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
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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.
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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
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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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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
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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
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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
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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
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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.
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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.
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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
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
H
S
I
\
l
I
»
vj ^3
y
nil
53
-------
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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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
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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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58
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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
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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
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. 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
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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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CO
e
H
M
PH
05
W
U
w
I
^1-
ed
o
01
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rt
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4)
ro
OJ
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c
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u
^
o
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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
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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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e
e
o
OlSf
*
m
OSAL SITE
e
e
0
o
CTDF AM .^ _ — *-
| &
) STAl
X
1<
x jg. EXPLANATION
ION SAMPLING POINT LOCATION
^^ 0 OBSERVATION WELL
^/ * CORE TEST
-«- 10' i
* * * * *
*****
' * * & * *
******
2'
* * * * * '
-<- 2' *•
SAMPLING STATION
Figures. Positioning and spacing of sampling stations for an
industrial waste landfill.
Source: after Malker
11
92
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FIGURE 6:
CROSS SECTION OF A TYPICAL PRESSURE-VACUUM
SUCTION LYSIMETER ASSEMBLY
2-WAY
VACUUM PORT AND GAUGE
r*p.
1
K==—^^fS^
PRESSURE VACUUM INs.
DI Acnr TiiRiwfi-*^ d8fe:>r^s
fl»H. ! .I-*1'
01
PLASTIC PIPE 24" LONG—. *
0
BACKFILL^ J[
sU
SILCA SAND- S
POROUS CUP—— ^Js
s*
•»
V,
BENTONITE--^Jj
• • * *
•'.«*.'
» • * %
• *•• '
**••*
£®
''••;ir
'*1V*
T
'•.'•
—
\
Ul
^
!&$g»>h,._
n
" 1
.SAMPLE BOTTLE
jf
.DISCHARGE TUBE
SSI— ~
i" ?"•'.•
—
— ^
^
'••
,"•
':.'
?::
\
'$
ffi
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-rfWli**
V
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a.
•
••
•*
12
•0
0»1
> t*«at
Source: Saint et al. after Parizek and Lane'
93
-------
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
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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
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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
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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
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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."
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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
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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
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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
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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
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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
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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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