-19, there are other
costs which must be borne in the future which cannot be determined
at this time. These include the impact of phasing out of ocean disposal
of wastes, and the impact of more sludge being generated at existing
facilities in future years.
IV-47
-------
D. GENERAL BENEFITS DISCUSSION
Data which would enable numerical dollar benefits to be computed
for the criteria do not exist, except for information contained in
several case studies of ground-water contamination. Benefits result-
ing from the avoidance of potential gas explosions have been derived
and are also discussed below.
1. Benefits Relating to Ground-Water Contamination
Table IV-20 presents data on well contamination case studies, in-
cluding EPA documentation on damage,* administrative,* and avoidance*
costs incurred at landfills as a result of ground-water contamination..
(Ref. 10, 15, 16, 51, 134, and 135). In sum, these costs range from
$7,000 to $2 million per site. Estimates on corrective** costs exist
for three sites and range from $8 million to $25 million per sites
(Ref. 10 and 134).
Total national benefits for ground-water have been estimated,
based on the following assumptions:
$8 million per site is required for corrective costs;
$150,000 per site is required for damage, avoidance, and
administrative costs; and
From l%-5% of the total number of landfills and surface
impoundments (3730-18650 facilities) require preventive
action for ground-water protection and 0.5% of the total
(450 sites) requirement corrective measures.
*pamage Costs are costs of damaged products and equipment as a result
of corrosion, staining or water pollution. Administrative Costs are
investigative, monitoring, legal, and engineering design costs.
Avoidance Costs are the costs to provide both temporary and permanent
watersupplies from an alternative source, including bottled or tank
water, and the cost to pipe in clean water or to develop an upgradient
(clean) water well.
**Corrective Costs are costs to render the contaminated water usable,
including retrofitting or removing the contamination source (disposal
site) and treating the contaminated water to make it potable.
IV-48
-------
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IV-49
-------
Using these conservative assumptions, the following ground-water
benefits derive from the implementation of the final criteria:
The total national benefit for damage,avoidance, and ad-
ministrative costs ranges from $134 million to $668 mil-
lion.
The total national benefit for corrective costs is esti-
mated at $3.6 billion.
Other obvious economic benefit of the criteria besides ground-
water protection are difficult to quantify; these include:
value of shellfish,crabs,and fish protected by the wet-
lands and surface water criteria;
- value of property not impacted by flooding;
value of reservoirs and recreational surface water pro-
tected;
value of decreased cleaning and property repair from
fewer particulate and corrosive gas emissions into the
air;
- value of health care need reduced by the disease vec-
tors, fires, gases, bird hazards, and access criteria;
value of property protected from damage by the gases,
fires, and bird hazard criteria; and
value of crops and health protected by the land appli-
cation criterion.
2. Benefits Resulting for the Avoidance of Gas Hazards
During the initial decomposition of refuse, oxygen is present as
a component of air and the principal gas produced is carbon dioxide.
When the oxygen is depleted and anaerobic conditions prevail, methane
gas is produced. Within a few years of refuse placement, production
rates of 0.04 to 0.05 cubic feet of methane per year per pound of
refuse are commonly reported, with a methane concentration of 50 to
70% of the total gas produced.
IV-50
-------
Methane is flammable in concentrations between 5 and 15 percent
by volume in air, at atmospheric pressure and ordinary temperatures.
Landfill methane in higher concentrations will pass through the flam-
mable range when diluted with air.
The migration of gas into the surrounding soils or overlying
structures occurs by processes of convection, or movement in response
to pressure gradients; and diffusion, or movement from areas of higher
gas concentration to lower concentration. Flow is greater in materi-
als with high permeability (e.g., sands and gravels). Since methane
is lighter than air, it will exist through a cover material which is
sufficiently permeable, but will travel laterally where conditions
favor this.
Sands and gravels are commonly used for foundation, subgrade ma-
terials, and for backfill materials for water, sewer, and other
utility lines which are connected to buildings. This tends to increase
the likelihood of landfill gas accumulating near buildings. If the
gas moves into a relatively large confined space, it can explode upon
ignition. It can also enter occupied spaces and cause asphixiation,
injury or less serious health effects.
The adverse effects of landfill gas range from catastrophic ex-
plosions resulting in loss of life and injury to minor damage and
nuisance effects. Many of the minor incidents are unrecognized and/or
unreported. Some incidents may have been attributed to natural gas
leaks when actually caused by landfill gas.
a. Major Gas Hazards
Major gas hazards are the larger explosions and fires which
can occur in the vicinity of a landfill. The degree of landfill gas
hazard is not necessarily proportional to the size of the landfill.
A relatively small landfill can generate sufficient methane to create
a serious gas hazard if curcumstances exist to permit migration and
accumulation of the gas. Other factors being equal, however, a
IV-51
-------
larger landfill will generate more gas which can migrate farther, cre-
ating more opportunities for damage to occur.
It is more difficult to predict the contribution to landfill gas
damage from industrial disposal facilities because of the variability
of wastes handled. Some facilities may produce large quantities of
methane gas while facilities with toxic constituents may produce none.
D. R. Streng of Systems Technology Corporation reports in the Proceed-
ings of the Third Annual Municipal Solid Waste Research Symposium,
September 1977, that refuse cells containing municipal solid waste ad-
mixed with industrial waste, produce large amounts of methane gas,
though significantly less than for municipal waste alone.
Table IV-21 summarizes the estimated damage and costs to date of
six major landfill gas incidents.
The consequences of these incidents are well documented but the
dollar costs are not. Therefore, dollar costs must be estimated based
on information available and on experience with similar events. In
the case of deaths and serious injuries, there is no completely satis-
factory means of cost estimation, however, the basis used was in terras
of lost economic productivity, as income, disability payments, etc.
Costs reported in the literature were adjusted to 1978 dollars. In
cases where residential neighborhoods were threatened by gas hazard
for one year or more, a loss of real property value was estimated on
the basis of 5% loss per residence affected. In cases where struc-
tures were destroyed, the loss was based on replacement cost.
Representatives of two of the facilities referred to in Table
IV-21 recently provided specific cost data for their major landfill
gas incidents. The Louisville and Jefferson County Planning Commission
letter of March 1, 1979 and the City of Richmond, Department of Public
Works letter of March 5, 1979 can be found in Appendix H. Their let-
ters use a different approach for cost estimation in that they do not
consider the economic losses related to deaths or injuries. Thus they
IV-5 2
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IV-54
-------
present lower cost estimates than those presented in Table IV-21, but
the estimates are still in the same order of magnitude. Their esti-
mates indicate costs at sites 3 and 4 of about $500,000.
One approach to estimate the expected future losses due to major
incidents of this type is to estimate the frequency and duration of
similar events. Landfill gas incidents have increased dramatically
in recent years. This phenomenon is related to the following factors:
1. The practice of open dumping is being replaced by sani-
tary landfill practice which tends to restrict the es-
cape of landfill gas to the atmosphere.
2. Total refuse in place is increasing and producing more
gas.
3. More disposal facilities are being closed and developed
for other purposes, with structures built on and near
them.
4. Covered facilities often are not designed with adequate
safeguards to control landfill gas.
Landfill gas damage costs were estimated with the assumptions
that:
1. Major landfill gas incidents will continue for at least
at rates experienced during the last four years with
equivalent consequences. The basis for this assumption
is given above. Major incidents have occurred from
one to three times per year, with a median or "most
probable" occurrance of once per year.
2. Landfill gas will continue to be produced in hazardous
quantities for an average of 30 years.
IV-55
-------
3. A conservatively low estimate of the costs resulting
from a "typical" major incident is $500,000.
Using these assumptions, future costs are estimated as one
$500,000 incident per year for 30 years, or $15 million dollars.
b. Minor Gas Hazards
Minor gas hazards include long-term effects such as damage
to vegetation and other problems due to presence or potential presence
of landfill gas.
The August 1969 report, "Development of Construction and Use
Criteria for Sanitary Landfills" prepared by Engineering-Science, Inc.
includes the results of surveys conducted to determine problem con-
ditions including those related to gas. About forty percent of the
facilities surveyed experienced problems related to gas production.
At one facility, employee headaches were reported to be caused by
odors and gases.
Some gas-related comments from the survey are summarized below:
Physical Characteristics
Facility No. of Facility Gas-Related Comments
S-l Depth: 20 feet Some odors reported around
Age: 20 years garages and golf course.
Class II refuse.
Used as golf course.
S-3 Depth: 19 feet Plant growth reported
Age: 15 years inhibited.
Used as skeet range.
S-4 Depth: 28 feet Gases controlled by Tiki
Age: 20 years burners and vinyl barrier
Class II refuse. under slab over gravel.
Used as trailer park.
IV-56
-------
Physical Characteristics
Facility No. of Facility
S-5 Depth: 110 feet
Age: 11 years
Class II refuse.
Used as botanic garden.
Adjacent use is residential.
S-13 Depth: 20 feet
Age: 8 years
Class II refuse.
Used as industrial building.
S-14 Depth: 20-40 feet
Age: 6 years
Used for industrial
building.
S-17 Depth: 60 feet
Age: 6 years
Used as rubbish transfer
station.
L-10 Depth: 25 feet
Age: 15 years
Used for concrete block
building.
L-36 Depth: 60 feet
Used as pistol range
with concrete building.
L-41 Depth: 17 feet
Used as recreation area
with large building on
concrete slab.
Gas-Related Comments
Gas seepage to adjacent
property, gas found in
greenhouses. Membrane
installed under one
greenhouse with vent system.
Utility trenches filled
with sand are acting as
as gas vents.
Gas and odors, now con-
trolled by vents through
floor to roof. Explosive
concentrations found by
"Explosiraeter".
Floor crack allows gas and
odors to enter. Odors
and gases have given
employees headaches.
Special maintenance on
structure - gas creeping
into structure at openings
for utilities.
Gas movement evidenced in
fill, shallow trench and
burners installed to vent
gases.
Fire from gases ignited,
passing through cracks
in the slab. Vent
installed later.
IV-57
-------
The minor hazards reported generally fall into the categories of
hazards to vegetation and hazards to structures. A discussion of each
follows:
(i) Vegetation Damage
Much of the research work on landfill gas effects on vege-
tation has been done by Franklin Flower's group at Rutgers University.
In his publication "Vegetation Kills in Landfill Environs", Proceedings
of the Third Annual Municipal Solid Waste Research Symposium, he con-
cludes:
The field examinations we have conducted of landfill vegeta-
tion throughout the United States indicate that poor growth
or death of the vegetation is directly associated with the
presence of landfill gases in the soil atmosphere. It ap-
pears that the vegetation dies as the soils become anaerobic
from the physical displacement and/or biological consumption
of the soil oxygen.
To obtain a successful growth of vegetation above or ad-
jacent to former refuse landfills the root zone of the vege-
tation must be protected from the gases of anaerobic decomp-
osition of the organic matter in the landfills.
A survey conducted in 1975 indicated that adverse effects on ve-
getation occurred in all geographic and climatic areas of the country.
Examples of the type of effects are found in the following table, ex-
tracted from the above referenced publication:
IV-58
-------
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IV-59
-------
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IV-60
-------
The results of a national mail survey are included in "A Study of
Vegetation Problems Associated with Refuse Landfills", May, 1978,
N.T.I.S. PB-285 228. This report concludes that 25 percent of land-
fills report vegetation problems on the site and 7 percent report
problems adjacent to the site. These percentages are conservative
because, the researchers found, many respondents did not realize they
had a problem.
Specific costs related to vegetation damage is difficult to ob-
tain. A 9- to 10-acre landfill in Camden County, N.J., was found to
contribute to the deaths of vegetation in a surrounding residential
area, including a spruce tree, rhododendron, Japanese Ewe, azeleas,
dogwood trees, flowering peach trees, scotch brooms, arborvitae, and
douglas fir, as well as an area of lawn grass. Soil gas tests indi-
cated a presence of combustible gases and C0_. Putrid ground odors
and oxygen deficiency were also noticed. In an out-of-court settle-
ment, the residents received $50,000 and the township was ordered to
vent gases from the landfill periphery.
At the 100-acre Cinnamonson Facility in Burlington County, N.J.,
8 to 10 acres of land within 50 to 60 feet of the landfill experienced
difficulties in vegetative growth. A legal settlement of $18,000 was
obtained in this case.
Another approach to evaluating the effects of landfill gas on
adjacent vegetation would be to estimate the amount of land affected.
Several papers have been published on this subject by Moore, Alzaydi
and Rai. They have developed equations to describe the flow of
gases around landfills. Certain assumptions are made regarding the
landfill shape, depth, and the surrounding soils. They have developed
design charts for the gas migration patterns for a landfill of
average dimensions, with average gas compositions and decomposition
time, and for typical soil, under atmospheric pressure of 1 atmosphere
and a temperature of 25° C.
IV-61
-------
Thus, using a typical landfill with a simplified cylindrical
shape, the extent of methane of at least 5% concentration is estimated
to be 450 feet beyond the edge of the landfill in all directions, or
a total of 49 acres of land off-site. Since in real landfill situa-
tions, off-site gas often encounters barriers or venting at some
points, the 49 acre figure should be regarded as a maximum.
The "First Annual Report" by Engineering-Science, Inc. on
"Development of Construction and Use Criteria for Sanitary Landfills",
1968, reports the results of landfill gas migration studies in
southern California. They found methane concentrations of 10 percent
at a distance of 600-700 feet from the fill in gravelly sand, but in
silty-clay, methane was detected only 200 feet from the fill. This
data tends to validate the Moore, et al model for an average facility.
The "Second Annual Report" of the same Engineering-Science, Inc.
Study, published in 1969, identified a total of 298 uses for completed
sanitary landfills, identified with the most common being:
1. Parks and Recreation - 31%. (This category includes
parks, athletic facilities, green-belts, golf courses,
and general recreational purposes.)
2. Industrial and Commerical Use - 21%.
3. Residential Use - 8%.
This data indicates that a substantial number of landfills, on
the order of 50 percent, have valuable landscaping on or near them.
The extent and cost of damage is difficult to assess. Using some
of the above parameters, if 50 percent of 9,000 facilities have valu-
able adjacent vegetation, with 49 acres/facility exposed to methane
with a conservative estimate of $50/acre average damage, the total
damage amounts to $11 million.
IV-62
-------
(ii) Housing Effects
The presence or potential presence of landfill gas results
in significant costs in the protection of structures. One aspect of
costs is in monitoring to determine the concentration of landfill-
generated methane near structures. A summary of commonly-used
detection equipment is included in the Appendix. One type of portable
detector is used to monitor methane concentrations in confined spaces
in or near the structure and costs about $500. Another type is
a personal alarm for workers entering a confined area and costs about
$400. It is assumed that a minimum of one unit of each type should
be used at each of the 9,000 facilities for a total cost of ($500 +
$400) (9,000) = $8 million dollars.
Other permanent construction measures must be taken as were done
in the example of the City of Nashua, New Hampshire, whose February
16, 1966 letter is included in the Appendix. In this example, a gas
sensing device was installed in a building of concern. These in-
stallations typically cost about $2,000, and if required on the aver-
age of one for each of 9,000 facilities would cost $18 million dollars.
There are numerous other protective measures which can be taken to
protect structures from encroaching landfill gas, some of which are
included in the Appendix. Some techniques are used for existing
structures and some for new structures. These measures are taken in
direct response to the landfill gas hazard and should be included in
this cost/benefit analysis. A conservative estimate is that $2,000/
facility would be required for such construction measures or an
additional $18 million dollars.
Very little information is available concerning the effects of
landfill gas on property value. General Behavioral Systems, Inc.
conducted a study in 1972 for the Office of Solid Waste Management
Programs entitled "The Effect of Solid Waste Disposal Sites on
Property Values." They concluded that "solid waste disposal sites
have no apparent negative effect on change in property value of single
IV-63
-------
family dwellings in their immediate environs" and that "the effects of
sanitary landfills are overwhelmed by general economic factors
affecting the community." A negative economic effect could be docu-
mented only where a readily observable disamenity exists such as
visible smoke from the facility. An obvious disamenity was observed
at one south central Virginia facility where landfill gas was migrat-
ing off-site into the basement of a school and in the nearby sewer.
Children in the area were lighting matches and blowing off manhole
covers for amusement. No attempt will be made to assign a cost to
this type of effect.
c. Summary of Annual Benefits Resulting from
the Avoidance of Gas Hazards
Item Cost
Major Gas Hazards $15 x 106
Vegetation Damage $11 x 10
Housing Effects
- Monitoring $ 8 x 10
- Protection $36 x 106
Total $70 x 106
The total annual benefits resulting from the avoidance of gas
hazards are estimated to be $70 million. Some of the parameters used
in developing this estimate are not well-documented in the literature,
however, there is sufficient documentation to conclude that this is a
realistic conservative estimate.
E. SOCIAL/EQUITY IMPACTS SUMMARY
Social and equity impacts were analyzed on the basis of available
data on municipal landfills, landspreading operations and State solid
waste disposal regulations. Unfortunately, the lack of comprehensive
data on the exact number of surface impoundments (See Ref. 107 for the
most complete study to date) made a comprehensive quantitative analy-
sis of these impacts impossible.
IV-64
-------
In spite of these limitations, the general effects of the criteria
on several special impact groups were evaluated; these groups include
rural areas, regions, States, and specific industrial groups.
1. Rural Areas
The impact of rural areas was evaluated for landfill disposal
only; industrial landfills and surface impoundments do not impact
rural areas vs. urban areas per se. Since industrial surface impound-
ments account for approximately 80% of the total surface impoundments
compliance cost, the rural vs. urban impact on the other types of im-
poundments would be minor. A more complete discussion of the impact
of the criteria on selected industrial groups is provided in Section
E-4.
The Waste Age survey and State revisions reported a total of
18,307 municipal landfill facilities nationwide. The survey distribu-
ted the facilities into six categories by daily operating capacity
with 14,005 (76%) being reported in the smallest (0-50 tons/day) cate-
gory. It is assumed that these sites serve the smaller populations in
the rural areas of the United States and the larger sites (greater
than 50 tons/day) serve more urbanized areas. Some rural areas un-
doubtedly have initiated regional systems, in which case the solid
wastes from the areas would be disposed of in a large capacity facil-
ity.
Using the average daily tonnages developed in the costing method-
ology (Appendix V, Volume II), one may estimate the tonnage of wastes
deposited in small sites serving rural areas. Based on an estimated
207 million tons per year (total wastes disposed in municipal land-
fills), approximately 36 million tons/year are placed in small, rural
sites. This means that only 17% of the municipal wastes are disposed
of in 76% of the landfill facilities.
While most of the costs of meeting the criteria are a function of
facility size, the relationship between upgrading costs and facility
size is not directly proportional. For example, doubling the facility
IV-65
-------
size will not result in a doubling of costs for manpower and equipment.
In effect, larger facilities typically found in urban centers are
able to benefit from an economy-of-scale approach to solid waste dis-
posal; on the other hand, small rural sites will not reap the benefits
of economy-of-scale. As a consequence, the cost impact per capita or
per unit of waste disposed will be significantly greater for small
landfill sites in rural areas than for larger landfills in urban areas.
The net increase in cost/ton due to the new federal criteria is
shown for each criterion and for each facility size in Table IV-23.
The ground-water costs for the 10 ton/day facilities are so high that
they represent a glaring inequity. Since these smaller facilities are
the predominant size in rural communities, this also represents an
urban/rural inequity. These very large costs/ton for small facilities
are a result of the relatively large capital costs of lining and
leachate collection and treatment for comparatively small facilities.
One significant effect of the criteria as they now stand is that
larger regional facilities will be the only alternative for many small
communities.
Given the relatively low income base in many rural areas, expen-
ditures for additional land, major control features (liners, gas con-
trol, levees, etc.), and equipment will impose a severe financial bur-
den in many communities. Where these costs are significant, the com-
munities will need to reassess their current disposal practices and
the alternatives of transporting their wastes and initiating larger
scale regional solutions.
Recognizing the potential inequity, Congress provided a mitigat-
ing factor by authorizing special funding to rural communities in Sec-
tion 4009 of RCRA, which provides for up to $25 million for the purch-
ase of landfill capital equipment.
Table IV-24, which identifies the total and per capita annualized
Federally induced costs,shows that the more rural States such as Iowa,
Maine, and Vermont, are impacted more than most "urbanized" States.
However, the other major factor affecting this cost increase is the
degree to which current State regulations address land disposal prac-
tices. IV-66
-------
TABLE IV-23
COMBINED ANNUALIZED CRITERIA-INDUCED AND PER TON COSTS
Criterion
Floodplains
Surface Water
-NFS Controls
-Wetlands
Ground Water
-Minimum
Technology
-Maximum
Technology
Disease Vectors
Air
Safety
-Gas Controls
-Fire
-Access
Site Size
10
100
300
10
100
300
10
100
300
10
100
300
10
100
300
10
100
300
10
100
300
10
100
300
10
100
300
10
100
300
Annualized
Costs
? 10,300
22,600
37,000
1,700
6,200
14^800
10,300
22,600
37,000
4,700
2,800
4,900
42,200
125,700
272,600
2,600
13,000
26,000
1,600
7,500
20,200
11,600
25,100
31,400
300
800
2,600
500
1,100
1,700
Costs per
Ton
3.96
0.87
0.47
0.65
0.24
0.19
3.96
0.87
0.47
1.81
0.11
0.06
16.23
4.83
3.49
1.00
0.50
0.33
0.62
0.29
0.26
4.46
0.97
0.40
0.12
0.03
0.03
0.19
0.04
0.02
IV-67
-------
TABLE IV-24
INCREMENTAL PER CAPITA UPGRADING AND CLOSURE COSTS FOR ALL LANDFILLS
(FEDERALLY INDUCED AUNUALIZED BASIS)
IV-6
-------
In those States which have adopted stringent regulations, the
impact of the criteria is minimal, and therefore the greatest impact
generally occurs where current regulations are less stringent than the
criteria. This factor probably impacts costs more than does the rural/
urban factors, and is discussed in Section D.3., below.
2. Regions Impacted by Specific Criteria
Each of the criteria was evaluated to determine if it would im-
pact general geographic areas or segments of our society more than
others (in addition to the obvious rural vs. urban dichotomy). The
geographic equity impacts were found to be related to the floodplains
and ground-water/surface water criteria.
a. Floodplains
Floodplains are most prevalent in the regions east of the
Mississippi, and in the Pacific Northwest. The data used for deter-
mining floodplain areas for each State was provided by the Federal
Insurance Administration, from their flood insurance program data
base. The existence of large floodplains in a particular region adds
an additional compliance burden to that region, beyond that imposed
by the other non-locational criteria.
b. Ground and Surface Water Criteria
The ground-water and surface water criteria will result in
equity impacts due to climatic and hydrogeologic factors.
(1) Climate
The eastern, and particularly the southeastern, region
of the United States receives a higher rainfall and has a lower rate
of potential evapotranspiration than the western region. As discus-
sed in Chapter III, the potential for ground-water and surface water
IV-69
-------
contamination resulting from leachate is greatest in areas where aver-
age annual precipitation exceeds the potential water losses by evapor-
ation and transpiration. Such areas are generally found east of the
Mississippi River and in the coastal region of the Pacific Northwest.
About 60 percent of the municipal refuse disposal facilities found in
the United States are located in these was surplus areas.
Although the production of leachate in landfill facilities in the
southeastern and Great Lakes regions has contribution to some contami-
nation of ground water and surface water, industrial impoundments in
these regions of high precipitation are of particular concern. Either
through faulty design, accident, or failure, impoundments containing
industrial effluents have been responsible for contaminating ground
water and leaking waste waters into streams, lakes or rivers. Impact-
ed significantly by the final ground-water criteria is the coal-pro-
ducing and steel-making region of this country;the combination of high
precipitation and impounded industrial wastes poses a threat to
ground-water quality in these States.
Further, the locational element of the surface water criteria,
concerning wetlands, causes additional impacts. Wetlands are most
prevalent in the low, coastal areas of the country. Therefore, this
component of the surface water criteria will affect the coastal areas
of the eastern and western seaboards, and in the south and southeast,
along the Gulf coastal areas.
(2) Hydrogeology
There are many factors that result in hydrogeologic en-
vironments unfavorable for land disposal of wastes. Such factors in-
clude soil porosity, thin soil cover, shallow bedrock, fractured and
jointed bedrock of shallow depth, and a high water table. A high rate
of precipitation may intensify already unfavorable site conditions.
IV-70
-------
Although hydrogeologic environments vary widely from site to
site, certain regions of the United States are characterized by
generally unfavorable hydrogeologic conditions. These regions in-
clude areas where shallow bedrock and volcanic terrain pose a threat
to ground water and consequently complicate the construction and
operation and landfills; such hydrogeologic problems are encountered
in the Pacific Northwest and in the eastern Appalachian region. In
these regions additional costs may be incurred in the design of
protective features to insure protection of ground water in areas of
shallow bedrock. In addition, the lack of adequate cover soil in such
regions will necessitate the importing of cover, thereby incurring
higher costs for landfill operation.
Throughout much of the Atlantic and Gulf Coast Plain, a high
ground-water table is encountered within permeable sandy deposits.
A difficult and costly technical problem to contend with in these
regions is the isolation of refuse from shallow ground water.
At least half of the population of the United States
relies on ground water as a source of drinking water; although the
equity impacts related to this use impinge most directly on rural
areas, there are certain regional trends that may be noted. The
South, Midwest and West (with the exception of Washington and Cali-
fornia) are impacted by this reliance on ground water as a source of
drinking water. Regions where this is particularly true are certain
areas in the South, Southwest, and West (Ref. 7).
The general component of the surface-water criteria is expected
to have significant economic impact on landfills and impoundments in
the northern Great Lakes region, where industrial production generates
substantial quantities of industrial wastes (some hazardous) (Ref. 7).
Added costs may be incurred in this region to implement technology re-
quired to protect streams, lakes, and rivers from the adverse environ-
mental impacts associated with the disposal of industrial wastes.
IV-71
-------
3. States
The specific social/equity impacts of the criteria in a given
State depend on a variety of factors, including:
the climatic and hydrogeological conditions;
reliance on ground water for drinking water and indust-
rial uses, and the quality of that ground water;
the current and past disposal practices;
- the extent of enacted State legislation governing the
disposal of solid waste;
the urban or rural character of a given State; and
the number, size, facility life, and environmental con-
dition of the existing disposal facilities.
Climatic and hydrogeological conditions have been discussed above.
These factors significantly affect the equity impacts in specific
States, as summarized below and illustrated in Table IV-25:
- States located in the low, coastal areas of the southeastern
and western parts of the country (Florida, Lousiana, South
Carolina, Georgia, and California), and along the flood-
plain areas of the Mississippi River (Illinois and Arkansas)
will be significantly impacted by the floodplains criteria
and the wetlands component of the surface water criteria.
Tables IV-26 and IV-27 provide the States with the largest
areas of floodplains and wetlands.
- States located in the eastern and southeastern parts of the
country receive relatively high levels of rainfall, and ex-
perience relatively low rates of evapotranspiration. As a
result, the general component of the surface water criteria
will have a substantial impact in these States.
IV-72
-------
TABLE IV-25
COMBINED ECONOMIC ItJPACT FOR EACH STATE:
LANDFILLS, SURFACE IMPOUNDMENTS, LANDSPREADING
(THOUSAND DOLLARS)
II LINOIS
INTIANA
IOW ft
KANSAS
I [NT1ICKY
LOUISIANA
7,571
1,275
1,179
12,234
11,434
2,313
297
13,765
54,675
4,748
1.65?
3,28),
9,553
6,872
10,996
3.HI
21,710
9,611
9,000
28,6?9
3,296
1,885
5.07fi
2.9B3
4,553
6,497
siTRr,\n WVHK.
1,962
348
1,168
7,962
1,126
2,223
2,510
3,940
3,906
41,826
1,137
652
3,/24
5,?99
4,165
2.8S8
1,525
6,721
20,650
5,225
4,090
16,704
8,542
5,019
3,250
3.F66
12,580
1,520
7,774
9,356
163,285
100,362
127,027
89,817
297,5!3
28,164
69,452
192,868
67.098
62,170
9,427
63,332
945
2,257
16,467
4,187
_19&_,&17_
7,810
4,047
2,954
7,151
955
5,859
8,590
l,75i
1,266
6,159
1,086
6,360
NOT IDEN-
TIFIED BY
STATE
IV-7 3
-------
TABLE IV-26
STATES WITH HIGHEST PERCENTAGE OF FLOODPLAINS
.
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
State
Florida
Louisiana
Mississippi
New Jersey
Arkansas
South Carolina
Maryland
North Carolina
Massachusetts
Alabama
Georgia
Connecticut
Tennessee
Percent Floodplains
25.4
24.8
18.7
17.0
16.5
16.3
15.8
15.5
14.2
13.6
10. 3
10.0
9.7
IV-74
-------
TABLE IV-27
STATES WITH HIGHEST PERCENTAGE OF WETLANDS
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
State
Florida
Alaska
Louisiana
South Carolina
Georgia
North Carolina
Arkansas
Delaware
Minnesota
Michigan
Mississippi
Wisconsin
New Jersey
Percent Wetlands
49.6
34.4
33.6
17.4
16.2
13.0
11.4
10.4
10.0
8.8
8.6
8.0
5.6
IV-75
-------
Highly industrialized States in the northern Great Lakes re-
gion (Ohio, Illinois, and Michigan) and in the northeast
(Pennsylvania and New York) will be impacted significantly
by the ground-water criteria and the general component of
the surface water criteria. These States generate sub-
stantial quantities of industrial wastes (some hazardous),
Many industrial impoundments and landfills in these State's
are expected to require upgrading to comply with these
criteria.
The next two factors, current and past disposal practices and en-
acted State legisltation, will obviously have a considerable impact on
the incremental cost to the State of meeting the criteria. Those
States whose disposal practices and solid waste legislatation reflect
more concern for environmental protection have already made upgrading
expenditures and therefore are expected to have a small incremental
cost to comply with the criteria.
These generalizations are illustrated in Table IV-28, which pre-
sents landfill costs per ton on a State-by-State basis, differentiating
between Federally induced and combined cost-per-ton increases (costs
incurred due to other Federal Regulations are not included). For all
the States, the average upgrading cost per ton due to the criteria is
$1.65, only 27% of the combined cost-per-ton average of $5.99. Three
of the states will incur no Federally induced cost-per-ton increases
since these States already have regulations equivalent to the proposed
criteria. On the other hand, in seven of the States, Federally induced
costs constitute over 90% of the total incremental upgrading costs for
landfills. The lack of environmentally oriented solid waste legisla-
tion in these States is responsible for the greater economic impact
of the criteria on incremental upgrading costs for landfills. In
addition, several rural States incur extremely high Federally induced
(rather than combined) costs (Vermont, Mississippi, and Maine). Be-
yond having cost-per-ton increases several times greater than the
national average, the total Federally induced costs for these States
are inordinately high. These largely rural States, then, are in-
IV-7 6
-------
TABLE IV-28
INCREMENTAL FEDERALLY INDUCED AND COMBINED COMPLIANCE COSTS:
ALL LANDFILLS
,il M!\M\
/ 1 a .1 A
\ M / 1 IN A
- |,K \N",AS
t M IlnK' 1A
( MnUA!>»
1 (I , ,1 ( mm
M L\U,il5
2, J17
'4 ,(.10
31, 72 i
2 , y i ,'
6, 781
fiW
11,09'J
/.G1)?
1,04}
2,662
24,697
10,429
19, 196
5,070
12,813
6,482
2,246
3,060
9,513
?9,669
6,885
2,410
5,499
1 , '* 2 7
3, 391
JJ5
2,168
14, 7 a
2,681
29, 6 '.5
14,846
926
19,U)5
4,768
4,495
15,361
2,223
8,858
1,784
7,194
18.184
3,910
H',2
5,101
8,788
3, 24j
15,483
111
406,721
i i in it M i
i IIMI-I !,M, I Ui , )-,
H , .&
2,321
312
725
7,911
1 ,345
17,507
6,534
1 ,045
S,782
1,887
2,723
9 ,901
1,496
3,858
1,133
3,953
11,183
2,066
447
2,549
4,057
1,119
9,661
373
232,817
IV-77
-------
equitably impacted by the criteria due to their large number of small
disposal facilities(which cannot realize the benefits of economies-of-
scale) and their current environmental regulatory processes.
In the past, the lack of adequate financial resources in some
States has hindered the development and implementation of progressive
solid waste disposal legislation. An important goal of RCRA is to re-
dress this inequity, thereby facilitating the upgrading of disposal
practices in these States. Under RCRA, special communities with low
populations and high levels of solid waste disposal are eligible for
grants to be used for the conversion, improvement, consolidation or
construction of solid waste disposal facilities (Ref. 6). Such grants
are designed to promote environmentally sound disposal practice's
throughout the country.
It is beyond the scope of this report to identify the specific
inequities that may result from State disposal practices and the inad-
equacies of environmentally oriented legislation. Data on such inequi-
ties will be available only after the inventory of open dumps has been
completed.
As discussed in Section E.(2),the urban regions of the nation ex-
perience less of a burden than do the rural regions. The impact of
such a distinction on individual States further illustrates the effi-
ciency resulting from economies-of-scale in highly populated, largely
urban States. Several rural States, particularly in the Midwest and
West (Arkansas, Missouri, and Wisconsin) incur high cost-per-ton in-
creases due to their large number of smaller landfill facilities (0-50
tons per day) and the current status of their environmental regulatory
processes.
To adequately assess the last factors identified as impacting on
States the number, size, facility life, and environmental condi-
tions obviously would require complete and specific data which is
not available.
IV-78
-------
4. Manufacturing Industries
a. Data Base
The most complete data available for a determination of the
impact of the criteria to industry was that on the two-digit SIC manu-
facturing industries (SEC 20-39). The data base consists of two com-
ponents:
The EPA report on surface impoundments entitled, "Sur-
face Impoundments and Their Effect on Ground-Water Qua-
lity in the OniteJ States," (Ref. 107); and
The study by Fred C. Hart Associates, Inc., entitled
"The Technology, Prevalence, and Economics of Landfill
Disposal of Solid Waste," (Ref. 141).
The above sources provided estimates on the number of surface im-
poundments and on-site industrial landfills for each of the manufactu-
ring industry groups. For a more detailed discussion of how these data
bases were interpreted, see Appendix B.
Table IV-29 provides the data base for each of these manufactur-
ing industry groups. For landfills, the non-electrical machinery group
(SSC 35) accounts for approximately one-third of the total on-site in-
dustrial landfills for the manufacturing industries. Another third are
divided betweed the Food Processing (SIC 20), Wood Products (SEC 24),
and Fabricated Metals (SIC 34) industry groups. The remaining third
are divided among sixteen other industrial groups. For two, Rubber and
Plastics (SIC 30) and Electrical ilachinery (SICO 36), no on-site in-
dustrial landfills have been attributed. For surface impoundments, the
distribution among the manufacturing industry groups is concentrated on
Food Processing (SIC 20), which has 28 percent of the total manufactur-
ing industries' surface impoundments. An additional thirty percent are
divided among the Chemicals and Allied Products (SIC 28) and the Stone
and Clay (SIC 32) industry groups.
IV-7 9
-------
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IV-80
-------
In addition to identification of the manufacturing industry
groups' landfills and surface impoundments, assignment of these dis-
posal facilities to floodplains and wetlands was necessary to deter-
mine compliance costs for the locational elements of the criteria. No
data on this is available,so several assumptions were necessary, based
on those made for the total landfill and surface impoundments assess-
ments. In addition, accurate knowledge of the conditions of industrial
disposal facilities is not available, so additional assumptions were
made concerning the degree of compliance necessary for each type of
disposal facility and for each criterion.
Location! The percentage of each industry's activity
which occurs in wetlands of floodplains was considered
to be related to the percentage of the national popula-
tion living in this areas. A detailed discussion of
this methodology is provided in Appendix B.
Condition; For landfills, it was assumed that all
would be upgraded for each criterion, except the gas
component of the safety criteria and the disease vect-
ors criterion. For these two criteria, only 10% of the
on-site industrial landfills would be upgraded. For
surface impoundments, sixty-six percent were considered
to require upgrading or closure for the wetlands compo-
nent of the surface water criteria,the floodplains cri-
teria, and the ground-water criteria. Five percent of
the total were closed. For the access component of the
safety criteria, 25 percent were upgraded.
An additional assumption was made in order to assess
ground-water compliance costs for each industry. Since
ground-water compliance costs are a function of the
rate of infiltration in a particular area, it was ass-
umed that the percentage of the national population
living in States with net infiltration would be the
same percentage of industrial disposal facilities in
these areas.
IV-81
-------
A detailed explanation of the rationale behind these assumptions
is provided in Appendix 3.
b. Major Enviromental Benefits
The benefits to the nation of compliance with the cri-
teria by the manufacturing industries are significant, as the quanti-
ties of industrial wastes increases and the potential for adverse en-
vironmental impact from the improper disposal of these wastes becomes
increasingly apparent. It should not be inferred that all industrial
wastes have an adverse environmental impact. Some, such as kiln dust
resulting from the manufacture of cement, which can often be used in
place of lime on agricultural lands, have the potential for favorable
environmental impact. However, the potential harm to the environment
from the improper disposal of industrial wastes, many of which are
toxic to plant, animal, and human life, makes the regulation of their
disposal of major importance.
Among the major environmental benefits resulting from the cri-
teria and the regulation of industrial waste disposal are:
- A reduction of the adverse impacts in low-lying indust-
rial areas. Greater assurance that the location of in-
dustrial activities in the floodplain and wetland areas
of the nation will not be adversely affected from the
disposal of industrial wastes. Potential for adverse
impact from flooding will be reduced;
Protection of habitats of endangered and threatened
species from the impact of waste disposal;
Protection of principal drinking water sources;
Protection of the nation's rivers, wetlands, streams,
and lakes from bacterial and chemical contamination;
- Reduction in air pollution caused by open burning;
IV-8 2
-------
- Reduction in safety (non-occupational) hazards; and
- Protection of the public health.
c. Unit Prices for Each Criterion
Unit prices for upgrading technologies and closure costs
for each criterion are the same as those presented in the previous dis-
cussions on landfills (Section E.I) and surface impoundments (Section
E.2).
d. State-Standard-Induced vs. Federally Induced
vs. Total Costs
State-standard-induced and Federally induced costs were
not determined for this manufacturing industries assessment because of
data limitations. Although national estimates of the number of dis-
posal facilities by industry are available, no information as to the
number of these facilities by State exists.
e. Major Cost Factors
The major cost factor for the manufacturing industries
is the ground-water criteria which accounts for 79 percent of the
total compliance cost of $2039.2 million. Other Federal regulations,
specifically those concerning point and non-point source discharges
to surface water, account for the second highest compliance cost to
the manufacturing industries. Of the remaining compliance costs
attributable directly to these criteria, seven percent are caused by
the safety criteria, six percent by the floodplains criteria, one
percent by the air criteria and six percent by the disease criterion.
The large ground-water cost for each industry is due to the assumption
that all industrial landfills in wetlands and 50% in net infiltration
areas would require upgrading to comply with the ground-water cri-
teria. The safety criteria were the second highest in Federally
induced cost because of the need to control access at most industrial
disposal sites, and due to the impact of the gas component of the
safety criteria at ten percent of the landfill sites.
IV-83
-------
Tables IV-30, IV-31, and IV-32 provide the compliance costs for
each industry for landfills, surface impoundments, and total.
f. Equity Features
The implications of compliance costs for each industry
are best understood in terms of the percentage of a particular indus-
try group's total annual sales which would have to be applied in order
to comply with the criteria. Simply assessing the equity implications
in terms of which industry has the greatest cost burden is inadequate,
because of the differences in size (number of establishments, annual
sales, etc.) between the industry groups. Table IV-33 provides the
percentage of total annual sales necessary for compliance with the
criteria for each industry.
The Lumber and Wood products group (SIC 24) incurs the greatest
cost impact in terms of annual sales (.792%). This is due primarily
to the large number of landfills associated with this industry group.
The Non-Electrical Machinery group (SIC 35) is the next largest im-
pacted industry group, requiring .746 percent of its annual sales for
compliance with the criteria.
Overall, the total manufacturing industries compliance burden is
less than half of one percent of their total annual sales (.189%).
F. IRREVERSIBLE AND IRRETRIEVABLE; SHORT AND LONG-TERM IMPACTS
1. Nature of Impact
Since the proposed criteria aim at environmental improvement, it
is useful to examine them in terms of the nature of the impact pre-
vented or reduced in magnitude. Table IV-34 shows these impact re-
ductions.
IV-84
-------
£ a
IV-85
-------
p
o
IV-86
-------
p
R
i-l CJ
m <
O fn
H P
Sj
H
IV-R7
-------
TABLE IV-33
COMPLIANCE COSTS AS A PERCENT OF ANNUAL SALES
FOR THE MANUFACTURING INDUSTRIES
SIC
20
21
22
23
24
25
26
28
29
30
31
32
33
34
35
36
37
38
39
Compliance Cost
Industry (Millions)
Food/Kindred Products
Tobacco
Textile Mill Products
Apparel
Lumber/Wood Products
Furniture
Paper/Allied Products
Chemical/Al lied
Products
Petroleum
Rubber /Plastics
Leather Products
Stone/Clay/Glass
Primary Metals
Fabricated Metals
Non-Electrical
Machinery
Electrical Machinery
Transportation
Equipment
Instruments
Miscellaneous
Manufacturing
TOTAL
199.4
2.1
53.6
155.1
236.4
56.2
43.1
146.2
19.5
0.8
5.2
110.6
44.2
186.2
787.5
1.3
54.6
35.1
94.6
2,231.6
*Source: Census of Manufacturing, "Current
Annual Sales*
(Millions) Percentage
180,929.7
36,389.2
34,758.4
23,129.4
14,232.0
48,218.1
104,138.6
82,347.0
31,765.2
7,176.0
30,635.2
93,001.8
77,507.1
105,525.2
73,867.1
141,025.5
25,030.1
16,285.9
1,177,585.9
Industry Reports,"
.110%
.023
.147
.446
.792
.395
.089
.140
.024
.003
.072
.361
.048
.240
.746
.002
.039
.140
.581
.189
Table 1, 1976.
IV-8
-------
a. Irreversible Changes
Solid waste disposal facilities can cause irreversible envi-
ronmental changes. The criteria for landfills and surface impoundments
would eliminate such impacts on floodplains, endangered and threatened
species, underground or principal drinking water sources, and surface
water.
b. Irretrievable Resources Commitments
To be implemented fully, certain of the criteria require ir-
retrievable resource commitments of land, energy and material. These
criteria include those for floodplains, surface water (wetlands and
treatment plants), ground water (lining, collection and treatment), and
air (greater use of land for disposal). The criteria for application to
land used for the production of food-chain crops may result in an irre-
trievable commitment of land if the dedicated facility approach to
cadmium control is opted for by a particular community. Future use of
this land would be greatly restricted.
The economic impacts of these irretrievable resource commitments
are given in Section IVB.
2. DurationofImpact
The final criteria will have certain environmental benefits which
are permanent and others which are only short-term. Short-term bene-
fits are the result of changes in waste disposal methods to eliminate
short-term or reversible adverse impacts. There are also short-term
and long-term economic impacts, discussed above in Section IVB. Long-
term impacts result from preventing irreversible environmental changes.
All of these impacts are shown in Table IV-34.
IV-89
-------
TABLE IV-34
ENVIRONMENTAL IMPACT EVALUATION*
DURATION OF
ENVIRONMENTAL
BENEFIT
Short
Term
CRITERION
1. Floodplains
2. Endangered and
Threatened Species
3. Surface Water +
4. Ground Water
5. Application to Food-
chain Crop Land
a. Heavy Metals +
(Cadmium)
b. PCB's +
6. Disease
a. Disease Vectors +
b. Sewage Sludge and +
Septic Tank
Pumpings
7. Safety
a. Gases +
b. Fires +
c. Bird Hazard +
d. Access +
Long
Term
NATURE OF IMPACT
Irreversible Irretrievable
Environmental Commitment
Changes of Resources
Prevented Required
Yes
Yes
Yes
Yes
Yes
No
Yes
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
* The absence of a plus (+) means no effect for that category.
IV-90
-------
G. ENERGY AND MATERIAL USE
At the present rate of solid waste production, the criteria will
cause increased energy consumption by increasing energy requirements in
many of the phases of solid waste management, including:
new construction
upgrading construction
transportation of solid waste
leachate collection, treatment, and monitoring
gas monitoring.
The increased energy requirements for solid waste disposal are in
contradiction with the national goal to conserve energy unless defin-
ite actions are taken to reduce overall energy use, as supported in the
National Energy Act.
The National Energy Act (NEA) was passed on October 15, 1978 and
contains five bills:
National Energy Conservation Policy Act of 1978
Powerplant and Industrial Fuel Use Act of 1978
Public Utilities Regulatory Policy Act
Natural Gas Policy Act of 1978
Energy Tax Act of 1978.
The passage of NEA was the first major attempt made by Congress to
emphasize the importance of energy conservation in a national energy
policy framework. Several of the acts have particular relevance in
encouraging energy conservation, and thereby reducing the overall
energy demand in the initial phases of solid waste management, espec-
ially resource recovery. These are:
IV-91
-------
Powerplant and Industrial Fuel Use Act of 1978
The requirement for the conversion from natural gas and/or
fuel oil to coal and/or an alternate fuel (e.g., recovered
wastes) forces the consideration of resource recovery.
Energy Tax Act of 1978
A tax incentive plan which offers tax credits on investments
made for the use of alternate fuels and recycling equipment
is outlined and encourages resource recovery.
In addition, at the solid waste disposal facility, energy produc-
tion as well as energy consumption may increase. With the likelihood
of larger and better environmentally-engineered landfills, and as a re-
sult of the criteria requirement for control of explosive gases, there
will be increased direct energy (methane gas) recovery from landfills
with the development of economically-feasible technologies for the
preparation of marketable methane.
Recycling is typically less energy intensive than virgin material
production, when all the stages of material acquisition, transporta-
tion, and processing are considered. One study, for example, estimates
that for five metals evaluated (comprising 80 to 90 percent of energy
consumption in all primary metals industries), secondary metal recovery
required only 1.5 to 31 percent of the energy per ton of product re-
quired by the virgin counterpart material. Other work also suggests
substantial energy savings from paper and glass recycling. Contract
research projects in progress will provide a considerably firmer basis
for developing quantitative perspective in this area (Ref. 137).
Currently, the disposal of solid wastes is done in conformance
with State permit requirements which vary widely across the fifty
States. In States which have very lenient permit requirements or in
IV-92
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which requirements are not enforced, open dumping and open burning of
wastes are practiced because they are the cheapest disposal options.
The criteria will impose nationwide requirements to cover and, under
certain conditions, line landfills, and treat the leachate emanating
from the fill; stop burning; insure proper grading and runoff; control
disease vectors; and control landspreading of wastes. All of these
measures will add to the cost of disposal, which will have the net
effect of making resource recovery more economically attractive as an
alternative. It is very difficult to assess all of the factors which
contribute to a community's decision to recover materials or energy.
However, local governments and private business usually require that
the selected process be at least as inexpensive as the prevailing dis-
posal options, including all economic and financial incentives offered
by the Energy Tax Act of 1978. If the cost of the prevailing disposal
options increases significantly, more and more decision-makers will
choose the resource recovery option. Therefore, the net effect of
these criteria on resource recovery will probably be to enhance its
economic feasibility in the near future.
1. Energy Recovery*
a. Theoretical Potential
In 1973, approximately 135 million tons per year of residen-
tial and commercial solid waste were generated. About 70 to 80 percent
of this waste was combustible, having an average energy content of
about 9 million British thermal units (Btu) per ton. Theoretically,
if all solid waste in the O.S. had been converted into energy in 1972,
about 1.2 quadrillion Btu per year would have been generated. This is
equal to more than 564,000 barrels per day of oil equivalent (B/DOE)**
or 206 million barrels per year of oil equivalent (BYDOE).** Growth
in population and per capita waste generation would cause these figures
to increase to 1,440 trillion Btu per year by 1980, or about 680,000
B/DOE or 248 B/YOE. These and other findings are summarized in Table
IV-35.
* Source of this discussion is Ref. 138
**Explained in Table 51.
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TABLE IV-35 (Ref. 138)
ENERGY POTENTIALLY RECOVERABLE FROM RESIDENTIAL AND COMMERCIAL
SOLID WASTE*
1973 1980
Btu B/DOE+ B/YOE Btu B/DOE B/YOE
(trillion)(thousand)(mil lion) (trillion)(thousand)(mil lion)
Theoretical
Available
Projected
recovery
1,194
899
564
424
206
154
__
1,440
1,085
85
680
512
40
243
187
15
*These estimates are a function of (1) population; (2) the average
amount of residential and commercial solid waste generated per person,
and (3) the energy content of the waste (4,500 Btu per pound). The
heating value of 4,500 Btu per pound (9 million Btu per ton) is gen-
erally accepted for "as received," unprocessed waste as delivered by a
collection truck to a processing or disposal facility.
+ Btu: British thermal unit
+ B/DOE: Barrels per day of oil equivalent. (Assuming 5.8
million Btu per barrel of oil and 365 days per year.)
B/YOE: Barrels per year of oil equivalent.
Based on all Standard Metropolitan Statistical Area
(SMSA's).
NOTE: Different waste processing methods have different recovery
efficiencies. For example, a shredding/air classification waste
processing system loses some potential energy by removing heavy com-
bustibles from the fuel fraction, while high-temperature incinera-
tion with no prior classification would lose far less potential
energy. However, no adjustment was made to allow for such processing
losses or energy conversion efficiencies (e.g., steam or electricity)
because no prejudgment can be made as to which energy recovery method
would be used in any given situation.
IV-94
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b. Available Potential
Not all waste is available for energy recovery. Energy re-
covery systems require large quantities of waste (at least 200 or 250
tons per day) delivered for processing at one site in order to achieve
economies of scale. For this reason, energy recovery appears feasible
only in more densely populated areas, such as most Standard Metropoli-
tan Statistical Areas (SMSA's). If energy recovery had been practical
in all SMSft's in 1973, almost 900 trillion Btu would have been re-
covered. This is equal to more than 424,000 B/DOE*, or 154 million
B/YOE .* By 1980, the energy potentially recoverable from the SMSA
waste stream is projected to be about 1,085 trillion Btu per year, the
equivalent of more than 512,000 B/DOE, or 187 million B/YOE,
c. Impact on Energy Demand
The quantity of energy potentially available from the waste
stream of more densely populated areas (SMSA's) is significant. For
example, the 424,000 barrels per day to oil equivalent that were avail-
able in SMSA's in 1973 is equal to:
4.6 percent of fuel consumed by all utilities in 1973
(9.2 million B/DOE)
10 percent of all the coal consumed by utilities in 1973
(4.1 million B/DOE)
28 percent of the oil projected to be delivered through
the Alaskan pipeline (1.5 million B/DOE)
1 percent of all energy consumed in the United States in 1973
(35.6 million B/DOE)
The energy recoverable from SMSA's can light every home and office
building in the country and is equivalent to twice the gasoline sav-
ings estimated for the .55-miles-per-hour fuel conservation program in
1973-74.
*Explained in Table VI-:34.
IV-95
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Perhaps more significant is the impact on energy needs of indivi-
dual users. For example, many industrial plants can generate at least
half the process steam they use from solid waste fuel, thus reducing
dependence on imported fuel oil and natural gas.
d. Projected Implementations of Energy Recovery Systems
Based on energy recovery systems existing or planned at the
present time, it is projected that by 1980 almost 30 cities and coun-
ties around the country should be operating the equivalent of about
thirty-six 1,000-ton-per-day plants, recovering an estimated 85 tril-
lion Btu per year, or 40,000 B/DOE, or 15 million B/YOE.
2. Material Recovery*
Detailed analyses of the practical quantitative potential for re-
source recovery to save natural virgin resources have not yet been de-
veloped. However/ some preliminary evaluations with respect to re-
source recovery potentials have been made that suggest the order of
magnitude of virgin material savings at issue.
While it is known that the potential for material recovery in in-
dustry exists, quantitative projections have not been made. Although
the quantities are small, nitrogen, phosphorus, zinc, cadmium, magne-
sium, selinium and manganese are recoverable from industrial processes.
Table IV-35 summarizes the recycling potentials for selected ma-
terials in post-consumer municipal waste in relation to certain mea-
sures of U.S. material consumption. The estimated recovery potentials
for the individual materials are based on the following assumptions:
(1) 95 percent of the waste generated is collected, either through
mixed-waste collection or specialized source-separated collection sys-
tems; (2) 70 percent of the collected waste is processed for recovery
IV-96
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of specific material and energy values (roughly equivalent to the waste
collected in U.S. SMSA's as defined by the O.S. Department of Com-
merce); (3) with respect to paper, it is assumed that only 40 percent
of SMSA collected weight is processed for fiber recovery; and (4) with
respect to the material actually processed for recycling, final mater-
ial recovery efficiency is assumed to be 80 percent. Although crude,
these assumptions are consistent with current knowledge of the waste
system itself and current (or soon-to-be-available) technology for ma-
terial recovery.
The final national recovery ratios themselves 53 percent for
minerals and 21 percent for total paper represent practical maxima
from a technical standpoint. They assume, for example, the existence
of large-scale recovery plants serving the entire U.S. SMSA population,
and they also assume implicitly a significant expansion in material-
user-industry capacity in most instances. They are thus, obviously, not
recovery values that could be implemented or achieved in the near fu-
ture under any circumstances and should not be so interpreted. They
represent what could conceivably be achieved with current or near-
future technology under a very vigorous implementation program. Note
that because they are based on current waste flow, they represent net
additions to any recovery already being achieved.
Thus, for example, if the incremental recycle quantity has been
achieved in 1971 for iron, then assuming the same total demand for the
material, it would have been possible to have supplied about 7 percent
of this demand from the municipal waste stream rather than from domes-
tic or imported virgin sources. For the six materials shown, the per-
cent of U.S. consumption that could have been supplied from post-con-
sumer wastes is seen to range from a low of 3 percent for lead up to as
much as 18.9 percent for paper and paperboard products.
IV-97
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The set of ratios in the next-to-last line of Table IV-36 is most
indicative of U.S. natural resource conservation benefits because it
relates to U.S. primary production based on domestic ore (or forests,
in the case of paper). The potential reductions in primary production
from virgin domestic resources could have amounted to 10.3 percent for
iron, 9.4 percent for copper, 6.8 percent for lead, 21.5 percent for
paper, and over 100 percent for aluminum and tin. In the case of alum-
inum, for which 90 percent of the U.S. primary production is based on
imported bauxite and alumina, it would have been possible in principle
to have reduced the aluminum industry's demand for domestic bauxite to
zero and also to have reduced imports. In the case of tin, where the
U.S. produces negligible quantities of ore and refines less than 1 per-
cent of our virgin consumption, the total substitution would neces-
sarily have to come entirely at the expense of imports.
Two principal conclusions emerge from these figures. The first is
that recycling post-consumer waste materials is not a panacea in the
sense that it cannot be expected to supply the majority of the Nation's
raw material demands. On the other hand, the substitution possibili-
ties,both with regard to total consumption and domestic virgin material
supply, are not insignificant.
In addition to these direct material resource savings, there will
also accrue further net indirect savings in the form of reduced capital
equipment and other material input requirements in the mining, ore re-
duction and beneficiation, and smelting sectors of the virgin mineral
industries, as well as similar reductions in the tree harvesting, wood
preparation, and wood pulping segments of the pulp and paper industry.
No attempt has yet been made to evaluate these in quantitative terms.
There will be, of course, some offsetting new capital goods require-
ments for processing the waste materials, but these generally appear to
be substantially less than those for virgin material.
IV-98
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APPENDIX A
CRITERIA FOR CLASSIFICATION OF SOLID
WASTE DISPOSAL FACILITIES AND PRACTICES
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