IPA/530/SW-156


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    An environmental  protection publication in the solid waste management
series (SW-156).  Mention of commercial  products does not constitute
endorsement by the U.S. Government.   Editing and technical  content of
this report were accomplished by the Hazardous Waste Management Division
of the Office of Solid Waste Management  Programs.

    Single copies of the publication are available from Solid Waste
Management Information Materials Distribution, U.S.  Environmental
Protection Agency, Cincinnati, Ohio ^5268.

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                   INDUSTRIAL WASTE MANAGEMENT

                     Seven Conference Papers
            These papers (SW-156)  were presented to
the National Conference on Management and Disposal  of Residues
         from the Treatment of Industrial Wastewaters
               Washington, D.C.,  February 1975
              U.S.  ENVIRONMENTAL  PROTECTION  AGENCY
                              1975

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                         FOREWORD
     With the passage of the Clean Air Act of 1970, the Federal
Water Pollution Control Act Amendments of 1972, the Marine
Protection, Research, and Sanctuaries Act of 1972, and the Safe
Drinking Water Act of 1974, came the gradual clean up of industrial
effluents to the air and water and a resultant dramatic increase
of land disposal of these wastes.  Concern is now shifting from
effluent treatment to the safe disposal of the treatment residues,
for it stands to reason that if it is unsafe to dispose of a waste
to the air or water, it is likely to be unsafe to dispose of it
haphazardly on land.

     EPA's Office of Solid Waste Management Programs has the
principal responsibility to lead EPA in dealing with this problem.
This responsibility includes problem definition and solutions, and
to make the affected industries and the general public aware of
both.  This collection of papers gives the overview and the context
of the problem, as well as illustrating specific examples of the
work being done in EPA.

     These papers were presented at the National Conference on
Management and Disposal of Residues from the Treatment of Industrial
Wastewaters in February 1975, in Washington, D.C.

     It is hoped that they will lay the groundwork for an under-
standing of the hazardous waste problem and its solutions.
                                    — ARSEN J. DARNAY
                                       Deputy Assistant Administrator
                                       for Solid Waste Management

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Table of Contents                                       Page


Keynote Address, Roger Strelow                            1

Industrial Waste Disposal Overview, John P. Lehman       10

Summary of Damage Incidents from Improper Land
 Disposal, Emery Lazar                                   32

Waste Volumes and Characteristics from Inorganic
 Chemical Industries, Sam Morekas                        47

Waste Clearing House Concept - Experience in Europe,
 Chris Porter                                            68

Overview of Land Disposal Technology for Industrial
 Wastes, Alfred Lindsey and Donald Farb                  78

Summary of State Standards for Industrial Residue
 Disposal, Murray Newton                                 98

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                 REMARKS BY MR. ROGER STRELOW
    ASSISTANT ADMINISTRATOR FOR AIR AND WASTE MANAGEMENT,
           U. S. ENVIRONMENTAL PROTECTION AGENCY
           BEFORE THE NATIONAL CONFERENCE ON MANAGEMENT
           AND DISPOSAL OF RESIDUES FROM THE TREATMENT
           OF INDUSTRIAL WASTE WATERS.
               Washington, D.C. ~ February 3, 1975
     Good morning ladies and gentlemen.  It gives me great
pleasure to be here today and to open this very important
meeting.  I am impressed with the seriousness and the "let's
get down to business" attitude of our program.  I will try
to keep my remarks in the same vein.
     The generation of residues from the treatment of industrial
wastewaters and stack gases is increasing at a fantastic rate.  We
expect that for some industries the wastes destined for land disposal
will double in the next 10 years due largely to air and water pollu-
tion control regulations.  Already in many industries, pollution
treatment residues greatly exceed all other forms of process wastes.
Much of this waste contains hazardous materials, and whether hazardous
or not, their management and disposal has become a major problem to
both industry and government.
     I would like to identify, first, the threat to both public
health and the environment posed by the haphazard storage, insufficient
treatment, and improper disposal of hazardous residues.  Because of
their concentration, quantities, or properties, these wastes are
frequently non-degradable or persistent in nature, often can be
biologically magnified, and may even be lethal.
      The potential for contamination of our public water supplies
through leaching from storage and disposal sites is a major concern.
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     The potential for contamination of our public water supplies
through leaching from storage and disposal sites is a major concern.
The leachate which is formed from water percolating through a disposal
site containing industrial sludges or residues from pollution control
facilities may contaminate groundwater supplies with heavy metals
and other chemical substances.  This is a potentially serious problem
since approximately 50 percent of our domestic water supplies in the
United States are derived from groundwater aquifers.
     Toxic substances can enter the environment not only by leaching
into the groundwater but also by sublimation and evaporation into the
atmosphere, or by overload runoff, or it may be taken up by nearby
vegetation.
     In addition, anyone coming in direct contact with these wastes --
such as workers, children, or animals -- can be injured or killed from
poisoning, skin contact, explosion, or fires.
     As we learn more about the components of hazardous wastes and
their effects upon man and the environment, we realize that special
care is needed for their handling and that we can no longer  rely on
the simple, customary means of waste treatment and disposal.  Based on
our findings in this area, we recognize that comprehensive Federal,
State or local regulations controlling hazardous wastes have been lacking.
As a result there has been little or no guidance or assistance to
industry on adequate treatment and disposal.

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     Vast sums of money have been invested by American
industry in wastewater treatment and emission control facilities.
But I shudder when I see what comes out at the end of the pipe --
the foul poisonous liquors pouring into lagoons or the piles of
noxious dusts.  I shudder to think that, were it not for these
treatment facilities, that stuff would be going into the air we
breath and the water we drink.  But mostly, I shudder to think
"what is to become of all this poisonous residue?  Where will it end
up?  In the groundwater?  In the sewer?  Blown into the air?  Are we
really saving our environment, or are we just engaged in some
monstrously expensive folly which merely collects and redistributes
pollution?"
     I know many of you have the same thoughts.  I recently heard
a story of a factory which built a multi-million dollar sewage
treatment plant and engaged a waste hauler to remove the sludge,
under assurances that it would be taken to an approved sanitary
landfill, only to find out later that it was being dumped in the
local creek which the treatment plant was built to protect.  I
know that soms of you could tell similar stories which make you
wonder if anybody knows what's going on.

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officials are only dimly aware of the full  scope.   The principal
environmental threat from residual  disposal is the threat of
groundwater pollution, which is also out of public sight.  Therefore,
public pressure simply has not been felt.  Nevertheless, we who know
that there is a growing problem have a responsibility to act when it
is clear that merely reacting is not good enough.   We must take the
lead in informing the public of the dangers of haphazard disposal of
industrial wastes and we must aggressively seek out new solutions.
     I have confidence that the environmental  "wall" will be completed.
With your cooperation and, your constructive criticism, we will
do our part to continually improve it and perfect it.  What we have
lacked in foresight we must now make up in perseverance.  In this
connection, EPA's Office of Solid Waste Management Programs is
preparing guidance and demonstrating new and improved treatment and
disposal technology for residuals management,  which other speakers will
address at this conference.
     Congress, too, is moving.  In spite of scant public pressure, several
bills dealing with hazardous waste management were surfaced in the last
session, and although none was passed, the prospects appear good for a
bill in this session.  The kind of bill we would like to see would
have EPA define what is and what isn't a potentially hazardous waste,
for land disposal purposes, and that the treatment of wastes be based
on "best available technology," taking into account the degree of
hazard and the cost of compliance.

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     Environmental regulation has been piecemeal.  Our
environmental laws and regulations are like the walls of
an ancient city, built in pieces by different people at
different times for different purposes.  There are several
gaps, including one where residual disposal guidelines and
standards ought to be.  There are some who will argue that
because the wall doesn't afford complete protection it should
be torn down.  And there are others who will silently take
advantage of the gaps.  But there are others who would plug
the gap, as your presence here bears witness.  I know the wall
is not perfect.  It may be too high in some places and certainly
is too thin in others.  But we have a big investment in that wall,
and our very lives depend on it.  We must plug the gaps.
     Why has this happened?  Why do we find these gaps?  In
a democratic society, the government tries to respond to the
pressures at hand, and that is as it should be.  In the past,
the public has shown justifiable concern over their air, their
rivers and their oceans, and the public representatives have
reacted to this concern.  But in doing so we have significantly
                                                         i
added to the problem of industrial solid waste disposal.  It is a
problem which has been out of public sight and therefore out of
the public's mind.
     The vast network of industrial residual generation and
disposal is carried on in concentrated isolated places, on
private property behind fences.  The public is hardly aware
of its existence.  Even local health and waste disposal

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     We would like to minimize Federal  involvement, and have the States
establish hazardous waste generator reporting systems and grant
permits for waste storage, treatment and disposal  subject to State
regulation under Federal guidelines.  We would like to limit direct
Federal regulation to only the most imminently hazardous wastes.
     EPA is a regulatory agency, and regulation is often viewed as a
negative business.  In keeping with the mood of this conference,  I
would like to help dispel this notion by dwelling on the more positive
aspects.  We have been, and would like to continue to be in the forefront
of promoting and disseminating better ways to handle residues.
Of course, we would prefer it if there were no residue  at all.
I am convinced that in many industries, residues can be substantially
reduced or even eliminated through process improvements.   We will keep
aware of such improvements and promote their implementation.
     We will continue to promote technology which will recover resources,
especially energy, from wastes.  We believe that environmental regula-
tions will lead to massing and centralized treatment of wastes, which
will provide the economics of scale necessary to recover and reuse
wastes limited only by ingenuity and enterprise of American
industry.  I see whole new industries springing up to recover and

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reuse industrial wastes.  This movement is inevitable,
and environmental considerations only serve to accelerate it.
You know better than I how material shortages and high energy costs
are causing American industry to husband its resources.
     In this connection, a report released last year by the National
Commission on Materials Policy called for under the Resource Recovery
Act of 1970 clearly outlines where we are headed if we don't change our
ways fast: toward greater dependence on other countries for vital
materials and predictable worldwide shortages for some materials,
especially as competition for them increases with increasing
industrialization in other parts of the world.
     The United States has run out of chromium and manganese, which are
vital to steel-making, and we import most of the bauxite which we use
for aluminum.  Of the 13 basic raw materials required by our modern
economy, we depended on imports for more than half of our supplies of
six of these in 1970.  By 1985, it has been projected that we will be
primarily dependent on imports for supplies of nine of these 13 raw
materials.
     There is evidence that suppliers of some raw materials have
attempted to emulate the organization of petroleum exporting countries,
and the politics of petroleum may become the politics of copper or
bauxite.  Whether or not these attempts are successful, there is
real reason for concern.  It would be folly in this day and age to
continue to fail to recover resources.

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     If the era of boundless resources is over, the era of limitless
dumps is over as well.  Both facts combine toward the same solutions --
recovery and reuse of wastes.  We at EPA are committed to making
recycling happen -- for both energy and materials.  The tools we
use are technical assistance, front-end planning assistance, and
system demonstration -- all three to the extent permitted by our
financial resources.  I know this won't come about overnight and
in the interim years, we must continue to deal with improving the
means of waste disposal and storage so that contaminants do not
enter the environment.
     The gains in cleaning up our air and water have created a
massive solid waste disposal problem for which industry has very few
management options.  Lack of available landfills to dispose of waste
in an environmentally acceptable manner, and the closing of many
landfills which do not meet environmental requirements, are placing
a much greater burden on existing acceptable landfills and forcing
industry to consider other alternatives such as operation of their own
landfills, or incineration.
     EPA is concerned and is working to develop and demonstrate
environmentally safe disposal and storage techniques as well as to
disseminate information on available waste handling facilities.  A
great deal of our time is spent answering inquiries on specific
problems, and we have helped many communities and industrial firms
find solutions to their waste disposal problems.

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     In closing, let me say that we must start thinking of clean
air and water as industrial resources.   We cannot continue to foul
our environment with our wastes and then move on when the stench
gets too bad because there will be no place to go.   And besides,
every bit of waste that comes out of a plant by the back door was
bought and paid for as raw material when it went through the front
door.  In other words the environment is not only birds and trees and
nature walks, it is also our natural resources which are our future
if we are going to remain an industrial nation.
     Thank you very much.

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           INDUSTRIAL WASTE DISPOSAL OVERVIEW

                   by John P. Lehman*
ABSTRACT.  Industrial waste management is emerging as a
major problem for all industrial nations.  In the context
of this paper, "industrial waste" refers to non-recycled
process and pollution control residues.  In the past,
industrial wastes have been largely ignored by the public
and government officials because traditionally these
wastes are managed outside the municipal waste collection
and disposal system.  This situation is changing rapidly,
however.  Recent studies show that industry produces
twice as much waste per year as is generated by municipal
sources, and 35 times more waste than do sewage treatment
plants.  Industrial waste quantities destined for land
disposal are expected to increase by up to 100 percent in
some industries in the next decade largely due to the
installation of pollution control equipment.  Improper
land disposal of industrial waste can result in ground
and surface water contamination and air pollution.  These
problems often go unnoticed because the effects are
usually long-term and chronic rather than acute.
Although technology is available for proper management of
many industrial wastes, it is expensive and not generally
used.  Further, the land disposal of industrial waste is
essentially unregulated.  Consequently, EPA has adopted a
regulatory strategy for the management of industrial
wastes with emphasis on resource recovery whenever
possible.

     Mr. Chairman, ladies and gentlemen, I am very pleased

to be here to discuss the management of industrial wastes,
     *Mr, Lehman is the Director of the Hazardous Waste
Management Division, Office of Solid Waste Management
Programs, U.S. Environmental Protection Agency.
                            10

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that is, non-recycled process and pollution control



residues.  Although the primary focus of this meeting is



on industrial wastewater treatment residues, I will try



to give you a perspective on how this aspect fits into



the overall industrial waste management picture.








     We in the United States are not alone in our concern



about the impact of industrial residues on our society.



This is emerging as a major problem for all industrial



nations.  Several international organizations have



recognized the problem and are beginning to develop



industrial waste management guidelines.  The World Health



Organization and the NATO Committee on the Challenges of



Modern Society both have active programs in this area.



In addition, the Scandinavian countries, Switzerland, and



Japan all have industrial residue control programs.  In



fact, the United States is lagging behind many European



countries in its industrial waste management program.








     Why is this so?  First, industrial wastes have been



largely ignored by the public and government officials



because traditionally these wastes are managed outside



the municipal waste collection and disposal system.



However, many of these wastes end up at the same disposal



site as municipal solid waste.  Second, we have a lot of



open land in this country.  Land is not as precious a
                           11

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commodity here as it is in European countries and Japan.



Consequently, land use is not as intensively managed, and



improper land disposal practices have been carried out



virtually unnoticed.







     But this situation is changing rapidly.  New



environmental laws and public awareness, new emphasis on



land use policy, and some celebrated cases of improper



waste management have swung the public searchlight into



focus on industrial wastes.  Consequently, the magnitude



of industrial waste generation and the public health and



environmental effects of improper industrial waste



disposal to the land have come under serious study in the



last year or two.








     Before quoting facts and figures, let me be



scholarly for a moment, and define some terms.  In Figure



1 Tfve shown a schematic of industry process outputs.



The main output is the product, of course.  There is some



non-process waste, such as office paper and cafeteria



waste, which is usually collected by a municipal system;



we count that as "municipal" waste.  The main waste



source is the manufacturing process itself.  In our



thinking, there are three process-related residual



streams:
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     (1)  Process sludges and residuals;







     (2)  Air and water pollution control sludges and



          residuals, and








     (3)  Wastes reused in the basic process (termed



          "home scrap") or recycled in the secondary



          materials market.








     In EPA's studies, we try to track all three, but in



what follows, when I say "industrial waste," I refer only



to the first two, that is, non-recycled process and



pollution control residues.








     In order to put industrial residuals into



appropriate perspective, Figure 2 shows the relative



contribution of all sources to the total waste stream.



Although mining wastes greatly overshadow all other waste



streams, they are largely composed of overburden which,



while representing a major materials handling problem,



appear not to represent as widespread an environmental



problem as manufacturing wastes.  Crop and feedlot wastes



represent almost all of the agricultural waste



production.  The potential for reuse and natural



degradation of crop and feedlot wastes diminish their



relative significance.
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                  FIGURE 2
         ESTIMATED INDUSTRIAL
       VERSUS OTHER RESIDUALS *
(DRY WEIGHT  IN MILLION TONS PER YEAR)
           AGRICULTURAL
               687
                           INDUSTRIAL
                              260
                             MUNICIPAL
                                135**
  * DATA REPRESENTS VALUES FROM 1970-1974.

** REPRESENTS VALUE "AS GENERATED" LE_. WITH MOISTURE.

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     The true magnitude of the industrial waste situation



is now beginning to come into focus, and the picture we



see is alarming.  Not many people appreciate the fact



that industry produces about 260 million dry tons of



waste per year which is almost twice as much waste each



year as is generated by residential and commercial



sources.  Further, industry generates about 35 times more



waste than do the sewage treatment plants; yet one hears



a lot more talk about the sewage sludge problem than the



industrial sludge problem.







     The industrial waste figures include about 40



million tons per year of residuals from the electric



power utility industry (bottom ash, fly ash, and captured



particulates).  Sulfur oxide scrubbers are not yet widely



used, so there are only small amounts of SOx scrubber



sludges being generated at present.







     The industrial waste figures are for the current



situation.  When the Effluent Limitation Guidelines



mandated by the Federal Water Pollution Control Act



Amendments go into force in 1977 and 1983, and as



industry gears up to meet the Clean Air Act requirements,



we estimate the industrial waste figures will jump



dramatically in many industries.
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     To illustrate, in Figure 3 I»ve shown our estimates
of the combined total waste and the pollution control
residual fraction for four major industries  (Inorganic
Chemicals, Paper, Steel, and Nonferrous
Smelting/Refining)  in 1971, 1977, and 1983.  The total
waste increases by 70 percent in 1977 and by 100 percent
in 1983.  A large part of the increase is due to the
anticipated installation of pollution control equipment.
Pollution control residuals account for about 75 percent
of the total waste in these industries.  While all
industries may not have this degree of waste growth, the
trend is unmistakable.

     These industrial waste quantity and growth estimates
are somewhat staggering.  But, an aspect causing even
greater concern is that many of these wastes are
potentially hazardous.

     Hazardous waste includes toxic and carcinogenic
chemicals, pesticides, acids, caustics, flammables,
explosives, biological and radiological residuals.  For
our 1973 Report to Congress on Disposal of Hazardous
Waste, we estimated the total amount of non-radioactive
hazardous waste generated in the United States to be
approximately 10 million tons per year.  Recent
information indicates that this number may be on the low
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              FIGURE 3
      PROJECTED GROWTH OF
 COMBINED WASTE QUANTITIES FOR
 FOUR REPRESENTATIVE INDUSTRIES
  (INORGANIC CHEMICALS, PAPER,
STEEL, AND NON-FERROUS SMELTING)
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                            1983
        PROCESS RESIDUE

        POLLUTION CONTROL RESIDUE
                   1977
1971
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side.  About 40 percent of these wastes by weight is



inorganic material and 60 percent is organic; about 90



percent occurs in liquid or semiliquid form.  Over 70



percent of hazardous wastes are generated in the mid-



Atlantic, Great Lakes, and Gulf Coast areas of the United



States.







     Mr. Strelow, EPA's Assistant Administrator for Air



and Waste Management, pointed out earlier in the program



that the public health and environmental effects of



improper disposal of hazardous wastes to the land are



manifested in many ways, ranging from ground and surface



water contamination by leachate from landfills to



personal injury via direct contact and explosions which



may result from the mixing of wastes in landfill



operations.  You will see some graphic examples of these



problems later on during Mr. Lazarfs presentation.







     Everyone can empathize with short-term, acute



environmental problems.  When a toxic chemical is dumped



in a river and a massive fish kill results, everyone



agrees we've got to clean up our water.  When people keel



over on the sidewalks during a smog alert, there is a



great hue and cry about cleaning up our air.
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     But improper Idnd disposal of industrial wastes



often goes unnoticed because the impacts occur on a



longer term and are chronic rather than acute.  It takes



decades, in some cases, for hazardous compounds which



have been buried in the land to leach through the soil



into our surface and groundwater supplies.   This was



amply demonstrated recently in Minnesota where several



people were hospitalized after drinking well water



contaminated by arsenic wastes buried 30 years ago on



nearby land.







     Adverse impacts to the public health and the



environment occur because of open dumping and burning of



industrial wastes or improper use of existing landfills.



These actions can be either overt or covert.  Also,



improper use of holding ponds on industrial land and



improper storage techniques cause problems.







     We believe that the reason this situation exists is



that there are no widespread economic or legislative



incentives for proper industrial waste management.







     We have found that technology is adequate for the



treatment of many industrial wastes by physical,



chemical, thermal or biological means.  Specially



designed landfills which isolate such wastes from the
                           20

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environment via natural or artificial membranes, with gas



and leachate collection where necessary,  can be and have



been built.  There are secure storage facilities



available for those few wastes to which current treatment



and disposal technology does not apply.







     The main problem is that the use of  this technology



is expensive and far exceeds the cost of  current



practice.  For example, the incineration  of wastes can



run as high as $50 per ton, whereas the current



inappropriate practices of open dumping or ocean dumping



cost less than $3 per ton.  So, we have a wide cost



variation between acceptable industrial waste management



practices and the cheap, unacceptable practices generally



used.








     The land disposal of industrial and  hazardous waste



is essentially unregulated at the Federal level and in



most States.  Only two Federal authorities deal with



parts of the hazardous waste management problem.  The



Federal Insecticide, Fungicide and Rodenticide Act, as



amended, provides for EPA regulation of the storage and



disposal of waste pesticides and containers.  The Atonic



Energy Act of 195U, as amended, provides  for AEC



regulation of these radioactive wastes produced in a



fission reaction; naturally occurring radioisotopes (such
                           21

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as radium)  and those produced by accelerators are



excluded.  Although most pesticide and radioactive wastes



are certainly hazardous, in aggregate they represent only



a small fraction of the total industrial waste problem.



Consequently, we have a big gap in the wall of



environmental law that Mr. Strelow referred to.








     We have reached the conclusion that environmental



insult and hazard of improper waste management will



continue in the absence of strong, uniform regulation of



land disposal and vigorous enforcement of regulations.



The longer the economic pressures tilt the balance toward



improper disposal, so long as no consistent and uniform



rules exist for public and private operations, and so



long as offending sites cannot be closed because no



alternatives exist, the necessary transition from poor



waste management to optimum management will not take



place.  For this reason, and because jawboning alone



appears insufficient to achieve acceptable standards, we



believe the key to the problem solution is government



regulation of waste management.








     Since hazardous wastes pose a particularly ominous



threat to public health and the environment, it is our



belief that, these wastes must be controlled from the



cradle to the grave in order to achieve effective waste
                           22

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management.  It is not sufficient to regulate only the



land disposal phase, since many uncontrolled pathways to



the environment would still exist.  Consequently, our



regulatory strategy includes hazardous waste generator



reporting requirements and waste hauler controls in order



to close the circle on hazardous wastes.







     We have attempted to establish a reasonable scenario



for hazardous waste flow after generation  (Figure 4).



Our philosophy, as the land protection group within EPA,



is to minimize hazardous waste disposal to the land.   Our



philosophy closely parallels that of the ocean disposal



group in this regard since both the ocean and the land



are ultimate "sinks" for residues of our society.



Consequently, we strongly support hazardous waste



recycling or detoxification treatment prior to land



disposal wherever possible.







     Our main strategy will be to concentrate hazardous



waste at the source rather than to dilute them into the



environment.  Hazardous waste concentration minimizes



handling and transport problems, makes resource recovery



from these wastes economically more attractive, and



allows better management control.  Such concentration



will occur naturally as air and water pollution control



systems extract noxious pollutants from waste flow
                           23

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streams,  Also, product bans, such as DDT, will result in



large, concentrated stocks of excess materials.








     We support the concept of an industrial and



hazardous waste clearing house, that is, to use the waste



as is, if possible (Figure 5).  One man's waste is



another man's teed stock.  A firm in Oakland, California,



was recently formed to provide this service for the



western area.  The clearing house concept has been



adopted recently in England, Scandinavia and West



Germany, as well.








     _Many industrial wastes contain valuable basic



materials, some of which are in short supply.  Chemical



treatment for material recovery makes sense from both



resource conservation and environmental points of view,



Extraction of materials from concentrated waste generally



requires less energy, and generates far less air and



water pollution, than the mining and processing



operations required to produce the material from virgin



resources.  As material shortages become more widespread,



material recovery from industrial waste will become more



economically attractive.  Even so, we know of one eastern



firm that actually buys industrial chemical waste for



material recovery right, now.
                           25

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     If industrial waste cannot be used or materials



recovered from it, and if it can be safely burned, we



would next recommend destruction by incineration with



energy recovery during this operation, if possible



(Figure 6).   Incineration of industrial waste generally



requires special, high-temperature equipment with



effective scrubber systems and effluent monitors.



Several large corporations and waste processing firms



have these incinerators in operation now, but they are



not commonly available throughout the nation as yet.








     Non-burnable hazardous wastes should be detoxified



and neutralized by chemical or biological treatment,



where possible, to minimize the amounts of toxic



materials destined for land disposal.








     For hazardous wastes not amenable to recovery or



destruction, we recommend volume reduction to minimize



land use requirements, followed by isolation techniques,



such as encapsulation, prior to land burial in specially



designated landfills which in turn may be isolated from



groundwater  supplies by natural geologic formations or



artificial membranes  (Figure 7).  Monitoring and



surveillance systems are required for such landfills to



detect any leachate and prevent unauthorized entry.
                           27

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                                    28

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    HI
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                                                     29

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     Let me summarize our perceptions of the industrial



waste management situation in the United States at this



time.  First, we now know that we have a problem, a major



problem which is common to all industrial nations.  We



know that industry produces almost twice as much waste



each year as is generated by municipal sources, and that



industrial waste is growing rapidly due? to several



factors.  We have found that the technology for adequate



waste management generally exists for many industrial



wastes but that this technology is costly, approximately



10 to 20 times as expensive as current unacceptable



practices, which consist mainly of land dumping or ocean



disposal.  Consequently, there are no economic incentives



for the use of this technology and, furthermore, there



are no strong regulatory incentives at either the Federal



or most State levels.








     Consequently, EPA has developed a regulatory



strategy for the management of industrial wastes with



emphasis on resource recovery wherever possible,  This



program will require a joint Federal, State, and private



sector response.  We see a lengthy period during which



legislation and regulations are developed and facilities



are made available, but eventually we would foresee a



regulatory program with adequate enforcement to prevent
                           30

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the potential public health and environmental damages



which can occur from improper management of these wast.es.
                              End
                           31

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                   SUMMARY OF DAMAGE INCIDENTS
                   FROM IMPROPER LAND DISPOSAL
                        by Emery C,  Lazar*
     Abstract.   The hazardous  waste disoosal  problem  has  assumed
     particularly significant  proportions  lately  because  of  the
     progressive implementation  of air  and water  pollution control
     programs,  ocean dumping bans, and  cancellation of  pesticide
     registrations.  The net result has been  an increased tonnage
     of land-disposed wastes,  with adverse impact on  public  health
     and the environment.   The problem  is  manifested  in groundwater
     contamination via leachate, surface water contamination via
     runoff, air pollution via onen burning,  evaporation, sub-
     limation and wind erosion,  poisonings via direct contact and
     through the food chain, and fires  and explosions at  land dis-
     posal  sites.  The subject presentation cites case  studies
     that are associated with  these various mechanisms  of damage.
     Several  speakers at this Conference have already dwelt  upon  the

growing trend to dispose of hazardous  industrial  wastes  on the  land,

as the Nation is moving toward implementation of  more stringent

reouirements  governing the discharge of toxic pollutants into the

media of air  and water.  Our studies to date have indicated  that  the

prevailing methods of land disnosal  of hazardous  wastes  are  largely

inadequate, due to a general lack of economic and legislative
     *Mr. Lazar is Program Manager—Public Health and Environmental
Damaqe Assessment, Hazardous Waste Management Division,  Office of
Solid Waste Management Programs, U.S.  Environmental  Protection Agency.

                               32

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incentives.^  This oaoer will  give an overview of the tyoes of
damages that can result from improper land disposal  of hazardous
wastes.
     Before entering into a discussion of damages, I would like
to emphasize that the term "damage" does not need to be associated
with a reported human or environmental injury of some sort.  The
Office of Solid Waste Management Programs has on file case studies
that document various degrees of injury to humans — some even with
fatal outcome—as well  as a broad spectrum of environmental damage.
It must be remembered,  however, that most cases of toxic exposure
to hazardous pollutants manifest themselves in insidious chronic effects
that are almost imoossible to trace back to the causative agents.
Onlv in rare instances  of chronic ooisoning is a positive correlation
of cause and effect oossible.
     In order to understand the full  extent of the problem, we at
the EPA have had to revise our concept of the damages resulting
from hazardous waste disposal  to include damages which are not
reoorted, not recorded, and not even known.   For examole, if
someone is drinking brackish well  water and not comnlaining because
he feels he has no alternative, he is damaged.   And  if someone drills
a well  and cannot use the water he finds and so has  to drill  another
well, he is damaged.  And if a company decides not to ooen a  plant
in a town because the groundwater is polluted,  there is damage.
In fact if leachate moves from a disposal  site to another person's
nronerty, even if no one uses  the water or is aware  of the movement,
                                33

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there is damage because the property owner has been deprived of the
potential use of his groundwater.
     We have investigated damage incidents which can be attributed
to the improper land disposal  of those industrial  wastes that fall
under the "hazardous" category, as defined in several  bills that
have been introduced to the Congress during the past two years.
In each case study the wastes  have constituents that "...  pose a
substantial  present or potential  hazard to human health or living
organisms because such wastes  are nondegradable or persistent in
nature or because they can be  biologically magnified,  or because they
can be lethal, or because they may otherwise cause or  tend to cause
detrimental  cumulative effects."*  Generally, the available case
studies pertain to hazardous chemicals belonging to the following
categories:   (a) toxic metals  (e.g., arsenic, chromium, lead, mercury,
cadmium); (b) toxic anions (e.g.,  cyanide and fluoride); and (c) a
variety of toxic organic chemicals (e.g., miscellaneous pesticides,
polychlorinated biphenyls, other chlorinated hydrocarbons, industrial
solvents).
     There are six major routes of environmental transport through
which the improper land disoosal  of hazardous wastes can result in
damage:
     1.  Groundwater contamination via leachate;
     2.  Surface water contamination via runoff;
     *This definition appeared in the Proposed Hazardous Waste
Management Act of 1973.
                                 34

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     3.  Air pollution via open burning, evaporation, sublimation,
         and wind erosion;
     4.  Poisoning via direct contact;
     5.  Poisoning via the food chain;
     6.  Fire and explosion.

     In the following, each of these forms of damage will be dis-
cussed in turn.  It is not the purpose of this paper to point an
accusing finger on any particular firm or industry category.  Our
objective is to demonstrate that the problem of hazardous industrial
waste disposal is real.  A public recognition of the problem is
paramount to its solution.

1.   Groundwater contamination via leachate
     It is interesting to note that the problem of groundwater
contamination received almost no attention until very recently,
although approximately fifty percent of the Nation's domestic water
supplies are derived from underground aquifers.   Throughout the
eighty-nine pages of the Federal Water Pollution Control  Act Amendments
of 1972, the term "groundwater" appears only twice!   It is encouraging
to note that there is a steadily growing concern now for  groundwater
quality, as evidenced by the recently enacted Safe Drinking Water Act.
     The quality of our groundwaters is closely related to land
disposal practices.   A recent study sponsored by the EPA  investigated
the groundwater situation in eleven northeastern States.   The study
concluded that the thousands of acres of landfills containing municipal
                                 35

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and industrial solid wastes are an almost universal  source of ground-
water contamination in the region investigated.   Another  major conclusion
was that industrial storage and disposal  lagoons, pits, and basins
are leaking many millions of gallons per  year of potentially hazardous
                              2
substances to the groundwater.
     The major perils inherent in groundwater contamination are the
elusive nature and the long duration of the problem.   Almost all  of
the case studies reported to date were discovered after the damage
to the groundwater had already occurred.   Also,  the  subsurface
migration of pollutants is a very slow process,  which  means that most
of the damages caused by the disposal  of  huge quantities  of hazardous
wastes during the past decades are still  to be evidenced.   And once
the problem manifests itself, it may take decades or centuries and
enormous resources--if the technology  is  available—to remedy  the
damages.  The following case studies will serve to illustrate these
points.
0    As a result of burying arsenic-containing pesticides in
     Minnesota in the mid- 1930's, eleven persons developed
     symntoms of arsenic poisoning in  1972, after drinking
     contaminated well water.  Two of  the victims required
     hospitalization and treatment.
0    A New York electroplating firm has been discharging  its
     waste waters into unlined settling ponds since  the early
     1940's.  Although the effluents have received chemical
     treatment since 1958, the surrounding groundwater was
                                 36

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recently found to be still contaminated with toxic
cadium and hexavalent chromium.
From 1953 to 1973, a laboratory company in Iowa utilized
a dump site for solid waste disposal.  Over 250,000
cubic feet of arsenic-bearing wastes have been deposited
there.  Monitoring wells around the dump have established
over 175 com arsenic in the groundwater.  (The U.S. Public
Health Service drinking water standard for arsenic is
0.05 ppm.)   The dump site is located above a limestone bed-
rock aquifer, from which 70 percent of the nearby city's
residents obtain their drinking and crop irrigation water.
Although there is no evidence that the drinking water is
being affected, the potential for contamination cannot be
underestimated.
In 1971, a major chemical  company contracted with a trucker
to haul approximately 6,000 drums of petrochemical wastes
to a landfill for disposal.  Instead, most of these wastes
were transported to an abandoned chicken farm in New Jersey,
where they were stockpiled and subsequently dumped.  Within
two years, a major aquifer had become contaminated with
petrochemicals, resulting in the condemning of approximately
150 private wells.  The cost of extending public water
supply into the area was about $300,000.  Moreover, this
incident resulted in adverse impact on local  building and
development.   The exact magnitude of the environmental  and
economic damage has not yet been delineated.
                            37

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0    For about nine years, a large municipal  landfill  in
     Delaware accepted both domestic and industrial  wastes.
     In 1968, this disposal site was closed and forgotten about.
     Four years later, chemical  and biological  leachates were
     detected in the groundwater.   According  to recent estimates,
     up to $26 million will be required to stop further deterio-
     ration of an underground aquifer which not only serves  as
     a drinking water supply to over 40,000 area residents but  is
     also needed for industrial  use.  To date,  approximately
     $2 million has been spent on this groundwater pollution
     incident, excluding administrative and legal  expenses.
2.  Surface water contamination via runoff
     Even relatively insoluble industrial  solid wastes that  are
dumned on land ultimately find their way into surface waters through
natural runoff.  Similarly, numerous case studies  have shown that
improperly lagooned liquid wastes travel  to surface  streams  by
overflow or seepage through dikes.   Quite often, the dumping of
hazardous wastes on land results in both ground- and surface-water
contamination, as the following damage incident illustrates,
0    From 1969 to 1972, an estimated 15,000 drums  of industrial
     wastes containing cyanides, arsenic,  cadmium, chromium,
     petroleum products, acids, and miscellaneous  other toxic
     and corrosive materials were dumped on   farm land in
     Illinois.  The problem first received attention in May  1974,
     when three dead cattle were discovered in the area.  Pathological
                                  38

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     examination revealed that the cattle had died of cyanide
     poisoning.  Chemical analysis of nearby surface water runoff
     indicated a maximum cyanide concentration of 365 ppm.  (The
     U.S. Public Health Service drinking water standard for cyanide
     is 0.2 ppm.)  After the dumping had ceased but before the
     damages were evident, a portion of the affected farm land
     was ourchased by a company which was subsequently faced with
     the clean-up problems.  A consulting firm, hired by the new
     owners, has preoared a comprehensive study of this incident,
     which documents the substantial damage to local wildlife,
     vegetation, and groundwaters.
3.  Air pollution via open burning, evaporation, sublimation, and
    wind erosion
     Frequently, the harmful effects of wastes dumped on land are
transmitted to the environment through the medium of air.   There are
relatively few reported damage incidents falling under this category,
because most monitoring and enforcement actions thus far have been
water pollution-related.  Burning dumps have not only emitted
irritating and toxic fumes but have also caused automobile accidents
by creating poor visibility.  One chain accident of such origin on
the New Jersey Turnpike made national headlines a few years ago.
Also, the evaporation and sublimation of volatile toxic industrial
liquid and solid wastes, respectively, is a public health  and
environmental  hazard that should not be underestimated.
                                  39

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0    One case in point relates to the land disnosal  of hexa-
     chlorobenzene (HCB) in Louisiana in 1973.   The HCB, v/hich is
     a toxic solid byproduct in the manufacture of perch!oroethylene,
     was dunned in a rural  landfill, where it sublimed into the
     air.  Other sources of HCB air emission were manufacturinq
     nlants in the area and snilled wastes from trucks haulinq
     the material  to the dump.  The HCB was ultimately absorbed
     into the body tissues of cattle.  As a result,  up to 20,000
     head of cattle were Quarantined by the Louisiana Department of
     Agriculture.   The economic loss to affected ranchers was
     estimated at $3.9 million.  Sampling and testing alone has cost
     the State and Federal  governments over $150,000.
0    Another well  publicized incident in this category nertains
     to an industrial solvent reprocessing firm in Maryland that
     dumned large Quantities of volatile orqanic: liquid wastes
     into a sand and gravel ouarry.   Wide-scale complaints by
     area residents about nauseating fumes resulted in State action
     that banned the dumoing in August 1974; however, the public
     health imolications of this incident are far from being resolved,

     Wind erosion of harmful dusts from land-disposed solid wastes
 is not only an occupational hazard for landfill operators but can
affect the health or area residents as well, as pointed out in the
following example.
0    One potentially debilitating damage to health is the inhala-
     tion of asbestos dust, which can cause asbestosis, lung

                                  40

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     cancer, mesotheliomas, and pleura! lesions in humans.
     Nevertheless, industrial asbestos wastes are often disnosed
     on land without oroviding a soil cover to prevent wind
     erosion of the harmful fibers.  In spite of amnle local
     oublicity about the potential  hazards, children are still
     using a playground in Pennsylvania that is located directly
     adjacent to an inactive 1.5 million cubic yard pile of
     industrial asbestos wastes.
4.  Poisoning via direct contact
     This tyoe of injury is very common to extremely toxic  wastes,
such as certain surolus pesticides  and nesticide containers,*  The
case studies in our files are generally illustrative of lack  of safe
disoosal rather than improper land  disposal.
0    In 1972, a 2 1/2 year-old child in Arkansas became ill
     after playing among a pile of  55-gallon drums.  He was
     admitted to the hospital, suffering from symptoms of
     organonhosnhate poisoning.   The drums were located approxi-
     mately 50 feet from the parents' front door on city property.
     The city had procured the drums from an aerial applicator,
     to be used as trash containers.   The residents were urged  to
     pick UP a drum in order to expedite trash collection.   It
     has been determined that these drums contained various
     pesticides, including methyl  parathion, ethyl  parathion,
     * On May 1, 1974, EPA issued disposal  and storage guidelines
designed to prevent such injuries.  These guidelines were promulgated
under authority of the Federal  Insecticide, Fungicide, and Rodenticide
Act as Amended in 1972.   (Federal Register 39:85,  po.  15236-15241,
40 CFR 165.)
                               41

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     toxanhene, DDT, and others.   The containe -s were in various
     states of deterioration,  and enough concentrate was in
     evidence to intoxicate a  child or anyone else who came
     into contact with it.
0    In 1969, Di-Syston was added to the soil  in a potato field
     in Idaho.  The "empty" paper baqs from the  pesticide were
     left in the field, and the wind blew them into the adjacent
     pasture.  Fourteen head of cattle died, some with convulsions,
     after licking the bags.
0    At least eighteen persons were hospitalized and two firemen
     suffered permanently disabling lung damage  in California in
     in 1973 after inhaling a  nematocide emanating from an undepleted
     300-pound pressurized canister that had been improperly
     disposed of by the manufacturer.  A businessman had obtained
     the canister in order to  "make a nice staridup fireplace."
5.  Poisoning via the food chain
     Land disposal-related incidents which result in this form of
damage are particularly difficult to identify and to confirm, because
of the existing gaps in the required scientific  evidence.  For
example, our data base at this juncture is  inacleauate to determine
the number of years before various food crops can be safely harvested
on farm land where certain hazardous wastes had  been deposited.
The following case study, which has received considerable publicity
in recent years, illustrates how land-disposed wastes can exert
health damage bv entering the food chain.
                                42

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     In  1969,  three children  in a  New Mexico fa;r:i1y su jta Inf-d



     serious  alkyl  mercury Doisoninc;  after eating contain. na led no^k.



     A fourth child in this family suffered conger' Lai mercun-



     ooisoninq after his mother hao  'jo^svmet! tbt same  nork  m  hey



     first  trimester of pregnancy.  The hog had ueen fed g^din



     treated  with a methyl mercury type seed dressing.  The  gr'e.in



     originated from a seed cormjar.y,  where the fanner'  :)f the



     children obtained the floor  sweepings withcrc,  ::"arne rn.j



     subsequently fed these to the hogs he was r.?,-'-inu,   i h  *



     incident Is not soec';f lea- >y  yol?tec! fo I.-MIC C;M":S>'•  \:-: ••



     Mexico.   It VMS estebi ished  by public health cin-'-or i ri?-



     that some of this d'jniDtd qra •;;•• -which origins [eu  "vs."  j



     different source than in the  orevious case--}'. .:: ..•",.••>  -•.. ?.'e-:c-.°d



     and used  as animal  ^eeu  .r t; c aves.   As a vn,./     : "  M.---



     number of hogs, chickens s i"\^ othet" animals I.". :/. .,.'.'  ' .'or .'nfi ie.1.
     We know oT  nunierous



caused by '7ire-  and  ux"",



orootr iafs;v/  •;* ''Cdbt •(..••"
                                    to  landfill  ODe>.;l>,



                                     -'It  accident? or^



                                      °d.   One fo> n; •.



                                    .  •"'."Mv react iv-
patlble  ma'ce^'!a;s,   /•, \ '



is the landfi'l 1 uicj  o-F uM

-------
     In October 1974, a bulldozer operator was killed in an
     exnlosion at an industrial  landfill  in New Jersey,  as he
     was burying and compacting  several  55-gallon drums  of
     unidentified chemical  wastes.   The  victim died as a result
     of burns, which covered about 85% of his body.

     To put the damage cases involving improper land disposal  of
hazardous wastes into a true perspective, one must realize that
the existence of only a very small  fraction of such incidents has
been uncovered.  In most cases of improper land disposal, nobody
is aware of these incidents except the disposers, and quite often
even they do not realize the full  environmental implications of
their actions.  In many instances where  local  citizens know about
or suspect environmental damages,  they do not report them.   Finally,
there are those cases of potential  damage that have been reported
but have never been verified by  competent authorities.
     Another point that requires emphasis is that except for some
transportation-related hazardous waste spills, the types of inci-
dents we have considered do not  fall  under the category  of accidents.
Practically all of these damages could have been avoided by prudent
and responsible hazardous waste  management.  In the course of our
investigations, we have found that a  wide array of treatment and
disoosal options is available for most hazardous wastes.  In those
particular situations where this is not  the case, safe and
controlled storage of the wastes is possible until adequate treatment
and disposal technology can be developed.  It is true that
                                 44

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environmentally sound hazardous waste management is costly,  but in
the long run it is less exoensive than seemingly cheap,  improper
land disposal, when measured in terms of the damages to  public health,
to the environment and to property, and the usually exorbitant mag-
nitude of clean-up costs, all of which are associated with the
latter alternative.
     Let me conclude this presentation on an optimistic  note.   We
at the Office of Solid Waste Management Programs are hopeful  that
the cooperation between government and industry, as exemplified by
this Conference, will  hasten the day when we shall  have  to search
for damage case studies in the dusty, forgotten  depths of our  archives.
                               45

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                            REFERENCES
1.  U.S. Environmental Protection Agency, Office of  Solid  Waste
      Management Programs,  Disposal of hazardous wastes;  report
      to Congress.   Environmental Protection Publication SW-115,
      Washington, U.S. Government Printing Office, 1974.   HO  p.

2,  Miller, D, W,,  F, A. PfS. ur?, and T. !., Tessier.  Ground  water
      contamination in c,v;; Ao--,neast States,  'Washington,  U.S.
      Government Printing Office, 1974.  325 p.

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               WASTE VOLUMES AND CHARACTERISTICS

             FROM THE INORGANIC CHEMCIALS INDUSTRY

                       by Sam Morekas*
ABSTRACT.  This paper summarizes some of the findings of a recently
completed contract study designed to assess hazardous waste generation
and treatment/disposal practices in The Industrial Inorganic Chemicals
Industry (Standard Industrial Classification 281).  Current and
projected estimated quantities of potentially hazardous wastes are
presented and are identified by geographic locations.  In addition,
current disposal methods are identified and briefly described.

     Material presented includes:

     (1)  Categorization of the industry;

     (2)  Identification of some of the significant
          types, amounts, and composition of potentially
          hazardous wastes;

     (3)  Description of treatment and disposal technology
          (other than techniques used for air and water
          pollution control)  which can be applied to
          reduce disposal hazards;

     (4)  Reported costs for hazardous waste treatment and
          disposal practices.
     *Mr.  Morekas is Program Manager for Hazardous Waste Assessment
in the Hazardous Waste Management Division, Office of Solid Waste
Management Programs, U.S.  Environmental  Protection Agency.
                             47

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     The material  and information described in this  paper represent
the author's preliminary evaluation and analysis of  the findings of
a study performed  for the U.S.  Environmental  Protection Agency by
VERSAR, Inc., Springfield, Virginia.   The study which is entitled,
"Assessment of Industrial Hazardous Waste Practices—Inorganic
Chemicals Industry," was conducted in 1974.  The final  report is
now in preparation and should be available later this year through
the National Technical Information Service of the U.S.  Department
of Commerce.  The  contractor's  study team was directed by
Dr. Robert G. Shaver.

     It should be  noted that, in addition to the aforementioned study,
the Environmental  Protection Agency's Office of Solid Waste Management
Programs is sponsoring several  similar assessements  of industrial
hazardous waste practices, covering a wide spectrum  of industries.
Some examples of these are the  petroleum refinery, organic chemicals,
pesticides, explosives, primary metals, electroplating, and metal
finishing industries.  All the  studies are designed  to provide EPA
with detailed information regarding the generation,  treatment, and
disposal of industrial wastes from manufacturing processes or from
waste treatment operations that are ultimately destined for disposal
                                   48

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in or on the land, and which [wastes] may produce potential  health
or environmental hazards if they are managed improperly.   It is
expected that the data and information gathered by these  studies,
augmented as necessary by other in-house and contract studies, will
form part of the data base for the future development of  guidelines
or standards to ensure environmentally adequate management of the
nation's potentially hazardous wastes.

The Inorganic Chemicals Industry
     The Inorganic Chemicals Industry, as classified under the
Standard Industrial Classification Code 281, in 1972 had  a total  of
1,607 plants producing approximately 112 million metric tons of a
wide variety of products with a dollar sales volume of $5.9  billion,
and employed 96,000 people.  The major industry subcategories
studied included:
          SIC 2812 - Alkalies and Chlorine
          SIC 2813 - Industrial Gases
          SIC 2816 - Inorganic Pigments
          SIC 2819 - Industrial Inorganic Chemicals,
                     Not Elsewhere Classified
     The presentation of the data was facilitated by further dividing
each subcategory into its respective 5-digit SIC classification
resulting in a total of 17 classifications.
     Within SIC 2812, Alkalies and Chlorine,  a total of  78  establish-
ments were identified with the heaviest concentration (about 30 percent)
in the Gulf Coast States representing 50 percent of the total production
                                 49

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of products.  For the production of chlorine and of sodium hydroxide
the major methods employed are the mercury cell  and diaphragm cell
processes.

     In SIC 2813, Industrial  Gases, the total number of establishments
is 514 with over 65 percent of them located in the East, South, Gulf
Coast, and Midwest regions of the United States.  For the production
of acetylene, one process only is used (reaction of calcium carbide
with water).  Seventy-five percent of the carbon dioxide plants use
the ammonia by-product process, and the vast majority of "Other
Industrial Gases" plants use either the air separation or carbon
monoxide/hydrogen processes.

     SIC 2816, Inorganic Pigments contains a total of 92 establishments
with the heaviest concentration (65 percent) in  the Northeast, East,
and Midwest.  Titania (SIC 28161) is made by either the sulfate or
chlorine process.  Most of SIC 28162 plants are  zinc oxide producers.
The processes used by SIC 28163 plants are fairly evenly divided
among chrome pigments/iron blues, iron oxides, lead oxides, and
others.

     The total number of establishments in SIC 2819, Industrial
Inorganic Chemicals, Not Elsewhere Classified is 923.  Of this
total, the States of the Gulf Coast contain 189.  The next heaviest
concentrations are in the Southeast and the Midwest with 156 and 140
plants, respectively.
                                 50

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Almost 50 percent of the total number of plants (442) are categorized
under SIC 28199. Other Inorganic Chemicals, N.E.C.  The number of
processes employed by this segment of the industry is as diverse as the
products produced.  In 1972, over 57 percent of the total inorganic
chemicals products were produced by plants within this SIC category.
Sulfuric acid (SIC 28193) accounted for over half the total.  In
terms of production capacity concentration, States in the Southeast
and the Gulf Coast regions accounted for 25 percent and 33 percent of
production capacity, respectively.

     Generally, the inorganic chemicals industry is very stable and is
expected to continue a steady growth.  Changes in the industry will
be dictated primarily by economic factors, energy, and raw material
availability conditions.  However, some environmental considerations
in selected segments of the industry will have an impact.  A case in
point is SIC 2812 where, reportedly, no new construction of mercury
cell process chlor-alkali plants is planned, and process changes are
planned to reduce wastes containing chlorinated hydrocarbons.  In
addition, because of both economic and environmental considerations
no new Solvay Process soda ash plants are expected to be constructed
in the near future.

     Before discussing waste generation from this industry, I would
like to touch briefly on two very important subjects that are probably
of interest to all concerned:  (1) How were the data developed, and
(2) How were "hazardous wastes" defined and identified?
                                  51

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Data Acquisition:  The primary sources of information were the following:
     1.  Literature searches of technical  literature,  trade journals,
        government reports, and technical surveys conducted by
        various industry associations.
     2.  Utilization of published and unpublished data collected
        during the contractor's work for  development  of EPA's
        effluent limitations guidelines for this industry.
     3.  Assistance and information from such trade associations
        as The Chlorine Institute and The Manufacturing Chemists
        Association.
     4.  Personal contacts,  interviews, and visits to  various plants
        and corporate offices of chemical  manufacturers, disposal
        sites (both on-site and  off-site), government agencies,
        and trade associations.  Over 100 site visits were conducted.
     The data thus gathered, along with engineering calculations and
estimates, were used in developing a series of mass balanced flow
diagrams for "typical" processes which depict the qualitative and
quantitative composition of specific waste streams of interest.
A schematic of such a flow diagram is shown on Figure 1.

Determination of Hazardous Wastes
     EPA required the contractor to investigate and report on the presence
in wastes of the following substances: asbestos, arsenic, beryllium,
cadmium, chromium, copper, cyanides, lead, mercury, halogenated
hydrocarbons, pesticides, selenium, and zinc.  Other  substances believed
                                 52

-------
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                53

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by the contractor as being potentially hazardous,  such  as  carcinogens,
were to be identified.   Criteria from documented evidence  of toxicity,
persistency, flammability, explosivity, or incapacitating  factors,
were used in defining wastes as "potentially" hazardous.   Initially,  all
waste stream constituents were considered to be "potentially"
hazardous.  Obvious innocuous items, such as water,  sand,  bricks,
dust, etc., were deleted.  The remaining substances  were  studied
in greater depth to determine whether they were toxic in  high or
low concentrations, and whether or not they were environmentally
persistent.  Those items that were persistent and  toxic at low
concentration levels were termed "potentially hazardous"  for purposes of
this study.  Figure 2 depicts the industry subcategory, the process
involved, and types of constituents identified as  "potentially hazardous"
in each waste stream.

     It should be noted that such characterization alone  is not
considered sufficient to conclusively define a given waste stream
as being "hazardous."  As noted earlier, EPA is supporting other
studies which, hopefully, will provide the additional information
needed to classify a given waste stream as "hazardous"--reasonably
and conclusively.
                                 54

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                                           55

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Volumes and Generation Centers of Hazardous Wastes
     The final report for this study, when published later this year,
will contain a great deal of detail  describing current and projected
quantities of hazardous wastes, the  processes involved, the composi-
tion of each waste stream, and the geographic distribution of
generation centers.   Following are a few highlights  of this information:
     SIC 2812 - Alkalies and Chlorine.   Wastes containing lead,
     mercury, asbestos, and chlorinated hydrocarbons are generated
     in quantities exceeding 1,000 metric tons per year in the
     Northeast, Midwest, South, and  Gulf Coast regions of the
     United States.
     SIC 2816 - Inorganic Pigments.   Wastes containing antimony,
     arsenic, cadmium, chromium, cyanide, lead, mercury, and zinc
     are generated in quantities exceeding 1,000 metric tons per
     year in Delaware, Maryland, West Virginia, New  York, and
     Georgia.
     SIC 2819 - Inorganic Chemicals  (N.E.C.) [Exclusive of SIC 28199.]
     Wastes containing arsenic and fluoride are generated in quantities
     exceeding 10,000 metric tons per year in the East, Midwest, Gulf
     Coast regions,  and in California.   Quantities generated in Florida
     and Oklahoma exceed 1,000 metric tons per year.
     SIC 28199 - Inorganic Chemicals (N.E.C.)  Wastes containing
     arsenic, chromium, fluoride, nickel, phosphorous, and zinc
     are generated in quantities exceeding 10,000 metric tons per
     year in Maryland, North Carolina, Tennessee, Alabama, Florida,
                                56

-------
     Texas, Idaho, and Montana, and in quantities exceeding 1,000
     metric tons per year in New Jersey, Ohio, and Missouri.
     Presented in Figure 3 is a summary of the quantities of potentially
hazardous wastes on a national basis currently generated and as pro-
jected for 1977 and 1983.  It should be noted that the quantities are
calculated on a "dry basis."
     The quantities of potentially hazardous wastes and their hazardous
constituents, as summarized in Figure 3, present a general overview of
the relative amounts of wastes emanating from the inorganic chemicals
industry in the United States.  From our preliminary review, some
general observations can be made as follows:
     .  Subcategory SIC 2819, Industrial Inorganic Chemicals (NEC),
        is by far the largest segment in terms of generating wastes
        containing potentially hazardous constituents.  Potentially
        hazardous wastes from this subcategory represent 90 percent of
        the total quantities reported for the entire industry.
     .  Within subcategory SIC 2819,  SIC 28194, Inorganic Acids,
        accounts for approximately 30 percent of the potentially
        hazardous constituents (primarily fluoride) and about 90
        percent of the total volume of wastes reported.  Of 135 plants
        manufacturing inorganic acids, 31 plants (23 percent) account
        for about 70 percent of the total quantity of wastes produced.
     .  The manufacture of phosphorous, under SIC 28199, Other
        Industrial Inorganic Chemicals, NEC, which accounts for about
        10 percent of the total quantity of wastes containing poten-
        tially hazardous constituents, contains about 40 percent of
                                57

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        the potentially hazardous constitutents (mostly fluorides and
        phosphorous).  Of 442 plants in this subcategory, 15 plants
        (about 3 percent) produce approximately 80 percent of the
        total quantity of wastes reported.
     .   Subcategory SIC 2812, Alkalies and Chlorine, while producing a
        relatively low 57,000 tons (about 3 percent) of the total
        quantity of wastes also accounts for about 13 percent of the
        potentially hazardous constituents (mostly chlorinated hydro-
        carbons, explosive flammable sludges, and asbestos).
        Potentially hazardous wastes from subcategory SIC 2813,
        Industrial Gases,  are generated in relatively negligible
        quantities.
     .   While SIC 2816, Inorganic Pigments generates the lowest amount
        of potentially hazardous constituents, the majority of these
        constituents (approximately 90 percent) emanate from subcategory
        SIC 28163, Chrome Colors and Other Inorganic Pigments, and
        these are found in a relatively low total waste quantity.
        The largest volume of total wastes from subcategory SIC 2816
        is generated by SIC 28161, Titanium Dioxide Pigments (about
        94 percent).
General Description of Present Treatment and Disposal Technologies
     Following are brief descriptions of most prevalent present treat-
ment and disposal technologies applicable to wastes from the inorganic
chemicals industry:
                                59

-------
     Chemical Detoxification treatments are employed to reduce or
destroy the toxic nature of wastes.   These treatments most often are
included in water quality control,  but can be utilized for land
destined wastes as well, particularly at off-site installations.
Most common treatments identified as suitable for inorganic chemicals
industry wastes included: Neutralization, pH Control, Oxidation-Reduction,
Precipitation, and Recovery and Reuse.
     High Temperature Processing -  This is one of the more promising
approaches to treatment of mercury  sludges from the mercury cell chlor-
al kali industry.  Smelting operations are also widely used for hazardous
metallic wastes.  High temperature  processing accounts for an estimated
1-2 percent of the total hazardous  wastes from this industry.
     Open Dumping - Open dumping of hazardous inorganic chemical wastes
into gravel pits, dumps and other uncontrolled disposal areas is still
a prevalent disposal practice.   Most of the companies producing inorganic
chemicals contacted during both this study and previous water quality
studies, however, have demonstrated increasing awareness and responsi-
bility for treatment, control,  and  disposal of hazardous wastes.
According to information from both  private contractors and inorganic
chemical producers that were interviewed, most chemical companies
want no "surprises" from disposal operations and are checking closely
on both their own and contract disposal sites and procedures.
     Massive processing types of wastes, such as ore residues and
unsaleable by-products, contribute  a major portion of the potentially
hazardous land-destined total waste volume from the inorganic chemicals
                                 60

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industry.  These large volume wastes, containing relatively small
amounts of hazardous components, are currently land dumped or land-filled
usually on-site.  Examples of such wastes are ore and water treatment
residues from the ore processing in chromates manufacture, calcium
sulfate contaminated with calcium fluoride from the production of
hydrogen fluoride, and ore residues from the production of lead and
zinc compounds.  The large volume and the obviously high economic
impact of more costly treatment and disposal technology make it necessary
to consider each of these situations very carefully.
     Municipal Sewers - Hazardous wastes from a number of inorganic
chemicals manufacturers currently go into municipal sewer systems.
These materials wind up in sewage sludge, some of which is destined
for land disposal.  Percentage of total volume of inorganic chemicals
industry wastes being disposed of in this fashion is judged to be
small (less than one percent).
     Deep-We11 Iniject1on - Disposal of inorganic chemicals industry
hazardous wastes by deep wells is done both on-site by the plants, and
off-site by contractors.  Most of the contract disposal wells encoun-
tered were in southern locations such as Texas, Oklahoma, Louisiana,
Florida, and Tennessee.
     Ocean Dumping - Currently, a number of hazardous wastes generated
by the inorganic chemicals industry are disposed of by ocean barging
and dumping.   Some of these wastes, undoubtedly, in the future will  be
destined for land disposal.   Sodium sludges, titanium dioxide wastes,
                                61

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and small quantities of miscellaneous hazardous chemicals are among
the materials currently involved.
     On-$ite Vs. Off-Site Disposal - Of a total of 175 plant sites, an
estimated 25 percent (35-45 plant sites) hire contractors for off-site
disposal of at least a portion of their hazardous wastes.  The remaining
75 percent treat and dispose of their own wastes.  In general, contractors
are used for small volume wastes,  particularly in congested areas where
treatment and disposal land is at a premium.   Contractors account for
10-15 percent of the total volume disposed.
     .  Specialized Disposal Sites - In the disposal of hazardous wastes,
        advantage is often taken of existing mines, quarries, abandoned
        government property and other facilities which have fortuitous
        geological and environmental isolation.  For example, abandoned
        missile silos in Idaho are utilized by a private contractor for
        disposal of hazardous wastes.  Clay pits in Ohio and California
        provide impervious liquid waste disposal sites.
        In general, however, specialized disposal sites are not utilized
        to any significant degree by the inorganic chemicals industry
        (less than 0.2 percent).
     .  Public and Private Landfills - Landfill ing is the most pre-
        valent method of disposing of hazardous nonflammable solids
        and sludges.  It is estimated that 75 percent of concentrated
        hazardous wastes of the land-destined hazardous wastes from
        the inorganic chemicals industry is disposed of in landfills
        currently.  Thesese landfills are classified as:
                                 62

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    .   General Purpose Landfills - Characterized by their acceptance
       of a wide variety of wastes, including garbage and other organic
       materials, and by the usual absence of special containment,
       monitoring, and leachate collection or treatment.
    .   General Purpose Approved Landfills - Some control is exercised
       over the types and quantities of hazardous wastes accepted, and
       provisions are made for monitoring wells and leachate control
       and treatment if required.  Many local regulatory agencies and
       landfill site owners are informally practicing such operations
       by selective acceptance of waste materials.
    .   General Purpose Secure Landfills - Used for a number of small
       volume wastes of extremely hazardous potential where additional
       safeguards, beyond those described for approved landfills, are
       instituted.  Such safeguards include careful site location; low
       soil permeability rates; a water table well below the lowest level
       of the landfill; provisions for diversion and control of surface
       water; monitoring wells; leachate control and treatment; and
       records of wastes disposed of.

Treatment/Disposal Technologies and Costs
     The final report for this study will contain detailed descriptions
of the various treatment/disposal technologies identified for the
various industry subcategories and the costs associated with each
method.  Based on a preliminary review of this material, however, some
general observations can be made.  Figure 4 is a tabulation of the
significant treatment/disposal technologies identified for the

                                 63

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                           Figure 4



      SUMMARY OF TREATMENT AND DISPOSAL PRACTICES (SIC 281)


Treatment/Disposal Technology                     Percent of Plants Using


Land Disposal                                            85


.   General purpose landfill/lagooning/dumping                    42

.   Anode conversion + landfill                                   11

.   Extraction + landfill                                          5

.   Treatment + ponding/landfill ing                                6

.   Drumming + landfill ing                                         7

.   Secure landfill                                               12

.   Deep Well Disposal                                             2


Recovery or Recycle                                      13
Ocean Dumping                                          	2_
                                                        100
                                 64

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total  inorganic chemicals industry, shown as a percentage of plants
using  these technologies.  It is obvious that some form of land disposal
is the prevalent method and is being used by 85 percent of the industry.
     Of the various land disposal technologies being used, over
one-half are general purpose landfills, lagoons, or land dumps.
It is  noteworthy, however, that the remainder of the land disposal
methods involve some form of pretreatment, or the use of secure landfills.
Significant also is the finding that 13 percent of the plants practice
some form of either in-plant or off-site recovery or recycle.
     Illustrative examples of the costs for the most prevalent
treatment/disposal technologies reported are as follows:
          Land Disposal
          .  On-site land dumping of 300 metric tons per day of
             treatment sludges from the manufacture of hydrofluoric
             acid costs  $1.83 per ton of waste, and can range as
             high as $7.94 per ton for off-site disposal of 1.7
             metric tons per day of process waste sludges from a
             chlor-alkali plant.
          .  Drumming and Landfi11ing (off-site) of one metric ton
             per day of waste treatment sludges from the manufacture
             of nickel sulfate can cost as high as $80 per ton.
          •  Off-site Landfilling in a secure landfill of 3 metric
             tons per day of waste treatment sludges from the
             manufacture of chrome pigments and iron blues costs
             $53 per ton.
                                 65

-------
          .   On-site Landfill ing in a secure  landfill  of 33 metric
             tons per day of waste treatment  sludges  from the  manufacture
             of aluminum fluoride costs  $3.35 per ton.
          .   Deep-we11 ing (on-site) of untreated waste treatment sludges
             from the manufacture of titanium dioxide  costs $4.09 per
             ton, at the rate  of 110 metric tons of waste per  day, and
             for deep-welling  (off-site)  of 560  tons  per day of the
             same sludges, $3.21 per ton.
     Recovery and Recycle costs  vary widely depending  on quantity,
     and quality of the wastes,  whether in-plant or at off-site
     plants, etc.  One plant recovering phosphorous from waste
     sludges resulting from the  manufacture of phosphorous reports
     costs of $7.62 per ton of waste treated.
     Ocean Dumping costs also  vary widely depending on whether the
     wastes  are delivered in bulk or drummed  form,  quantities
     involved, and distances traveled.   As an example, dumping at
     sea of drummed sodium wastes in 20-drum  lots costs $85 per drum;
     whereas, liquid wastes in barge-lots of  38,000 liters per week
     cost from $6.60 to $8.20  per metric ton.
Conclusions
     Generally, our preliminary  review and analysis of the information
developed by this study indicates that:
     .   Wastes from the inorganic chemicals industry  contain
        significant amounts of potentially hazardous  constituents.
                                 66

-------
The total quantities of potentially hazardous wastes destined
for land disposal are significant and will  continue to increase.
The most prevalent methods employed for disposal  of most
potentially hazardous wastes are ponding, lagooning, landfill ing,
and dumping.
The preponderance of currently employed methods for land disposal
of potentially hazardous wastes are not reported as providing
adequate containment, monitoring, or leachate control.
With relatively modest increases in cost, in some cases,
appropriate safeguards can be implemented to upgrade land
disposal operations.
Industry, generally, is aware of the potential hazards inherent
in improper management of its wastes, and evidence of appropriate
corrective action exists in some industry subcategories.
                       67

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             DEVELOPMENT OF A,gATA BASE FOR THE
         EXCHANGE AND RECYCLING OF HAZARDOUS WASTES
                 by Christopher H. Porter*
ABSTRACT.  The nature and estimated magnitude of the
Nation's hazardous waste disposal problem was documented in
the U.S. Environmental Protection Agency's Report to
Congress;  Pisposaj. of Hazardous Wastes.

    As a partial solution to this problem, EPA is currently
exploring the potential applicability of the "waste
exchange11 concept, which avoids complex treatment and
disposal issues by addressing the opportunity for material
recover.  Utilizing this concept, a waste stream generated
by a particular manufacturing process is used as a raw
material for another process — often across industry lines.
The waste is generally transferred "as is," thereby
eliminating the necessity of pre-treatment by the generator.

    In some European countries, notably West Germany, the
Netherlands, Belgium, Switzerland, and the Scandinavian
countries, industry trade associations have assumed the role
of clearinghouse for member firms.  In West Germany, over
400,000 metric tons of wastes generated by the chemical
industry were exchanged during the first 10 months of
operation in 1973.  An undetermined portion of this tonnage
could be classified as hazardous.

    The industrial waste clearinghouse concept is still in
its infancy in the United States, and its wide applicability
to the exchange of hazardous wastes remains to be
demonstrated.
    ""Hazardous Waste Management Division, Office of Solid
Waste Management Programs, U.S. Environmental Protection
Agency.
                             68

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INTRODUCTION







    In its Report to Congress^  Disposal of Hazardous Wastes



the U.S. Environmental Protection agency (EPA)  estimated



that approximately 10 million tons of nonradioactive



hazardous wastes are generated annually and that hazardous



waste generation increases at an annual rate of 5 to 10



percent.^ The Office of Solid Waste Management Programs



(OSWMP) believes that one means of dealing with the ever



increasing industrial, and especially hazardous industrial,



waste disposal problem is to foster the implementation of



the industrial waste exchange concept.  The primary



advantage of the waste exchange concept is that wastes are



transferred from the generator to the user "as is," thereby



reducing the need for costly treatment processes and the



incidence of potentially harmful disposal practices.







    The waste exchange concept is not a new concept.  In the



United States several major chemical manufacturers exchange



wastes.  At least one private firm was established in the



United States as a brokerage to expedite the exchange of



wastes for its customers.  Finally, periodicals have long



carried advertisements seeking chemical process wastes.  The



European community has carried the concept further by



establishing national and international waste exchange and



utilization clearinghouses.




                             69

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ISI EUROPEAN CONCEPT







    Industrial waste exchange clearinghouses have been



established in a number of European countries during the



past two years.  The literature indicates the existence of



industrial waste exchange clearinghouses in the Netherlands,



Belgium, Switzerland, West Germany, and the Scandinavian



countries. '•*The clearinghouses in the Scandinavian countries



and in West Germany are unique and interesting because they



are international in scope.  Denmark, Sweden, Norway, and



Finland participate in the Scandinavian clearinghouse, while



Austria has joined West Germany in its waste exchange



program.







    The European industrial waste exchange clearinghouses



have several similarities.  In general, they are operated by



a national industrial association.  The West German



clearinghouse is operated by a national chemical



association, while the Scandinavian version of the waste



exchange clearinghouse is operated by a Scandinavian inter-



governmental foundation and an alliance of industrial



associations representing each of the four member countries.



The European clearinghouses do not participate in the



recycling of material such as waste paper and scrap inetal



for which a market has already been established.  Nor do



these organizations charge a fee for the waste exchange



services which they normally provide.



                              70

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    Advertisements are used to make the availability of
wastes known.  In West Germany, the industrial association
advertisements offering industrial wastes appear in its
monthly news organ.  The Scandinavian clearinghouse member
associations received the advertisements every other month
and are free to present them in a manner best suited to
their respective national conditions.  The nature and
formate of these advertisements are similar.  They are
identified with a code number, so the source of the waste
will remain confidential.  The advertisements include the
quantities of waste available, the frequency that it is
available, and chemical and physical specifications.  In
both the West German and Scandinavian systems, any potential
user can express an interest in obtaining the waste by
requesting additional information from the clearinghouse.
The clearinghouse forwards all inquiries pertaining to a
given waste to the waste generator who originated the
advertisement.  It is the waste generator's responsibility
to contact the potential user if he so desires.  This
procedure maintains the confidentiality of the system.

    The Scandinavian clearinghouse reported that 142 items
were accepted for publication during the first ten months of
operation from November 1973 to the end of August 197U.4
These items attracted 250 inquiries.  The plastic and the
textile-leather categories attracted the greatest number of
inquiries, while the acid-pickling liquor category attracted
no inquiries at all.  The Scandinavian clearinghouse
                             71

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surveyed the participants in the program during the first



ten months.  They received replys from approximately twenty



percent of those surveyed.  Eleven of the items advertised



during the first ten months of operation were utilized in



other processes.  Twenty-one negotiations were still in



progress at the end of the first ten months and twenty-two



negotiations ended without agreement for various reasons



(i.e., legal, economic, quality, etc.).







    The Scandinavian clearinghouse did not report the



quantities of waste which were exchanged.  Other exchanges



have apparently been more successful than the Scandinavian



clearinghouse as is evidenced by the 400,000 metric tons of



chemical wastes which were exchanged through the West German



clearinghouse during its first ten months of operation in



1973.5







    The Department of Industry in the United Kingdom in



cooperation with a group of environmental specialists from



the chemical industry is establishing a waste exchange



program.  The program is similar to the other European



programs previously described except that a government



agency will be responsible for the operation of the



exchange.  Advertisements will be accepted for wastes which



do not currently have an adequate market and will be



published on a quarterly basis free of charge.  The



Department of Industry plans to send invitations to 25,000




                             72

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to 30,000 organizations which are potential participants in



the program.







XH! OSWMP CONCEPT







    The Office of Solid Waste Management Programs {OSWMP)



does not intend to organize and manage an industrial waste



utilization clearinghouse at this time.  The waste



utilization concept does, however, appear to be one means of



reducing the quantity of industrial and especially hazardous



wastes which would otherwise be destined for land disposal.



The industrial waste utilization concept remains in its



infancy, and the wide applicability to the exchange and



utilization of hazardous wastes remains to be demonstrated.



As mentioned earlier, there is some activity in the United



States which suggests that some waste exchange is taking



place.







    In order to stimulate waste exchange and utilization



activity, OSWMP will be funding a study of the European



waste clearinghouses as well as other institutional



arrangements through which a viable industrial waste



utilization, exchange, and recycling program can be



implemented in the United States.  The institutional



arrangements which will be considered include governmental



entities (e.g.. State or local governments), industry trade



associations, private entrepreneurs (e.g., waste brokerage



firms), and non-profit institutions (e.g., non-profit

-------
research institutes).  The criteria to be used to judge the



merits of each institutional arrangement include an



assessment of the potential success of each institutional



arrangement based on its economic viability and social and



political acceptability.







    The study will identify those institutional arrangements



that appear particularly suitable for a typical Standard



Metropolitan Statistical Area {SMSAJ, a typical State, and a



region consisting of three or more States.  OSWMP



anticipates that the limiting factor for industrial waste



exchange and utilization in the United States will be the



distance that a usable waste can be economically



transported.  Since the United States is larger than any of



the areas covered by the European exchanges, the first



American exchanges will probably promote their activities in



specific regions rather than nationally.  These regions may



be as small as a single SMSA or they may include several



States depending upon the types and amount of industry.



Many of the characteristics of the European system may be



included in the American exchanges, but the American



exchanges may be operated by several different types of



organizations.







    For three of the institutional arrangements which appear



to be most promising, a clearinghouse implementation program



will be developed.  The outline of the program will



                              74

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incorporate an analysis of the economics as well as the



anticipated problems and recommendations for their solution.







    As raw material prices increase in the world markets,



material recycling and waste utilization should become



increasingly popular.  By studying the various potential



institutional arrangements, OSWMP hopes to encourage the



establishment of waste exchange brokerages and thus expedite



waste exchange and utilization.







    In order to further stimulate the implementation of the



waste utilization concept a systematic methodology will be



developed to assess the potential uses for industrial and



especially hazardous industrial waste streams.  The



methodology will include consideration of raw material feed



stock requirements and the relationship of those



requirements to comparable feed stocks available in waste



streams.  Consideration will be given to economic as well as



technological feasibility.







    The usefulness of the systematic waste utilization



methodology will be demonstrated for at least fifty



industrial waste streams.  At least thirty-five of the



streams will have significant hazardous constitutents.  The



utilization of wastes is to be examined within a specific



generating industry  (e.g., within the electroplating



industry)  as well as across industry lines (e.g., between



the electroplating and the paint manufacturing industry).



                             75

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The results of this portion of the study will be organized



to identify the waste generator and user, raw feedstock



needs, the nature and quantity of the process waste streams,



the hazardous component and its concentrations, and the



technology and economics of utilizing waste.







    The systematic waste utilization methodology, the fifty



example waste streams, and the outline for program



implementation will provide a basis for interested



individuals to judge the feasibility of the waste



utilization concept.  Hopefully, the concept will prove to



be an attractive alternative and lead to a significant



reduction in the quantity of hazardous wastes disposed of on



land.







    One final interesting aspect of the study will be to



assess the environmental and economic impact of potential



industrial waste exchanges in a specific metropolitan (SMSA)



area.  Such an assessment should help to draw conclusions



concerning the environmental and economic impact in other



similar SMSA's and may provide motivation for regional



organizations (public or private) to establish waste



utilization programs.







    Completion of the study is presently scheduled for June



1976.  A published report of the findings should be



available shortly thereafter.



                             76

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                     REFERENCES

U.S.  Environmental  Protection Agency,  Office of Solid
Waste Management Programs.   Disposal  of hazardous  waste;
report to Congress.  Environmental  Protection Publication
SW-115.   Washington, U.S.  Government  Printing Office, 1974.
110 p.

McQueen, S.  Haste disposal  through  ads.  Chemical
Engineering  (International  Edition),  80(10):34F,
Apr.  30, 1973.

Smith, J., and S. McQueen.   Waste exchanges  win kudos.
Chemical Engineering (International  Edition), 81(3):
20J.20M, Feb.  4, 1974.

Bouveng, H.O., and  H.  Hargback.  The  Nordic  organization
for waste exchange; first  progress  report.   Stockholm,
Swedish  Water  and Air  Pollution Research Laboratory,
Sept. 1974.  15 p.

Keune, H. Uber 400,000  Tonnen Ruckstande vermittelt [Over
400,000  tons of refuse  procured].  Umwelt,  (l):22-23,
Feb.-Mar. 1974.  (English  translation  available from
Franklin Research Laboratories, Philadelphia.)

Government sets up  British  waste materials  exchange.
Technology Ireland, 6(7);46. Nov. 1974.
                         77

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                  LAND DISPOSAL  TECHNOLOGY

                    FOR INDUSTRIAL  WASTES

                          ABSTRACT
     American industry traditionally  has  used  the  land  as  an
ultimate disposal  sink for its wastes.     In recent years,  stronger
air and water quality regulations have led to  even more wastes
destined for land disposal.  Usually  the  waste materials in
question are either solids or semi-solid  slurries  from  industrial
waste management activities which strive  to remove and  concentrate
waste stream constituents.  Having achieved the primary goal  of
separation and concentration, the first inclination may be to
dispose of the collected sludges in an open dump or conventional
sanitary landfill.  However, many of  these industrial wastes  are
hazardous or potentially hazardous to the environment.   Such
practices can lead to the contamination of surface or groundwater
due to leachate and runoff problems,  particularly  in  areas where  the
annual precipitation rate exceeds the evapotranspiration rate.
Methods have been proposed which modify the conventional sanitary
landfill to ensure proper disposal of chemical and hazardous
industrial wastes.  In general  terms, secure landfills  provide
complete long term protection for the quality  of surface and
subsurface waters from hazardous wastes deposited  therein.

     This paper will examine some of  the  techniques currently
available to prevent, collect,  treat, monitor, and manage
chemical waste landfill leachates.  In addition, hazardous
waste preparation techniques, employed to minimize waste
hazards prior to secure landfill disposal, will be presented.
A discussion of the proposed EPA chemical waste landfill
demonstration will be included.
                           78

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        LAND DISPOSAL TECHNOLOGY FOR INDUSTRIAL WASTES
                        by Donald Farb*
     Studies of The Environmental Protection Agency to date indicate
that most industrial and hazardous waste is disposed of on or in the
land, by open dumping, landfill ing or lagoon ing.  It is expected that
land disposal of industrial and hazardous waste will continue to grow due
to increases in industrial production, stricter air and water pollution
controls, ocean disposal restrictions, and material bans such as DDT and
those proposed for aldrin and dieldrinj
     Hazardous wastes have been characterized as any waste or combination
of wastes "which pose a substantial present or potential hazard to human
health or living organisms because they are lethal, non-degradable, per-
sistent in nature, can be biologically magnified, or otherwise cause or
tend to cause detrimental cumulative effects."^  EPA's report to Congress
on Disposal of Hazardous Waste revealed that inadequate hazardous waste
management practices have the potential to cause public health and
environmental damage.  EPA has uncovered incidents in several states
where improper land disposal  practices have culminated in public health
damage or environmental degradation.  Among these are incidents of arsenic
poisoning in Texas, Minnesota, and Pennsylvania, pesticide poisoning in
Arkansas, Louisiana, and Idaho, heavy metal contamination in New Jersey
                                                                2
and New York, and cyanide disposal damage in Texas and Colorado.
     *Mr. Farb is a physical scientist with the Hazardous Waste
Management Division, Office of Solid Waste Management Programs,
U. S. Environmental Protection Agency.
                              79

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     It has not been possible to date to develop an inclusive
formula for defining the degree  of hazard presented by various
waste materials.  The criteria are numerous and a lack of available
data hinders quantification.   As a minimum, chemical waste land
disposal decisions should include consideration of the waste's:
          chemical form (inorganic or organic)
          persistency
          acute or chronic toxicity
          genetic effect
          f1ammabi1i ty/reacti vi ty
     Currently, most landfills designed to accept hazardous
non-radioactive wastes are located in areas where existing
hydrogeological and climatological conditions provide sufficient
groundwater protection, such  as the Class I disposal sites in
California.  However, as Table 1  indicates, the majority of the
industrial waste centers are  located in humid regions east of the
Mississippi River.  Humid regions are characterized by annual
precipitation rates that are  in excess of annual evapotranspiration
rates, thus creating a leachate management problem (figure 1).
Such problems do not exist in arid regions.  Hydraulic connections
between the landfill and groundwater or surrounding environs
provide pathways by which leachates containing chemical constituents
may reach the general public  or other life forms.  These pathways
may be direct or indirect and result in either acute (immediate) or
                             o
chronic (long-range) effects.   Due to the waste's inherently
                              80
                              2

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                            TABLE 1:
        ESTIMATED INDUSTRIAL HAZARDOUS WASTE GENERATION
              BY REGION* IN TONS PER YEAR (1970)+
Region                 Tons     Metric tons       Percent of
	total
New England            304,000    275,450            3.1
Mid Atlantic         2,260,000  2,047,800           22.9
East North Central   2,385,000  2,163,600           24.2
West North Central     393,000    350,800            4.0
South Atlantic         986,000    891,100           10.0
East South Central     528,000    480,300            5.4
West South Central   1,989,000  1,803,400           20.2
West (Pacific)         813,500    739,770            8.3
Mountain               191,500    173,840            1.9
         TOTALS
	9,849,500  8.929,060	100.0
    *Refers to Bureau of Census regions
                                    2
    *Source:  EPA Report to Congress
                                81

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INFILTRATION

(inches/year)
   |—— I  o
          o-io

          10-20

          over 20
          Figure  1:  Geographic distribution of groundwater infiltration

                                                       4
                    rates.  Source:  Weddle and Garland
                                         82

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greater hazards, chemical and industrial waste landfill ing
practices require greater attention to site selection, site
engineering, and materials handling procedures.
SITE SELECTION
     Minimizing public health and environmental degradation from
long-term waste decomposition and migration while maximizing
occupational health and safety are primary objectives of industrial
waste landfill site selection procedures.  A comprehensive
evaluation of health, safety, and environmental criteria is a first
step in the site selection process.  These criteria embrace the
disciplines of: 5
          Earth science
          Economics
          Ecology
          Environmental health and safety
          Resource utilization
     An evaluation of a site's potential to limit leachate migration
is critical to determining its environmental adequacy.  Foremost
among these site characteristics are its infiltration rate,
filtering capacity, buffering capacity, absorptive capacity,
distance to groundwater, and groundwater movement pattern and
rate.  Figure 2 defines several  site selection criteria in greater
detail.
     In  humid regions where precipitation rates produce a net
groundwater infiltrate, it is likely that natural  site conditions
alone will  not be sufficient to  prohibit leachate movement.
                              83

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                    Figure 2:  Site Selection Criteria

 Geology

      0  Low relief to minimize erosion and landslide potential.
      0  Impervious stable rock formations, such as deep sedimentary rock
        formations are preferable.  Active faults, high seismic risk zones,
        and highly permeable formations, such as karst areas, and glacial
        outwash plains, should be avoided.

 Hydrology
      o
        Bottom of the landfill should be well above the historical high
        groundwater table.  Flood plains, shore lands, and groundwater
        recharge areas should be avoided.
      0  Significant hydraulic connection (surface or subsurface) between the
        site and standing or flowing surface water should be absent.

Soil

      °  High sorption capacity, alkaline pH, and high cation exchange
        capacity (CEC) are preferable.
        Homogeneous, workable soil, such as clay, sflt, or combinations of clay
        and silt, with low permeability is preferable.

Climatology

      0  Outside the paths of recurring severe storms, such as tornados and
        hurricanes.
      0  Low air pollution potential (e.g., low inversion potential, good
        circulation, prevailing winds away from populated areas).

Transportation Economics

      0  Accessible by all weather highways and/or railroads
      0  Close proximity to waste sources.
      0  Low spill and accident potential (e.g., short haul distance, low
        population densities, and low congestion).
      0  Adequate water and power supply.

Environmental Health

      0  Locate away from private wells for human and/or livestock use and
        from municipal water supplies, reservoirs, or wells.
      0  Low population density.
Ecology
        Low fauna and flora diversity.
        Avoid wilderness areas, wildlife refuges, and migration routes.
        Avoid areas of unique plant communities or animal populations.
Resource Utilization
        Low alternative land use value.
        Avoid areas with high recreational use potential (scenic open space
        wetlands, and wilderness areas).
Source:   after Battelle5
                                      84

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Additional  site engineering, such as liners and leachate collection
techniques, will be necessary to preclude leachate movement.
However, since soil conditions provide a secondary waste barrier,
the use of liners or other leachate management techniques should
not minimize efforts to locate the best available hydrogeologically
secure site.  In the event of system failures, existing soil
conditions will serve to minimize leachate impact until remedial
action can be taken.
HASTE HANDLING TECHNIQUES
     Physical and/or chemical treatment techniques may be
employed to modify chemical wastes prior to their disposal.  The
objective is to minimize the potential hazard and/or make the most
efficient use of landfill space.  Figure 3 enumerates several
waste preparation techniques.  Volume reduction and solidification
techniques are applicable to many industrial wastes, such as heavy
metal sludges.  Such versatility is important in designing a facility
to handle a wide variety of chemical wastes and also achieve economics
of scale.  Volume reduction and solidification techniques also reduce
initial moisture content and thus reduce the potential for
early leachate generation and migration.  Detoxification and chemical
degradation techniques may yield saleable or non-hazardous
by-products, but are generally more waste specific.  In addition,
many detoxification techniques are still in their development stages.
     The potential for occupational health and safety problems
implies a need for extra attention to waste handling procedures.
                               85

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FIGURE 3:  LAND DISPOSAL WASTE PREPARATION TECHNIQUES


Volume Reduction

       filtration
       precipitation
       coagulation
       incineration
       settling

Encapsulation/Solidification

       polyethylene encapsulation
       asphalt encapsulation
       lime/flyash fixation
       Portland cement
       plaster of pan's
       metal  silicate fixation
       bentonite adsorption
       vermiculite adsorption

Detoxification and Degradation

       oxidation/reduction
       hydrolysis
       catalysis
       photolysis
       biological degradation
       chlorinolysis
       activated carbon
       electrolysis
       low temperature
       microwave
       ion exchange

pH Adjustment/Neutralization
                           86

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 Laboratory analysis,  segregated storage, labeling, waste
 inventories,  routine  medical  testing, and chemical fire fighting
 and  safety equipment  will  help assure a safe work environment.
 The  incompatibility or  synergistic effects of certain wastes
 further  demonstrate  the need for  segregated  landfill ing techniques
 and  sample analyses to  screen out incompatible wastes.  The
 possibility of waste  reuse or future site repairs substantiates the
 usefulness and value  of three dimensional burial maps and waste
 inventories.   If  such inventories are kept, it will be  feasible to
 locate and extract any  given  waste with minimal searching.
I EACHATE MANAGEMENT TECHNIQUES
     As a general  rule,  land disposal  of hazardous  wastes in
humid regions requires some form of leachate  management to
maintain groundwater quality.  Given sufficient time,  excess
precipitation will lead to leachate formation  and movement
through the soil  profile.  Leachate management techniques
include impermeable liners, leachate collection and treatment,
and environmental  monitoring.
     When an  impervious  basin is  desired,  liners  are  a potential
solution to the problem.  Common  types  of impervious  liner
materials include: clay, rubber,  asphalt,  concrete,  polyvinyl
chloride (PVC), and hypalon (a chlorinated  polyethylene).    The
choice of ? liner material will be determined by the degree of pro-
tection required,  waste hazard,  cost,  and  liner compatability with
wastes.  For example,  asphalt is  susceptible  to solvents and,
therefore, is not recommended for lining solvent  disposal  sites.
                               87

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Initial evaluations of liner integrity reveal  the following
durability ranking:
              Concrete> Plastic> Rubber> Asphalt
     Due to the relatively few applications  and recent  emergence
of various liner materials, their long-term  effectiveness  in  the
presence of hazardous wastes has  not been clearly defined.   In
recognition of the need for better liner  integrity data,  EPA's
Solid and Hazardous Waste Research Laboratory  (Cincinnati, Ohio)
has initiated a 30-month study to demonstrate  liner durability,
determine cost effectiveness, and provide design data to  predict
                         o
the life of the material.
                                            9
     Early cost data for liner materials  are:
              Clay (2 ft. thick):  $0.20  per square foot
              Plastic (PVC):  $0.15-$0.25
              Rubber and Hypalon:  $0.25-$0.50
              Concrete (4-8 in.)  with Hypalon:  up to $2.00
     The use of liner materials requires  that  the disposal unit's
drainage pattern include a network of perforated plastic  pipes,
risers, and pumps to facilitate collection and drainage of accumu-
lated leachate.  Figure 4 illustrates one possible design  for an
industrial waste landfill trench  or cell  unit.
     Waste parameters which control leachate generation include
field capacity, initial moisture  content, permeability, and  density.
Initial leachate production may be attributable to channeling or
the initial waste moisture content (many  wastes are liquids).
                                88

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-------
As surface infiltration due to precipitation  continues,  the
disposal  unit will  eventually reach field capacity,  and  in  effect,
resemble a perched  water table from which accumulated  leachate may
be collected.
     Capping the landfill  with an impervious  liner,  such as
those mentioned earlier, may serve to further minimize leachate
production once the disposal unit is filled to capacity.  Even with
such precautions, it is likely that leachate  production  will  be
a factor at some period in the landfill's existence.  Leachate
collection and treatment will then be required.  Leachate
treatment techniques include:  recycling, fixation,  encapsulation,
evaporation, biological treatment, or advanced waste water  treatment.
Leachate constituents, availability of public treatment  facilities,
and costs are primary factors in selecting a  leachate  treatment technique.
     If the disposal unit is capped with an impervious liner, or
includes organic wastes which may produce gases during biodegradation,
unit design should  provide for gas collection and odor control.  Gases
may be vented out of the burial unit via pipes inserted  through the
impervious final cover.  The vents, in turn,  are connected  to
perforated lateral  pipes that are positioned  in a shallow bed of
gravel immediately  below the impervious cover.
MONITORING TECHNIQUES
     Monitoring and long-term care imply routine sampling schedules
and environmental surveillance to identify system failures  and
initiate remedial action before environmental or public health damage
                              90

-------
occurs.   Prior to the deposition of hazardous  wastes,  baseline  data
should be gathered and used to define site characteristics,  such  as
hydrologic budget, and groundwater flow and use patterns.
     Each site is a unique entity with its own physical  characteristics.
Sampling point distribution and monitoring procedures  will  be
determined by the geological, hydrological, and chemical  complexities
of the site.   The interface between soils with different permea-
bilities, such as sand, loess, or glacial till, will  be  an  area of
active groundwater or leachate movement and should be  monitored as
a potential  leachate pathway.
     Lysimeters, observation wells, earth resistivity  measurements,
and core samples are techniques which may be employed  to monitor
soil  and groundwater.  Observation wells and lysimeters  down gradient
from the landfill area and at different depths are recommended, as
a minimum, to collect representative samples of leachate activity
in the soil  profile.  Very complex sites, with variable  soil  pro-
files, require closer monitoring and surveillance.  In such instances,
a square grid network of monitoring points as  illustrated in Figure
5, will  provide more informative monitoring data.
     Pressure-vacuum lysimeters are relatively inexpensive  and
can be placed at strategic positions, including beneath  the
landfill liner.   The simplicity of the pressure-vacuum  lysimeter
is illustrated in Figure 6.
     Earth resistivity techniques may be employed  to measure
the concentration of electrolytes in solution  between  two points
in the soil  profile.  Since most leachates are high in electrolytes,
                               91

-------

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* * * * *
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' * * & * *
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* * * * * '
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SAMPLING STATION
Figures.   Positioning and spacing of sampling stations for an
           industrial waste landfill.
      Source:  after Malker
                           11
                               92

-------
                                FIGURE 6:

           CROSS SECTION OF A TYPICAL PRESSURE-VACUUM
                    SUCTION LYSIMETER ASSEMBLY
           2-WAY

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                                             > t*«at
             Source:  Saint et al.   after Parizek and Lane'
                                 93

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a change in resistivity under or near the landfill  may be
indicative of leachate escape.  The method relies on comprehensive
baseline data and is subject to periodic changes in soil  moisture
and interstitial water chemistry.
     Recent studies, reported by Walker, suggest that core
sampling from the saturated and unsaturated zones may be preferable
to observation wells for positive definition of chemical  constituent
concentrations and their movement.
     The need for long-term care is supported by incidents of
public health damage from hazardous waste burial sites which were
                                    2
not maintained or properly recorded.   Long-term care implies main-
taining permanent site records, including waste inventories, con-
tinued sampling after the site is closed, and contingency plans to
either remove/retreat the waste, or repair site defects, as necessary.
EPA CHEMICAL HASTE LAND DISPOSAL PROGRAM
     The Technology Assessment Program of EPA's Hazardous Waste
Management Division, Office of Solid Waste Management Programs
(OSWMP), has been established to evaluate and demonstrate new ap-
proaches to chemical waste disposal.
     Disposal concepts for chemical wastes in humid regions have
been based largely on theoretical, laboratory, and pilot-scale
evidence.  Commercial-scale demonstration of the environmental
adequacy, economic feasibility, and operating practicality of a
variety of currently promoted land disposal concepts is needed
before workable disposal  guidelines and regulations can be
developed.  In recognition of the need for further information on
                              94

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land disposal techniques, EPA has solicited for a grantee to
demonstrate a commercial-scale chemical  waste landfill.
     The demonstration will  be managed jointly by EPA and a non-
profit grantee, with expertise provided by one or more grantee
selected contractors.
     The overall project goal is to conduct a complete demon-
stration of a chemical waste landfill  which examines the tech-
nological, economic, organizational, and social/institutional
issues involved in establishing and managing an environmentally
acceptable landfill site designated for hazardous wastes.
     Specific objectives include:
          0  demonstration of site selection methods
          0  demonstration of appropriate site preparation
             techniques
          0  demonstration of waste preparation techniques
          0  demonstration of monitoring and surveillance
             techniques
          0  evaluation of waste handling and operational
             procedures
          0  determination of cost ranges
          0  evaluation of social and institutional  issues
     In order to serve as a model which will be useful in helping
solve the nation's hazardous waste management problem, the land
disposal demonstration will  be located where:
          0  climatological  and hydrogeological characteristics
             ensure a demonstration of solutions to  leachate
             management problems which might be expected to
                               95

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             develop in humid regions  where  the majority  of
             industrial wastes are produced
          0  industrial diversity is  sufficient to ensure availability
             of a wide variety of potentially hazardous  industrial
             wastes
          0  the legislative and regulatory  atmosphere is suitable
             to ensure long-term use  of the  facility
     EPA is also demonstrating pesticide/sewage sludge incineration,
hazardous waste incineration, chemical detoxification and waste re-
covery techniques to further the objective of evaluating  disposal
techniques with promising hazardous waste management potential.
EPA also has identified private chemical  waste management facilities
and prepared fact sheets on each facility.  These fact sheets are
available and may serve as a source document for chemical waste man-
agement assistance at the local or state level.
                               96

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                           REFERENCES
 1.   Lehman,  0.  P.   Federal  program  for hazardous waste management.
       Waste  Age,  5(6):6-7,  66-68, Sept.  1974.

 2.   U. S.  Environmental  Protection  Agency, Office of Solid Waste
       Management  Programs.   Disposal  of  hazardous wastes; report
       to Congress.   Environmental Protection Publication SW-115.
       Washington,  U.  S.  Government.  Printing Office, 1974.  110 p.

 3.   Hanks, T.  G.   Solid  waste/disease relationships; a literature
       survey.   Public Health  Service  Publication No. 999-UIH-6.
       Washington,  U.  S.  Government  Printing Office, 1967.  179 p.

 4.   Weddle,  B.  R.,  and G. A.  Garland.  Dumps; a potential threat
       to our groundwater supplies.  Nation's Cities, 12(10):21-22.

 5.   Program  for the management  of hazardous waste for Environmental
       Protection  Agency, Office of  Solid Waste Management Programs;
       final  report.  Richland,  Wash., Battelle Memorial  Institute,
       July 1973.   385 p.

 6.   Lindsey, A. W., and  T.  Fields,  Jr.   Land disposal of hazardous
       wastes.   Washington,  Office of  Solid Waste Management Programs,
       May  1974.   35 p.   (Unpublished  report.)

 7   Saint, P.  K.,  C.  P.  Straub, and H. 0. Pfannkuch.  Effect of
       landfill  disposal  of  chemical wastes on groundwater quality.
       Presented at Annual Meeting,  Geological Society of America,
       Minneapolis,  Nov.  14, 1972.   41 p.

 8.   Roulier, M. H., R. E. Landreth, and  R. A. Carnes.  Current
       research  activities relating  to disposal of hazardous wastes.
       Presented at 1974  National Conference on Control of Hazardous
       Material  Spills, San  Francisco, Aug. 25-28, 1974.  10 p.

 9.   Personal communication.  J. P.  Lehman, Office of Solid Waste
       Management  Programs,  to the Record, Jan. 23, 1974.

10.   Fungaroli,  A.  A.   Pollution of  subsurface water by sanitary
       landfills,   v.l.   Environmental Protection Publication
       SW-12rg.  Washington, U.  S. Government Printing Office,
       1971.   132  p.

11.   Walker,  W.  H.   Monitoring toxic chemical pollution from land
       disposal  sites  in  humid regions.   17 p.  (Unpublished report.)


                                97

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            HAZARDOUSTWASTE MANAGEMENT IN THE STATES


                        by Murray Newton*
ABSTRACT.  Regulating land disposal of hazardous waste is an area
of relatively new emphasis in the States.   While some States have
begun their regulatory programs, many others have elected to wait
for the enactment of Federal legislation which would delineate
the responsibilities of the States,  where States have begun to
regulate hazardous wastes they have usually attacked one or both
of two points in the residuals life cycle:  transportation and
disposal.  Regulation at the disposal sites is the more common
but less certain method, as the State cannot be certain how much
waste fails to reach an approved site.  Regulation of hazardous
waste haulers gives the States information on what is leaving
generators' sites, and thus is more effective.

     The States which have begun hazardous waste management
programs have a head start over those States which are waiting
for Federal legislation to guide them,  with or without Federal
legislation, the States will continue to be the focal points for
hazardous waste management.


     Hazardous waste management represents a relatively new

concern for the States as well as for EPA.  While some States

have been aggressive and innovative, others have elected to wait

for Federal legislation and the better definition of responsibili-
     *Mr. Newton is the Program Manager for State Implementation,
Hazardous Waste Management Division, Office of Solid Waste Manage-
ment Programs, U.S. Environmental Protection Agency.
                               98

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-ties for all parties which will inevitably follow.  This paper



deals with hazardous waste management (rather than with hazardous



waste disposal)  because EPA believes it is essential to control



the life cycle of hazardous wastes from generation to ultimate



treatment and/or disposal.  Many of the States have recognized



this necessity in their own programs.  One result of this policy



is that some States are regulating the transport of hazardous



wastes, with a few even requiring reports and records from the



generators.







liIGISLATIV]E_AUTHORITY







     Only California, Minnesota, and Oregon have passed



comprehensive hazardous waste management legislation.  The laws



passed in these States are "comprehensive" in that they give the



State authority to designate those wastes to be considered



hazardous; to write rules and regulations for the



treatment/disposal of such wastes; and, to require such records,



reports, and inspections as the State deems necessary.  The law



in each of these States defines "solid" or "hazardous" wastes to



include liquids, sludges, slurries and (in Minnesota) contained



gases.  This kind of authority gives the States more complete



control over hazardous wastes than it ordinarily has over other



types of wastes destined for land disposal.
                               99

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     Minnesota is beginning to develop implementing rules and



regulations for its hazardous waste management legislation, and



Oregon and California have both drafted regulations over the last



few months.  The latter State, by the way,  appears to be



considerably ahead of the rest of the nation in implementing its



program.







     A few States have begun to regulate "hazardous11 wastes and



call them by that name {or "toxic"); but many States which do not



have legislation or regulations on "hazardous" wastes do have



authority over "noxious," "special," "liquid," or "industrial"



wastes.  The categories are neither mutually exclusive nor



interchangeable, but those states using their authority to



regulate one of them can control the kinds  of wastes with which



we in EPA's Hazardous Waste Management Division are concerned.







     California and Oregon have begun to wrestle with the problem



of what is "hazardous."  These two States have drafted or adopted



clear standards as to LD«   levels, flash points, or the like, to



be used in determining that something is or is not "hazardous."



Most States, however, make a case-by-case determination.  Even



those states which are required to maintain lists of hazardous



wastes  (or substances) often do so without  explanation.  The



Massachusetts regulations, for example, establish the



classification of "Toxic Metals, Etchants,  Pickling and Plating



Wastes," which are defined to include aqueous solutions and





                                100

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sludges containing certain toxic metals such as cadmium and



arsenic, tut t.here is no reference to concentration or quantity.







     As the so-called "solid waste management" staff is often



charged with managing hazardous wastes whatever their physical



state, there seems to be a trend toward emphasizing the disposal



media rather than the waste,  consequently, control of the land



disposal of all wastes becomes the mission of the solid waste



staff.  This trend parallels the responsibilities of air, water,



and ocean disposal staffs to protect their respective media from



environmental insult by any wastes.







APjPRQACgES







     Some States have not begun programs to manage the whole life



cycle of hazardous wastes, but rather have attacked one or both



of two points in that cycle:  disposal and transportation.  The



more common, if less certain, approach has been to attempt to



control hazardous wastes at the disposal site.  The appeal of



this is obvious, as the State solid waste offices deal with site



operators under existing authority, often requiring a permit for



operation.  In its simplest form, this approach might have a



State designating one or a few land disposal sites in the State



as being adequate for hazardous wastes, and requiring that all



other sites refuse to accept such wastes.  Idaho has designated



what was formerly a Titan missile silo for this purpose, and





                               101

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requires that hazardous wastes be disposed of at that site only.



Oklahoma also has a single site for hazardous wastes, as does



Colorado.







     A similar approach classifies every site in the State



according to the wastes it may accept.  Several States use a



Class I, II and III system.  California and Texas are two such



States.  In both of these States, class I sites are allowed to



accept the most hazardous wastes; Class II sites are allowed to



accept municipal and commercial refuse; and class III sites, only



innocuous wastes, such as brick and wood wastes.







     The logic behind designating one or a few sites is that



requiring the use of known and controlled sites protects the



public health and environment more than allowing hazardous wastes



into hundreds of sites of varying quality scattered across a



State.  The principle is a sound one, and we continue to endorse



the attempts of States to funnel hazardous wastes into the fewest



and best possible sites available to them.







     The other area of attack has been the collection and hauling



of hazardous wastes.  While Indiana regulates "liquid waste



haulers," Massachusetts regulates "hazardous waste" haulers and



New York haulers of "commercial waste and industrial waste



products."  The intent and effect are to control the



transportation of the same wastes in which EPA's Hazardous Waste






                               102

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Management Division is interested.  The appeal of regulating



those who collect and transport industrial wastes is largely that



they are usually an easily identifiable group.  In the



Netherlands, incidentally, regulation of this group is the key



element in their program because, as they put it, "they are a



small group, well-known to the authorities."







     Regulating the haulers answers in part the most telling



weakness in systems aimed solely at disposal sites:  the State



has no way of knowing how much waste fails to reach permitted



disposal sites.  By regulating haulers the State moves one step



closer to the generator, is aware of wastes leaving the



generator's site (through reports from haulers), and thus can



compare that to the wastes reaching permitted disposal sites.



Connecticut, Indiana, Kentucky, Michigan and South Carolina have



made this the initial step in their hazardous waste management



programs.  California, Massachusetts and New York have combined



this element with other aspects of their programs.







     Even here there is a potentially serious weakness:  some



States only regulate haulers "for hire."  Generators who haul



their own wastes, or who buy small collectors and operate



"captives," sometimes escape regulation.  These generators may



account for enormous proportions of the industrial wastes in a



State.  In Kentucky and New York, interestingly, regulation was
                               103

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initially aimed at haulers "for hire," but is now being extended



to all hazardous waste haulers.








     Programs based upon regulation of disposal and of



transportation suffer the defect of failing to close the circle



on the management of hazardous wastes.  Only regulation of the



generator as well would accomplish this end.  Even where no



permit is issued to the generator, or the State has no right of



on-site inspection, the State can close this circle if generators



are required to report their hazardous wastes.  Only then can the



States compare the quantity of wastes reaching disposal sites



with what is being generated.  States regulating the collectors



and haulers nearly always require the generator to disclose the



nature of his wastes to the hauler.  Depending upon the accuracy



and specificity of this disclosure, the State may obtain a



considerable part of the data it needs on hazardous waste



generation from reports submitted by the haulers.  But this



requirement, although essential, is not sufficient by itself;



those States which hope to base their regulation of hazardous



wastes solely on the requirement that generators report their



wastes will probably find it ineffective.








     The responsibilities and obligations of those being



regulated must be clear.  Several States have a section in their



general solid waste regulations to the effect that generators of



"special11 wastes must ask for prior approval to landfill such
                               104

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wastes.  The regulation might state, for example, that "wastes



which are hazardous or hard to manage shall be disposed of in a



sanitary landfill only if special provisions are made for such



disposal and are approved by the Department."  Several of the



terms used are usually undefined or defined in such a way as to



be of limited value to the public.  Whether or not a waste is



"hard to manage" depends upon several factors, including the



manager.  "Hazardous" is difficult to define, and the designation



more difficult still to defend.  Lastly, the kind of requirement



mentioned above gives the State an enforcement tool of extremely



limited value.  The State tells the generator to seek approval



for "hazardous" waste disposal without telling him which wastes



it considers hazardous or what constitutes "approved" disposal.



No records or reports are required, no fees or obligations



specified.  Unfortunately, most States are no more explicit in



their hazardous waste requirements than the above example.







     At least two States prohibit land disposal of hazardous



wastes.  Hawaii and Florida have both published regulations



requiring that hazardous wastes be "rendered safe" or



"detoxified" prior to land disposal.  Neither State has published



standards for determining which wastes are "hazardous," or the



criteria applied to determine that those wastes have been



"rendered safe."
                               105

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     Because this is a new emphasis for the States,  and because



there are no national standards or guidelines in this area,  the



States have moved along different paths to improve regulation of



this critical problem.  One of the more productive steps several



have taken has been to offer a "technical assistance" capability



to the public.  Currently, at least 16 States have specialists to



help advise the public on the disposal of hazardous  wastes.



Professionals with strong chemistry backgrounds — in at least



two States they are people with 20 to 30 years experience in



industry — are able to assist generators, haulers and disposers



in assuring that hazardous (or potentially hazardous)  wastes are



handled safely.  Many States are finding that it is  easier to



chase "midnight dumpers" than to come up with the right answers



on sound hazardous waste disposal.
PROBLEMS







     Mention should be made of some of the problem areas we see



in regulating hazardous waste management.  The first of these is



administrative or political obstacles to seeking new legislation,



or even clearing regulations for publication in many States.



Georgia's response has been to publish "Guidelines" in which the



State recommends procedures for the proper disposal of certain



hazardous wastes.  Utah may publish an "Interpretation" of some



more general regulations, in which the State can go on record
                                106

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with its preferred methods for the benefit of the public.  In



both these States as in many others, the authorities perceive a



need to inform and assist people who are concerned with the



proper management of hazardous wastes, rather than a need to



"strongarm" a reluctant public.  At least for now, misfeasance



rather than malfeasance is the problem as they see it.








     A second problem (although it may be a blessing) is that the



generation of industrial hazardous wastes seems to be



concentrated in a relatively small number of States.  While there



are some hazardous wastes from industry in all the States, the



problem is far greater in some States than in others.  For the



most part this has evoked a regulatory effort from the States



having the most severe problems.  EPA«s "Report to Congress"



estimated that 70 percent of the hazardous waste in the United



States was generated in the Mid-Atlantic, Great Lakes, and Gulf



Coast regions.  More recent studies have tended to confirm that



the above regions plus California generate nearly three-quarters



of the hazardous wastes in the United States.  This concentration



of generators is a problem because it means that improper



management of hazardous wastes in a f_ew of the States is



considerably more serious than improper management in most of the



States.  But, it may be a blessing in that the affected States



are showing an interest and are beginning their programs.  This



may well lead other States to begin their programs, for the
                               107

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regulatory efforts of neighboring States will otherwise drive



wastes into the more lenient areas.







The third problem involves the free movement of hazardous wastes.



Some States have tried to restrict the transport of out-of-state



hazardous wastes into or through their areas.  EPA has opposed



these "non-importation*1 provisions wherever they have appeared.



We have gone on record in support of an active role for the



private sector and we recognize that this requires giving a



treatment/disposal firm freedom to operate over a large area,



often encompassing many counties, or even States.  Other States



have recognized the importance of allowing service companies to



collect from, and transport hazardous wastes through or into,



several jurisdictions.  Florida, for example, has gone so far as



to explicitly include in its regulations the provision that



"Transportation and disposal of solid waste into or through the



State...shall not be impeded," so long as it is not mismanaged.



     The last problem area is the lack of a data base.  EPA is



studying certain industries on a national basis, but the States



will have to know far more about the specifics of the hazardous



waste problem within their own borders than we.  Both as



justification for regulation, and as insurance that regulation is



effective, the States will have to conduct hazardous waste



surveys.  To our knowledge, only California, Idaho, Oregon and



Washington had published such surveys by the end of 1974.



{Minnesota has published a survey for the Twin Cities which





                               108

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represents most of the industrial hazardous waste for the State



as a whole.)   Other States are working on them now, but not all



States.  We consider such surveys extremely important, since they



have numerous uses.







     One use of these surveys is to define and document the



problem.  Another is to focus attention on those industries or



geographic areas that need attention.  In most cases such surveys



can be used to argue for legislation, but at least three States



have considered seeking legislation to conduct surveys in the



first place (Arizona, Iowa and Ohio).







     The purpose of these surveys is to determine:







WHAT - the types and combinations of hazardous wastes being



generated;







HOW_MUCH - the quantity being generated within the State; and,







WHERE - where it is being generated within the State.  Is it all



being generated from a few places, for example?







     Once the state has made these determinations the obvious



questions present themselves:  Where is it going?  Who is



collecting it (if it is going off-site)  and what is he doing with
                               109

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it?  The answers to these questions are essential to a successful



hazardous waste management program.
COLLUSION








     What are the prospects for the future?  We expect activity



in all aspects of hazardous waste regulation to increase



dramatically from now on.  At least four States (Arizona,



Colorado, Iowa and Ohio)  have already drafted legislation  which



encompasses hazardous waste management, and several others have



told us of their intention to do so.  Still others, such as



Illinois, may choose to establish regulations under whatever



legislative authority they already have.  In either case,  their



recognition of the need is an encouraging first step.








     EPA has provided, and most likely will continue to provide,



financial and technical assistance to the States in doing  all of



the things discussed above.  States that have used this



assistance to begin hazardous waste management programs have



given themselves a lead over the rest of the States in preparing



for the time when the Congress passes enabling legislation in



this field.  But even more importantly, if the congress does not



pass regulatory authority for a Federal hazardous waste



management program, the States will have to get the job done on



their own, and that job gets harder as time passes.  With  or
                               110

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without  Federal legislation, the States will become the focal



points for  the proper management of hazardous  wastes.   The head



start of some States will serve them and their citizens well; SPA



applauds them and hopes others will begin  soon.   By the time



Federal  legislation is enacted, some States will  have  been quite



aggressive  in the management of hazardous  wastes.   On  balance,



there may be  fewer of these States than of States which cannot or



will not act  until we in EPA do.  But we have  seen a beginning



already,  and,  we think, a rather good one.
  yoll6l
HJ.S GOVERNMENT PRINTING OFFICE 1975 582-1423/288 1-3       111

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